On February 26, 2026 the Hochul Administration “leaked” a New York Energy Research & Development Authority (NYSERDA) memo that said that “full compliance with New York’s 2019 Climate Leadership and Community Protection Act (Climate Act) could cost upstate households more than $4,000 a year – on top of what they are already paying today”. On March 5, 2026, a group of 29 New York Democratic state senators responded with a letter (“Democratic Letter”) to Governor Hochul saying they “categorically oppose any effort to roll back New York’s nation leading climate law” and urging Hochul to “stand strong in the face of misinformation” about affordability. I wrote an article arguing that the senators missed the point but think that Richard Ellenobogen’s response also deserved to be published here.
I am convinced that implementation of the 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.
Richard Ellenbogen has been speaking to NY State policy makers and regulators since 2019 regarding the deficiencies inherent in NY State Energy policy. He has a proven record implementing carbon reduction programs at his own manufacturing business in Westchester County where it has reduced its electric utility load by 80% while reducing its carbon footprint by 30% – 40% below that of the downstate system. I have previously published other articles by Ellenbogen including a summary description of his issues with the Climate Act.
The following is a lightly edited copy of his document responding to the Democratic Letter.
Introduction
The 29 State Senators who wrote the Democratic Letter to Governor Hochul regarding NYSERDA’s recent memo apparently have no understanding of physics, math, economics or current events and have their heads in the sand. Unfortunately, this is a bad way to govern. Denial of current events doesn’t make them go away, it just makes the denier appear ignorant and results in letters like the one sent to Governor Hochul.
They make several claims in the letter, but nowhere do they explain the basis for those claims. They say that their letter is science based but if they are correct, I may request that Cornell refund my tuition because the science , math, economics, and engineering that I was taught at Cornell can’t even remotely reconcile the claims that they are making.
Letter Claims
Let’s examine the claims they make in the letter because those claims are not rooted in reality. Unlike their letter, I will provide math and statistics to explain why their letter is devoid of reality.
First, there is the following statement in their letter:
In reality, rolling back the CLCPA will not save our constituents money because it is not the cause of increasing costs. It is the fossil fuel status quo that has created the affordability crisis New Yorkers are now suffering from, and it is bold action to deliver renewable energy and energy efficiency that will give them relief, saving money for individuals in the immediate-term and for all utility customers in the medium- and long-term. When it comes to energy generation capacity, renewables can be deployed cheaply and quickly to meet our needs. And over the last year, through heat waves and polar vortexes, renewables have proven that they add much-needed reliability to the grid, reducing price spikes in the process, like those driven by wars in Europe and the Middle East.
They claim that renewables can be installed cheaply and quickly.
Regarding “cheaply”
The offshore wind bids that New York State (NYS) received came in at $150 per Megawatt-hour (MWh), about double the existing wholesale cost of electricity in NY State. Clean Path, the renewable transmission line from Central NY State to New York City (NYC) was cancelled due to excessive costs. These projects were heavily subsidized. Numerous solar projects were canceled when tax credits were eliminated, and the renewables will not support energy systems without enormous amounts of storage. That cost has not been factored into the existing structural issues in NY State. While everyone loves to state that solar is “cheap”, $40 – $60 per MWh, it will not provide the same functionality as our existing generation without storage and grid inertia systems. If the storage costs are added, the cost rises to $110 – $150 per MWh, 50% to 70% more than the existing cost of electricity in NY State. Synchronous condensers that would be needed to stabilize the system would cost billions of dollars beyond that.
