On 1/28/26 the Public Service Commission (PSC) issued a notice soliciting comments regarding the Coalition for Safe and Reliable Energy petition. This post describes issues related to transmission planning that I think impede the Public Service law 66-P provision for safe and adequate service. I will submit comments arguing that these findings obligate the PSC to hold a public hearing to determine if these transmission issues impede safe and adequate service.
I am convinced that implementation of the New York 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 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.
Background
There is a fundamental Climate Act implementation issue. Clearly there are bounds on what New York State ratepayers can afford and there are reliability risk limits for a system reliant on weather-dependent resources. The problem is that there are imprecise criteria for acceptable affordability bounds or reliability limits.
Proponents of the Climate Act argue that the transition strategies in the law must be implemented to meet the net-zero mandates regardless of affordability or reliability constraints because it is the law. However, they do not acknowledge that Public Service Law (PSL) Section 66-P, Establishment of a Renewable Energy Program, is also a law. PSL 66-P requires the Commission to establish a program to ensure the State meets the 2030 and 2040 Climate Act obligations but includes bounds. PSL 66-P (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.
Two petitions have been filed calling for such a hearing. On 8/12/25 the Independent Intervenors filing argued that there were affordability and reliability issues and that there was an explicit requirement for the hearing because the customers in arrears threshold has been exceeded. The Coalition for Safe and Reliable Energy filing on 1/6/26 made a persuasive argument that there are sufficient observed threats to reliability that a hearing is necessary to ensure safe and adequate service. On 1/28/26 the Public Service Commission issued a notice soliciting comments regarding the Coalition for Safe and Reliable Energy petition which are due on 3/30/26.
Onshore Transmission Requirements
A grid relying on wind and solar cannot be implemented without significant transmission upgrades. The New York Independent System Operator (NYISO) has noted that New York’s Climate Act renewable energy projects depend heavily on transmission because “most new renewable capacity is being built where the wind, sun, and land are available, not where the loads are, and the existing grid cannot move that energy to the major demand centers without large curtailments and reliability problems.”
NYISO noted that dependence on a few critical transmission projects has risks. The 2024 RNA Report notes that the base case assumes timely completion of Champlain Hudson Power Express (CHPE) and Clean Path NY (CPNY) by 2027-2028. The status of these projects could impede safe and adequate service.
CHPE is in late-stage construction and the developer is still targeting an in-service date of May 2026. CHPE is a 1,250 MW HVDC line delivering clean hydropower into Astoria, New York City. The contracted delivery is on the order of 10.4 TWh per year, corresponding to a high assumed capacity factor (around 95%) and 1,250 MW of firm capacity sales. Hydro‑Québec has stated that deliveries will be split roughly half in winter and half in summer (10.4 TWh total, 5.2 TWh per season), with an incentive to use the full line capability. However, the Hydro‑Québec bid “includes summer‑only unforced delivery rights,” with “no specific delivery obligations during the winter peak.” NYISO’s Short‑Term Reliability Process Report states that while CHPE is expected to contribute to reliability in the summer, “the facility is not expected to provide any capacity in the winter.” The future of energy availability on this transmission line is foreshadowed by the New England Clean Energy Connect (NECEC) HVDC line that had been energized only about a week when the January 23-27 winter storm hit. Power flows from Québec to New England from this line and others largely collapsed during the cold snap.
At least it will be operating in the summer. The Clean Path New York project has been terminated. It was initially selected and approved as part of the Tier 4 program in Case 15‑E‑0302 (Order Approving Contracts for the Purchase and Sale of Tier 4 Renewable Energy Credits, issued April 14, 2022. The associated 178‑mile HVDC transmission facility from Delhi to Queens was advanced in Case 22‑T‑0558, Application of NYPA and Clean Path New York LLC for a Certificate of Environmental Compatibility and Public Need. NYSERDA and the Clean Path NY developers (NYPA plus the Forward Power JV of energyRe and Invenergy) “mutually agreed to terminate” the Tier 4 REC Purchase and Sale Agreement in late November 2024. The termination reflected cost escalation after the original 2021 award; developers sought higher subsidies, but the state declined, leading to cancellation of the underpinning contract for the 175‑mile, ~1,300 MW HVDC line and associated renewables. NYPA later sought Priority Transmission Project (PTP) designation for the ‘Clean Path Transmission Project’ in Case 20‑E‑0197; but the Commission denied that petition in its Order Denying Petition (issued August 14, 2025). The PSC denied NYPA’s petition because the project did not meet criteria for PTP designation, in part because NYISO studies showed relatively low projected utilization compared with CHPE and concern about ratepayer cost recovery for a line whose major flows might not materialize for decades.
