Author: rogercaiazza

I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and (https://pragmaticenvironmentalistofnewyork.blog/) reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative (https://reformingtheenergyvisioninconvenienttruths.wordpress.com). Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.

NYISO Resource Outlook Concerns

At the May 6, 2026, Transmission Planning Advisory Subcommittee meeting, the New York Independent System Operator (NYISO) described an update to the 2025–2044 System & Resource Outlook (Outlook) and invited stakeholders to provide feedback on the planned analyses.  This post describes the comments I submitted related to recent Regional Greenhouse Gas Initiative (RGGI) developments and last winter’s extreme weather.  I also filed these comments to Case 15-E-0302 – Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard and Case 22-M-0149 – Proceeding on Motion of the Commission Assessing implementation of and Compliance with the Requirements and Targets of the Climate Leadership and Community Protection Act.

I have extensive experience in two relevant areas: the Regional Greenhouse Gas Initiative (RGGI) and meteorological impacts on electric utility systems, and I based my comments on that experience. The opinions expressed in this post and in my filing do not reflect the position of any of my previous employers or any other organization with which I have been associated; these comments are mine alone.

Background

The NYISO is responsible for electric resource planning for New York State.  The Comprehensive System Planning Process (CSPP) consists of four components: the Local Transmission Planning Process (LTPP), the Reliability Planning Process (RPP), the Economic Planning Process, and the Public Policy Transmission Planning Process. My particular interest is the RPP.

Last December a NYISO update on the CSPP that described the Reliability Planning Process.  It is a two‑year process that starts in even years and has two components. The Reliability Needs Assessment (RNA) “evaluates the adequacy and security of the Bulk Power Transmission Facilities (BPTF)

over a seven-year Study Period (years four through ten of the next ten years) and identifies Reliability Needs defined as violations of Reliability Criteria” established by regulatory authorities.  The System & Resource Outlook is performed in the years between RNA.s  It includes the following:

  • 20-year study of system and congestion
  • Identifies, ranks, and groups congested elements
  • Assesses the potential benefits of addressing the identified congestion
  • Provides information to developers and marketplace regarding future challenges in the New York power system

The current analysis covers 2025 to 2044, so it must consider the transition requirements of the Climate Leadership & Community Protection Act (Climate Act).

RGGI

I recently published several articles describing RGGI issues that are relevant to the Outlook.  In the first article, I provided background information on the impact of the April 29, 2026 RGGI statement that Virginia was rejoining the program. In the days that followed, the futures market price of RGGI allowances nearly doubled, and the spot market cost also increased significantly.  In response on May 8, the RGGI states issued a notice that they were monitoring the allowance market in response to a sharp increase in the secondary futures market price.  This is relevant to the Outlook because it indicates that current and future allowance prices, allowance availability, and overall generating unit economics are far more volatile than in the past

RGGI Allowance Availability Risk

My second article compared historical emissions to the current RGGI allowance cap trajectory.  My analysis of RGGI emissions shows that the primary cause of historical emission reductions was fuel switching, and that RGGI emissions have leveled off since 2019, when opportunities for further fuel switching ended. When I analyzed the 2023 RGGI investment proceeds report, I estimated that only about 8% of observed emission reductions could be attributed to RGGI‑funded projects.  Changes to federal policy, supply chain issues, retirement of key nuclear assets, rejection of new permits to build natural gas combined‑cycle units, and inflation coupled with load growth all indicate that significant near‑term reductions in RGGI emissions are unlikely.

Figure 1: Eleven State RGGI CO₂ Emissions (short tons) for all Programs 2006–2025

The RGGI webpage describes the current allowance cap trajectory.  The RGGI states developed the allowance cap trajectory so it would be consistent with state laws that require emissions to go to zero.   As a result, the allowances allotted to the program decline by approximately 10.5 percent of the 2025 budget per year from 2027 through 2033.

To determine when the allowances will run out it is necessary to consider emissions, allowances held in the market and when allowances are added to the market.  RGGI does not provide a report that describes the status of the allowance bank, so I had to develop my own estimate.

The projected trajectory of emissions and allowances is shown in Figure 2. It plots the quarterly emissions (green), allowance cap (dark blue), added allowances (light blue), and allowance balance (orange).  For this analysis, I assumed emissions stay constant.  This analysis estimates that during the third quarter of 2032 there will be insufficient allowances for expected emissions.  Needless to say, the Outlook must account for the potential that generating units will have to shut down to comply with the RGGI regulations well before the Outlook end date of 2044.

Figure 2:  Quarterly RGGI Allowance Balance, Emissions and Allowance Cap

RGGI Market Cost Adder

I was encouraged by electric system experts to write a post and submit comments about the two effects of RGGI allowance prices on customer supply costs: the direct cost of the allowances needed for each generating unit and the impact of the cost adder used by generating units in their bid prices.  My third recent RGGI article estimated the impact of the cost adder relative to recent RGGI allowance price volatility.

The third article provides details so I will not describe the analysis details here.  The impact on consumers is complicated and I did not understand the ramifications until now.  When generating units bid to sell their power in daily auctions, they include the cost to purchase replacement RGGI allowances.  If the clearing price is set by a unit that must comply with RGGI, then the added cost of RGGI allowances is included.  The problem for consumers is that every generating unit gets paid the clearing price.  That means facilities with no RGGI compliance obligations still get paid as if they did.  As a result, they garner windfall profits at the public’s expense.

When allowance costs were low this effect was relatively small, but allowance costs increase when there is uncertainty (like adding Virginia to the program) or there is a scarcity of allowances (like will happen with the unrealistic allowance cap trajectory).  Costs are no longer low and will only go higher.  I estimated the effect of the NYISO market clearing-price adder that is passed through to ratepayers in a range of scenarios that represent possible adder costs. 

Prior to this personal revelation, I was under the impression that the cost to consumers was only the cost of allowances consumed, which in 2025 was about 708 million dollars.  My analysis found that if every fossil unit in New York were a modern state-of-the-art combined-cycle unit then the market costs would add $1.16 billion to consumer bills.  Using average 2025 heat‑input‑weighted data for New York RGGI units, the estimated statewide cost impact is 2.26 billion dollars.  I believe that the true cost is closer to this estimate, which is nearly three times the direct cost of purchasing allowances alone

It gets worse because the windfall profits do not accrue just to New York generators.  All imported electricity delivered to New York is affected by RGGI costs. Imported electricity from outside New York has the same perverse outcome: embedded RGGI costs paid in the exporting state are included in the prices paid by New York consumers.  My analysis does not include these costs, so  I am underestimating the impact of RGGI costs.

When the RGGI announcement that Virginia was going to rejoin the program was made, there was a price spike that approximately doubled the cost of RGGI futures. If futures prices are a good indicator of future allowance prices and that projection is realized, then all of these cost estimates would roughly double.

There is another impact.  The allowances proceeds available for investments are much less than the cost to consumers due to the electric market impact.  In 2025 there were 20,902,887  New York adjusted allowances available and at an average cost of $22.09  that means that $461,797,031 was raised that can be invested for RGGI program objectives.  These results show that the RGGI revenue collections available to reduce emissions and mitigate cost impacts are much less than what ratepayers are paying for the RGGI program.  For all the talk of mitigating impacts to low- and middle-income consumers with RGGI proceeds these results show that regressive RGGI electric market prices likely exceed the benefits of those investments.

This is relevant to the NYISO and Outlook analyses because affordability must be a consideration.  I recommend that NYISO develop refined estimates of the electric market impacts to ratepayers caused by RGGI allowance prices, especially the potential for much higher prices due to market scarcity as the existing allowance bank declines.  I suspect that the models the NYISO use could track all the market costs.  Given the impact of these effects on consumer costs, I requested that NYISO report on the annual and peak market clearing price impacts of RGGI.

2026 Extreme Winter Weather

My comments on the Outlook addressed weather impacts.  My primary meteorological concern is reliability planning related to weather-dependent generating resources. I recently published a blog post that showed that last winter’s extreme weather proved that dispatchable emissions-free resources (DEFR) are necessary to achieve net-zero in New York.  The Winter 2025-2026 Cold Weather Operations presentation by the NYISO is an excellent summary of the conditions observed.

In 2023, Judith Curry and I prepared a white paper titled “Historical Weather and Climate Extremes for New York“.  We noted that there is substantial variability in seasonal temperatures and occurrence of temperature extremes on interannual, decadal, and multidecadal time scales. We also pointed out that the most recent 5-year period used in many NYISO planning analyses does not capture the most extreme temperature events that have been observed in the historical records. We also noted that the possible worst-case scenario could be a 15-day period from January 20 to February 3, 1961,

I recommend that this winter’s January 23–February 9, 2026 weather observations be included in Outlook analyses because the upper‑air pattern was similar to that of the 1961 event.  Including this winter’s event data will capture an extreme temperature event that is necessary to incorporate the impact of weather extremes as wind and solar resources increase.  For example, I considered  proposals to replace peaking units with renewables and storage for last winter’s cold snap. Using the liquid‑fuel generation during the event as a proxy for peaking units, I showed that oil‑fired units supplied roughly 2 million MWh over the episode while total renewable energy production was only 469,308 MWh. The scale of firm backup currently needed is much larger than what can be stored in batteries, meaning that oil-fired peaking units cannot be retired until DEFR backup is available. 

My recommendations stated that the Outlook should address timing for DEFR support.  Given that we do not yet know what DEFR resources will be commercially available before 2044, I believe that the Outlook should emphasize the importance of DEFR to the Climate Act’s Public Service Law 66‑P Renewable Energy Program.  That program mandates renewable resources which, in my view, cannot fully achieve reliability objectives without including DEFR.

Discussion

There is an affordability crisis in New York.  As of December 2024, over 1.3 million New York households were behind on their energy bills by sixty days or more, collectively owing more than $1.8 billion.  In response to the New York State Public Service Commission notice  soliciting comments regarding a petition for a hearing to suspend or temporarily modify the Renewable Energy Program, I demonstrated that the increase in the number of accounts in arrears from 2019 (before enactment of the CLCPA) to 2025 is statistically significantfor statewide totals and for four of the ten utilities.  In that light the unacknowledged RGGI electric market costs must be reconsidered. 

My analysis exposes fatal flaws in RGGI.  A billion dollars in added consumer costs due to an arbitrary accounting decision that gives most generators windfall profits can no longer be ignored.  Those costs are not part of the “dividend” benefits that only accrue when allowances are sold at auction.  The fact that the market costs far exceed the auction revenues means that RGGI is simply a regressive tax. 

Another unavoidable implication is now clear.  The presumption that a binding cap can ensure emission reductions is false.  RGGI emissions have been essentially constant since 2019 despite massive investments.  There should be no expectation that the factors causing emission reductions to stall will suddenly reverse so that emissions begin to match the allowance cap reduction trajectory.   The RGGI states must either modify the cap trajectory or accept that affected generating plants will stop producing power to comply with their rules.

Conclusion

I submitted comments on the NYISO Resource Outlook program because these recent events should be considered in long-range resource assessments.  In my opinion, the NYISO has avoided explicit policy recommendations for too long.  The potential that RGGI requirements will shut down power plants in less than seven years should spur a clear statement that the rule must be changed.  The longer there are no changes, the longer higher costs should be expected due to shrinking allowance availability.  The Outlook is an opportunity to hold policymakers accountable.

Compliance Impacts of Virginia Joining RGGI – When will the Allowances Run Out

On April 29, 2026, the Regional Greenhouse Gas Initiative (RGGI) states released a statement that Virginia was rejoining the program. On May 8, the RGGI states issued a notice that they were monitoring the allowance market in response to a sharp increase in the secondary futures market price. In a recent article I described the financial impact.  This article addresses compliance.

Dealing with the RGGI regulatory and political landscapes is challenging enough that affected entities seldom see value in speaking out about fundamental issues associated with the program.  I have been involved in the RGGI program process since its inception and have no such restrictions when writing about the details of the RGGI program.  I have worked on every cap-and-trade program affecting electric generating facilities in New York including RGGI, the Acid Rain Program, and several Nitrogen Oxide programs, since the inception of those programs. I also participated in RGGI Auction 41 successfully winning allowances and holding them for several years.   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.

