Draft NYS Energy Plan Pathways Scenario Scam

This is part of my continuing coverage of the New York State Energy Plan.  On July 23, 2025, the Draft Energy Plan was released for comment.  This post explains how the analyses for the Draft Energy Plan are hiding the true costs to meet the Climate Act targets.

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. 

I acknowledge the use of Perplexity AI to generate summaries and references included in this document.  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. 

Net-Zero Aspirations

The Climate Leadership & Community Protection Act (Climate Act) established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda” was based on an Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA).  The Climate Act is not the only legislation or regulation that was promulgated to achieve reductions in greenhouse gas emissions to address climate change.  That fact has a major bearing on the NYSERDA Draft Energy Plan Pathways scenario.

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.

The driving factor for the Energy Plan is the net-zero ambitions of New York’s ruling political party.  This is the first update of the Energy Plan since the Climate Act was passed in 2019.  I have provided more background information and a list of previous articles on my Energy Plan page. 

In this iteration of New York climate policy the Pathways Analysis is equivalent to the Integration Analysis. Responsibility for implementing the Energy Plan as well as all the Climate Act programs lies with NYSERDA.  Over my multi-decade career, I have seen an ever-increasing level of political influence on NYSERDA’s research priorities and, more recently, the research results. This post explains how the Pathways Analysis scenarios are being used by NYSERDA to hide costs of the Energy Plan net-zero transition.

Costs

I recently gave my first impressions of the Draft Energy Plan released for comment at the most recent Energy Planning Board meeting.  NYSERDA President and CEO Doreen Harris is the Chairperson the Energy Planning Board.  This post focuses on this one aspect of the meeting.  After a presentation regarding the Transmission and Distribution Reliability Study she said.

You may recall during our last meeting in which we discussed the pathways modeling for this plan. And to remind you, the analysis showed that New York’s citizens and businesses will need to invest over one hundred billion dollars each year in the energy system, no matter which future path we take.

I have one immediate response.  There is a future path that would not cost over $100 billion.  NYSERDA, ever beholden to the Hochul Administration’s political plans, has prepared a comprehensive roadmap using a misleading limited assessment  As was the case with the Integration Analysis and Scoping Plan, NYSERDA is interpreting the “No action” scenario as one that includes all legacy programs in place prior to the passage of the Climate Act.  The appropriate baseline scenario is one that excludes all programs that were promulgated to reduce GHG emissions.

Legacy Programs

The Energy Plan Pathways Analysis defines the “No Action” pathway scenario as “reflecting outcomes in the absence of the Climate Act and energy policies enacted from 2019 onwards”.  The Perplexity description goes on: “It includes federal energy incentives and legacy New York State policies (i.e., those in place as of early 2025), but it explicitly excludes any state and local climate, decarbonization, or efficiency policies put in place since 2019.”

I have found that Perplexity is a very useful research tool enabling me to easily find references needed to document my articles.  However, its summaries are colored by the references it finds.  The query response concluded that “This scenario thus serves as a baseline representing a world without recent state-driven climate action”.  No, it does not.  It reflects New York State driven climate action since 2019 not a baseline without climate action. 

The Pathways analysis refers to previous actions as “legacy programs”.    When I requested a Perplexity description of the legacy program investments required no matter which future path New York takes I received the following summary (with my annotations):

Core Infrastructure Investments

According to the pathways modeling presented at the June 25, 2025 New York Energy Planning Board meeting, certain investments will be necessary across all energy scenarios through 2040. These “pathway-independent” investments represent critical infrastructure needs that New York must address regardless of the specific energy future the state ultimately pursues.

NYSERDA has not differentiated between investments necessary for greenhouse gas emission reduction aspirations and those unrelated to climate action.  The failure to differentiate means that the climate action costs are underestimated.

Baseline System-Wide Spending

The pathways analysis revealed that baseline system-wide spending of approximately $120 billion annually (in 2024 dollars) through 2040 will be required to maintain and modernize existing energy infrastructure, replace aging equipment, and purchase fuels to meet energy needs. This represents the foundational investment needed to keep New York’s energy system operational.

Note that when Harris said that investments over $100 billion were required the actual number is $120 billion.  The complication is that there are indeed energy costs that will occur whatever pathway occurs, but they are buried amongst the programs that are included to meet the targets for an 85% emission reduction by 2050, 70% of the electricity must come from renewable energy by 2030, and all electricity must be generated by “zero-emissions” resources by 2040..

Continued Investment in All Fuel Systems

A key finding from the pathways modeling is that all major fuels used in New York today will continue to meaningfully contribute to the state’s energy mix through 2040, including electricity, natural gas, and petroleum fuels. As stated in the Draft Pathways Analysis: “Continued investment in all fuel systems is necessary to assure safe and reliable energy services, in particular to meet peak day needs and to increase resilience”.

Natural Gas System Infrastructure

Despite projected declines in gas consumption across all scenarios, the natural gas system will require continued investment to ensure safe and reliable provision of service. The pathways modeling showed that while gas consumption is projected to decline, it remains a significant resource throughout the relevant period, necessitating ongoing system maintenance and upgrades.

