Energy Plan 25 June 2025 Meeting – Pathways Analysis Modeling Approach

This is part of my continuing coverage of the New York State Energy Plan.  This is the first update to the Plan since the Climate Leadership & Community Protection Act (Climate Act) was implemented so it has important ramifications on the net-zero transition.  My intent is to describe most of the sections of the June 25, 2025, meeting presentation.  As part of my attempt to reduce the size of my articles I will focus this article on the Pathways Analysis modeling approach that is being used for the draft Energy Plan.  Note that this article is out of order.  I published what was intended as a follow on to this earlier this week.

I am convinced that implementation of the 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 550 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.

Energy Plan Overview

According to the New York State Energy Plan website (Accessed 3/16/25):

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

I have provided more background information and a list of previous articles on my Energy Plan page.  My biggest concerns are whether the Hochul Administration will use the Energy Plan process as an opportunity to consider the implications of the observed transition so far and if the advice of stakeholders in its stakeholder process will be treated as an opportunity to improve the transition or an obligation with no attempt to meaningfully engage with any comments inconsistent with the narrative

June 25, 2025 Board Meeting

The materials for the meeting include the following:

• Meeting Notice [PDF]
• Board Meeting Presentation [PDF]
• Board Meeting Recording Meeting Recording 

I have included links to the locations of the video in the following descriptions.  Also note that a transcript of the presentations is included at the meeting recording video platform.  There is a nice feature for this video.  If you set auto scroll on then  you can follow the presentation transcript.  All quotes below come from that transcript.

I previously summarized this meeting’s presentations that described the analyses conducted for the State Energy Plan and described the electricity topic area. This article will evaluate one aspect of the overarching Pathways Analysis, namely the bottom-up modeling framework.

Pathways Analysis

Doreen Harris, head honcho of the New York State Energy Research & Development Authority and co-chair of the Climate Action Council, introduced the Pathways Analysis discussion.  The Pathways Analysis is the Energy Plan equivalent of the Scoping Plan’s Integration Analysis.  Recall that the Integration Analysis was the quantitative assessment of emission reduction strategies that formed the basis of the Scoping Plan outline of policy strategies to achieve the Climate Act net-zero transition.  Harris emphasized that while similar, the assessment approaches for both analyses are different.  The Integration Analysis was “top down” whereas the Pathways Analysis is “bottoms up”.  There are significant differences between these methodologies. 

The Integration Analysis top-down approach started with large-scale policy strategies and used the Energy and Environmental Economics (E3) using model framework to choose a selection of policy options that produced the necessary emission reductions.  Never forget that the feasibility of those policy option expectations and implementation schedule were never tested for feasibility.

The bottom-up approach starts with specific policy options and determines how they can be used to achieve the targets.  On the face of it the bottoms-up approach is more grounded to reality.  However, when Harris explained the approach she listed adjustable factors:

This analysis uses a bottom-up assessment of the various energy supply and delivery systems that will be available to meet forecasted energy needs through 2040, accounting for policies, technology availability, and consumer uptake, and the energy planning law requirements to consider energy affordability, reliability, economic development and jobs, equity, and environmental needs.

Accounting considerations and energy planning law have many levers that can be manipulated to get the desired answer.  Absent transparent documentation that describes the assumptions for all those considerations and a process that engages the subject matter stakeholders for refining them, this bottom approach will not be grounded in reality .

Consider, for example, the different levers Harris described that can affect infrastructure deployment:

• Disruptions due to the pandemic
• Resulting supply chain disruptions
• Inflation, and
• Changes in energy policy from the Federal Administration, including the potential to cancel tax credits provided under the Inflation Reduction Act, planned denial of permits for wind generation, and attempts to remove state based clean car and clean truck rules by revoking California’s ability to enforce stricter vehicle emission standards.

Missing from this list is physics.  Years from now, historians will look back and wonder why New York State went down this path without considering the immutable laws of physics that precluded some of the naïve assumptions inherent in the proposed wholesale transition to diffuse and intermittent weather-dependent generating resources.

Pathways Outlook

The presentations to the Energy Planning Board hint that there are issues.  It is still necessary to read between the lines to understand the implications.  In one of the biggest under-statements of this transition process Harris conceded that the considerations will “likely impact state progress on statutory emissions goals”.

She went on to state “I would say we are continuing to monitor changes in federal policy and may need to explore the impacts of these changes in the final state energy plan that we will be driving toward this year.”   Then Harris claimed that:

Yet even with these challenges, the current analysis shows that New York can build on our successes, such as the creation of the nation’s largest green bank, the deployment of six gigawatts of distributed solar ahead of schedule, the completion of South Fork wind, the groundbreaking for the Champlain Hudson Power Express, Empire Wind One, and Sunrise Wind. And, of course, we have governor Hochul’s commitment to invest over a billion dollars of public funds in the sustainable future program, the largest single climate investment in state history.

I suspect that the recent passage of the “big, beautiful bill” is not going to represent a minor adjustment in renewable energy development.  Federal policies affected all the claimed success stories Harris described so a complete re-assessment is warranted.

Discussion
New York is at a crossroads  The inevitability of Climate Cost affordability being a political liability has been acknowledged even by Hochul. 

I am particularly incensed by this statement by Harris: “Importantly, this analysis demonstrates that we can continue to make meaningful progress toward our energy goals while preserving reliability and affordability for our citizens.”  They have not defined affordability or what reliability risks are acceptable.  Without those definitions this is just a slogan.

New York’s Climate Act implementation was not well planned.  The Scoping Plan’s Integration Analysis ignored the impact of uncertainty on their projects, and the stakeholder process did not acknowledge input contrary to their narrative.  I will concede that the supply chain effects of the Pandemic were unanticipated, but I am pretty sure stakeholders comments mentioned the risk that if everybody is planning a similar electrification transition that there will be supply chain competition as the suppliers gear up.  It is not clear how much of the supply chain issue is due to that competition as opposed to the convenient scapegoat of the pandemic.

Conclusion

As mentioned before, there is every indication that slavish devotion to the aspirational goals of the Climate Act is the goal of the Energy Plan process.  At the same time NYSERDA and DPS claim that the transition “must be managed within the constraints imposed by Federal and State reliability requirements and at a justifiable cost to ratepayers.”  Qualitatively the Governor’s recent admission that Climate Act costs contribute to recent rate case increases means that the planned transition is not affordable.  If the State were to establish specific limits, then I am sure affordability would be cause for a reassessment of the schedule and ambition of the Climate Act.  This should be a cornerstone objective of the Energy Plan.