The last several weeks I have written multiple articles about the State Energy Plan and the Energy Planning Board. This post describes a letter I sent to the members of the Energy Planning Board that said that it was premature to approve the Plan at this time. I wrote this post to document the fact that Board was told that there were issues before they voted to approve the Energy Plan because someday it will be obvious that approving the plan was a mistake.
In short, implementing New York’s net-zero dreams are unaffordable. The State Energy Plan analysis of total monthly household energy costs estimates that the capital costs to install replacement appliances and vehicles that can meet the Climate Act zero-emissions mandate is nearly $600 a month more than replacement with conventional household appliances and vehicles even when the savings of more efficient equipment are considered.
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 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
The New York State Energy Plan is billed as a “comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers”. I have provided background information and a list of relevant articles including summaries of recent meetings on my Energy Plan page. My latest article discussed presentations of findings from analyses completed since last summer (presentation and recording) at the December 1 meeting.
NYSERDA presentations and documentation are carefully curated to amplify the political messaging of the Hochul Administration, so it is necessary to read between the lines and carefully check all the statements that are made. The most important finding in the presentation on December 1 is what I think is a clear admission of expected unaffordable costs necessary for New York households to achieve the Climate Act mandates for zero emissions. I have explained how I derived the $600 a monthcost estimates in multiple posts and in a summary description of the Equipment Cost Sensitivity slide in the NYSERDA energy affordability presentation.
This information is not explicitly mentioned in the Energy Affordability Fact Sheet (Fact Sheet). I recognize that this is an extraordinary claim, so I prepared two articles focusing just on the calculation of that estimate. The Energy Affordability Initial Thoughts at SEP Board Meeting on 12/1/2025 article was my first attempt to document this finding. My latest article specifically addressed the claims in the Fact Sheet but also documented the location of every value in the Energy Affordability Data Annex spreadsheet published on 4 December 2025 after my first article on this topic.
State Energy Plan Process
This description of the process is based on the Summary for Policy Makers Public Input, Section 1.2, . On September 9, 2024 the Hochul Administration initiated the development of the State Energy Plan announcing the release of a draft scope of the plan. The Board solicited written public comment on the Draft Scope from September 9, 2024 to December 16, 2024. Comments were reviewed and incorporated into the final Scope, which was adopted by the Board in March 2025. In July 2025, the Board approved the release of the Draft Plan for public comment. The public comment period ran from July 23, 2025 to October 6, 2025. Nearly 15,000 written comments on the Draft Plan were submitted, with over 250 from organizations and the balance from individuals (80% of which were through 13 comment campaigns). A “thematic summary of public comments” was discussed at the November 2025 meeting of the Energy Planning Board. On December 16, 2025, the final act in the process will occur when the Board summarily approves the State Energy Plan.
The process is playacting. The outcome was never in doubt. Despite claims about the value of public engagement and input to inform the development of the State Energy Plan there is no record that all the input was considered. On October 7th the Energy Plan comment website promised that “All comments will be posted on the State Energy Plan website as soon as practicable” but they still are not posted. During the State Energy Planning Board meeting presentation on November 13 Karl Maas stated: “This presentation and its appendix, which includes comments on each plan chapter, will be posted after this meeting.” I used Perplexity AI to search for the appendix and confirmed that my search of the Energy Plan website had not missed that this was posted. Perplexity concluded: “The State Energy Planning Board appears to have failed to follow through on its commitment to publicly release the detailed comments appendix, despite the explicit promise made during the meeting. This lack of transparency undermines the credibility of the public comment process for the Draft State Energy Plan.”
The bottom line is that the Energy Planning Board was never told anything that negatively reflected on the Administration’s narrative that the Energy Plan implementation meeting the Climate Act mandates would Be a comprehensive roadmap to “build a clean, resilient, and affordable energy system for all New Yorkers”.
My Letter
My final effort to reach the Energy Planning Board to reconsider rubber stamping the Administration’s overly optimistic Energy Plan was to send the following letter to the Board.