Fossil Prices Cause Unaffordability
The claim that “Fossil Fuel prices” are the root cause is belied by the fact that other states are reliant on fossil fuels, and their costs haven’t risen nearly as much as those in NYS. The same legislators have supported blocking pipelines but when you restrict gas capacity, you force the dual fuel generators to burn oil on cold days so that people that use gas can still heat their homes. Oil combustion is both more expensive and raises the carbon footprints of the generating plants by about 50%. Telling people to switch to heat pumps on NY State’s generating system will only add more load to those generating plants and raise emissions even higher. Restricted pipeline capacity also forces trucks laden with compressed natural gas (CNG) or liquified natural gas (LNG) onto the highways where they burn large amounts of diesel fuel and release about 7 pounds of CO2 for every mile driven. As the trucks can’t backhaul any other freight, a trip as short as 160 miles will add an extra metric ton of CO2 into the atmosphere that would not happen with a pipeline. Further, the process of liquifying natural gas or compressing it to the high pressures needed for transportation are far more energy intensive than the compression needed for pipelines. An AI analysis of pipeline versus truck transport of natural gas shows a 10% – 60% higher carbon footprint depending on truck types and distances. All of these factors raise costs.
The renewables may avoid fuel price spikes but that is only because the electricity generated from them is so expensive to begin with. Germany, a country that started this process over thirty years ago and is 34% wind and solar, has electric rates twice those of France next door which is 70% nuclear. When you start from a high-cost basis, price increase percentages are lower. Furthermore, while near-zero marginal-cost wind and solar suppress prices in “easy” hours, prices spike when demand is high and wind/solar underperform, because the system must lean on higher-cost dispatchable units during those tight hours. The inevitable result is more price spikes.
While certain efforts at energy efficiency would help, the heat pumps prescribed by the climate act as energy efficiency will double heating bills when used on the NYS system. As a result more homes upstate are now burning wood on cold days because of the high energy costs. That releases enormous amounts of PM2.5, PM5 and PM10 into the atmosphere along with 2.5 times the amount of CO2 per therm of natural gas. They will use more energy at the generating plants than they save at the homes or businesses. The burning of wood and increasing fossil fuel usage IS NOT energy efficient.
Quick Renewable Deployment
The claim that renewables can be deployed quickly is contradicted if someone actually reads the Scoping Plan for the Climate Act, something that these senators have apparently not done. The Plan documents that NYS would need about 60 Gigawatts (GW) of solar arrays, 23 Gigawatts of wind turbines, 21 Gigawatts of Batteries, and 20 Gigawatts of Zero Carbon Resources to meet its goals by 2050. Those are Scoping Plan numbers, not mine. I think they are an extreme underestimation of the resources needed (About 100,000 Gigawatt hours of energy short based upon actual loads and 15 – 17 GW of Zero Carbon Resources short according to the NYISO and the Anderson Lab at Cornell)
Consider the reality of installation rates. Between 2019 and 2024, NYS installed about 6 GW of solar. At that pace, it would require 50 years ( 2076 – 26 years after the 2050 deadline) to reach 60 GW except the arrays only have a lifespan of 25 years so more than twice that amount would have to be installed to meet the goals plus replace aging arrays. As a result of that, the state will never be able to install enough to meet its needs by 2050 unless it quadruples installation rates but there is not enough labor, material, or money to do that.
Additionally, no one has figured out what the 20 Gigawatts of Dispatchable Emission Free Resources (DEFR) will be. Nuclear is a potential resource but nuclear isn’t ideal for being a dispatchable resource that can ramp up and down with varying loads so it isn’t truly dispatchable. Further, if the state were going to build 20 Gigawatts of nuclear to support renewables, they could just build fewer nuclear plants and not install the renewables at all and wait until the nukes were nearly complete to build a viable storage system using a storage technology that won’t contaminate the environment as the current technology will. Beyond that, 20 GW of nuclear power would take decades to install and that is not “quick”. Construction of 2 Gigawatts, 10% of NY State’s “needs”, recently required fourteen years to complete in Georgia. People that have obviously never built anything in their lives, like the Senators that wrote that letter, seem to believe that they can blink and create a carbon free generating plant, interconnected solar array or wind farm. They apparently watched too much “I Dream of Jeannie” as children.
