This post documents the oral comments I presented at the Draft State Energy Plan virtual public hearing on September 30, 2025. The New York State Energy Research & Development Authority (NYSERDA) only allocated two minutes per person, so this article documents the statements that I made. My comments addressed the irrational vilification of natural gas in the Draft Energy Plan.
I am convinced that implementation of the New York Climate Leadership & Community Protection Act (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.
Net-Zero Aspirations
The 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.
According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.” The New York State Energy Planning Board is a “multi-agency entity established under Article 6 of the Energy Law, playing a core role in the State Energy Plan process”. Among its responsibilities is adopting the State Energy Plan: The Board has the authority to adopt the comprehensive statewide energy plan, and the stakeholder process should be an important component of that responsibility.
The driving factor for the updated Energy Plan is net-zero ambitions of the Climate Act. This is the first update of the Energy Plan since the Climate Act was passed in 2019. I have provided more background information, links to summaries of previous oral comments, and a list of previous articles on my Energy Plan page. Because of the importance of this process on the future energy system of New York I am following it closely and will be submitting oral and written comments.
Comments
This section documents the comments I made on September 30, 2025. I used bullets to differentiate my comments from the explanations.
- My name is Roger Caiazza. Documentation for these comments has been posted on my Pragmatic Environmentalist of NY blog.
As noted in the introduction I am convinced that implementation of the New York Climate Act will do more harm than good.
- The Draft energy plan must reflect the reality of natural gas attributes and not the dreams of politicians.
The same ideologues that convinced the politicians that achieving Climate Act mandates would require no new technologies hate natural gas.
- New York’s obsession with eliminating natural gas is irrational. Concerns about the higher observed global warming potential of methane molecules compared to carbon dioxide drive the rationale to control natural gas. However, laboratory measurements ignore the fact that in the atmosphere changes in methane concentrations have negligible climate impacts compared to CO2.
New York’s war on natural gas or methane is not based on pragmatic balancing of issues of cost, efficiency, and benefits, but only on an ideology built on the hatred of the natural gas industry. Worst of all the foundational argument that controlling methane is necessary because of enhanced impacts on global warming is not correct.
The relative impact of methane and carbon dioxide emissions on longwave radiation that causes the greenhouse gas effect is described in the following references.
Steve Gorham explains that “Because of greenhouse gas saturation in the atmosphere, methane regulations across the world will have no measurable effect on global temperatures.” This is a good overview of the irrelevance of methane.
Wijngaarden and Happer also did a paper on methane itself. They argued that the effect of the observed rate of CO2 molecules is so much bigger than the increase in methane atmospheric concentrations so the methane forcing is one tenth that of CO2. The paper is attempts to explain complex relationships for the general public but is still dense. Fortunately Vijay Jararaj summarized their work and conclusions.
Clyde Spencer explained that changes to radiation effects occur on a molecule-by-molecule basis in the atmosphere in an article titled The Misguided Crusade to Reduce Anthropogenic Methane Emissions. The Climate Act tracks emissions by weight. In the atmosphere CO2 is more than two orders of magnitude more abundant than CH4 on a molecular basis. The Climate Act uses the global warming potential that estimates the mid-range, long-term warming potential of CH4 is 32 times that of CO2. However, that equivalence is for equal weights of the two gases! Using a molecular basis (parts per million-volume mole-fraction) to account for the lighter CH4 molecule reveals that the annual contribution to warming is a fraction of that claimed for CO2. Methane emissions on a molecular basis are increasing at a rate of 0.58% of CO2 increases. Therefore, changes in methane emissions have insignificant effects.
Methane molecules affect the outgoing radiation in the same spectral band as water vapor. The lab measurements are based on a standard dry atmosphere. In the atmosphere, methane’s two main infrared absorption bands) are completely overlapped by two of the several broader and much stronger water vapor absorption bands. In a world averaging about 2% specific humidity, any methane effect is literally swamped by water vapor effect. In particular, water vapor reduces the potency of methane by about 82 percent at 80% relative humidity and at 46% relative humidity (from the US Standard Atmosphere) the reduction is 75%.
Ralph B. Alexander describes another molecular consideration ignored in the Climate Act. Each greenhouse gas affects outgoing radiation differently across the bell-shaped radiation spectrum One of the reasons that CO2 is considered the most important greenhouse gas is that its effect coincides with the peak of the bell shape. On the other hand, the effect of CH4 is down in the tail of the bell shape. As a result, the potential effect of CH4 is on the order of only 20% of the effect of CO2.
Andy May’s excellent summarization of Wijngaarden and Happer’s important paper “Dependence of Earth’s Thermal Radiation on Five Most Abundant Greenhouse Gases” explains that the greenhouse effect of methane is not only related to the effect on longwave radiation itself but also the concentration in the atmosphere. Because the atmospheric concentration of methane is so small doubling concentrations change the “outgoing forcing by less than one percent”. In other words, doubling emissions or cutting emissions in half of methane will have no measurable effect on global warming itself.
