My most recent post argued that it is time for New York to decide what the future energy system should look like. On September 22, 2026, Governor Hochul announced an Energy Infrastructure Development Plan (EIDP) as part of her Clean, Highly Affordable, Reliable, Grid Expansion (CHARGE) agenda. The announcement says the EIDP will provide “an actionable blueprint” for the infrastructure New York needs to meet surging electricity demand. In this post I describe what was announced and compare it to the recommendations I have made here for a reliability-first, affordability-driven approach to New York energy planning. My bottom line is that the EIDP gets the diagnosis right but, so far, it is more political rhetoric than a possible solution to the unfolding energy crisis.
I am convinced that implementation of the Climate Leadership & Community Protection Act (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 and have written extensively about its implementation. I have spent over 50 years in the electric generation industry analyzing the effects of air pollution control policies on operations. The opinions expressed in this post 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. I acknowledge the use of Perplexity AI to research the material summarized in this article and prepare an initial draft.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes a requirement that all electricity generated be “zero-emissions” by 2040. The 2022 Scoping Plan outlined how to “achieve the State’s bold clean energy and climate agenda.” Since then, the gap between the Climate Act transition and reality has become hard to ignore, and the Hochul Administration has increasingly framed its energy messaging around affordability and reliability. The EIDP is the latest example.
What was Announced
According to the Governor’s press release, the Governor is “directing the New York State Energy Planning Board to engage in comprehensive integrated planning to ensure the State has a clear and actionable perspective on the infrastructure it needs to reliably meet demand.” The release says the plan “will guide the infrastructure investment decisions by the State over the coming decades.”
The announced approach “leverages the tools available to the State including neighborhood-scale alternatives, distributed solar, and energy storage, and coordinates the development of new utility-scale clean generation and transmission.” The stated outcome is that “the EIDP will ensure the lights stay on and that progress towards a zero-emission grid continues all while controlling costs.”
The schedule is the part that caught my attention. The release states that “the EIDP process kicks off this year as part of the State Energy Plan, with an Interim Plan due in 2027 and the first comprehensive plan finalized by December 2029.” The American Public Power Association and Harris Beach Murtha summarized the announcement the same way.
The EIDP builds on the 2025 State Energy Plan that the Energy Planning Board approved on December 16, 2025. That plan provides “broad program and policy development direction” with an outlook through 2040. I see the EIDP as an attempt to add an infrastructure-specific layer to that high-level policy document. Unfortunately it still proposes no feasibility analysis.
What the EIDP Gets Right
I want to give credit where it is due. For years I have argued that New York energy planning is poorly coordinated. Climate Act targets, Scoping Plan implementation strategies, NYISO reliability analyses, utility rate cases, NYSERDA procurements, transmission proceedings, and local siting decisions all proceed on separate tracks with no one responsible for making sure the pieces fit together. The EIDP announcement acknowledges that problem.
There are four points I can support:
- The State now accepts that load growth from manufacturing, electrification, and data centers requires a different planning response than the flat-load assumptions of the past.
- Generation, storage, transmission, distributed resources, and demand-side alternatives are being considered together in one infrastructure discussion.
- The announcement says grid development must address reliable service and customer costs, not just emissions targets.
- The state needs to reconcile the work of NYISO, the Public Service Commission, NYSERDA, NYPA, and the utilities.
Those are not trivial changes. The language is closer to the premise of a pragmatic system plan than anything that came out of the Scoping Plan process or the latest Energy Plan.
Where it Falls Short
The problem is that the announcement offers words like “reliably” and “controlling costs” without any commitment to the decision rules that would make those words mean something. The following table compares the EIDP announcement to the recommendations I have made.
| Issue | EIDP Announcement | My Recommendation | My Assessment |
| Planning philosophy | Comprehensive integrated planning by the Energy Planning Board | Replace siloed, target-driven planning with one integrated plan that reconciles load, retirements, generation, transmission, siting, and costs | Strong agreement in principle |
| Reliability | Promises to “keep the lights on” | Use NYISO and New York State Reliability Council resource adequacy standards, including multi-day wind and solar lulls in winter | No reliability standard is defined |
| Load growth | Central motivation for the plan | Separate committed load from speculative data center announcements and make new large loads pay for their own infrastructure | Right diagnosis, no cost-allocation commitment |
| Resource mix | Distributed solar, storage, “utility-scale clean generation,” transmission | Procure enough firm, dispatchable capacity; keep existing reliable units until replacements are proven. This includes repowering existing and building new natural gas generation. | Firm capacity is not mentioned |
| Dispatchable emissions-free resources (DEFR) | Not mentioned | Quantify the need, set milestones, and identify off-ramps if the technology does not show up | The biggest gap |
| Nuclear | Not mentioned in the EIDP announcement | Retain and expand nuclear as the proven zero-emissions firm resource | Unresolved |
| Affordability | “Controlling costs” | Publish full-system costs and customer bill impacts for each pathway | An aspiration, not a test |
| Siting | “Cut through red tape” | Make land use and community impacts real planning constraints | Potential conflict |
| Transparency | Not addressed | Publish assumptions, models, and data; provide independent review | Unproven |
| Schedule | Interim plan 2027, comprehensive plan December 2029 | Act now on known reliability risks and economic development risks. | Too slow |
The DEFR Problem is Still Being Ignored
Regular readers know that I consider the dispatchable emissions-free resource (DEFR) problem to be the central risk of Climate Act implementation. The NYISO 2023-2042 System & Resource Outlook projects that “at least 20 GW of DEFR capacity would be needed by 2040 to replace the current 25.3 GW of fossil generation,” and that “upwards of 40 GW” could be required. The NYISO lists candidate technologies such as long-duration batteries, small modular nuclear reactors, hydrogen-powered generators, and fuel cells. None of them is commercially available at the scale needed today.