Reliability Claims
As far as the “reliability” claims in their letter, several studies have shown that exceeding 25% – 40% renewables on a system puts the system at extreme risk of encountering stability issues. A paper that I wrote for Con Ed and the Public Service Commission in 2008 predicted this based upon measurements that I made at my factory. Spain and Portugal experienced this firsthand when their system, powered by about 80% renewables (solar and wind), collapsed because the inverters couldn’t handle perturbations on the system and shut down over the course of a few minutes. The renewables don’t provide the necessary grid inertia. Even worse, Spain and Portugal could not even restart their renewable based system with their own generators. They needed the high inertia nuclear generation from France to restart the system after the blackout. How is that the definition of “Reliable”? Texas which has installed 25 Gigawatts of wind in the West Texas region is having extreme reliability issues because of similar problems to those experienced in Spain and Portugal and is now installing $800 million worth of equipment to try and solve the problem. Denmark, which had wanted a fully renewable system, is now backing away from that because of these issues. It is only NY State politicians that seem to be determined to drive the state into an energy ditch.
They argue that the Climate Act is reducing pollution and is “science based”. They also claim that it will protect a “livable climate”.
At a time when the Trump Administration is doing everything possible to tear down decades of progress in the fight against climate change, it is incumbent on states like New York to reject this new wave of climate denial and put forward bold policies that will save New Yorkers money, reduce pollution, and protect a livable climate for our constituents and our children and grandchildren.
The reality is that NY State’s attempt to legislate physics and defy physical reality is squandering resources and preventing them from being used on actual “science based” solutions. Nothing that could be done in NYS to reduce carbon emissions will impact global climate and their claims that it can is the definition of hubris. According to Statista, a statistics database, global emissions of CO2 in 2019 when the CLCPA was passed were 35.3 Gigatons (Gt or billion metric tons). That is 185 times NY States 190 million metric tons. Global emissions are projected to rise to 43.08 Gt by 2050. That will be an increase of 7.74 GT. The CO2 increase by 2050, the year that the CLCPA was supposed to be fully implemented, will be 40 times NYS’s total controllable CO2 emissions.
Their demand for heat pumps will result in higher emissions at the generating plants than could be achieved with far less expensive solutions at the building level. The cost of operating the heat pumps results in them not being used and increased wood burning as does restricting pipeline capacity. The costs of trying to implement their policies prevents funding of workable solutions that could actually reduce carbon emissions. I write this as someone that has a factory with carbon emissions 30% – 40% lower than the Con Ed utility system the building is attached to and the utility bills there went down by 3.4% last year while gas and electric costs went up between 5% and 18% because we have actually applied “Science based solutions” to the problem. The building operates with energy costs one-third that of comparable facilities in NYS. As someone that understands “Science Based Solutions”, I can definitively say that their solutions are not science based and the fact that their policies are driving utility rates sky-high are clear evidence of that.
“Climate Progress” Conclusion
There is no climate progress because emissions elsewhere are rising faster that NY State’s entire CO2 output and even NY State’s electric system emissions are projected to increase by 2% by 2030 according to the State reports.
Between us we carry significant legislation on a broad number of policies large and small that will reduce New Yorkers’ costs and move us toward our science-based climate targets. We stand ready to work with you and your administration to implement comprehensive climate policies that truly meet the needs of this moment – but we cannot support abandoning our commitment to climate progress.
What the politicians and the environmental movement fail to recognize is that the demand for fossil fuels is inelastic. This link explains “inelastic demand” and the policy makers in NY State should read it.
The current war in Iran and the closure of the Straits of Hormuz is showing what happens when access to fossil fuels is restricted because portions of the world economy are currently grinding to a halt. After only two weeks, fuel prices are climbing rapidly. I have received price increase letters for numerous products at my business over the past two weeks as have many other manufacturers and those increases will be showing up in the near future throughout the entire economy. Beyond the fact that NY State’s policies being promoted by the senators are doing nothing because of the reasons listed above, NY State’s efforts to restrict fossil fuels over the past several years, and even more so through “Cap and Invest”, is a microcosm of the energy shortages caused by the current war. The New York politician’s claims that their policies are not causing higher costs for energy related commodities would be laughable if it wasn’t so tragic.
Pragmatic Environmentalist of New York 