Initial Thoughts on the Draft NYS Energy Plan

This is part of my continuing coverage of the New York State Energy Plan.  After a series of Energy Planning Board meetings this year, on July 23, 2025, the Draft Energy Plan was released for comment.  While there are some indications that reality is dawning on the Hochul Administration, the meetings, the description of the document, and my brief review of the document, there are still troubling aspects of this process.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) 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.

Responsibility for implementing the Energy Plan as well as all the Climate Act programs lies with the New York State Energy Research & Development Authority (NYSERDA).  Over my career I have seen an ever-increasing level of political influence on the research priorities and, more recently, the research results.  If something that could embarrass the administration manages to get funded, the results get buried if they don’t fit the narrative.  This bias was blatantly obvious during the development of the Scoping Plan and it evident here too.

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

July 23, 2025 Board Meeting

The materials for the meeting include the following:

Meeting Materials

Presentations

Draft State Energy Plan

Draft Plan under review by the State Energy Planning Board:

Volume I: Summary for Policymakers [PDF]

Volume II: Topical Chapters [PDF]

Volume II: Analysis Chapters [PDF]

Transmission and Distribution Systems Reliability Study [PDF]

Data Annexes:

The Draft Energy Plan documents will be updated to remove the “under consideration” caveats.  I will post articles on details of the meeting later.

Initial Impression

Yesterday’s meeting was a vivid reminder that everything associated with the Climate Act is politically motivated.  It was a political theater from start to end.  They pretended that the Board could provide meaningful comment that might prevent the release of the draft plan but the schedule for hearings and end date for submitting comments was spelled out in all the documents.  With very few exceptions, everything was scripted including the transition between speakers.  After presentations, there were very few questions.  Questions would require going off the script.  During the discussion about whether to release the Draft Energy Plan the responses by board members were scripted too. 

The NYISO representative commented that his organization had been working with NYSERDA.  I got the impression from the commentary and some of the findings mentioned that outside experts have been involved.  While that is encouraging, it remains to be seen how the process will acknowledge and reconcile differences of opinion. 

Affordability

There were numerous references to affordability in the meeting presentation.  I asked my new best friend, Perplexity AI, how many?  I acknowledge the use of Perplexity (https://www.perplexity.ai/) to generate the following summary.

The NYS Energy Plan presentation contains numerous references to affordability, emphasizing its importance throughout. Based on a detailed review of the full presentation text, here is the count and context for the most relevant references:

  • The word “affordable” and its variants (such as “affordability”) appear at least 28 times in the presentation.
  • References span across core planning goals, specific program actions, sector recommendations, and equity discussions.

Key references by section include:

  • Planning Goals and Principles: Affordability is listed as a guiding principle, alongside reliability, equity, and environmental health (slides 75-76, 79-80).
  • Program Actions: The Energy Affordability Policy and bill discount programs for lower-income and below-median-income customers are called out specifically (slide 7, 43).
  • Sector Strategies: Explaining the goal of affordable zero-emission vehicles and affordable, reliable transit (slides 25, 27-28).
  • DAC and Equity: Additional references address minimizing costs for electric ratepayers, reducing disproportionate energy burdens (slides 29, 34, 80, 43).

Summary: The presentation repeatedly highlights affordability as a defining priority for New York’s energy transition—both as a policy goal and via specific programs, especially for low- and moderate-income and disadvantaged communities.

I am sure that the Draft Energy Plan will also emphasize affordability and reliability.  For example, the Summary for Policymakers “pending Board consideration” released  at the meeting says the Energy Plan will be “Advancing abundant, reliable, affordable, and clean energy for New York”.

This is a controversial topic for me.  Until such time that those criteria are defined, talking about affordability is nothing more than a political slogan.  I am going to comment that it is necessary to establish specific affordability, reliability, and environmental impact criteria, set up a tracking mechanism for each, and formulate a mandatory course of action when the criteria are exceeded for the Hochul Administration to have any credibility regarding these key conditions.

Going Forward

A common refrain during the discussion of the release of the Energy Plan was the importance of stakeholder involvement.  This is also a controversial topic for me.  In a matter as complex as the New York energy system, there will be differing opinions about substantive aspects of the different components of the energy system.  The only way for the development process to be credible is for stakeholder comments to be documented and the rationale for how controversies were resolved explained so that when the Energy Planning Board votes to approve it, they will have all the information.

The Climate Act implementation process was not a model to follow.  The differences of opinion between stakeholders and NYSERDA during the Scoping Plan process were not documented.  During the Energy Plan presentations, there were references when speakers implied surprise that the results to date did not comport with the expectations of the analysis performed for the Scoping Plan.  In more than one instance, they referred to something that I know was brought up and ignored during the Scoping Plan stakeholder process.  I cannot recommend strongly enough that this process should respond to all comments and reconcile any differences between NYSERDA and NYISO electric grid projections in a clear and transparent manner.

Politics

Unfortunately, my recommendations flounder on the political reality of New York.  The Democratic Party controls the New York Assembly and Senate, and the Governor is a Democrat.  The Energy Planning Board membership consists of ten agency heads, appointees of the Governor, Speaker of the Assembly, President of the Senate, and Presiding Officer of the New York State Independent System Operator (NYISO).  Of the fourteen members only two have technical energy backgrounds.   All decisions will be decided based on political considerations.  Given the fact that the politicians got us into this mess, I have little hope that they will willingly get us onto a pragmatic path based on reality.

Conclusion

I am encouraged that the Hochul Administration has finally realized that the Climate Act schedule and ambition are impossible to meet.  The presentations at this meeting are consistent with that epiphany.  It is not clear how they intend to reconcile the problems that introduces.

In my opinion, there are two critical requirements for a satisfactory Energy Plan.  Defining metrics for affordability, reliability, and acceptable environmental impacts should be a primary component of the Energy Plan.  A transparent and comprehensive stakeholder process is needed for credibility. I do not expect that my concerns will be addressed.

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Author: rogercaiazza

I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and (https://pragmaticenvironmentalistofnewyork.blog/) reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative (https://reformingtheenergyvisioninconvenienttruths.wordpress.com). Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.

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