Background

RGGI is a market-based program to reduce greenhouse gas emissions from the power sector. It has been a cooperative effort among Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont since 2008, with New Jersey rejoining in 2020 and Virginia scheduled to rejoin beginning July 1, 2026; Pennsylvania recently decided not to join.

According to the RGGI program description, the states issue permits to emit a ton of CO₂ or allowances that are distributed almost entirely through regional auctions, and the proceeds are then reinvested in strategic energy and consumer programs. Those investments include energy efficiency, clean and renewable energy, beneficial electrification, greenhouse gas abatement and climate adaptation, and direct bill assistance, with energy efficiency receiving the largest share.

In a recent article I explained that the cost of RGGI allowances obtained at auction is not the only cost to consumers.  In New York’s de-regulated market, the cost to purchase the allowances is embedded in the  price bid by RGGI program fossil-fired power plants in the New York Independent System Operator (NYISO) energy auction.  The NYISO chooses the power plants that will run based on the economic dispatch clearing price.  When a RGGI-affected generating unit sets the price, all the generating units providing power get paid for the added cost of RGGI even though many do not have compliance obligations.  I showed that this more than doubles the cost of compliance or more depending on the cost of allowances, making the cost an important affordability consideration.

RGGI allowance costs are driven by basic economic considerations. When there is scarcity, prices increase; when there is uncertainty about scarcity, costs also go up. The difference is that price increases associated with uncertainty can drop when more information is available, whereas if the RGGI plans for reducing the emission cap are unrealistic that bakes in scarcity so prices will increase structurally. When RGGI announced that Virginia was going to rejoin the program there was a market price spike based on a lack of information. 

RGGI Cap Trajectory

The RGGI webpage describing last summer’s changes to the program included a graph that compares the current regional base cap (light blue) with the updated cap trajectory (dark blue). The orange and yellow lines display the total updated regional cap if all allowances are released from the updated first and second Cost Containment Reserve (CCR)  tiers, respectively.  The CCR tiers were added to reduce allowance costs.  The bottom line is that the changes reduce the regional emissions cap in 2027 to 69,806,919 tons of CO2 from 75,717,784 tons under the previous Model Rule and then reduces allowances  Allowances decline by approximately 10.5% of the 2025 budget, thereafter through 2033.

The RGGI emission cap trajectory was designed to be consistent with state net-zero targets.  However, that trajectory is unrealistic.  Figure 2 plots CO₂ emissions by fuel type across all eleven states from 2006 to 2025.  What you see is fuel switching caused the reductions and that there are only minor opportunities for future fuel switching.  When I analyzed the 2023 RGGI investment proceeds report, I estimated that only about 7.6% of observed emission reductions could be attributed to RGGI‑funded projects despite RGGI auction proceeds of over $7 billion since 2021.  Changes to Federal policy, supply chain issues, and inflation coupled with load growth all indicate that reductions from other programs are unlikely as well.  The cap trajectory is simply incompatible with reality.

Figure 2: Eleven State RGGI CO₂ Emissions (short tons) for all Programs 2006–2025

To determine when the allowances will run out it is necessary to consider emissions and the allowance trajectory.  For this analysis I assume that future emissions equal the average of the last three years.  In Figure 3, I plotted the updated cap trajectory (orange), total updated regional cap if all allowances are released from CCR Tier 1 (purple), CCR Tier 2 (green) and emissions in grey.  I assume that allowance prices will exceed the trigger for the CCR allowance release every year.  Note that in 2028 the emissions become greater than the allowances added to the market without Virginia in RGGI.

Figure 3: RGGI Emissions and Cap Trajectories for RGGI States Without Virginia

Figure 4 provides similar information with Virginia added to RGGI.  There is no appreciable change to the time when the allowance allocations are less than the emissions so I believe that the addition of Virginia will not affect impacts.

Figure 4: RGGI Emissions and Cap Trajectories for RGGI States With Virginia

Allowance Bank

Comparing the allowance allocations to the emissions does not consider the allowances already in the system.  The “allowance bank” is the aggregate number of allowances in circulation that have been issued but not yet surrendered for compliance (i.e., held in accounts or set‑asides). The original distribution of  RGGI allowances was before the fracking revolution made natural gas a cost-effective substitute for replacing oil and coal generating units.  When power plants switched to lower-emitting  natural gas, much larger reductions in emissions than expected occurred and the allowance bank grew so large that the RGGI States implemented several adjustments to the allowances allocated to reduce the bank.  These adjustments ended in 2025.

To refine when emissions could exceed the allowances available it is necessary to account for the allowance bank.  RGGI does not provide a report that describes the status of the allowance bank, so I had to develop my own estimate.

Potomac Economics provides independent market monitoring analysis of RGGI that provide the information needed to estimate the bank.  The Quarterly Reports on the Secondary Market are released several week after the end of a quarter.  The Quarter 4 2025 report includes a description of CO2 allowance holdings:

CO2 Allowance Holdings – At the end of the fourth quarter of 2025:

  • There were 175 million CO2 allowances in circulation.
  • Compliance-oriented entities held approximately 125 million of the allowances in circulation (71 percent).
  • Approximately 142 million of the allowances in circulation (81 percent) are believed to be held for compliance purposes.

Quarterly Allowance Status

The allowance bank is simply the difference between allowances being added and emissions that subtract allowances.  Allowance transactions occur on a quarterly basis.  Allowances are added at each auction and the annual true-up when allowances are surrendered to account for emissions occurs in the first quarter following the end of the year.

Emissions are used to reduce the allowance bank.  Historical quarterly emissions are available on the RGGI COATS platform.  Table 1 lists historical and projected CO2 emissions by state starting in quarter 4 2021 and ending in 2029.  Historical emissions are not highlighted.  For the second quarter of 2026 (highlighted in blue) I assumed that emissions would equal the average of the last two years.  Starting in the third quarter of 2026 I assumed that emissions would equal the average of the three years when Virginia was part of RGGI.  This is supported by Figure 2 that shows emissions have been relatively level since 2019 for the eleven states now in RGGI.  The annual emissions are simply the sum of the four quarters.  The 2026 total highlighted because it represents a mix of observed and projected emissions.

Table 1: RGGI Quarterly CO2 Mass Emissions (short tons)

The allowance bank is the balance of allowances awarded and surrendered.  Figure 4 described the projected allowance distribution that was used to project future annual allowance distributions.  I assume that all the CCR Tier 1 and Tier 2 allocations will be awarded in the first quarter and the remaining allowances distributed by the same amount each quarter.  The Virginia allowance distribution has not been announced so I assume that they will be awarded in proportion to the control period when Virginia was a member. 

The purpose of this analysis is to determine when the allowances in circulation are less than the emissions.  The quarterly number of  allowances in circulation is equal to the sum of the previous quarter allowances in circulation and the allowances awarded with allowances surrendered subtracted.  Allowances are surrendered annually but I subtracted the emissions on a quarterly basis to get finer resolution.

Figure 5 plots the quarterly emissions (green), allowance cap (dark blue), added allowances (light blue) and allowance balance (orange).  This analysis assumes that emissions remain constant and shows that as the allowance cap is reduced the bank of allowances eventually is exhausted.  When the allowance balance is less than zero there are no longer sufficient permits to emit CO2 and affected units must shut down or end up out of compliance.  Table 2 lists the balances and shows that during the third quarter of 2032 there are insufficient allowances. 

Figure 5:  Quarterly RGGI Allowance Balance, Emissions and Allowance Cap

Table 2: Quarterly RGGI Allowance Balance, Added Allowances and Emissions

Discussion

To sum up, RGGI allowances necessary for facilities to operate will run out in the third quarter of 2033 if emissions remain constant and that the share of Virginia allowance allocations remains proportional to the period when Virginia was in RGGI.  Note, however, that the market will be so tight in 2033 that some facilities will run out sooner.  I would like to think that Virginia will remain consistent, but it is worrisome that Virginia decided to rejoin before the end of the current compliance period that ends this year.  In the past states entered and left the program consistent with the three-year compliance period.  If that decision was driven by an ideological desire to save the planet there is the possibility that a different allowance allotment will be used.  If the Virginia allocations are proportional to the past the addition of the state will not markedly affect when the allowances run out.

This analysis does not try to distinguish between allowances held by compliance entities and those without compliance obligations.  At the end of the fourth quarter of 2025 the Quarter 4 2025 report on the secondary market stated that “Approximately 142 million of the allowances in circulation (81 percent) are believed to be held for compliance purposes.”  There are two implications.  RGGI states have always assumed that the remaining 19% of the allowances are held for investment purposes and would eventually be used for compliance.  Given that facilities need those allowances to operate it will be a seller’s market and prices should skyrocket when they are needed.  There is another possibility.  Some of those allowances could be held by organizations that want to prevent CO2 emissions and may not sell them at any price.  In that case, the market will run out of allowances sooner.

On May 8, the RGGI states announced that they were aware of the short-term volatility associated with the announcement that Virginia would rejoin RGGI:

Recent futures prices are above thresholds established to automatically mitigate price growth by releasing additional allowances at auctions for cost containment. RGGI has a long history of stability. Regular program reviews have made adjustments to align the program with policy objectives of a reliable, affordable, and clean electricity supply. A sustained period of elevated auction prices would not meet these objectives and may require renewed consideration of improvements.

These results indicate that renewed consideration of the program design is necessary now to prevent sustained elevated auction prices. 

Conclusion

For years the sources affected by RGGI and me have been warning that RGGI is headed to the point where there are  insufficient allowances to enable sources to run and remain in compliance.  If left unchecked this will lead to an artificial energy storage,  The allowance cap trajectory is simply incompatible with observed and likely generating resource development that can displace existing resources.  When RGGI announced that Virginia would rejoin the program, futures prices nearly doubled and the spot market price also spiked.  Cost impacts will be evident before the allowances run out because scarcity will drive allowance prices higher because the present regulations bake in scarcity.

All politicians in RGGI states who are worried about energy affordability should seriously consider dropping out of the program because it is simply unaffordable and risky without major changes.

New York Grid Inertia Past and Present

I believe that it is necessary to reconsider the New York Climate Leadership & Community Protection Act (Climate Act) net zero transition because the reality is that there are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and figure out how best to amend the law.  Grid Inertia support is another example illustrating reliability and affordability concerns.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 650 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.

I am currently overwhelmed with blog posts that I want to write, regulatory submittals I should submit, and it is spring so my life outside of this blog demands time too.  As a result, I unapologetically acknowledge the use of Perplexity AI to produce this post because it would not have been written were it not for its support.  I edited the output, checked references and added my own references.

Grid Inertia Past

I started working for Niagara Mohawk Power Corporation (NMPC) in 1981.  At the time it was a vertically integrated utility responsible for generating, transmitting, and distributing electricity.  The importance of reliability was an all-encompassing driver at the company.  Since then, much has changed and, in my opinion, not for the better.  NMPC proudly described their generation mix of coal, oil, nuclear, and hydro as resilient and reliable. 

The emphasis on reliability took many forms but there was an explicit mandate to support the ancillary gird services needed to keep the lights on.  Grid inertia is one example ancillary service that helps keep the power system frequency stable by using the stored kinetic energy in large rotating machines, such as synchronous generators or synchronous condensers, that are physically spinning in sync with the grid. When there is a sudden mismatch between supply and demand—like a generator trip—this rotating mass resists the change in speed, slowing the rate at which grid frequency deviates and buying operators time to respond.

When NMPC was responsible for providing electricity to consumers the system was built around large rotating machines synchronized with all the other generators in New York and beyond.  NMPC owned and operated many hydro-electric units that provided additional grid inertia support.  For example, the hydro plants on the Black River could provide grid inertia and did so for 70 years until sold about 30 years ago when New York politicians demanded a de-regulated electric system.  At that time NMPC had to sell all their generating plants and got out of the power management business.

Grid Inertia Present

In today’s electric system the New York System Operator (NYISO) runs the system: “NYISO-administered markets send price signals designed to attract and retain investment in the types of flexible, firm, cleaner, dispatchable resources essential for efficiently maintaining system adequacy into the future.”  The design of the market establishes price signals necessary to provide the services needed keep the lights on.  However, The Climate Act is shutting down traditional plants faster than we can replace all the resources they provided so the grid loses the resilience that NMPC provided. Eventually, NYISO system operators will need to procure inertia explicitly as an ancillary service, either from remaining synchronous machines or from technologies that can emulate inertial response.

