On December 16, 2025 the Energy Planning Board approved the State Energy Plan. Despite all the talk about public participation the fact is that the stakeholder process was a failure. It has no credibility because it did not publicly address all stakeholder comments. At the start of the Draft Energy Plan comment period I published an article expressing my fear that this process would replicate the perfunctory treatment of stakeholder comments in the development of the Scoping Plan. All my fears came true.
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”. According to the Energy Plan Process webpage:
In September 2009, a law was passed that statutorily establishes the State Energy Planning Board and calls on that Board to launch an energy planning process and to complete a State Energy Plan (opens in new window). The goal of the planning process is to map the state’s energy future by showing how the state can ensure adequate supplies of power, reduce demand through new technologies and energy efficiency, preserve the environment, reduce dependence on imported gas and oil, stimulate economic growth, and preserve the individual welfare of New York citizens and energy users. To support the development of the State Energy Plan, numerous white papers, forecasts, and policy documents are developed based on input from energy experts and concerned citizens.
I have provided background information and a list of relevant articles including summaries of recent meetings on my Energy Plan page.
State Energy Plan Stakeholder Process
This description of the process is based on the Summary for Policy Makers Public Input, Section 1.2. In July 2025, the Energy Planning 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 Board summarily approved 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 showing 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 were only posted immediately after the 16 December Planning Board meeting where the Plan was approved. 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 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 only record of the comments received was a list of comments searchable by “comment text, commenter name, group name, etc.”
The bottom line is that the Energy Planning Board members were never given a comprehensive summary of all the comments. I believe that they were never told anything that negatively reflected on the Administration’s narrative that the Energy Plan represented a comprehensive roadmap to “build a clean, resilient, and affordable energy system for all New Yorkers”.
My Stakeholder Process Concerns
In early August I published an article stating that I was worried that the Hochul Administration would just go through the motions of using stakeholder input. My primary concern was the need for a transparent and comprehensive stakeholder process. I included two examples of issues that I had highlighted as problems in the Scoping Plan that were also present in the Energy Plan.
I argued that a credible stakeholder process needs two components. The first is interactive meetings. In this process NYSERDA read their findings from scripts and gave the Energy Planning Board the opportunity to ask questions but never took questions from the public. During the public comment meetings, people were given two minutes to speak, no opportunity to ask questions, and NYSERDA staff at the meeting never asked questions. If the State was serious about considering public input for the energy plan, then they would hold a series of meetings to cover specific technical topics that includes interactive sessions.
The second component of a credible process is a public response to all the substantive comments submitted. Documentation describing specific comments, responses to the issues raised by comments and the recommendation for resolution in the final Energy Plan should be provided to the Energy Planning Board, the Public Service Commission and the public. If the State is to have any credibility regarding their Energy plan stakeholder process, then they must provide documentation showing that all the comments were considered and addressed. To be trustworthy the authors of the documents at the New York State Energy Research & Development Authority should explain why issues raised in comments don’t need to be addressed. Importantly, this information was especially necessary for the Energy Planning Board to consider when they voted on accepting the Energy Plan.
Reaction to Stakeholder Process
I searched through the transcript of the statements made at the Energy Planning Board meeting to see how Board members referenced the stakeholder process. Eight members mentioned the stakeholder process. Consdider two examples. Chair Harris claimed, “In the last four months alone, our draft, we have delivered significant ground in terms of updating our draft plan to incorporate thousands of public comments”. NYSERDA’s Karl Maas said the Energy Plan “represents the work conducted by dozens of State Energy staff and technical experts informed by stakeholders and public commenters and ultimately shaped by members of this Board.”
In reality, the incorporation of comments by stakeholders and public commenters was incomplete. I will show examples where my comments were not acknowledged but had bearing on material presented in the Final Energy Plan and presumably could have influenced votes to approve the Plan.
One of the emphasized points in descriptions of the Plan was that “Implementing New York’s State Energy Plan is projected to improve air quality, resulting in public health benefits for all communities throughout the State, with the greatest benefits realized in disadvantaged communities.” This point warranted its own Public Health Impacts Fact Sheet. However, I submitted comments explaining that there were issues with the numbers in the following table from the Fact Sheet.