The NYISO 2025 Power Trends report transmission section states that without major transmission (CHPE, CPNY) project completion that NYC reliability margins will become deficient which could impede safe and adequate electric service. The PSC must address in a heating whether the transmission line status will impede the ability to provide safe and adequate service.
Offshore Transmission Requirements
The Climate Act includes a requirement for 9,000 MW of offshore wind by 2035. According to a Perplexity AI query response: “New York’s offshore wind transmission situation is defined by two contrasting realities: the projects already under construction are advancing their dedicated transmission lines despite federal disruptions, while the broader coordinated transmission planning effort for future projects has been shelved due to the Trump administration’s hostility toward offshore wind.”
There are two transmission lines under construction.
Empire Wind 1 (810 MW), developed by Equinor, is the first offshore wind project that will deliver power directly into New York City. As of late 2025, export cable installation was actively underway. Equinor reported that trenching, cable-laying, and cable pulling were ongoing on the outer continental shelf, and the export cable was brought onshore in 2025. The onshore substation at SBMT was under construction with transformer delivery completed in early 2025. An offshore substation was scheduled for installation in early 2026. The project was approximately 60% complete as of late December 2025 when the Trump administration issued a stop-work order suspending the lease. A federal judge issued a temporary injunction in January 2026 allowing construction to resume while the legal case proceeds. Empire Wind aims to deliver first electricity by late 2026 and reach commercial operation by 2027.
Sunrise Wind (924 MW), developed by Ørsted, is the first U.S. offshore wind project to use High Voltage Direct Current (HVDC) transmission, which reduces the number of cables needed and improves efficiency. As of December 2025, onshore transmission work — including the converter station and duct bank — was over 90% complete. Offshore, the export cable was being tunneled through the surf zone (at 11–60 ft deep), with nearshore installation to follow. Approximately 44 of 84 monopile foundations were installed, and the HVDC offshore substation arrived from Norway and was installed in September 2025. Like Empire Wind, Sunrise Wind’s lease was suspended by the Interior Department on December 22, 2025. A federal judge cleared the project to resume construction in early February 2026. The project is expected to be completed and operational in 2027.
Additional transmission would be needed to service the remaining 9,000 MW of mandated offshore wind. This was supposed to be provided by the NYC Public Policy Transmission Need (PPTN) program.
In June 2023, the PSC identified a Public Policy Requirement for new transmission facilities to deliver at least 4,770 MW — and up to 8 GW — of offshore wind energy into New York City by 2033. The NYISO launched a solicitation in April 2024 and received 28 proposals from four developers, with estimated costs ranging from $7.9 billion to $23.9 billion.
On July 17, 2025, the PSC voted to withdraw the PPTN determination, effectively cancelling the process. The Commission stated it could not responsibly commit ratepayers to billions in transmission costs when the federal government had halted offshore wind permitting and leasing, making it impossible to predict when new generation projects would move forward. PSC Chair Rory Christian emphasized that this was about timing and ratepayer protection, not abandoning offshore wind, stating “it is a matter of when, and not whether, offshore wind generation projects will move forward”.
The PSC must address in a heating whether these decisions about offshore wind will impede the ability to provide safe and adequate service.
Conclusion
The NYISO 2025 Power Trends conclusion states that there is a risk that cumulative factors (retirements, electrification, delays) will create reliability metric violations. It is clear from the transmission status described here that there will be a lack of sufficient transmission to get the wind and solar energy from where it is collected to where it is needed to achieve the Climate Act schedule. This will create reliability metric violations that are incompatible with safe and adequate electric service. In my comments on the petition request, I will argue that the PSC should hold a PSL 66-P hearing to determine whether to temporarily suspend or modify the obligations of the Renewable Energy Program is therefore appropriate.
Pragmatic Environmentalist of New York 