NYISO does not have a standalone “inertia” market today.  Instead, synchronous generators, synchronous condensers, and certain non‑generator devices can be paid  when this resource is needed.  This is insufficient in my opinion.  As evidence the current owner of NMPC, National Grid is building synchronous condensers because they must think they are necessary for reliability.

In June 2024, GE Vernova announced that it would build two turnkey synchronous condenser sites for National Grid at the Coffeen and Taylorville 115 kV substations. Each site will include three synchronous condenser units and associated transformers, with the stated purpose of improving grid stability as the resource mix shifts under New York’s Climate Act decarbonization policies.

Market Failure

I think the construction of the these plants represents  market failure. The Coffeen St substation used to serve the Black River hydro plants.  Now these plants are paid only when they produce power.  I have heard from NMPC retirees that said it t was hard to believe that you can contract for power and and not contract for the inertial support and other ancillary services.  He said It would take less than 24 hours to bring this back to how it was run before if there was a suitable market.

New York already had synchronous resources that historically supplied many of the services necessary to support the electric system. New York is not simply adapting to a new grid. It is paying to replace a reliability function that legacy hydro plants once provided. That should raise a basic question for both the Public Service Commission and NYISO: why are customers paying for new synchronous condensers instead of first determining whether existing hydro facilities could be contracted or compensated to provide comparable system-strength services?

The fact that there is a market gap matters. If the only straightforward compensation mechanism is for dedicated voltage support equipment, then utilities and regulators will naturally gravitate toward building new rate-based infrastructure. Existing hydro resources may be physically capable of helping, but unless there is a contract or explicit market design to value those services, they will be overlooked. The losers are New York ratepayers.

Discussion

This is why the Coffeen and Taylorville projects are more than a local transmission story. They are evidence that the Climate Act is driving a second layer of costs that is rarely acknowledged in public debates. New York is not just paying for renewable generation. It is also paying for replacement grid services that were once provided by conventional and hydroelectric units as part of ordinary operations.

That fact alone should change how New Yorkers think about the claimed cost of the energy transition. Wind and solar developers may claim that their projects are cheap, but that comparison often ignores the system cost of all the additional equipment needed to keep the grid operating reliably once conventional generators are retired or used less often. The Coffeen and Taylorville projects are a clear example of those hidden costs now being imposed on upstate ratepayers.  The observed increases in recent utility rate cases are not caused exclusively by the Climate Act but there is no question that buried costs like this are exacerbating costs at the time there is an affordability crisis.

Before more synchronous condenser projects are approved, state regulators should require a transparent comparison of alternatives. That analysis should evaluate whether existing hydro units, especially those historically operated by Niagara Mohawk, could be returned to ancillary support service through contracts, tariff changes, or operating modifications. If that can be done at lower cost, then building new synchronous condensers should be the last resort, not the default option.

Conclusion

The larger lesson is straightforward. The Climate Act does not merely require more wind, solar, and batteries. It also requires an electric system strong enough to survive with fewer conventional synchronous machines. When policymakers ignore that reality, ratepayers end up paying twice: once for the new intermittent resources, and again for the equipment needed to compensate for what those resources do not provide.  Implementation of the Climate Act Renewable Energy Program needs to be paused to address this hidden affordability burden.

RGGI Unacknowledged New York Cost Impact

On April 29, 2026 the Regional Greenhouse Gas Initiative (RGGI) states announced that Virigina was rejoining.  The original intent of this post was to describe the potential impact of that development, but while doing research it became obvious that the bigger story is the impact of the cost adder for RGGI allowances on the electric market.  On May 8, the RGGI states issued a notice that they were monitoring the allowance market in response to a sharp increase in the secondary futures market price so I am not the only one concerned about this development.

Dealing with the RGGI regulatory and political landscapes is challenging enough that affected entities seldom see value in speaking out about fundamental issues associated with the program.  I have been involved in the RGGI program process since its inception and have no such restrictions when writing about the details of the RGGI program.  I have worked on every cap-and-trade program affecting electric generating facilities in New York including RGGI, the Acid Rain Program, and several Nitrogen Oxide programs, since the inception of those programs. I also participated in RGGI Auction 41 successfully winning allowances and holding them for several years.   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.

Background

RGGI is a market-based program to reduce greenhouse gas emissions from the power sector(Factsheet).   It has been a cooperative effort among Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont since 2008, with New Jersey rejoining in 2020 and Virginia scheduled to rejoin beginning July 1, 2026.  Pennsylvania recently decided not to join. 

According to the RGGI program description, the states issue CO2 allowances that are distributed almost entirely through regional auctions, and the proceeds are then reinvested in strategic energy and consumer programs.  Those investments include energy efficiency, clean and renewable energy, beneficial electrification, greenhouse gas abatement and climate adaptation, and direct bill assistance, with energy efficiency receiving the largest share. 

Virginia Rejoins RGGI
The RGGI Statement said that, with Governor Spanberger’s approval of Virginia’s regulation reinstating the state’s CO2 budget trading program, Virginia’s participation and compliance obligations will resume on July 1, 2026.  Virginia’s allowance budget for the second half of 2026 will be 11.48 million allowances, and the state will participate in the September 9 and December 2, 2026 auctions.  Virginia will also originate 1.148 million Cost Containment Reserve allowances for the remainder of 2026, and later this year the state will undertake regulatory action to align its program with the Third Program Review and the updated Model Rule by January 1, 2027. 

Cost Impact of Virginia Rejoining RGGI

RGGI allowance costs are driven by basic economic considerations.  When there is scarcity prices increase and when there is uncertainty about scarcity costs also go up.  The difference is that price increases associated with uncertainty can drop when more information is available.  Whereas it is possible that the RGGI plans for the emission cap are so aspirational that scarcity is baked in.  A Perplexity AI review of the Annual RGGI Market Monitor reports describes observed price spikes were associated with the following:

  • A regime change in supply (cap adjustment, Cost Containment Reserve (CCR) exhaustion, bank recalculation) alters the scarcity narrative and raises uncertainty.
  • That uncertainty interacts with short‑term shocks—Clean Power Plan expectations and nuclear retirements in 2015, cap/bank adjustments in 2021, CCR exhaustion plus an expanded derivatives market in 2024, and the 2025 program review, the Virginia state election, and winter demand expectations in late 2025.
  • A growing options and futures market means those shocks are transmitted and sometimes amplified via hedging and speculative flows, which shows up explicitly as higher option‑implied volatility in the RGGI monitor reports.

The price of RGGI allowance futures recently rose sharply after the announcement that Virginia would rejoin RGGI.  There is no publicly available resource describing the price of allowances on the secondary market.  Instead, subscription-based trade news services determine the secondary allowance prices.  The Carbon Pulse article RGGI Market: Historic rally rages over 30% into new week as RGAs breach $40 description stated the following before the article contents were available only to subscribers:

Last week’s surge in RGGI Allowance (RGA) futures carried over into the new week as prices broke all-time highs above the $40 threshold, up more than 30% in the last three days, with traders telling Carbon Pulse it’s unclear where and when the current rally could reach a pinnacle.

RGGI Cost Impacts

Several NYISO market experts have pointed out to me that this is a serious issue that should be addressed.  RGGI costs have two effects on customer supply costs: the direct cost of the allowances themselves for each generating unit and the impact of the cost adder used by generating units in their bid prices.  After a long delay I finally have found time and agree that this needs to be discussed.

In a deregulated electric market such as that run by the New York Independent System Operator, power plants, load-serving entities, and other participants submit competing bids and offers to an auction that determines the least-cost set of resources needed to meet demand while respecting grid limits.  NYISO’s day-ahead energy market is a financially binding, security-constrained auction in which generators, loads, and other participants submit bids and offers for each hour of the following day.  NYISO then runs an optimization that selects the least-cost portfolio of resources from those bids that can reliably meet forecasted demand given transmission limits and unit constraints, and the resulting locational marginal prices are used for settlement. 

A useful way to picture the market is as a stack of generator offers, with the cheapest megawatts at the bottom and progressively more expensive plants piled on top until the stack is high enough to meet NYISO forecast load.  At that point, the most expensive marginal unit needed sets the clearing price for the zone.  If the marginal unit must add a CO2 allowance cost to its bid, then the clearing price rises accordingly, increasing the price paid to all accepted generators in that market interval.  Lower-emitting generators still incur their own allowance costs, but their revenues also increase because they are paid the higher clearing price, and non-emitting units receive the clearing-price increase as pure profit without any direct CO2 compliance cost. 

RGGI Cost Estimate

To calculate the best estimate of the cost of RGGI on the New York electric system, it would be necessary to obtain hourly emissions and operating data for all units participating in the NYISO market.  Unit-specific operating information is proprietary and not publicly available.  For a first-cut estimate, emission monitoring data for RGGI program units were downloaded from the EPA CAMPD database for 2025.  Those hourly data include CO2 emissions, heat input, and gross load, so estimates of heat rate and CO2 emission rate can be derived.  However, this database was not designed specifically for heat-rate analysis, and the hourly values necessarily rely on simplifying assumptions about fuel heat content for emissions-trading purposes.  Nonetheless, the data are indicative. 

Figure 1 plots 2025 annual operating time against annual heat rate for New York RGGI units.  It would be better to plot heat rate against capacity factor, but the EPA data do not include nameplate capacity in a form that can be readily matched to NYISO data.  Three clusters stand out: highly efficient gas-fired combined-cycle units with low CO2 rates (red circle), steam boilers in the middle of the distribution (purple circle), and older simple-cycle turbines with the highest heat rates and CO2 emission rates (dark yellow circle). 

Operating Time for NYS RGGI Units

To illustrate the effect of the RGGI cost adder, the estimates below use annual values as a proxy for the hourly impacts that would ideally be summed across the year.  In 2025, statewide gross energy from New York RGGI units totaled 67,094.6 GWh, those units emitted 32,037,339 tons of CO2, the average quarterly RGGI auction price was $22.09 per ton, and NYISO Gold Book Table III-2a reports total net New York energy of 132,182 GWh.

The direct cost of allowances alone can be estimated by multiplying annual emissions by the average auction price: 32,037,339 tons times $22.09 per ton, or about $707.7 million.  That simple estimate does not account for the effect of the NYISO market clearing-price adder that is passed through to ratepayers. 

Table 1 provides bounding estimates for that market effect.  The first section, “Cost of Allowances for Annual Emissions,” documents the direct allowance-cost numbers just described.  The Annual Total section lists the NYISO total net energy used in the scaling calculation.  The remaining scenarios use observed heat rates and observed CO2 emission rates derived from EPA data to estimate an allowance-cost adder in dollars per MWh, which is then multiplied by total NYISO energy to estimate the statewide annual cost impact. 

Table 1: 2025 New York State RGGI Unit Operating Characteristics &  Emissions, RGGI Allowance Cost, and Consumer Cost Impacts

Using average 2025 data for New York RGGI units, the “RGGI Average” scenario yields an estimated statewide cost impact of $1.39 billion, nearly double the direct cost of purchasing allowances alone. Using the heat input weighted input data, the statewide cost impact would be $2.26 billion.  If every fossil unit in New York were a modern state-of-the-art combined-cycle unit, represented here by the average of the Cricket Valley and Valley Energy Center units, the “Modern CCGT” scenario yields about $1.16 billion.  A representative steam-boiler scenario yields about $1.74 billion.  The worst-case “Old Combustion Turbine” scenario yields about $2.01 billion, although that result is not realistic because it would require an old combustion turbine to be marginal in every hour and every relevant zone. 

Discussion

RGGI allowance prices raise the marginal bid of emitting generators in NYISO, so the allowance “cost adder” lifts the market clearing price on essentially all electricity consumed in New York, causing total costs to ratepayers that can be two or more times higher than the direct allowance expenditures and creating a windfall for non‑emitting “free‑rider” units. In simplest terms assuming that the weighted average heat rate is the marginal heat rate (11,700 mmBtu/MWh), the weighted average emission rate (0.77 tons/MWh), the last auction RGGI closing price ($22), and apply that allowance adder to all delivered MWh (150 TWh) shows that RGGI raises retail bills on the order of $2.26 billion dollars per year at the allowance cost in late March.  The recent price spike doubled this cost increasing this impact of RGGI to $12.3 million a day.   The generators’ direct compliance costs are much smaller, with the difference accruing as bonus money to non‑emitters. It is not yet clear whether the recent spike in RGGI allowance futures will be the new normal or whether it is the result of today’s uncertainty about the impact of Virginia rejoining RGGI. 

