March 21, 2022
The Honorable Steven Englebright, Chair
New York State Assembly Environmental Conservation Committee
Legislative Office Building
Albany, New York 12248
Re: Opposition to A.7389C
Dear Chair Englebright:
This letter is submitted on behalf of the Blockchain Association (the “Association”), a member-led, member-driven organization dedicated to improving the public policy environment for crypto networks through innovation, collaboration, leadership, networking, diversity and representation. The Association recently opened an office in Albany, and we are eager to share our expertise with the legislature in the weeks, months and years ahead.
It has come to the attention of the Association that the Environmental Conservation Committee is considering advancing A.7389C. As you know, if enacted, this bill would establish a moratorium on certain existing or new operations that use proof-of-work consensus mechanisms to validate blockchain transactions unless they use 100 percent renewable energy. The crypto industry shares the goal of increasing the usage of renewable energy, and while we believe mining can assist in driving investment and greater progress toward this goal, it will take some time to achieve. We urge the committee to hold off on consideration of this legislation and instead take time to examine the full impact behind crypto’s energy consumption and the importance of this sector to New York’s economy and US competitiveness, and broaden the conversation to include other sectors.
The US crypto industry shares the Committee’s interest in combating climate change, and we are committed to ensuring that the energy mix used for this critical process includes as much renewable energy as possible. Proof-of-work validation, including bitcoin mining, does indeed consume energy to secure networks. But compared to the non-crypto sector, US crypto mining operations already have a more favorable energy mix. And more importantly, the co-location of mining operations with renewable energy resources allows those sources of energy to become profitable. As more renewable resources are deployed alongside these operations, the energy mix of bitcoin and other proof-of-work networks will continue to advance. If there is a ban on bitcoin mining, it will push mining operations to less climate-focused jurisdictions, which will halt the incentive to deploy new renewable energy sources here in New York.
Furthermore, we respectfully request that you hold this proposal in Committee because it singles out the crypto industry with unfair standards that don’t apply to other sectors. Bitcoin and blockchain technology provide a tremendous amount of value to people in New York and across the world. This legislation ignores the energy consumption of other industries, including traditional financial services, transportation, hospitality and many others. It creates unreasonable standards for an industry that is only just beginning to establish itself in New York and holds crypto mining to a different standard.
Thank you for the opportunity to comment on this important issue. We look forward to being a resource to the Committee as it continues to tackle climate change and other issues related to the environment.
Cc: New York State Assembly Environmental Conservation Committee Members