Non-dispatchable, always-on gas-powered fuel cells should NOT be considered marginal producers. One clear issue with Intro 1982-A is that there's no authoritative source of granular marginal emissions data for New York State. This is a stupid, bad law...
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We can anticipate that users of other gas-powered generators will soon demand to have the same benefits that are being claimed by gas-powered fuel cell users. If this continues, New York City will end up saying that all gas-powered generators "reduce" marginal emissions. Stupid.
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