On July 23, 2025, the Draft Energy Plan was released for comment and comments were due on October 6, 2025. On November 13 the State Energy Planning Board will meet to discuss public comments on the Draft document. I predict that the New York State Energy Research & Development Authority (NYSERDA) will avoid specifics and only describe the comments received in general terms. I have no expectations that NYSERDA will provide a summary of comments received or document how comments submitted were treated. The Draft Energy Plan also has addressed affordability, but it is not clear how that will be treated going forward. I will publish a summary soon after the meeting to verify my prediction.
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 nearly 600 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 background information and a list of previous articles on my Energy Plan page. While there are some indications that reality is dawning on the Hochul Administration, the process has not given me a lot of confidence that those concerns will be addressed sufficiently. 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.
Supreme Court Decision
There is another interesting angle to this meeting. I recently described the Oct. 24, 2025, New York Albany Supreme Court decision as a fork in the road. Multiple environmental organizations sued the New York State Department of Environmental Conservation (DEC). The judge ordered DEC to issue final regulations establishing economy-wide greenhouse gas emission (GHG) limits on or before Feb. 6, 2026 or go to the Legislature and get the Climate Act 2030 GHG reduction mandate changed. There has been no indication yet how this will be addressed.
This is relevant to the resolution of the Draft Energy Plan because during the legal process the State submitted a letter that addressed “two categories of new developments: (1) the publication of the 2025 Draft New York State Energy Plan by the New York State Energy Planning Board on July 23, 2025 and (2) additional actions by the federal government that impede New York’s efforts to achieve the Climate Act. The letter argued that it was inappropriate to implement regulations that would ensure compliance with the 2030 40% reduction in GHG emissions Climate Act mandate because meeting the target is “currently infeasible”.
Ordering achievement of the 2030 target would equate to even higher costs than the net zero scenarios and would affect consumers even sooner. Undoubtedly, greenhouse-gas reducing policies can lead to longer-term benefits such as health improvements. This does not, however, offset the insurmountable upfront costs that New Yorkers would face if DEC were forced to try to achieve the Legislature’s aspirational emissions reductions by the 2030 deadline rather than proceeding at an ambitious but sustainable pace.
The letter concluded that the Climate Act is unaffordable:
Petitioners have not shown a plausible scenario where the 2030 greenhouse gas reduction goal can be achieved without inflicting unanticipated and undue harm on New York consumers, and the concrete analysis in the 2025 Draft Energy Plan dispels any uncertainty on the topic: New Yorkers will face alarming financial consequences if speed is given preference over sustainability.
The biggest question for the State Energy Planning Board discuss of the resolution of the Draft Energy Plan is how this acknowledged affordability issue will be addressed.
Resolution of My Comments
My Energy Plan page lists 6 articles describing the Pathways Analysis that provided quantitative information for the Draft Energy Plan and 18 more articles about comments on the Plan. Here are some highlights that I will be watching for
The New York Independent System Operator (NYISO) comments included recommendations that are sure to infuriate proponents of the Climate Act. They say that we are not ready to retire existing fossil-fired generating plants, the necessary resources to replace them will not be ready any time soon so we need to build new fossil-fired units, and maintaining existing nuclear facilities is necessary. Will these reality-based comments be incorporated in the Final Energy Plan?
I submitted comments that described significant problems with the Health Benefits Analysis chapter including over-simplification of the air quality analysis used to predict health impacts, failure to correctly verify the new model used, claiming health benefits when there is no observed relationship between annual average PM2.5 and emergency room visits related to asthma, and suggesting significant benefits when the effects are much less than the observed inter-annual variation. This makes the Draft plan claims of benefits invalid. Will the final energy plan acknowledge this?
I also submitted comments that described why New York is not ready to eliminate the use of natural gas. I addressed natural gas use for transportation, unacknowledged advantages for natural gas used for electric generation, arbitrary permitting decisions that have blocked necessary infrastructure projects, and the use at peaking power plants that provide critical reliability support. Will NYSERDA support natural gas use?
In my first oral comments I stated that unless the process includes stakeholder meetings that give the public to ask clarifying questions and there is a commitment to document the response to all comments submitted, the stakeholder process will have no credibility. NYSERDA never held a stakeholder meeting, and I doubt that the comment responses will be documented.
Discussion
This will be interesting. Despite my pessimism that NYSERDA will meaningfully respond to all stakeholder input, the meeting’s discussion of affordability relative to the position of the Attorney General’s supplemental letter will be fascinating. I also wonder if they will acknowledge that something must be done relative to the judge’s decision. In the best case, they will describe a path forward.
Stay tuned.
Pragmatic Environmentalist of New York 