RGGI allowance prices from 2009 to 2018 were generally below $5 per ton, but since then both prices and volatility have increased materially (Figure 2).  It is not yet clear whether the recent spike in RGGI allowance futures will be fully reflected in future auction prices.  Importantly, when generating units incorporate the RGGI cost into their market bids they use the current spot market price.  In other words, the impacts of this price spike are showing up in electric prices now.  When the net monthly bills go out if this trend continues there will be a noticeable increase in costs.

Figure 2: RGGI Quarterly Auction Allowance Clearing Prices

Only the NYISO has the proprietary hourly market and unit-commitment information needed to estimate the total consumer impact of the RGGI cost adder with confidence.  Even so, the bounding scenarios presented here indicate that the added cost to consumers is likely substantial and that a significant portion of that added cost appears as windfall revenue to lower-emitting and non-emitting generators. 

The theory that auction revenues support cost-effective consumer benefits typically considers only the direct cost of allowances.  Even if all the allowance auction proceeds were directly returned to customers this analysis shows that when the market-clearing-price effects of the RGGI allowance adder are included consumer impacts will be significant.

Conclusion

My market expert tutors pointed out that the RGGI carbon tax has been ignored for years.  The ultimate beauty of the program is that the costs of RGGI allowances are not visible on electric bills because the allowance costs are buried in the bid prices.  We are sure that the PSC would never allow any information about RGGI allowance costs to be included as information items on electric bills. Ultimately the best tax is a hidden tax.

This issue was reportedly a topic of conversation at NYISO during the early years of RGGI implementation.  Given that allowance prices are now an order of magnitude higher than they were for many years and could go higher still, it is time for NYISO to reconsider the windfall profits that non-emitting units are reaping on the backs of New York ratepayers. 

PSL 66-P Petition Filing – Analysis of Future Utility Rates

The comment period for comments regarding the safety valve provision in New York Public Service Law (PSL) § 66-p for the Renewable Energy Program in the Climate Leadership & Community Protection Act (Climate Act or CLCPA) recently ended.  I published a series of posts describing this process that was summarized in my most recent post.  Independent Intervenors Richard Ellenbogen, Constantine Kontogiannis, Francis Menton, and myself explained why we thought it would be appropriate to hold a hearing addressing the safety valve provisions in our filing.  We agreed that we would not submit technical arguments from all of us but we are all driven by a common motivator that when we see something outlandish, we have to respond.  Richard Ellenbogen’s filing describing an Artificial Intelligence (AI) analysis impact of the Climate Act on utility rates was initiated by such a trigger.

Richard Ellenbogen has been speaking to lawmakers, policy makers and regulators since 2019 regarding the deficiencies inherent in New York State (NYS) 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.

Background

New York Public Service Law (PSL) § 66-p establishes a renewable energy program for the Climate Act.  It  provides that 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”.  This safety valve was included because even the lawmakers realized that it may not be possible to transition the electric system to “zero-emissions” by relying on renewable energy. 

In response to the PSL 66-P safety valve, Ellenbogen filed a description of his analysis of the results of other jurisdiction’s attempts to implement energy policies like the Climate Act.  His filing was titled: “An AI Analysis of the CLCPA that Shows it will raise Utility rates between 50% and 150% over the Next 40 years with no rate relief appearing for between 100 – 150 years, IF EVER” and was described:

“Prejudices Inherent in the drafting of the CLCPA Introduced a rigid framework, unsupported by scientific facts, that preclude better long-term solutions from both a carbon emissions standpoint and an economic frame of reference”.  He also submitted a spreadsheet that was developed by Perplexity in response to his queries.

This post is based on the filing and his email description circulated to his mailing list.  I have lightly edited his work for consistency.

AI Analysis Background

Both Ellenbogen and I have been using Perplexity AI more as a research tool and we are just starting to realize the potential of its use.  He explains how he used it for this analysis:

For the past three weeks, i have been sitting and asking energy related questions of Perplexity AI.  The questions were asked without bias and conditions were only added based upon responses from prior questions, although as I learned over time, the AI algorithm remembered all of the conditions without my asking and applied those to subsequent questions.

The paper covers everything that I could think of.  It has AI answers to the major problems facing NY State.  I added context to the answers to help people understand them and explain how we got here.

The questions were asked in plain English.  Some of the AI responses can be technical in places. 

The first 23 pages tell most of the story with the 50 pages of appendices adding context.  AI has become a frighteningly powerful tool.  Watching it generate code to answer some of the questions was comparable to what an incredibly fast human would do that could access information at a pace that no human could possibly do, let alone think of all the parameters needed. When I was building the spreadsheet, the second query was to add BESS to the calculation to make the wind dispatchable so that it would be more of an “apples to apples” comparison to the retooled gas plants.  I didn’t specify how much but the AI algorithm automatically researched it and found NYISO requirements and pulled those into the calculation.  It also was telling me what it was doing as it did it.

An experienced utility analyst looked at the spreadsheet and said, “That’s exactly what I used to do for the utility companies, except that would take at least a week.”  It took me an hour.  It was built from three queries and the AI wrote code,  produced results, checked conformity, found its errors, redid the code and checked conformity again until the results made numerical sense.  It took about 20 minutes for each question.  It then added the additional questions to the same spreadsheet and suggested more related questions to research. It could turn into an infinitely long research rabbit hole. When I asked about natural gas prices, it had remembered my questions about the LI gas plants and automatically related the pricing questions to those without my asking.  It inferred that was why I was asking.

I spent time checking the answers which accounted for much of the time writing the document.  I knew the answers to many of the questions before I asked them based upon extensive reading and almost fifty years of experience dealing with energy systems.  I am hoping that AI confirmation of the answers will make people realize that this is not ideological.

On a final note, I’m a tech geek and this technology is very useful but a little creepy.   When I was doing this, I felt like I was dealing with “Skynet”.  The rate of evolution of the technology is breathtaking, and I don’t think that I could have generated this report six months ago.

Ellenbogen’s Filing

Consistent with Ellenbogen’s use of AI, I submitted the following question to Perplexity: “Provide an overview summary of Ellenbogen’s filing that I can incorporate into a blog post. “ The following is the response:

Core thesis

Ellenbogen’s filing argues that New York’s CLCPA will drive very large, long‑lasting rate increases and will not deliver genuine rate relief for at least 100–150 years, if ever, under anything resembling realistic assumptions. He frames CLCPA as a capital‑heavy, prejudiced policy design that blocks cheaper and faster emission‑reduction options (notably repowered gas and nuclear), locking customers into a multi‑generation cost burden for modest climate benefits.

Australia as the warning case

A central plank is a detailed Australia comparison, which he uses as a “best possible” renewable case study to bound what New York can realistically expect. Australia has six times New York’s solar capacity, far higher solar capacity factors, far more land at a fraction of New York’s cost, and far lower heating loads, yet wholesale prices only clearly began trending down in 2024–2025 after roughly 20 years of policy implementation, and even then retail bills are only expected to fall about 5 percent over the next five years.

He then scales this experience to New York’s much worse fundamentals: four times the per‑capita heating load, roughly half the solar capacity factor, far less developable land, and much higher land and interconnection costs. On that basis, he argues New York would need 80–150 years before seeing durable rate relief, with residential rates rising on the order of 50–150 percent over the next 30–40 years and upstate households facing bill increases of 2,000–5,000 dollars per year at the peak of the transition.

Grid, labor, and supply‑chain constraints

The filing emphasizes that official NYSERDA/CLCPA planning assumes “ideal” supply chains and grid conditions that do not exist. He cites transformer shortages with multi‑year lead times, insufficient trained labor to electrify buildings and upgrade panels and substations, and local grid stress already appearing as “blue sky blackouts” in electrified pockets like the Albany area.

Because load from electrification is ramping faster than new dispatchable capacity and network reinforcements, he argues New York is replicating Victoria’s mistakes in Australia: voltage problems, constrained substations, and reliability risks driven by “electrify first, supply later” policy sequencing. His bottom line is that these constraints stretch the transition into a 40‑year or longer construction effort, add huge cost premiums, and push any hypothetical “payoff” far into the next century.

Cost comparisons: offshore wind, storage, and gas repowering

A major section uses an Excel LCOE framework, fed by AI‑generated parameter sets, to compare offshore wind plus batteries against repowered combined‑cycle gas at Long Island sites like Northport, Barrett, and Port Jefferson. Across a wide range of gas prices (current Henry Hub and 2–4× that level), the model shows that offshore wind plus 4–8 hours of battery storage remains substantially more expensive than repowered gas over 20‑ and 40‑year horizons, even after layering in a state carbon tax on gas.

He also notes that the wind‑plus‑storage cost stack in his base case does not include synchronous condensers and other stability equipment required in a heavily inverter‑based system, which would drive the renewable system cost even higher relative to combined‑cycle plants. In his framing, the oft‑repeated “renewables are cheaper” line collapses once you include the full system cost of firming, transmission, and stability equipment in a New York context, as opposed to Texas or Australia with far better wind and solar resource.

Nuclear and statute‑driven “prejudice”

Ellenbogen then asks, via AI prompts, what an unconstrained least‑cost, low‑carbon system for New York would look like over a 60‑year horizon. When the CLCPA’s statutory renewable carve‑outs and timelines are removed, the response (which he quotes extensively) favors a nuclear‑heavy system, with long‑life reactors providing 60–100 years of output at high capacity factors and lower firm system LCOE than “firmed renewables” once overbuild, storage cycling, replacements, and grid expansions are included.

He uses that to argue that the CLCPA embeds an explicit prejudice against nuclear and gas repowering by design, because it hard‑codes high penetrations of wind and solar irrespective of system cost, reliability, or practical feasibility. In his conclusions, he characterizes the CLCPA as an ideologically driven statute that overrides physics and engineering judgment, and he urges the PSC to invoke its PSL‑66 powers to pivot toward a combination of repowered gas as an interim 40–60‑year bridge and nuclear as the primary long‑term zero‑carbon backbone, with hydrogen‑fueled peakers using excess nuclear output as a complement.

Discussion

Ellenbogen’s email concludes that the analysis shows a very grim future for NY State if there is not a course correction.  He notes:

Hopefully, an impartial question and answer session with the world’s computer systems will alter the discussion and make people realize that if we proceed down this path, we will be increasing emissions while needlessly increasing costs in search of a holy grail that is not feasibly attainable in NY State’s climate.  As I have written on several occasions, the CLCPA was a college thought experiment about what could be done if there were no limitations on money, labor, supply chains, land, and if there was no public resistance to having large renewable installations located near their homes.  Unfortunately, our state government, and particularly Andrew Cuomo,  turned that thought experiment into public policy.  While the authors of the thought experiment considered it attainable, engineers in the energy industry understood that the concept was preposterous in NYS.

Conclusion

I have a great deal of respect for Ellenbogen because he has personally approached the challenge of decarbonization as an experiment.  His home and manufacturing facility were the subjects and included data monitoring systems for the test.  He knows what will work and his opposition to the Climate Act technology transition plan is based on what his experiment shows will not work. 

His use of AI is based on his experience and the results are consistent with what he has learned.  I recommend his entire analysis for the unconvinced.  This analysis is another great example why New York should conduct a PSL 66-P hearing to determine if renewable energy can provide safe, adequate, and affordable electricity in New York.

Filings Opposed to the PSL 66-P Safety Valve

New York Public Service Law (PSL) § 66-p establishes a renewable energy program for the Climate Leadership & Community Protection Act (Climate Act or CLCPA) and includes a safety valve provision.  In recently  published posts I provided a status update that provides extensive background information, a description of the Independent Intervenor (Richard Ellenbogen, Constantine Kontogiannis, Francis Menton, and myself) filing describing how the hearing to address the safety valve should be handled, described how the Independent Intervenors think the Public Service Commission should respond to the hundreds of identical comments prompted by advocacy organizations, and finally described the Independent Intervenor filing.  This post describes comments opposing the petition from parties to the cases.

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 650 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.  I acknowledge the use of Perplexity AI to generate summaries included in this document. 

