TEAM R11 (Draft)

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University of California, Irvine *

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Political Science

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Feb 20, 2024

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MEMORANDUM TO: Kathy Hochul, Governor of the State of New York FROM: Staff Analyst DATE: July 8, 2023 RE: New York State Budget Reducing Reliance on Fossil Fuels Issue: Is the ban of natural gas in the state of New York constitutional? Rule: To determine if the ban of natural gas in the state of New York is constitutional, it must not be a private action or violate the 1st, 5th, or 14th Amendments. Analysis: 1. Issue: Is there government action to the banning of natural gas in the state of New York? Rule: For the law to be constitutional, it must not be a private action or regulation. Analysis: Per the memorandum shared with us by Governor Kathy Hochul of the State of New York, we believe there is strong government action enacted in this Provision that helps enforce its constitutionality. The government’s action has a clear objective where it aims to reduce dependence on fossil fuels, promote renewable energy sources, and address building emissions’ impact on greenhouse gasses. The Provision originated in part from statistics shared by the New York State Energy Research and Development Authority that states “the contribution of building emissions to the state’s greenhouse gas emissions, account for about 30% [of New York’s greenhouse gas emission]”. The Provision’s intent to transition to a cleaner emission program aligns with the government’s action to address harmful gas emissions from natural gas stoves which cause health concerns. In addition, the state has provided clear effective dates and highlighted required specifications and alternatives. It states, “Effective as of January 1, 2026, all new-construction buildings less than seven stories can no longer utilize equipment and building systems based on fossil fuels. The requirement for taller buildings takes effect on January 1, 2029.” The alternatives shared in place of fossil fuels include heat pumps, geothermal systems, and electrical appliances. Exceptions were also provided in detail incorporating practical limitations and considerations. Conclusion: Overall, this Provision provides a clear indication of government action through the reduction of greenhouse gas emissions and the protection of public health for the general population. 2. Issue: Is the ban of natural gas in the state of New York a violation of the First Amendment of the US Constitution? Rule: When deciding whether the ban of natural gas is a violation of free speech, fully protected speech must produce an imminent lawless action, limited protected speech must be false or misleading, or unprotected speech must be obscene, dangerous, or defamatory. Analysis: The discussion of the ban of natural gas is not a fully protected speech because there are no discussions of politics. In Texas v. Johnson, SCOTUS determined that burning a flag was political speech. Here, there is no political action or debate when discussing the switch from natural gas to all electric. There is also no limited protected speech that is false or misleading nor any unprotected speech that is obscene, dangerous, or defamatory. 1
Conclusion: Banning natural gas in the state of New York is not a violation of free speech, therefore, the free speech standards are satisfied. 3. Issue: Is the ban of natural gas in the state of New York a violation of the Procedural Due Process within the Fifth Amendment of the US Constitution? Rule: When determining whether the Procedural Due Process within the Fifth Amendment was violated, it must take away the liberty or property without proper notice and a hearing. Analysis: The Provision provides concise dates in which the installation of fossil-fuel equipment and building systems will be prohibited for buildings seven stories in height or less and for buildings eight stories in height or more. These dates can be considered notice for any builder, contractor, or other individual or corporation involved in the construction of a new building. Furthermore, the dates allow time for opponents of the Provision to request hearings , amendments, or other related information or requests related to the Provision. Conclusion: The provision provides notice and hearing and therefore satisfies the needs of procedural due process. 4. Issue: Is the ban of natural gas in the state of New York a violation of the Substantive Due Process within the Fifth Amendment of the US Constitution? Rule: This concept derived from the 5th Amendment prohibits the government from depriving individuals of their fundamental rights without a legitimate reason. We must consider factors such as fundamental rights, and balancing test to determine if the process has been satisfied. Analysis: Although the ban of natural gas in New York may potentially impact various rights such as property rights and the rights of contract for business owners and the owners of the building with gas piping, we think the purpose of ban of natural gas in New York still satisfies substantive due process because it does not guarantee absolute protection of rights and allows the government to regulate them to serve important public interests. By examining factors such as government interests and we found that the ban may bring a positive impact on illnesses such as childhood asthma and reducing greenhouse gasses emitted by gas appliances. Conclusion: As the ban of natural gas does not strip individuals from their fundamental rights, it can be said that the ban does not violate the Substantive Due Process within the Fifth Amendment of the US Constitution. 5. Issue: Is the ban of natural gas in the state of New York a violation of the Fourteenth Amendment of the US Constitution? Rule: The Fourteenth Amendment provides that “No State shall … deny to any person within its jurisdiction the equal protection of the laws.” This is the Equal Protection Clause, and it means that governments must treat people equally. Analysis: The Provision to transition New York residents away from the use of fossil fuels in all newly constructed buildings does not discriminate against any race, ethnicity or infringe upon any fundamental right. Additionally, it does not discriminate against a protected class or create hardship on individuals in an economic or social class. Furthermore, to address opponents who argue the Provision will result in higher utility costs, thus discriminating against an economic class, research concluded that single-family homes would spend $904 less annually. Conclusion: As contained in this memorandum, the rights of all protected classes are not 2
being taken away by transitioning away from fossil fuels in New York homes. Conclusion: As the ban of natural gas is not a private action and does not violate the 1st, 5th, or 14th Amendment of the U.S. Constitution, it can be concluded that the ban of natural gas is constitutional. 3
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