Author: rogercaiazza

This post documents the oral comments I submitted at the virtual Draft State Energy Plan Public Hearing on September 13, 2025.  The New York State Energy Research & Development Authority (NYSERDA) only allocated two minutes per person, so this article documents the statements that I made.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 575 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. 

Net-Zero Aspirations

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.

According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.”  The New York State Energy Planning Board is a “multi-agency entity established under Article 6 of the Energy Law, playing a core role in the State Energy Plan process”. Among its responsibilities is adopting the State Energy Plan: The Board has the authority to adopt the comprehensive statewide energy plan, and the stakeholder process should be an important component of that responsibility.

The driving factor for the updated Energy Plan is net-zero ambitions of the Climate Act.  This is the first update of the Energy Plan since the Climate Act was passed in 2019.  I have provided more background information and a list of previous articles on my Energy Plan page.  Because of the importance of this process on the future energy system of New York I am following it closely and will be submitting oral and written comments. 

Comments

This section documents the comments I made on September 13, 2025.  I used bullets to differentiate my comments from the explanations. 

• My name is Roger Caiazza.  Documentation for my comments will be posted on my Pragmatic Environmentalist of NY blog

As noted in the introduction I am convinced that implementation of the New York Climate Act will do more harm than good.

• I have not seen any indication that NYSERDA is going to seriously consider stakeholder input, so I have no plans to submit written comments on all the problems I have seen in the draft.  Air quality modeling is a particular expertise of mine so I have looked at the Public Health Impact Chapter air quality modeling analysis.

I submitted comments at the first virtual meeting on August 19 that argued that there had to be assurances that the process will respond to stakeholder input if the process is to be credible.  There hasn’t been any suggestion that the process will respond to stakeholder input.  Moreover, despite assurances that recordings of the hearings would be posted, links to the first hearing were not posted until September 12.

I have been employed as an air pollution meteorologist since 1976.  According to Perplexity AI that means I am a “specialized atmospheric scientist who applies meteorological principles and techniques to understand, predict, and mitigate air pollution impacts.”  To predict air pollution impacts I have used several models that use source characteristics, emission rates, and meteorological conditions to estimate pollution concentrations.

• The modeling methodology is new and, in my opinion, flawed because it over-simplifies inhalable particulate air quality source-receptor relationships.  At the same time, it applies the model to an extraordinarily large emission inventory. I will submit written comments addressing those concerns.

I am still working on detailed comments about these flaws.  In brief, they use a simplified approach that cuts down on computer time but I think they have oversimplified the source to receptor metrics.  For example, one of the simplifications is to limit the meteorological inputs to four wind directions.  Given that wind direction is enormously impactful on pollution impacts I think that is unacceptable.  A minimum of 16 wind directions are necessary to represent impacts satisfactorily.

• To establish credibility the modeling must prove the methodology is accurate.  The appendix to the health impact chapter purports to validate the model for this reason.  An air quality model verification analysis uses historical meteorology and emissions input to predict air quality concentrations and compares those results with observed concentrations over the same time period.

While working for a consulting firm I did extensive air quality model evaluation work.  The process is not complicated.  It is necessary to compare model results against observed concentrations.  Obviously, the observations need to be for the same time period as the predictions.

• The draft does not do that.  On page A-13 the draft states: “Because model projections were only available starting with year 2025, these results were compared against multiple years of observational data”. 

When I first read that statement, I did a double take and read it again. I could not believe it.  It is inconceivable that a reputable analysis could claim to evaluate model performance by comparing observed historical concentrations against future predicted concentrations.

• That is just plain wrong.  The verification statistics presented are worthless.  It means that the health benefit claims are unsupportable.

The biggest problem describing this situation is finding the right terms to describe the enormity of the error without using profanity. 

Discussion 

The Public Health Impacts fact sheet claims the following health effect benefits. 

All these calculations are based on air quality impacts estimated using a new methodology that has not been validated.  I have many other questions about this methodology that I need to research before I can comment.  I am not denying that there will be benefits but the magnitude of the claims appears to be exaggerated.  My first impression is that because the range of observed PM2.5 concentrations is greater than the projected emission reductions then these projections are suspect.

There are troubling implications associated with this finding that a critical component in the health impact analysis is incorrect.  It does not speak well for the scientific integrity of the work products.  I presumed that NYSERDA hired experts to review the draft before it was released but the enormity of this error indicates that the review process failed. 

Also consider that in the Scoping Plan analysis NYSERDA estimates of the benefits were deliberately misleading.   The Draft Energy Plan is similarly hiding the true costs needed to meet the Climate Act targets.  In both cases the primary trick was to use an inappropriate future baseline scenario.  I have no doubt that the primary charge given to NYSERDA was to make the costs and benefits look as good as possible.  It appears those marching orders override scientific principles.

