My last post documented the oral comments I submitted 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, and I had more arguments that I wanted to make so this article documents them. My comments address plans to eliminate 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.
Oral Comments
My last post documented the oral comments I made arguing that New York’s irrational vilification of natural gas risks an unreliable, unsafe, and unaffordable energy system. I explained that laboratory measurements showing greater impacts of methane emissions than carbon dioxide (CO2) ignore the fact that in the atmosphere changes in methane concentrations have negligible climate impacts compared to CO2. I noted my personal experience with the benefits of natural gas when I lived through electric blackouts. Finally, I pointed out that hoping that a presently unavailable dispatchable, emissions-free resource can be deployed by 2040 is too risky so natural gas generation must be maintained. The rest of this document describes some of my other concerns about eliminating natural gas.
Transportation
Many argue that air pollution from diesel trucks is an environmental issue. The Transportation chapter of the Draft Energy Plan states:
Medium and Heavy Duty Vehicles (MHDVs) and non-road vehicles are major energy users within the transportation sector and substantial contributors to the sector’s GHG and local criteria pollutant emissions. Both industry segments have opportunities to electrify and move to ZEVs but are still in the early stages. MHDVs are a priority for New York State to electrify, with particular attention on electrifying school buses.
The chapter goes on to optimistically claim that markets for zero emissions options are “nearing maturity” but the reality is that there are significant issues. I acknowledge the use of Perplexity AI to generate a summary of substantial barriers to the success of electrification efforts for school buses and MHDVs That summary listed the following items: financial and economic barriers, technical reliability and performance issues, cold weather performance limitations, infrastructure and grid capacity challenges, manufacturing and industry instability, and workforce issues. I would add that New York is a single jurisdiction and mandates for long-haul heavy-duty vehicles would require buy-in from many other jurisdictions.
I believe that natural gas use for transportation, particularly heavy-duty trucks and buses, would improve inhalable particulate impacts decades before zero-emission alternatives could be deployed because the technologies involved mature proven technologies. Another Perplexity AI query described the benefits of adopting CNG trucks. CNG trucks have up to 90% lower nitrogen oxide emissions and similar reductions of inhalable particulate matter mass emissions. There are fuel cost savings, a strong return on investment, and reduced maintenance costs while at the same time providing comparable power and performance and enhanced vehicle longevity. Also note that diesel trucks can be converted to run on CNG which is a claim that electric trucks will never make.
Natural Gas Electric System Advantages
The Draft Energy Plan does not acknowledge benefits of natural gas generation for New York’s electric system.
To address intermittency of wind and solar resources it is cost-effective to over-build capacity. For example, if we were to rely entirely on solar, then we would have to build enough solar generation to provide the necessary power for the winters shorter days. In the summer the days are longer, and less capacity would be needed. It is simply not possible to build a system with sufficient energy storage capacity to avoid over-building. This results in curtailment which “involves deliberately reducing renewable energy output below maximum potential, resulting in significant economic losses and underutilization of clean energy resources”. Because natural gas units can be dispatched as needed curtailment is not an issue.
As noted in my previous post a new Dispatchable Emissions-Free Resource (DEFR) is needed for an electric generating system that relies on wind and solar. I believe that the most likely DEFR 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. Nuclear works best as a baseload resource while natural gas generators can provide load-following and peaking services. It is common sense to replace aging natural gas-fired generating units that are nearing the end of their expected lifetime now rather than investing enormous money in renewables because they could be a false solution.
Arbitrary Permitting Decisions
I believe that environmental policy decisions should balance risks and benefits and that the rationale for permitting decisions should not be based on politics. The Draft Energy Plan should recognize that historical New York permitting decisions for natural gas pipelines are inconsistent with the on-going plans for renewable energy inspired transmission lines are inconsistent.
In one instance permits for the Constitution pipeline were rejected because of an inadequate water resource analysis for stream crossings. The Department of Environmental Conservation (DEC) was particularly worried about stream crossings. Rather than including permit conditions that require directional drilling to minimize impacts, DEC rejected the permit application outright. The permit denial came on Earth Day April 22, 2016, removing any thought that this was a political decision rather than a technical decision
The Northeast Supply Enhancement (NESE) Gas Pipeline was also rejected by DEC because of water quality concerns. The project would have caused 17.4 miles of underwater sediment disturbance in New York waters as part of a 23.5-mile total route from New Jersey coast to Rockaway, Queens. The
26-inch diameter natural gas pipeline required 4-6 feet burial depth. DEC’s denial of the Water Quality Certification in May 2020 was based on the project’s inability to demonstrate compliance with applicable water quality standards, particularly for mercury and copper contamination.
On the other hand, transmission line projects for renewable energy have managed to get permits. The Champlain Hudson Power Express (CHPE) successfully obtained permits because they “incorporated comprehensive monitoring and mitigation measures”. Testing demonstrated that sediment disturbance was brief and temporary, with values remaining below established threshold levels. However,NESE pipeline installation would also have had brief and temporary impact.
A portion of the CHPE transmission line and lines for two offshore wind facilities will be routed through New York Harbor and presumably would also have mercury and copper contamination issues. On one hand the burial process for the transmission lines is less intrusive but on the other hand the disturbance lengths are longer. CHPE travels approximately 27.8 miles in New York Harbor. The Queensboro Renewable Express (Rise Light & Power) transmission line will have 18.5 miles of underwater sediment disturbance in New York waters with two HVDC cables within a 200-300 foot wide corridor. Equinor’s Beacon Wind project had planned a much longer 115+ nautical mile transmission system from the offshore lease area OCS-A 0520 to the Astoria power complex. However, the company withdrew its transmission application in February 2025, citing project economics and regulatory challenges
These permitting decisions were clearly decided because of politics. New York’s Energy Plan should demand fuel-neutral permitting decisions.
Natural Gas for Peaking Power Plants
The Draft Energy Plan must acknowledge that natural gas peaking power plants provide necessary reliability support. Environmental justice advocates like the Peak Coalition, have convinced state politicians that New York City peaking power plants are “perhaps the most egregious energy-related example of what environmental injustice means today.” The enacting law for the New York Power Authority (NYPA) Draft Renewables Strategic Plan specifically directed NYPA to publish a plan by May 3, 2025, to end generating electricity with fossil fuel at its 11 small natural gas power plant (SNGPP) units located at 7 sites in New York City and on Long Island by the end of 2030 if reliability and environmental requirements are met. I have documented that the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. In brief, the continued operation of these facilities will have no discernable impact on local neighborhood air quality and shutting them down is solely political virtue-signaling. On the other hand, these facilities serve specific reliability needs that are not easily replaced.
Discussion
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 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. The Draft Energy Plan should recommend that criteria for safe, adequate, and affordable electric service be established so that New Yorkers are assured that current reliability standards are maintained.
Conclusion
The policies incorporated into the Climate Act that drive the Draft Energy Plan are not based on facts or research but ideology. Viewed through a pragmatic lens, the New York obsession with eliminating natural gas is irrational. Increased use of natural gas has been responsible for most electric generation emission reductions observed in the state. Natural gas provides efficient, resilient, and safe energy to homes and businesses. Not so long ago the idea that natural gas could also be used a bridge fuel until the aspirational “green” 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 rational approach. The Draft Energy Plan must ensure that ideological demands to eliminate natural gas do not result in harm to society.
Pragmatic Environmentalist of New York 