I am writing to the members of the State Energy Planning Board to argue that it is premature to consider and act upon a resolution to adopt the State Energy Plan at the Board meeting scheduled for December 16, 2025. The Energy Plan is supposed to be a “comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers”. The draft documents labeled “pending board decision” show that there are untenable upfront costs that New Yorkers would face if the State follows the existing State Energy Plan roadmap to achieve the Legislature’s aspirational 2030 deadlines.
The State Energy Plan will have no energy affordability credibility if the Energy Planning Board adopts a plan that its analyses show is unaffordable. The 2025 Energy Plan Data Annex spreadsheet titled Energy Affordability Outputs and Input Data contains unacceptable affordability information. In the Equipment Cost Sensitivity slide there are monthly total energy costs including levelized equipment costs for a single household profile. As documented here, the projections for a moderate-income household in Upstate New York that uses natural gas found the difference between replacement of conventional existing equipment and the highly efficient electrification equipment necessary for Climate Leadership & Community Protection Act (CLCPA) compliance increases monthly average energy expenditures $594 when capital costs are considered. Only the wealthy could consider that affordable.
The Attorney General’s Office agrees that there are the “insurmountable upfront costs” if the Energy Plan is consistent with the CLCPA as it stands. Earlier this year there was a court case considering whether the Department of Environmental Conservation had to issue final regulations establishing economy-wide greenhouse gas emission (GHG) limits. During the case, the Attorney General 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 CLCPA.” The letter argued that it was inappropriate to implement regulations that would ensure compliance with the 2030 40% reduction in GHG emissions CLCPA 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.
There is no obvious record of what insurmountable State Energy Plan upfront costs led to that statement in the Attorney General letter, but the statement is consistent with the Equipment Cost Sensitivity analysis. I find it troubling that this finding received so little attention in the NYSERDA presentations to the Board. This information is not explicitly mentioned in the Energy Affordability Fact Sheet, in the Volume I: Summary for Policymakers or in the Energy Affordability Impacts Analysis chapter. The findings were mentioned in a 41 second segment of the December 1 Energy Affordability presentation (Page 8 in the annotated transcript): “What we can take away is that the net costs for efficient electrification journeys could be thirty five to forty percent higher than conventional replacement when accounting for equipment, reinforcing the importance of action to address upfront equipment costs so that households are able to access the benefits of these systems.”
In addition, the Pathways Analysis shows that meeting the 2030 CLCPA 40% GHG emission reduction target and electric system 70% renewable energy mandates are impossible. Those results are consistent with other State agency findings. I believe that these conclusions and the affordability results clearly show that it is time to amend the CLCPA consistent with the Ulster County New York Supreme Court decision ordering the Department of Environmental Conservation 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 schedule changed. The Hochul Administration and DEC appealed the decision on November 25, 2025 claiming that “it is impossible for the Department to simultaneously comply with both the Court’s order and its substantive statutory obligations.”
The State Energy Plan for approval on December 16, 2025, does not recognize these findings. Ignoring them to meet an arbitrary schedule means the Plan will be immediately obsolete. The Plan must explicitly state that the CLCPA mandates cannot be achieved and are unaffordable so must be amended for a State Energy Plan that ensures a clean, resilient, and affordable energy system for all New Yorkers. Failure to do so would be a serious disservice to New Yorkers.
Discussion
I do not expect that there will ever be any acknowledgment of the letter. This post documents that the State Energy Planning Board was told that total monthly household energy costs estimates for the capital costs to install replacement appliances and vehicles that can meet the Climate Act zero-emissions mandate are nearly $600 a month more than replacement with conventional household appliances and vehicles even when the savings of more efficient equipment are considered. Only the wealthy could consider that affordable. The Energy Plan is supposed to consider affordability so ignoring this finding destroys the credibility of the document.
Conclusion
My hobby of fighting the Climate Act mandates certainly keeps me busy but certainly does not have any effect on New York energy policy. I hope that someday I will be able to say I told you so.
Pragmatic Environmentalist of New York 