All these health benefits are based on air quality impacts estimated using a methodology that is based on the premise that air quality improvements associated with reductions in GHG emissions are the driver for these health effects. My comments raised issue with that presumption.
NYSERDA tried to determine community-scale impacts with the resolution required to predict impacts to disadvantaged communities. This is an enormous challenge given the number of emission sources and receptor locations, the characteristics of the pollutants considered, and difficulty projecting future emissions for all of society. As a result, a “newly developed air quality and health impacts modeling framework—the NY Community-Scale Health and Air Pollution Policy Analysis (NY-CHAPPA) model —rather than using the Environmental Protection Agency’s (EPA’s) CO-Benefits Risk Assessment Health Impacts Screening and Mapping Tool (COBRA)” was used. My comments showed that this new model over-simplified the relationship between sources and receptors. The most important factor affecting pollution impacts is wind direction. NYSERDA modeling only used four wind directions whereas COBRA uses 16. They also only used one year of observed data instead of the five typically used. Using one year of data weakens the estimates but using only four wind directions invalidates the projected estimates. NYSERDA evaluated model performance to justify using their new model by comparing observed historical concentrations against future predicted concentrations. That approach is laughably inappropriate. I do not deny that reductions in most of the pollutants will improve air quality but assigning quantitative values to the improvements is inappropriate because the modeled numbers are so imprecise.
I also demonstrated that the asthma exacerbation metric was invalid. This metric claims a reduction in emergency room visits due to asthma is related to reductions in inhalable particulate concentrations. I demonstrated the the approach used is wrong. I showed that there are environmental, socio-economic, healthcare access, clinical, comorbidity, behavioral, clinical management and psychosocial confounder factors affecting asthma. Claiming that any one of the factors affecting emergency room visits is the unique cause of observed changes in asthma rates is not likely to represent what is happening. My comments also documented that the claim that there would 1300 avoided emergency room visits due to reductions in inhalable particulate concentrations were invalid. I compared the observed inhalable particulate concentrations with the observed emergency room visits and found no correlation. Correlation does not prove causation, but no correlation means that there cannot be causation.
Discussion
Everyone associated with the Energy Plan process brags about how there is a “robust” stakeholder process that “informed” the process. This article debunks those claims.
This article gives two examples of impactful issues that I identified in my comments that were not acknowledged, much less addressed. With all due respect, no one at NYSERDA has the air pollution meteorology experience that I do. The failure to act on expert input that impacts the analysis and results means that New York’s energy plan is not as good as it could be.
NYSERDA notes that “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).” I acknowledge that sifting through the volume of comments is a challenge. However, most of the comments from organizations and campaigns are similar so the number of unique comments is much less. Moreover, comments like that are typically thinly veiled lobbying submittals supporting their vested, and probably, financial interests, instead of comments addressing particular technical issues.. Those comments can be addressed simply an would reduce the total response to muc less than the number of comments submitted.
I believe that NYSERDA must develop a stakeholder comment process that raises substantive issues to another level of consideration. For example, there could be technical issue workshops where a dialogue between NYSERDA and stakeholders is encouraged and a resolution to the problem developed. For example, such a workshop would recommend that in the next edition of Energy Plan that the NY-CHAPPA model be modified to use more wind directions.
The stakeholder process associated with regulations proposed by the Department of Environmental Conservation (DEC) require the agency to respond to all comments. That addresses one of my recommendations, but DEC also cannot interact with anyone once the regulation has been formally proposed. That means that my second recommendation that interactive meetings are necessary is not possible. NYSERDA has no such restriction but refuses to respond to comments in any way.
Finally, there are two other ramifications. First, I gave two examples of many that I found in my evaluation but could have provided many more. There is no doubt that others raised many other technical issues associated with the Draft Energy Plan that were similarly impactful and not addressed. The second issue is that this information is especially necessary for the Energy Planning Board to consider when they voted on accepting the Energy Plan. That they voted with incomplete information is another example of why the New York stakeholder process is simply political theater.
Conclusion
The State Energy Plan is too important for it to be a politicized process. The flaws in the stakeholder process of the recently approved Energy Plan prove that the process is undeniably politicized. Selective treatment of stakeholder input does not further the goals of the Hochul Administration to provide a “comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers”.
Pragmatic Environmentalist of New York 