This post combines 2022 residential annual residential customer sales and the cost recoveries for Climate Leadership & Community Protection Act (Climate Act) related initiatives in 2022 to estimate the fraction of sales dedicated to Climate Act initiatives. The fraction of Climate Act costs was as much as 22% of the total residential utility customer costs in 2022.
I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim reduction target of a 40% GHG reduction by 2030. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. However, the Hochul Administration has never fully accounted for the ratepayer impact of the transition apparently because the impacts are so high.
Residential Collection Data
In a recent article I described a source of data that includes the total dollar amount of residential customer sales. The New York Open Data website contains the Quarterly snapshot of residential collection data file. According to the general description: “This dataset provides a quarterly snapshot of residential bill collection activity for New York State’s ten largest electric and gas distribution utility companies regulated by the Public Service Commission. “
Table 1 lists the annual sum of the quarterly residential customer sales for the ten utilities in the Quarterly snapshot of residential collection data file. The ten utilities are: Consolidated Edison, Orange & Rockland, Public Service Electric & Gas, Central Hudson, National Grid – LI, National Grid – Upstate, National Grid New York, New York State Electric & Gas, Rochester Electric & Gas, and National Fuel Gas.
Table 1: Annual Residential Customer Sales
Climate Act Cost Recoveries
In July 2023 the Public Service Commission (PSC) released its first annual informational report on the implementation of the Climate Act. In August 2023 I noted that the informational Report explained that Climate Act costs that have been authorized and were in the 2022 residential bills total $1.2 billion. The Report notes that in 2022 the costs already associated with the Climate Act increased the Upstate residential monthly electric bills 7.6% or $7.15 per month for NYSE&G customers; 7.7% or $7.54 for RG&E customers; and 9.8% or $9.38 for Niagara Mohawk customers.
I followed up with another article that documented post hearing comments related to the NYSEG electric rate case 22-E-0317, RGE electric rate case 22-E-0319, the NYSEG gas rate case 22-G-0318, and the RGE gas rate case 22-G-0320 that address Climate Act costs. I concluded that Climate Act costs are a major factor in this extraordinarily large rate case request. This is an issue in this instance and every future rate case for every New York utility is going to have similarly large costs.
The Informational Report included a summary of cost recoveries for 2022:
For purposes of estimating the cost recoveries of CLCPA related initiatives in 2022, Staff issued information requests to each of the utilities. Specifically, Staff requested the utilities provide 2022 cost recoveries for: CES (electric only), CEF (electric only), certain VDER (electric only), Electric Vehicle Make Ready Program (electric only), Clean Heat programs (electric only), Integrated Energy Data Resource (electric only), and Utility Energy Efficiency programs (electric and gas).
The cost recovered in 2022 by the utilities associated with these gas and electric programs described above are detailed in the following tables.
Climate Act Costs and Residential Customer Sales
I combined the information from the two sources. The total residential sales in 2022 were $5,867 billion. The Climate Act costs for the gas (excluding Corning) and electric utilities were $1,289 billion. The Climate Act cost share of the total sales is 22% using these two data sets.
I have limited experience with these data sets, so I have reservations about the precision of the estimate. The 22% number is probably an upper bound because the total costs should be spread over all the residential customers of the state as well as the commercial and industrial customers. In 2021 residential natural gas and electricity sales were 80% of the total residential, commercial and industrial sales. If the Climate Act costs are apportioned evenly that would reduce the Climate Act percentage of residential bills down to 18%. I understand that municipal utilities are not treated the same so that affects the percentage estimate too.
Discussion
It is notable that I had to rely on data from 2022 despite the mandate annual status updates that include costs. On April 14, 2025, I published an article describing a letter I sent to Public Service Commission Chairman Rory Christian regarding the requirement for annual informational reports. In March, Michael B. Mager Counsel to Multiple Intervenors sent a letter to Chairman Christian noting that the annual report was late. Soon thereafter Jessica Waldorf, Chief of Staff and Director of Policy Implementation for the Department of Public Service (DPS) posted a response letter. My letter explained that I agreed with the comments submitted by Multiple Intevenors and was disappointed that the DPS response did not commit to a schedule for the next update of the annual informational report. The point is that the data in the Informational Reports are political dynamite. The estimate that the Climate Act costs are responsible for up to 22% of the cost recoveries in 2022 is just the beginning. The Hochul Administration has every reason to delay the release of update informatoin as long as possible because the Climate Act costs are going to be higher.
The estimated fraction of costs attributable to the Climate Act in only for one component of the costs of the Climate Act net-zero transition. These costs don’t include costs to electrify homes, personal transportation, and the hidden costs for things like upgrading electrical service to be able to electrify everything. Also it does not include societal costs like the need to electrify school buses and pay for less impactful refrigerants used by grocery stores. The list of hidden costs goes on and on.
I recently described an Empire Center poll that asked questions about the Climate Act. I noted that one third of the respondents are not willing to pay anything on their monthly energy bill for cleaner energy. Another 28% are only willing to pay up to $20 a month for cleaner energy while another 20% would pay up to $40 a month. Nineteen percent are willing to pay up to $200 a month but only 3% are willing to pay more than $200 per month. Given all the necessary costs I believe that $200 per month is not nearly enough for the transition.
These data also raise the question of what the point is. New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990. Furthermore, New York’s impact on global warming is unmeasurable. Table 2 projects the amount of global warming “savings” for the 1990 and 2022 historical emissions. The calculations are based on a Perplexity AI query “What is the expected change in global warming per ton of CO2 reduced”. If total New York GHG emissions from the baseline in 1990 or the most recent year (2022) available were to go to zero, the projected change in global warming is too small to measure.
Table 2: Potential Warming Savings for Historical Emissions
Conclusion
The costs to implement the Climate Act were about one fifth of the monthly bills in 2022. I have no doubt that the costs that will be in the 2023 Informational report will increase that fraction. Sooner or later the public is going to catch wind of these unsustainable costs. Given that the investments will not meaningfully affect global emissions or global warming I cannot imagine that the voters will be willing to continue this madness. The reckoning cannot come soon enough.
Pragmatic Environmentalist of New York 