Background

New York Public Service Law (PSL) § 66-p establishes a renewable energy program for the Climate Act.  It  provides that 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”.  This safety valve was included because even the lawmakers realized that it may not be possible to transition the electric system to “zero-emissions” by relying on renewable energy. 

Party Comments Opposing the Petition

There were ten submittals that opposed the petition:

In response to a query to summarize and critique these comments Perplexity AI responded.

The opposing party comments generally argue that a PSL §66‑p(4) hearing is unnecessary, legally unwarranted, and contrary to the CLCPA’s purposes; however, across the various filings there is a recurring tendency to conflate “opposition to the program” with “request for oversight,” to rely on policy aspirations more than record evidence on reliability and costs, and to treat §66‑p’s hearing provision as effectively formally in effect but no longer necessary.

The Perplexity response addressed each of the comments.  The following are the highlights.

The “Green Energy Developers” coalition (Advanced Energy United, ACE NY, CCSA, NY‑BEST, SEIA) positions the petition as a broadside against the CLCPA and the clean‑energy transition rather than as a procedural request to use §66‑p(4). In other words, they do not want anything to get in the way of their revenue stream.  They argue that granting a hearing would increase investor uncertainty, slow project development, and jeopardize achievement of the 70‑by‑30 and 100‑by‑40 mandates. Their comments emphasize sunk costs, signed contracts, and an existing “orderly” procurement framework, and they tend to characterize reliability and bill‑impact concerns as either already addressed in prior Commission orders or overstated by petitioners.

New York State Solar Energy Industries Association (NYSSEIA) has similar interests as the Green Energy Developers coalition, but their comments focused on small developers and customer-sited projects.  They made the same arguments that the act of holding a hearing is tantamount to rolling back the Climate Act and their desire for investor certainty and program continuity are more important than reliability and cost impacts.

The “Green Energy Advocates” group (Citizens Campaign for the Environment, Earthjustice, NRDC, NYLCV, Sierra Club, etc.) generally frames the petition as an attempt to “roll back” CLCPA mandates and to “suspend” the renewable program, emphasizing the urgency of climate action, public‑health co‑benefits, and environmental‑justice goals. They argue that any delay or reconsideration via a §66‑p(4) hearing would violate the CLCPA’s spirit, exacerbate climate risk, and perpetuate fossil‑fuel pollution in disadvantaged communities. The comments rely heavily on broad climate‑science consensus and statewide emissions‑reduction imperatives rather than on the specific evidentiary record on reliability, costs, or implementation feasibility.

Consolidated Edison and Orange & Rockland’s joint comments oppose the petition for a hearing but do so in a more procedural and incremental tone. They emphasize that reliability is being managed through existing NYISO and DPS processes, that the Commission has previously reviewed and adjusted the Clean Energy Standard and related programs, and that another formal §66‑p(4) hearing could be duplicative or disruptive. Note as rate‑regulated entities with pass‑through cost recovery, these utilities have a structural incentive to avoid procedural steps that might slow capital deployment or introduce new prudence reviews, a factor not fully acknowledged in their arguments.

Other opposing commenters include Environmental Defense Fund, the First Unitarian Church Environmental Justice Ministry, Public Utility Law Project (PULP), the Sabin Center for Climate Change Law, Third Act Upstate New York, and the PEAK Coalition. EDF and the Sabin Center focus on the legal structure, arguing that §66‑p(4) gives the Commission discretion (“may”) and that existing orders, impact analyses, and ongoing CLCPA implementation proceedings already satisfy any implied need for review. They argue that the petitioners have not met the burden to show that safe and adequate service or just‑and‑reasonable rates are at risk.  PULP and EJ‑oriented commenters stress that low‑income and disadvantaged communities stand to benefit from the CLCPA and that a hearing framed around costs and reliability could be used to justify delaying those benefits.  This is frustrating because it does not recognize their benefits are societal but the cost and reliability impacts personally affect low-income and disadvantaged community members.  The PEAK Coalition emphasizes the point that delays are unacceptable because local public health impacts improvements and peaker plant retirements would be delayed.  All these commenters do not recognize the risk that reliability events or bill spikes could politically endanger the very Environmental Justice‑oriented clean‑energy policies they want to protect.

Perplexity Summary

•            Most opposing parties reframe the petition as an attack on the CLCPA itself, not as an effort to use a statutory safeguard that the Legislature expressly included. This framing lets them avoid a granular debate over NYISO reliability indicators, actual bill trajectories, and implementation challenges.

•            There is heavy reliance on prior Commission orders and broad policy goals instead of a acknowledging the observed evidence of impacts on system reliability, project attrition, cost escalation, and deliverability constraints that have emerged since 2019.

•            Several commenters implicitly treat §66‑p(4) as a purely discretionary “safety valve” never actually meant to be opened, which risks reducing a substantive statute to symbolic surplusage.

•            Investor confidence, climate urgency, and EJ goals are repeatedly invoked as reasons not to hold a hearing but rarely balanced against the statutory obligation to ensure safe and adequate service and just and reasonable rates. A more balanced approach would treat a narrowly focused, evidence‑driven hearing as a way to protect those goals from backlash driven by reliability events or bill shocks.

Public Comments

In addition to the comments filed by parties to the cases, the PSC accepted public comments. In a previous post I described how the Independent Intervenors think the Public Service Commission should respond to the hundreds of identical comments opposing the petition.  From the very first comments submitted about the petition in early March until May 1, 2026, there were 3,789 public comments submitted in Case 15-E-0302 and 2,516 comments submitted in Case 22-M-0149.  Case 15-E-0302 covers a wide range of topics and there were some public comments submitted in this time frame addressing other topics.  Nonetheless there are thousands of comments that were essentially identical.  As described in the previous article, the arguments made do not warrant rejecting the petition or make a convincing argument that the PSL 66-P Renewable Energy Program obligations may not need to be temporarily suspended or modified to ensure safe, adequate, and affordable electricity.

Steve Helmin pointed out that there is a pattern to these nearly identical comments that suggests the use of automation in submitting to the DMM site.  This pattern and what has been observed in other proceedings suggests that advocacy organizations are collecting comments on their own servers and then pushing them to the PSC, as opposed to requiring commenters to navigate the DMM interface to submit comments.  This enables a “Click Button” knee jerk reaction that insulates commenters from any potential independent review of the case materials and enables an unrivaled single point of context for commenters as they never even see the DMM website.  This automation reinforces my opinion that State Agencies should not be swayed by the number of comments but judge each different opinion on its merits.  The stakeholder process in the Scoping Plan and the Energy Plan did not respond to comments in this manner.  This must change.

Discussion

Consider this quote from the PEAK Coalition comment:

The Coalition for Safe and Reliable Energy (“Petitioner”)—solely representing business interests—has requested a hearing to permanently suspend or modify the Renewable Energy Program pursuant to PSL § 66-p(4), alleging that the program and its associated CLCPA targets “might negatively impact electric reliability” (emphasis added) and may subsequently impede the Commission’s duty of ensuring safe and adequate electric service.

This illustrates a fundamental misunderstanding in common with many other opposition comments.  The petition is only requesting a hearing to determine if the Renewable Energy 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”.  If the hearing finds that there are problems, then the PSC “may temporarily suspend or modify the obligations” of the Renewable Energy Program.  In my opinion, the most likely outcome, given all the renewable energy deployment problems observed since 2019, is some modification to the schedule for renewable energy deployment. 

Opponents who demand that the request for the hearing consistent with PSL 66-P be denied suggests that they are not confident that renewable energy programs can provide safe and adequate electricity.  Given that there has never been a feasibility analysis confirming that the schedule and ambition of the Climate Act are possible and the fact that no jurisdiction has successfully implemented an electric system totally consistent with the Climate Act should be red flags.  Don’t forget that the Climate Act was passed during the 2019 budget process without the opportunity for the public to weigh in.  It is long past time that New Yorkers are given a complete accounting of what will be needed, what it will cost and how it will risk safe and adequate energy supply.  I naively hope that if there is a hearing that those issues will be addressed for the renewable energy system.

Conclusion

Opponents of the petition to hold a hearing to consider whether the Renewable Energy Program can provide safe, adequate, and affordable energy do not have strong arguments against holding a hearing.  I also believe that they oppose the hearing so much because they know that their support of the Program cannot be defended.  Finally, a hearing would expose the impacts of the Climate Act to many New Yorkers who are unaware of it.  I think those are three good reasons to hold the hearing.

Independent Intervenor Filing in Support of PSL 66-P Safety Valve

Update: 5/3/2026

Here are the links in the DPS DMM System for our filing and the three exhibits

  • Filing in support of petition
  • Exhibit 1 documents the trend of New York customers in arrears
  • Exhibit 2 is the spreadsheet with the calculations and data for the results in Exhibit 1. 
  • Exhibit 3 responds to a public comment submitted by hundreds of individuals to illustrate why the stakeholder process must change for the hearing from that used in the Scoping Plan and State Energy Plan.

New York Public Service Law (PSL) § 66-p establishes a renewable energy program for the Climate Leadership & Community Protection Act (Climate Act or CLCPA) and includes a safety valve provision.  In posts published this week I provided a status update that provides extensive background information, a description of the Independent Intervenor filing describing how the hearing to address the safety valve should be handled, and described how the Independent Intervenors think the Public Service Commission should respond to the hundreds of identical comments prompted by advocacy organizations.  This post describes the filing the Independent Intervenors submitted in support of the petition for a safety valve hearing.

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 nearly 650 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

New York Public Service Law (PSL) § 66-p establishes a renewable energy program for the Climate Act.  It  provides that 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”.  This safety valve was included because even the lawmakers realized that it may not be possible to transition the electric system to “zero-emissions” by relying on renewable energy.  New York State never followed up with a feasibility study proving that it could be done, never pointed to another jurisdiction that implemented such a system successfully, and has not provided clear and comprehensive cost estimates. 

I have joined Richard Ellenbogen, Constantine Kontogiannis, and Francis Menton (“Independent Intervenors”) submitting comments in a few Public Service Commission proceedings.  I am a retired utility meteorologist, with extensive electric energy and environmental regulatory analysis experience.   Ellenbogen is an electrical engineer who is President of Allied Converters where he has pioneered how “green” manufacturing can work.  Constantine Kontogiannis is an engineer who has decades of experience providing energy consulting services.  Menton is a retired lawyer and now writes articles on his Manhattan Contrarian blog that analyze New York’s energy transition.  We have no financial interest in Climate Act policy, have received no funding from any outside interests for our filings, and have invested thousands of hours of our time in efforts to explain why physics, engineering and economics prevent a Renewable Energy Program that powers a safe, adequate, and affordable electric system in New York State.

Petition Support

The Independent Intervenor filing argued that the Legislature included this safety valve precisely for the circumstances New York now faces.  Proponents of the Climate Act argue that the transition strategies must be implemented to meet the net-zero mandates regardless of affordability or reliability constraints. However, PSL § 66-p is also a legal requirement, and it charges the PSC with implementing the Renewable Energy Program subject to feasibility safety valve conditions for affordability and reliability. We described four lines of evidence that support the need for the hearing.

Safe and Adequate Service Is Imperiled by Declining Reliability Margins

The New York Independent System Operator (NYISO) has documented a systematic deterioration of grid reliability since the Climate Act was enacted. NYISO data show a net loss of 2,041 MW of dispatchable capacity (4,315 MW retired versus 2,274 MW added). Fossil retirements are outpacing new supply additions, with additions largely consisting of intermittent renewables and limited-duration storage that cannot provide the firm, dispatchable capacity the grid requires.

NYISO’s 2024 Reliability Needs Assessment (RNA) identifies an actionable reliability need in New York City beginning in 2033, with deficiencies ranging from 17 to 97 MW, and high-risk scenarios show the deficiency could begin as early as 2025 and grow to over 1,000 MW by 2034.  The “high‑risk scenarios” are from the RNA’s High Demand Forecast Scenario and related NYC risk scenarios documented in the 2024 RNA report’s “Exploring Uncertainty: Scenarios and Risks” section and detailed in Appendix E/F scenario figures and text. The 2025 Q3 Short-Term Assessment of Reliability (STAR) Report identifies a Zone J (NYC) summer 2027 reliability need requiring retention of peaker units scheduled for retirement. Statewide, NYISO projects that by 2034 there will be no surplus power without further development of reliable sources of electricity.