The residence time of the two gases is different. Methane only has a lifetime of about 10-12 years in the atmosphere. The “consensus” science claim is that 80% of the anthropogenic CO2 emissions are removed within 300 years. (Note however that there are other estimates of much shorter residence times.) This means that CO2 is accumulating in the atmosphere. CH4 is converted to CO2 and is then counted in the monthly CO2 measurements as part of the CO2 flux. Because methane does not accumulate the same way as CO2 it should be handled differently. However, the Climate Act doubles down on using the same approach. Climate Act authors claimed it was necessary to use 20-year global warming potential (GWP) values because methane is estimated to be 28 to 36 greater than carbon dioxide for a 100-year time horizon but 84-87 greater GWP over a 20-year period.
Dr. Mathew Wielicki gives a good, illustrated description that puts methane in perspective. Note that some of the article is behind a paywall.
- Politicians must recognize the residential reliability benefits of natural gas. I have lived in my home for over 40 years. I have never had an outage of natural gas service. There have been many minor electric outages and two multi-day blackouts. We survived the long blackout because we had natural gas for heating and cooking. Surviving and recovering the grid in an all-electric energy system will be extraordinarily challenging.
I do not think that the Energy Plan has adequately recognized the resiliency value of natural gas and its benefits during electric outages. My described personal experience is shared by many and ignored in the Draft Energy Plan. I think it must acknowledge that recovery of an all-electric energy system will be extraordinarily challenging and that natural gas provides the fuel diversity necessary for a resilient energy system.
- NYSERDA’s recently released GE Grid Performance Gaps Study states that New York needs approximately 25 gigawatts (GW) of capacity contribution by 2040 to replace the fossil fuel fleet. Politicians must acknowledge that dispatchable emissions-free resources simply will not be available by 2040.
One of the themes in the Draft Energy Plan is that the Climate Act law mandates compliance deadlines. However, it does not adequately acknowledge that Public Service Law (PSL) Section 66-P, Establishment of a renewable energy program, is also a law. PSL 66-P requires the Public Service Commission (PSC) to establish a program to ensure the State meets the 2030 and 2040 Climate Act obligations. It includes provisions stating that the PSC is empowered to temporarily suspend or modify these obligations if, after conducting an appropriate hearing, it finds that PSL 66-P impedes the provision of safe and adequate electric service.
With Richard Ellenbogen, Constatine Kontogiannis, and Francis Menton I submitted a filing in a PSC generic proceeding. As described here, our submittal includes the primary filing, two exhibits documenting the customers in arrears safety valve trigger, and five supporting exhibits. Responsible New York agencies all agree that new Dispatchable Emissions-Free Resource (DEFR) technologies are needed to make a solar and wind-reliant electric energy system viable during extended periods of low wind and solar resource availability. Two of the supporting exhibits document the implications of this necessity. Exhibit 4 – Resource Gap Characterization analyzes gaps between Climate Act mandates and available resources, and Exhibit 5 – Dispatchable Emissions-Free Resources explains that the need for a resource that is not currently commercially available risks investments in false solutions. I maintain that safe and adequate electric service can only be guaranteed if the necessary DEFR technology has been proven feasible.
In my opinion, the most promising DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready, can be expanded as needed and does not suffer from limitations of the Second Law of Thermodynamics. If the only viable DEFR solution is nuclear, then renewables cannot be implemented without it. But nuclear can replace renewables, eliminating the need for a massive DEFR backup resource. It is common sense to replace aging natural gas-fired generating units now rather than hope that the necessary replacement technologies will appear as needed in the future.
New York State has not developed a plan to ensure DEFR will be available as needed and that means that a natural gas generation must be available. NYSERDA’s coordinated study to assess future grid reliability and stability under high-renewable scenarios in the GE Grid Performance Gaps Study states that New York needs approximately 25 gigawatts (GW) of capacity contribution by 2040 to replace the retiring fossil fuel fleet. Politicians must acknowledge that zero-emission resources that provide all the grid reliability services provided by natural gas generation simply will not be available by 2040. We must use natural gas as a bridge fuel until proven dispatchable emissions-free resources are available.
I am going to follow up with another post on natural gas and the Draft Energy Plan. The oral comment time constraints prevented me from covering other topics. I will explain that natural gas has a place in the transportation sector, there are unacknowledged natural gas advantages, and the State used arbitrary permitting decisions to deny permit applications for needed infrastructure improvements.
Conclusion
My oral comments concluded using similar terminology to this. The policies incorporated into the Climate Act that drive the Draft Energy Plan are not based on facts or research but ideology. They are, in a word, irrational. Not so long ago the idea that natural gas could be used a bridge fuel until the aspirational “clean” generating resources and energy storage technologies could be tested at the scale needed, perform like a natural gas fired generating unit, and provide power at a similar cost, was generally accepted as a pragmatic approach. The only rational approach to maintain reliability and lower costs is to go back to that concept.
Pragmatic Environmentalist of New York 