In my opinion, investments in these legacy programs are appropriate for the “no GHG emission reduction mandates” programs.

Electricity System Expansion

The modeling demonstrated that electricity use is expected to grow substantially to power economic growth and expanded use of electric vehicles and heat pumps. This growth requires buildout of a diverse set of resources, including:

• Wind and solar installations
• Energy storage systems
• Advanced nuclear facilities
• Repowering of aging combustion power plants

Clearly every penny spent on these example buildouts is only included to meet the Climate Act mandates.  Saying anything otherwise is misinformation at best and a lie in my opinion.

Transmission and Distribution Infrastructure

Extensive transmission investments will be necessary to deliver renewable energy across the state and address new constraints appearing across the electric system. The New York Independent System Operator has identified that transmission expansion is “critical to facilitating efficient CLCPA energy target achievement” and noted that “the current New York transmission system, at both local and bulk levels, is inadequate to achieve currently required policy objectives”.

Specific transmission needs include:

• Major public policy transmission projects already approved by NYISO
• Local transmission upgrades (Phase 1 and Phase 2 projects approved by the PSC)
• Infrastructure to accommodate up to 6,000 MW of offshore wind capacity into New York City

This is a mixed bag of programs specifically related to the Climate Act and other necessary infrastructure maintenance.  I have been told that there is a big push to replace aging transmission lines.  If the replacement infrastructure maintains current capacity, it is maintenance but if it is upgraded with additional circuits to collect wind and solar power, then that component is not necessary no matter which energy path we take.

Grid Reliability and Resilience Investments

The pathways analysis emphasized that investments in transmission and distribution systems must be designed to withstand climate change. This includes:

• Upgrading aging infrastructure
• Enhancing system reliability metrics
• Incorporating scenario-based planning processes to address climate change impacts
• Advanced transmission technologies deployment

These are also a mixed bag of necessary infrastructure programs and programs that would not exist were it not for GHG emission reduction aspirations.

Load Growth Accommodation

All scenarios showed significant new large loads interconnecting to the system, driving growing electricity demand across both annual loads and peaks. Early planning for abundant supply is essential to accommodate this load growth and ensure continued opportunities for economic development.

This is a complicated situation.  If the load growth is due to new manufacturing or cost-effective electrification, then this is true no action energy path cost.  If the upgrades are due to mandated home electrification and electric vehicles, then including the costs in a “no action” Pathway scenario is malfeasance.

Energy Efficiency and Weatherization

Across all pathways, households can lower their overall energy costs by making energy-saving choices such as home weatherization, efficient appliances, and fuel-efficient vehicles. Policy action to reduce up-front costs and other barriers will be necessary to make such choices more accessible.

This is even more complicated.  Energy efficiency and weatherization programs have been in place for decades.  Are they driven by net-zero fantasies or pragmatic cost effectiveness concerns?

Discussion

I believe that the NYSERDA rationale for not including a Pathways scenario that does not include any programs that are only included to address climate change is that there are laws mandating those programs.  Public Service Law Section 66-P Establishment of a Renewable Energy Program is the law that implements the Climate Act renewable energy mandates.  NYSERDA ignores the provisions for bounds on implementation in PSL 66-P. PSL 66-p(2),b states “The commission may, in designing the program, modify the obligations of jurisdictional load serving entities and/or the targets upon consideration of the factors described in this subdivision.”  Section 66-p (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.

The existence of those safety valve provisions and the current changes in Federal clean energy policies necessitate the inclusion of a Pathways Analysis scenario that does not include any New York or Federal emission reduction programs.  I believe that the majority of New Yorkers agree with me that we want to know the total cost, irrespective of which regulation requirement, that the Energy Plan projects will be necessary to meet the net-zero and electric system mandates of the Climate Act.  In my opinion, there is no question that those costs would be enormous and no question that that fact is being covered up by NYSERDA at the behest of the Hochul Administration.

The NYSERDA Pathways Analysis projects that energy system investments will total $120 billion per year out to 2040.  There are approximately 7.8 million households in New York State.  This equates to over $1200 per month per household.  How much of this is due to net-zero aspirations?

Conclusion

“Fooled me once, shame on you.  Fooled me twice, shame on me.”  NYSERDA is repeating the playbook of the Scoping Plan to hide the costs of Climate Act implementation.  I raised the issue in my Scoping Plan comments but there was no acknowledgement by NYSERDA.  I do not believe that the members of the Climate Action Council who voted to approve the Scoping Plan were told about the comment.  I did not reach enough people to get a scenario included that would represent no emission reduction program costs.  The result was a massive underestimate of the costs of the Climate Act.  The same approach is being used in the Energy Plan.  I believe that the only way to get this to change in the Energy Plan proceeding is for legislators to demand change.   Please contact your legislators and demand a full accounting of all the costs to achieve the Climate Act mandates.