NYISO has officially stated that the dispatchable emission-free (DEFR) technologies needed to replace fossil generation “are not yet available on a commercial scale”. The CLCPA and Scoping Plan implicitly assume large volumes of firm zero-emission resources will be available, cost-effective, and sited in New York by 2040, but there is no clear procurement or market framework to ensure they materialize. This represents a technology and market design gap between what the CLCPA requires and what is under contract or in interconnection queues today.

The Renewable Energy Program depends heavily on transmission infrastructure that either does not exist, has been terminated, or faces severe uncertainty:

  • Clean Path NY terminated: NYSERDA and developers mutually agreed to suspend the Tier 4 REC Purchase and Sale Agreement in late November 2024 due to cost escalation. The PSC subsequently denied NYPA’s petition for Priority Transmission Project designation in August 2025. There are no plans to revive Clean Path NY.
  • Champlain Hudson Power Express (CHPE) winter limitations: Although CHPE is in late-stage construction, NYISO’s Short-Term Reliability Process Report states that “the facility is not expected to provide any capacity in the winter.” The New England Clean Energy Connect experience during the January 2026 cold snap, where power flows from Québec largely collapsed, foreshadows this vulnerability. This is a serious failure of planning given the prospect that New York grid demand will peak in the winter rather than, as now, in the summer, if building and transportation electrification advances. 
  • Offshore wind transmission withdrawn: The PSC voted to withdraw the NYC Public Policy Transmission Need determination in July 2025, cancelling the process for delivering 4,770 to 8,000 MW of offshore wind into New York City. Proposal costs ranged from $7.9 billion to $23.9 billion.
  • Federal disruptions to offshore wind: The Trump administration’s stop-work orders on offshore wind projects and suspension of leasing have further compromised the transmission pathway for the mandated 9,000 MW of offshore wind by 2035.

NYISO has warned that without major transmission project completion, NYC reliability margins will become deficient. NYISO has concluded that cumulative factors — retirements, electrification, and delays — risk creating reliability metric violations incompatible with safe and adequate electric service.

The Affordability Crisis Demands a Hearing

The affordability evidence satisfies the PSL 66-p(4) threshold of “a significant increase in arrears or service disconnections.” As of December 2024, over 1.3 million New York households were behind on their energy bills by sixty days or more, collectively owing more than $1.8 billion. Independent Intervenors have demonstrated that the increase in the number of accounts in arrears from 2019 before enactment of the CLCPA and 2024 are statistically significant for statewide totals and four of ten utilities.  We filed exhibits that updated the analysis through 2025. We found the same results.

The cost trajectory is alarming. The recently completed New York State Energy Plan found that Climate Act costs are expected to require $120 billion in annual energy system investments through 2040, equivalent to over $1,200 per month per household. NYSERDA’s own Energy Affordability analysis shows that Climate Act compliance adds approximately $594 per month (a 43% increase) for an upstate moderate-income household that fully electrifies.

Recent rate cases approved by the PSC between March 2025 and January 2026 for five major utilities have markedly increased residential electric bills, and as Kris Martin of NY Solar Divide has noted only “a small fraction of Climate Act expenses” have been incurred to date — the bulk will hit ratepayers in the next 5-10 years as onshore and offshore wind, grid-scale solar, and electrification mandates ramp up.

The State’s own Attorney General has acknowledged that achieving the 2030 target is “currently infeasible” and that “New Yorkers will face alarming financial consequences if speed is given preference over sustainability”. DPS staff estimates that Climate Act residential impacts range from 4.6% to 10.3% of 2023 monthly electric bills, and these estimates are widely considered conservative.

The PSC’s existing 6% energy burden target for low-income households lacks any tracking or compliance reporting mechanism. Despite the urgent need for clear affordability metrics, the Hochul Administration and Legislature have not adopted transparent tracking systems or mandatory corrective actions when affordability thresholds are exceeded.

Multiple Independent Sources Confirm the Need for a Hearing

The case for a hearing is supported by multiple independent, authoritative analyses:

  • NYISO: Reliability Needs Assessments, STAR Reports, and Power Trends documents consistently identify declining margins, capacity shortfalls, and transmission dependencies.
  • New York State Comptroller: The July 2024 audit found that PSC and NYSERDA plans “did not comprise all essential components, including assessing risks to meeting goals and projecting costs”.
  • DPS Biennial Review: Concluded that the 70% renewable target by 2030 “will likely not be achieved until 2033” and that a delay “may be unavoidable”.
  • State Energy Plan: Acknowledged that “current renewable deployment trajectories are insufficient to meet statutory targets”.
  • DPS Second Informational Report: Identified four feasibility concerns, including that the 2030 target is “likely unattainable,” offshore wind faces “major obstacles,” transmission remains a “critical bottleneck,” and grid reliability challenges are “mounting”.
  • State Attorney General: Acknowledged on the record that the current implementation schedule creates unacceptable affordability liabilities.

Responding to Opposition Arguments

ACE NY and WE ACT have urged the Commission to reject this petition, suggesting that all progress would stop if a hearing were held. This characterization is inaccurate. PSL 66-p(4) authorizes temporary suspension or modification — not abandonment — of Climate Act obligations. A hearing represents pragmatic management to ensure safe, adequate, and affordable service while the clean energy transition continues. Refusing to invoke the safety valve does not eliminate the underlying reliability and affordability problems; it simply ensures they go unaddressed until a crisis forces emergency action.

The Commission Should Proceed Directly to a Hearing

The evidence presented by the Coalition for Safe and Reliable Energy, the Independent Intervenors, NYISO, the State Comptroller, and the State’s own agencies demonstrates that the statutory criteria for a PSL 66-p(4) hearing have been met. Our filing recommended that rather than further delaying action through an extended review period, the Commission should proceed expeditiously to conduct the hearing that the law contemplates.

At minimum, a hearing should:

  1. Establish clear affordability metrics — Define “safe and adequate electric service” and “significant increase in arrears” with specific, measurable criteria so that the safety valve operates as the Legislature intended.
  2. Evaluate reliability margins — Examine NYISO’s documented capacity shortfalls, transmission deficiencies, and the gap between policy assumptions and physical grid reality.
  3. Assess the technology gap — Determine whether the firm, zero-emission resources assumed by the CLCPA will be available on the timelines required.
  4. Review transmission status — Evaluate whether the termination of Clean Path NY, the winter limitations of CHPE, the withdrawal of the offshore wind PPTN, and federal disruptions collectively impede the ability to provide safe and adequate service.
  5. Require transparent cost reporting — Mandate that DPS and NYSERDA provide comprehensive, auditable cost projections covering all CLCPA implementation costs, not just utility rate case impacts.  NYSERDA should be instructed to develop comprehensive cost projections that reflect the total expense of meeting CLCPA mandates, rather than limiting estimates to individual CLCPA program elements.

On April 17, 2026, we filed a recommendation regarding the stakeholder process.  Our filing recommended that once everyone has had an equal chance to raise their concerns that the Commission categorize and prioritize the technical issues submitted and convene a technical hearing conference that resolves the substantive issues raised in comments.  Resolution of issues is necessary to assure New Yorkers that the PSL 66-P Renewable Energy Program can provide safe, adequate, and affordable electricity.

Conclusion

The Legislature included Section 66-p(4) precisely to address the situation New York now faces: implementation challenges that threaten reliability and affordability as the aggressive timelines and technology requirements of the Climate Act confront real-world constraints. The Commission has both the authority and the obligation to act. I am relatively optimistic that the Commission will call for a hearing, but I am 100% sure that any decisions regarding the need to temporarily delay or modify the Renewable Energy Program obligations will not occur until after the election.

Climate Act Budget Status and Cap-and-Invest Program

This year’s New York budget negotiations include significant changes to the Climate Leadership & Community Protection Act (Climate Act).  One of the contentious issues is implementation of the New York Cap-and-Invest (NYCI) program.  This post addresses a misleading opinion piece published in the Albany Times Union by environmental organizations.

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 650 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. I acknowledge the use of Perplexity AI to generate an outline and draft for sections of this post.

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 an interim reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.

In a recent post I described several initiatives that have led Governor Hochul to suggest that the timeline for the Climate Act electric sector goals needs to be revised. Legislative leaders and Hochul have not yet announced a final climate plan deal.  Reporting as of April 19–21 describes a stalemate with ongoing behind‑closed‑doors talks rather than agreed‑upon bill text.  Environmental groups have rejected the proposed revisions to the Climate Act.

I believe that opinion pieces published in the Albany Times Union have an out-sized impact on negotiations in Albany simply because everyone sees what is published.  I also believe that the Times Union is biased towards the environmentalist side.  This post addresses the Governor Hochul is mispresenting our CLCPA lawsuit (“TU Letter”) piece published this week written by Josh Berman, senior attorney with the Sierra Club’s Environmental Law Program and Eric Walker, energy justice senior policy manager at WE ACT for Environmental Justice.  I do not think that the Times Union will publish a response to  the op-ed that is long enough to rebut what I think is a misleading opinion.

NYCI Lawsuit

The first argument in the TU Letter describes the author’s rationale for the lawsuit.  I will only address the claims associated with NYCI. The letter states:

The governor asserts that only a cap-and-invest program with no checks on cost will satisfy the law and litigants. This is false.

The Preliminary Statement in the litigation Petition filed by the authors clearly states that they wanted to ensure that the emission reduction requirements were achieved. 

Statement 2 states that

Although the climate law sets mandatory limits on New York’s statewide greenhouse gas emissions, it does not specify how the emissions reductions will occur or obligate any polluting entity to reduce emissions. Instead, the Legislature directed the New York State Department of Environmental Conservation (“DEC”) to give the law teeth by issuing regulations that ensure the state achieves its statutory greenhouse gas reduction mandates.

Statement 2 states that

Although the climate law sets mandatory limits on New York’s statewide greenhouse gas emissions, it does not specify how the emissions reductions will occur or obligate any polluting entity to reduce emissions. Instead, the Legislature directed the New York State Department of Environmental Conservation (“DEC”) to give the law teeth by issuing regulations that ensure the state achieves its statutory greenhouse gas reduction mandates.

Statement 10 states that

DEC’s abdication of its statutory duties is unlawful and critically threatens the state’s ability to achieve the emissions reductions requirements of the CLCPA. DEC’s failure to implement the Legislature’s directive is also endangering Petitioners’ members who continue to breathe dirty air, suffer from pollution-related illnesses, and face economic barriers in their efforts to protect themselves and their communities by replacing fossil fuel-burning equipment with clean new technology. The state must not be allowed to continue to violate the law by withholding a climate solution that it has deemed necessary to achieve the greenhouse gas reduction targets of the climate law and that it estimates will prevent many premature deaths and asthma-related emergency room visits each year.

The litigation clearly states that they sued to ensure the state achieves its statutory greenhouse gas reduction mandates. 

The petition also describes the timeline of the regulatory process.  It started in 2023 with the release of draft regulations and public meetings.  Of particular interest was the June 1, 2023 pre-proposal Cap-and-Invest overview session because DEC requested feedback on the Cost Containment Reserve (CCR) program stability mechanism.  As described in the NYCI Second Stage Outreach: Preliminary Analysis Overview Preliminary Analysis on January 26, 2024, the CCR is a price control mechanism.  If the bidding price reaches a preset trigger limit, additional allowances would be released to the market.  That results in lower prices.  However, the CCR is a pool of extra allowances that is only used if the trigger price is exceeded and that means that the cap will be exceeded if used.  I

I always felt that this was an inconsistency that would eventually cause problems.  Proponents of the economy-wide cap-and-invest approach presumed compliance with the Climate Act mandates, but this affordability mechanism would cause non-compliance.  Frankly, I do not think that the litigants understood that this provision was inconsistent with their desire to ensure the state achieves its statutory greenhouse gas reduction mandates. 

As the petition notes everyone understood at the end of 2024 that the regulations were ready and would be released in January 2025.  That did not happen.  The only regulation released was the greenhouse gas emission reporting rule and that was months later.  The cap-and-invest rule regulation was put on hold and on March 31, 2025 the litigants filed the petition demanding that the Department of Environmental Conservation (DEC) issue the draft regulations.

In October 2025, the New York Supreme Court issued a decision ordering the DEC to either issue the regulations or revise the regulations.  DEC appealed the decision, a hearing was held in the last month, but no decision has been made. 