The EIDP announcement does not use the term DEFR. It does not acknowledge that quantifying how much firm capacity New York will need and when it will be needed is an enormous challenge but most of all it does not recognize the Immediate need for an off ramp if it does not arrive on time or the interim need for firm, dispatchable resources that must include natural gas repowering and new builds and fuel delivery pipeline expansion to address observed problems. Any infrastructure plan that leaves those issues out is not addressing the hardest part of the problem. Wind, solar, storage, and transmission do not substitute one-for-one for dependable capacity during an extended winter cold snap with low wind and little sunlight.
Affordability Needs a Number
“Controlling costs” is not a standard anyone can check. If the Administration is serious, the EIDP should publish, for each major pathway, the capital costs, interconnection and transmission costs, backup and balancing costs, distribution upgrades, land requirements, RGGI carbon costs, and resulting customer bill impacts. It should also say how much of the cost of serving new data centers and other large loads will be paid by those customers rather than existing ratepayers. Until those numbers are on the table, affordability claims are just claims.
“Cutting Red Tape” Works Both Ways
I support faster approval of projects that are demonstrably needed. However, the “cut through red tape” language worries me. My work on utility-scale solar projects such as Horseshoe Solar shows that the permitting process is often the only place where local land-use, agricultural, and community impacts get any consideration. Streamlining without siting safeguards could simply accelerate energy sprawl. The EIDP should compare alternatives by energy density and land use, and consider rooftop and parking lot solar, brownfields, existing transmission corridors, repowering, and low-footprint firm generation.
The Schedule Does Not Match the Risk
An interim plan in 2027 and a first comprehensive plan in December 2029 provides little comfort because there are problems now. During January and February 2026, New York energy consumers were forced to bear $800/MW energy prices, Special Case Resource Winter Dispatches, and high system uplift because our aging generation portfolio was stressed. Decisions about retaining existing generation, starting natural gas and nuclear development, adding new natural gas fuel delivery capability and committing to transmission need to be made now, not 2029 if new resources are going to be in service in time to meet growing load requirements and attempt to meet the 2040 zero-emissions mandate.
What a Credible Interim EIDP Should Include
If the EIDP is going to be more than another politically-driven policy document, I believe the 2027 interim plan must include the following:
- A reliability-first planning standard based on NYISO and New York State Reliability Council resource adequacy criteria that explicitly addresses extreme winter weather and multi-day renewable lulls.
- Load forecasts by location and season that separate existing, committed, probable, and speculative large loads.
- An explicit firm-capacity balance by zone and season that does not count wind and solar at nameplate capacity or assume DEFR will arrive on schedule.
- A DEFR and nuclear strategy with a definition, capacity targets, in-service milestones, and contingency actions if the technologies do not materialize.
- A rule that no dispatchable unit retires until its replacement is operating and has demonstrated dependable performance, not merely been contracted or permitted.
- Recognition of the risk of the aging dispatchable units in the system and support to deploy fossil generation resources that can provide firm capacity where needed to bridge the transition until the Nuclear Backbone is deployed.
- A full-system affordability test with published customer bill impacts and cost allocation to large loads.
- A land-use and siting screen that compares alternatives on their environmental and community impacts.
- Strategies must manage economic development, energy needs, and environmental mandates in unison not separate silos.
- Transparent governance with published assumptions, models, and data, and formal opportunities for NYISO, consumer advocates, municipalities, and independent analysts to challenge the results.
The EIDP is Not Enough
I think that in addition to the EIDP the Hochul Administration must champion legislative and regulatory changes that recognize that reliability is paramount and that affordability controls the rate of spending are required. The EIDP will only be successful with changes to the current rules including revising the Climate Act 2040 zero emission requirement, changing any regulatory limits on deploying dispatchable generation such as natural gas fired units, and expanding the natural gas fuel delivery infrastructure to support them. Anything less is the default to our current death spiral that is impacting every NY consumer and making NY a hard choice for new economic opportunities.
Conclusion
Governor Hochul’s Energy Infrastructure Development Plan is a welcome acknowledgement that New York cannot meet unprecedented load growth, maintain reliable service, pursue its zero-emissions goals, and protect customers from rising costs through disconnected planning and procurement processes. The EIDP could provide the integrated framework New York needs.
But the announcement is a process commitment, not a reliability plan. Moreover, its timing and vagueness reeks of campaign politics. Its value will depend on whether the State identifies firm-capacity requirements, evaluates nuclear and other dispatchable resources honestly, plans generation and transmission against actual rather than aspirational load forecasts, protects communities from unnecessary energy sprawl, and publishes a transparent full-system cost test. If the EIDP relies on hoped-for DEFR technologies, vague affordability claims, and renewable nameplate capacity instead of demonstrated dependable resources, it will simply repackage the existing planning deficiencies under a new name. Done incorrectly risks continuing consumer affordability concerns, and missed “economic opportunities” especially for upstate New York.
I support the integrated-planning premise. I will be watching to see whether the interim plan becomes an engineering-based resource adequacy and affordability plan or just another document that assumes the Climate Act schedule can be met without saying how and delays reality through rhetoric vs actionable and timely steps forward.