However, this is an election year and the Governor is pushing an affordability agenda.  David Caralfamo described the political theater that preceded the budget deliberations:  “Two days after Governor Hochul’s own budget director stood up at a hearing and all but announced that CLCPA rollbacks were coming, a conveniently alarming memo from NYSERDA — dated the very same day — found its way into the press.”  The NYSERDA memo was allegedly a new analysis, but I believe that these numbers have been available since early 2024 and were the driver for the recommendation to include the CCR mechanism.  That is the key.  These are the cost estimates for NYCI without the CCR which will necessarily increase the costs but is also the only way to ensure compliance.

NYCI Affordability

The TU Letter addresses Hochul’s affordability arguments:

Hochul appears to have forgotten that many of our groups had expressed support for a program that controlled for cost and would have lowered energy bills by over $1,000 a year for families making under $200,000. That’s not our number; it’s based on two independent research reports. There is no reason such a program cannot move forward now.

I addressed those “independent research reports” when they came out.  I believe they are referring to a January 2025 report titled New York’s Affordable Energy Future and a January 2026 report titled Investments for New York’s Future.  In my opinion described research reports as “independent” when they were sponsored by the authors’ organizations is misrepresentation.  The 2025 report was funded in part by WE ACT for Environmental Justice and the 2026 report was funded by EDF.  Moreover, there was no independent peer review of the reports so they are not unbiased independent analyses.

I raised a number of concerns with the 2025 analysis by Switchbox. I found that while the report does acknowledge that cap-and-invest alone won’t achieve the 2050 goals (which is honest), it doesn’t adequately address a critical problem: the proposed investments cannot achieve the required annual emission reduction rates to meet 2030 targets. I showed that under Scenario C (lower revenue), the program falls short of the 2030 goal entirely, and neither scenario achieves the 2050 target.

The bigger problem, and one that exemplifies the authors’ presumptions about NYCI, is that fundamental feasibility problems are not addressed.  The authors assume compliance as a matter of faith and ignore reality. There are no add-on controls that achieve zero emissions for any sector. The only strategy is to convert to different energy sources, which takes time and is partially outside the control of compliance entities.  The political timeline of the Climate Act has never been evaluated for feasibility and the record since 2019 proves that it is impossible. 

Another feasibility aspect is the cost-effectiveness of controls.  I showed that using New York’s experience with Regional Greenhouse Gas Initiative proceeds that the proposed spending allocations will not provide meaningful reductions.  Furthermore, in the book Making Climate Policy Work, the authors argue that the level of expenditures needed to implement the net-zero transition vastly exceeds the “funds that can be readily appropriated from market mechanisms”. 

The TU Letter and this report don’t acknowledge what happens if the program fails to meet emission reduction targets. Organizations don’t voluntarily violate compliance requirements, and the penalties are severe. If the schedule or technologies aren’t feasible, the only remaining option is to simply stop selling fuel or generating power.  This could create an artificial energy shortage with serious consequences as the only way to comply with the regulations.

I concluded that while Switchbox is more transparent than some analyses in acknowledging price ceiling limitations, it remains advocacy research designed to support a predetermined conclusion. It overstates benefits while downplaying the fundamental feasibility challenges of meeting Climate Act targets, and it doesn’t adequately address whether the proposed investments can actually deliver the emission reductions needed—especially by 2030.

I also reviewed the2026 EDF Investments for New York’s Future report and found that it was advocacy research, not independent analysis. I showed that:

  • Greenline Insights explicitly states they “develop compelling research questions and build the right mix of tools to answer them” – which I interpret as getting the results clients want
  • EDF has been actively lobbying for cap-and-invest since 2023 and has a vested interest in the program’s success
  • They strategically rebranded the program as the “Clean Air Initiative” (CAI) instead of using the official “New York Cap-and-Invest” (NYCI) terminology – a deliberate messaging strategy

I also explained that the methodology has serious flaws:

  • The analysis doesn’t account for opportunity costs—what else could be done with those resources
  • It assumes idle economic resources, which is unrealistic in a full employment economy
  • It measures “gross economic activity” without subtracting displaced economic activity elsewhere
  • It’s missing “the Missing Peter Problem”—robbing Peter (existing economy) to pay Paul (clean energy sector) while claiming total growth

I also showed that the economic projections are questionable and concluded that the report is simply a lobbying presentation that was commissioned by EDF. The benefits are overstated, the costs are minimized, if not ignored, and the methodology is sketchy.

Discussion

The TU Letter was published without qualification at a critical time in the Climate Act revision negotiations by the organizations that sued the DEC to release the NYCI regulations.  It is ironic that the unintended consequence of their successful lawsuit turned into political cover for the Governor to argue that NYCI would be unaffordable.  However, the TU Letter attempt to resolve the perverse result of their actions is flawed and their arguments that the Climate Act does not need to be changed are without merit.

Their lawsuit explicitly demanded NYCI regulations that “ensure the state achieves its statutory greenhouse gas reduction mandates”.  The authors of the TU Letter disagree with the presumption that “only a cap-and-invest program with no checks on cost” will satisfy the law and their litigation.  However, I showed that the CCR checks on cost mechanism in the pre-proposal documents was incompatible with ensuring compliance with the reduction mandates. 

The two reports referenced in the TU Letter do not provide credible affordability mechanisms.  Moreover, the reports do not acknowledge that the CCR mechanism is necessary to keep the costs palatable.  The NYSERDA memo with the high costs that Hochul cites as the reason that revisions to the rule are necessary simply shows costs for NYCI without the CCR mechanism.

Conclusion

This opinion piece offers no credible reasons why New York State should not be considering revisions to the Climate Act but got published in Albany while negotiations are underway.   I plan to submit a letter to the editor of the Times Union summarizing this post.  Unfortunately, a word limited summary could not incorporate the explanations why this letter was flawed even if it was accepted.  This is a perfect example of the BS Asymmetry Principle: Alberto Brandolini: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.”

PSL 66-P Safety Valve Advocacy Comments  

New York Public Service Law (PSL) § 66-p establishes a renewable energy program for the Climate Act and includes a safety valve provision.  In posts published this week I provided a status update that provides extensive background information and a description of the Independent Intervenor filing describing how the hearing to address the safety valve should be handled.  This post explains how the Independent Intervenors think the Public Service Commission should respond to the hundreds of identical comments prompted by advocacy organizations.

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 nearly 650 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

New York Public Service Law (PSL) § 66-p establishes a renewable energy program for the Climate Act.  It  provides that 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”.  This safety valve was included because even the lawmakers realized that it may not be possible to transition the electric system to “zero-emissions” by relying on renewable energy.  New York State never followed up with a feasibility study proving that it could be done, never pointed to another jurisdiction that implemented such a system successfully, and has not provided clear and comprehensive cost estimates. 

I have joined Richard Ellenbogen, Constantine Kontogiannis, and Francis Menton (“Independent Intervenors”) submitting comments in a few Public Service Commission proceedings.  I am a retired utility meteorologist, with extensive electric energy and environmental regulatory analysis experience.   Ellenbogen is an electrical engineer who is President of Allied Converters where he has pioneered how “green” manufacturing can work.  Constantine Kontogiannis is an engineer who has decades of experience providing energy consulting services.  Menton is a retired lawyer and now writes articles on his Manhattan Contrarian blog that analyze New York’s energy transition.  We have no financial interest in the Climate Act, have received no funding from any outside interests, and have invested thousands of hours of our time in efforts to explain why physics, engineering and economics prevent a Renewable Energy Program that powers a safe, adequate, and affordable electric system in New York State.

The Problem

As I explained in my previous post, the Independent Intervenors filed a petition on April 17, 2026 recommending that the stakeholder process for the PSL 66-P hearing should differ from the process used in the Scoping Plan and the Energy Plan.  In those proceedings the response to comments was handled by the New York State Energy Research & Development Authority (NYSERDA).  NYSERDA did not use the stakeholder process as an opportunity to improve those plans.  Instead, they went through the motions of stakeholder interaction and only provided a list of comments without any responses.  I was particularly disappointed that the NYSERDA general characterization of comments was along the lines of “most of the comments agreed” with the draft documents. As a result, green energy advocacy organizations were encouraged to organize advocacy campaigns to swamp the public comments with comments supporting their policy preferences.

To have a stakeholder process that informs the PSC decision on the PSL 66-P hearing we stated that the Commission should order the following process steps:

  1. A notice opening an initial comment period that gives all stakeholders a meaningful opportunity to identify issues relevant to the statutory findings required by PSL § 66-p(4).
  2. At the conclusion of the comment period, Commission Staff should prepare an issue list that categorizes and prioritizes the comments received into major technical subjects, including reliability, resource adequacy, transmission readiness, contract and compliance obligations, arrears and disconnections, and definitions of safe, adequate, and affordable service.
  3. The documentation should identify opposing positions on each material issue so that participants and Staff can see where there is consensus, where there is factual disagreement, and where methodological disagreements require focused review.
  4. The schedule must provide sufficient time for written comments, reply comments, and preparation of supporting technical materials so that the record is not limited to conclusory assertions.
  5. One or more technical conferences should be convened at which both sides of disputed issues are presented in a structured manner, with sufficient time for questions from Staff and stakeholders.
  6. A dedicated conference session addressing the meaning of “safe,” “adequate,” and “affordable” service should also be included, because those terms are central to the Commission’s statutory findings and need common definitions before competing analyses can be compared.
  7. A post-conference report prepared by Staff that summarizes the issues raised, the competing positions presented, the areas of agreement and disagreement, and explains how those discussions inform the Commission’s determination under PSL § 66-p(4).
  8. This information would enable the Commission to determine if it is necessary to temporarily suspend or modify obligations under the Renewable Energy Program.

This post explains how I think the proposed stakeholder process should handle hundreds of similar advocacy comments expressing policy preferences without technical or economic support.

Recommended Response to From Letter Campaign

The Independent Intervenors plan to submit our comments on the petition on May 1. Our filing addresses a comment submitted by hundreds that express policy preferences without technical or economic support. The comment lacks the analytical detail needed for meaningful regulatory consideration.  We are not suggesting that these comments lack value.  In our April 17 filing, we recommended that once everyone has had an equal chance to raise their concerns that the Commission categorize and prioritize the technical issues submitted and convene a technical hearing conference that resolves the substantive issues raised in comments.  This exhibit is an example of issues that need to be addressed in this manner.

As an example of our recommended comment process consider 100 public comments number 1151 posted on 4/23/26 through number 1050 posted on 4/3/26 at Case Number 22-M-0149.  The first 50 characters of more than half these comments were identical, which clearly indicates a campaign to submit comments.  Comment number 1151 posted on 4/23/26 by Melanie Acampora met these criteria.  It states:

Dear PSC Commissioners, I urge the Public Service Commission (PSC) to reject the petition filed by the Coalition for Safe and Reliable Energy, which would improve neither safety nor reliability, and would instead raise utility costs by deepening New York’s reliance on expensive and volatile fossil fuels. With the cost of oil and gas skyrocketing as a result of the U.S. war on Iran, this is not the time for New York to be considering rollbacks to our renewable energy targets. I urge the PSC to remain committed to the goals of the Climate Leadership and Community Protection Act (CLCPA) and the Clean Energy Standard. Temporarily modifying or suspending the clean energy mandates in the CLCPA will not benefit New Yorkers and is entirely unnecessary to maintain a reliable electric grid. In fact, any further investments in the fossil fuel economy will have a negative financial impact on New Yorkers. Costs of energy in New York are driven by the price of fossil fuels, which are highly volatile and affected by events outside of the control of New York, such as the invasion of the Ukraine by Russia and the U.S. war on Iran. Sticking to fossil fuels means unpredictable, unaffordable bills for New Yorkers. Renewable energy – which requires no fuel – offers predictable costs which makes families less vulnerable to energy price shocks. Renewable energy is a long-term cost-saving strategy that will promote affordability and protect New York utility customers from the impacts of volatile fossil fuel prices. I urge the PSC to reject the unsupported request to hold a hearing to consider temporarily modifying or suspending the renewable energy and zero-emission energy goals. Sincerely,

This comment appears many other times since the first comment addressing the petition (Comment number 33) appeared in the record on 3/9/26 in Case Number 22-M-0149.  It also appears many more times in the public comments for Case Number 15-E-0302.  The Independent Intervenors believe that the comment incorrectly characterizes the petition as an attempt to “roll back” or “suspend” the CLCPA mandates and asserts, without record support, that a §66‑p(4) hearing is “unsupported” and “entirely unnecessary.”  In the following sections we describe our responses to this comment as an example of responses to a disputed issue that should be resolved in a hearing.

Recommended Response

The form letter argues that the petition filed by the Coalition for Safe and Reliable Energy should be rejected because it “would improve neither safety nor reliability and would instead raise utility costs by deepening New York’s reliance on expensive and volatile fossil fuels.”  However, it does not provide any support for those claims.

It argues that “Temporarily modifying or suspending the clean energy mandates in the CLCPA will not benefit New Yorkers and is entirely unnecessary to maintain a reliable electric grid.”  It is important to note that the hearing will not necessarily temporarily modify or suspend the Renewable Energy Program, but it will address feasibility.  The fact is that the State has never done a feasibility analysis to determine if Renewable Energy Programs are a viable path to a zero-emissions electric system.   If the hearing finds that safe and adequate energy is not impeded by the Renewable Energy Program, then we can continue the current path reassured that it is feasible.  However, the Independent Intervenors cannot help but think that the concerted effort to flood the docket with comments that all say do not even consider the hearing is a sign that even devoted proponents have concerns.

The comment goes on to argue that fossil fuels are the cause of the high prices and that renewable energy is a long-term cost saving strategy.  The Independent Intervenors believe that this argument needs to be addressed at a hearing.  We believe that cheap intermittent energy does not lead to a cheap energy system.  The claims that renewable energy is cheaper are based on an incomplete analysis that tells you what it costs to produce electricity under ideal conditions, but it leaves out what it takes to run a system that has to perform under real ones. Accounting for reliability, timing, infrastructure, and risk, the picture changes and renewable costs are not cheaper.

The commenters deserve to have their arguments addressed.  As detailed below, the Independent Intervenors believe that those arguments are flawed but they must be addressed.  A PSL 66-P hearing is the appropriate venue to resolve the issues raised.

The Petition Properly Invokes PSL §66‑p(4)

The Coalition’s petition expressly requests that the Commission “hold a hearing pursuant to Public Service Law §66‑p(4) to evaluate whether to temporarily suspend or modify the obligations under the Renewable Energy Program established as part of the Climate Leadership and Community Protection Act.”

Thus, a hearing is the statutorily prescribed mechanism for testing whether the safety‑valve criteria are satisfied; it is not an extraordinary or anti‑CLCPA measure but part of the CLCPA implementation framework itself. The adverse comment’s request to deny a hearing disregards this structure and effectively ignores §66‑p(4) in the statute. Note however, that the hearing must resolve issues.

Reliability and Affordability Triggers Have Been Met

Multiple filings in Case 22‑M‑0149, as well as the Coalition petition, present credible evidence that the current implementation of the Renewable Energy Program may: (a) impede safe and adequate service, and (b) coincide with a significant increase in arrears, thereby implicating both primary §66‑p(4) triggers. The recommended technical conference would evaluate this evidence.

The Commission itself has acknowledged in Case 22‑M‑0149 that PSL §66‑p(4) includes safety‑valve provisions and that the customers‑in‑arrears condition has been specifically raised as a trigger. The adverse comment does not grapple with any of this record; it simply asserts that a hearing is “unsupported” and “unnecessary,” which is inadequate given the clear statutory language and evidence already before the Commission.

Mischaracterization of the Petition and of Fossil Fuel Risk

The form comment argues that granting the petition and potentially modifying obligations would “deepen New York’s reliance on expensive and volatile fossil fuels” and that “sticking to fossil fuels means unpredictable, unaffordable bills for New Yorkers.”

If this issue were addressed as proposed we believe that it would show the Coalition petition does not seek to abandon the CLCPA’s targets; it seeks a recalibration of obligations and timelines, if warranted by the evidence, so that the Renewable Energy Program is compatible with reliable and affordable service. A transition that outpaces feasible infrastructure development, transmission build‑out, and proven firm zero‑emission resources can actually increase reliance on emergency fossil generation and expensive backstop measures, thereby exacerbating the very fuel‑price and affordability risks the comment highlights.

Granting the Hearing is Consistent with, Not Contrary to, the CLCPA

The Independent Intervenors generally support the CLCPA’s broad decarbonization objectives, but durable climate policy must be aligned with reliability and affordability constraints. A PSL §66‑p(4) hearing is the means the Legislature chose to ensure that alignment. If there was a hearing these concerns could be addressed.

Conclusion

New York’s climate and energy policy choices are too consequential to ignore the legal mandate to confirm that the Renewable Energy Program can provide safe, adequate, and affordable electricity.  The Independent Intervenors believe that genuine stakeholder processes require open discussion of trade‑offs, clear documentation of how comments are handled, and a willingness to adjust course when the evidence points in a different direction.  In my opinion, green energy advocacy organizations are trying to game the system by submitting an overwhelming number of comments.  While they deserve to have their opinions heard, the system should transparently address their concerns.  In the example shown, the arguments do not warrant rejecting the petition or make a convincing argument that the PSL 66-P Renewable Energy Program obligations should not be temporarily suspended or modified.

One Thousand Posts

I started posting on this blog on January 11, 2017 so it took a few months over nine years to produce 1,000 posts.  This is a similar retrospective to my 500th post published on January 28, 2023.

The goal of my blog is to describe environmental issues from a pragmatic viewpoint.  Pragmatic environmentalism is all about balancing the risks and benefits of both sides of environmental issues.  It is not possible to grow and maintain our society without environmental impacts.  Public perception is too often driven by scary one-sided sound bites that describe all impacts as existential threats.  Unfortunately, those stories must be rebutted by getting into details.  I have tried to show the complicated “other” side of environmental issues that gets overlooked during policy discussions.

My background as a scientist and my earlier responsibilities to provide technical comments on new or revised regulations means that I have the experience to explain the nuances of environmental policy.  However, I tend to get bogged down in technical details that are, too be kind, wonky.  To address that I publish a fortnightly summary of posts where I try to simply describe recent posts.  If you want to get that summary, use the contact form.

There is another option.  In May 2024 I started a Substack blog.  I generally only use that site to publish the summary of posts on this blog.  I have been asked why I don’t switch to Substack.  After publishing a thousand posts I have the routine down for WordPress and it does not whine when my posts run long.  I also get storage for media files, spreadsheets and reports which I use regularly.  I have used that feature to provide a link to reports that have not shown up on the web elsewhere.

Topics

Although my posts cover a wide range of topics that interest me there are two primary topics covered.  At the time of my 300th post, the Climate Leadership and Community Protection Act implementation process accounted for 109 articles.  When I hit 500 articles 169 of the 200 latest published articles addressed the Climate Act for a total of 278 out of the 500 articles. Now there have been 651 articles about the Climate Act.  This obsession is caused because I truly believe that the Climate Act “solution” will be far worse than the impacts of the problem they are trying to address and that does not consider the enormous costs.  My other main topic is the Regional Greenhouse Gas Initiative (RGGI).  This greenhouse gas control program is frequently described as a success but I have not been able to resist pointing out the flaws in that belief.

In the past year I have started using Perplexity AI to research topics and provide an outline for documents. It is very useful for me as a search engine if I cannot recall when I wrote about a specific topic.   It is an amazing resource, but I have found that I cannot rely on its references, so I have to verify all the references and frequently replace what was recommended with something more appropriate. 

Consider this example Perplexity query: What are the main topics covered in the blog?  It provided the following response with my corrections and some changes.

The blog has focused on a consistent set of energy‑ and climate‑policy themes, with an increasing emphasis on New York’s Climate Act after 2019.

Core long‑running themes (Note that this query searched the website and listed topics that have been present since the beginning but does not try to rank the themes by the number of posts on each theme.)  I have modified the references from the query response to point to specific pages.

  • Pragmatic environmentalist principles – Foundational posts laying out principles such as balancing risks and benefits, finite resources (“we can do almost anything but not everything”), and the “iron law of climate.”
  • Air quality issues – Pieces drawing on air pollution and meteorology experience, including regulatory analysis and discussion of real‑world air quality outcomes.
  • Regional Greenhouse Gas Initiative (RGGI) – I have been involved in the RGGI program process since it was first proposed prior to 2008.  Dealing with the RGGI regulatory and political landscapes is challenging enough that affected entities seldom see value in speaking out about fundamental issues associated with the program. 
  • New York State Energy Plan – I spent a  lot of time evaluating the 2025 State Energy Plan
  • New York energy policy – Ongoing coverage of NYISO, resource mix, reliability, and how state policy interacts with the grid and markets.
  • New York environmental policy – Broader state environmental initiatives beyond energy (regulatory, legislative, and planning actions) viewed through a pragmatic lens.

Climate Act and decarbonization focus

  • Climate Leadership and Community Protection Act (Climate Act) – Since the law’s passage in 2019, this has been the dominant topic: targets, implementation plans, schedule changes, and feasibility concerns.
  • Climate Act implementation pages – Dedicated pages summarize “many articles on various aspects of the Climate Act,” including high‑level guides and deeper technical material considered too detailed for general audiences.  (If you are interested in a specific topic I recommend using an AI search engine to find what you want because my documentation leaves a lot to be desired.)
  • Cap‑and‑invest and carbon pricing – Multiple articles on New York’s cap‑and‑invest proposal and comparisons to other emissions trading programs, especially RGGI.

Technology and infrastructure topics

  • Electric sector and “zero‑emissions” resources – Repeated analysis of the 70 percent renewables by 2030 and 2040 zero‑emissions electricity targets, including reliability, resource adequacy, and what counts as “zero‑emissions.”
  • Wind, solar, and energy storage impacts – Posts under “Zero‑emissions Environmental Impacts” look at land use, wildlife, materials, and other environmental consequences of large‑scale wind, solar, and batteries.
  • Electric vehicles – A dedicated section notes “many issues associated with widespread implementation of electric vehicles,” including infrastructure, grid impacts, and cost.

Cost, policy design, and tradeoffs

  • Green energy costs – The blog links to and discusses estimates of green‑energy costs in other jurisdictions and how those lessons apply to New York.
  • Affordability and iron‑law themes – Posts frequently emphasize that willingness to pay for climate objectives has limits and that aggressive targets without feasibility studies pose affordability and equity risks.
  • Policy “doing more harm than good” – Principles posts (e.g., Ridley’s paradox) and later climate‑policy analyses highlight cases where policies may impose real economic or environmental costs with limited climate benefits.

How the content is organized

  • The Menu and dedicated Climate Act summary pages serve as hubs that group posts by topic (Climate Act, electric vehicles, green‑energy costs, RGGI, air quality, New York energy and environmental policy, and the principles series).
  • Substack summary updates (since about 2024) provide fortnightly or periodic digests of recent posts, reiterating that the blog has been “writing about the pragmatic balance of the risks and benefits of environmental initiatives in New York since 2017 with a recent emphasis on the Climate Act.”

Website organization is definitely a weak point. You know it is bad when the blog author resorts to searching with Perplexity AI because it is easier than trying to track something down on the blog.

Impact

One question I have asked myself is whether my obsession with this blog has been a success and to me success is having people read the blog.  According to the WordPress statistics, the views of the blog have been steadily increasing and there have been over 79,927 visitors.  In context, popular blogs get this many views and visitors in a week and the most popular can match my totals on a good day.

Table 1: Overall Statistics

So where are the people coming from to find the blog.  Very early on Judith Curry included this blog on her blogroll and a large percentage of the visitors visited since then.  Tom Shepstone started reposting my articles at his Natural Gas Now blog starting 12/28/18 and continues to do so on Energy Security and Freedom.  My thanks to both for bringing visitors.

I have also done blog posts for Judith’s site and Watts Up With That and there usually is a flurry of visitors after those posts.  The comments on my work at those sites dwarf the responses on the blog itself and I am sure the total views were larger too.

Finally, it is a source of amusement to me that people from all over the world have visited the site.  Someone has visited the site from every country that is highlighted in the following map since the blog started.

Conclusion

In conclusion this has been a rewarding experience for me.  I devoutly believe that it is important to keep busy during retirement and this blog keeps me busy.  Just when I get discouraged and think about quitting, some insane proposal or article comes up that provides more than enough incentive to keep writing.  My thanks to everyone who has read my work.