The Climate Act includes requirements to address disadvantaged community impacts.  To respond to that requirement NYSERDA needed a new model so they developed the modeling approach used here.  I think it is likely that the pressure to produce favorable benefits at the resolution necessary was greater than the pressure to do so following scientific principles.  They probably assumed that no reader would sift through the documentation and pick up on the fact that their modeling validation study was bogus.  Of course, the fact that NYSERDA does not respond to comments means that they will just ignore the flaw that I documented here.

Conclusion

When I described this to one of my friends, he remarked that this is proof that science and NYSERDA cannot be used in the same science.  I agree completely.

Stay tuned for a follow up post on this component of the Draft Energy Plan.

I believe that the New York Climate Leadership & Community Protection Act (Climate Act) has always been about politics.  It was enacted to cater to specific constituencies and implementation will only change if politicians realize that the majority of New Yorkers have limited appetite for the effects on affordability and personal choice and modify the Climate Act.  This post presents an opinion piece by Assemblyman Phil Palmesano (R,C-Corning) who argues that New York energy policies must ensure energy affordability, reliability, feasibility, safety, choice, and fuel diversity.

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 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. 

Net-Zero Aspirations

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.

In July the Draft Energy Plan was released for public comments.  According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.”  The driving factor for the updated Energy Plan is net-zero ambitions of the Climate Act.  I have provided more background information and a list of my previous articles on my Energy Plan page. 

The opinion piece released by Palmesano is in response to the Draft Energy Plan public stakeholder process. I present it in its entirety below.  Assemblyman Palmesano represents the 132nd District, which includes Schuyler County, Yates County and Parts of Chemung County, Seneca County and Steuben County. He is the ranking member on the Assembly Energy Committee, a role he has held since 2013. For more information about Assemblyman Palmesano, please follow him on Facebook.

New York Leaders Need to Listen to the People

As you may have seen recently, I have embarked on a statewide energy tour, joining with my Assembly and Senate Republican colleagues at all locations across the state where the New York State Energy Research and Development Authority (NYSERDA) is holding public hearings on the state’s proposed energy plan. The goal of this tour is simple: to make the public aware that Gov. Hochul and Democrats in the Legislature are pushing policies that will continue to increase utility rates for New York families and businesses. The fact of the matter is the policies they continue to advance are designed to dismantle the affordable and reliable natural gas infrastructure, supply and delivery system. This, despite the fact that 60% of New Yorkers heat their homes with natural gas, and 40% of our generation comes from natural gas. Their policies are designed to take away consumer choice on how you heat your home, cook your food, power your buildings and the vehicle you drive. Their policies will jeopardize the reliability of the grid, leading to dangerous and deadly blackouts and will continue our nation-leading outmigration crisis of more families, farmers, small businesses and manufacturers leaving our state. The governor and Democrats in Albany are on mission to fully electrify our state’s energy grid with no concern for energy affordability, reliability, feasibility, safety, energy choice or fuel diversity.x`x`

NYSERDA also needs to expand its hearings to include Central New York, the North Country and the Southern Tier. Currently, in-person hearings are only being held in Buffalo, Rochester, Albany, the Hudson Valley, New York City and Long Island, along with three virtual hearings. It is completely unacceptable and unfair that the citizens and businesses of Central New York, the North Country and the Southern Tier do not get an opportunity to voice their input and concerns at an in-person hearing. Therefore, we have called on NYSERDA to schedule in-person public hearings at these three locations,  as well as grant an extension of the public comment period by 90 additional days until January 4, 2026, so a more thorough process can be achieved. Given the far-reaching impact of our state’s draft energy plan, coupled with the radical energy/climate policies being advanced in Albany, it is critically important more time be granted for New York families and businesses to weigh in on our state’s energy future.

The state’s draft energy plan says we need an “all of the above” approach to our energy plan, including the use of natural gas, nuclear and fuel diversity. Unfortunately, the policies being pushed and advanced in Albany don’t match the words. Gov. Hochul and the Albany Democrat-controlled Legislature continue to side with far-left Green New Deal advocates instead of siding with everyday New Yorkers. Families and businesses across the state have already seen their energy bills sky-rocket while utilities continue to call for even higher rates because of the Democrats’ green energy mandates, with more to come. In fact, in July of 2023, the PSC approved $43B in future ratepayer increases to pay for green energy mandates. The comptroller and others have estimated these green energy mandates will cost more than a quarter-of-a-trillion dollars. 

Some of these costly policies include the following. First, you have the CLCPA (New York Green New Deal), which requires net-zero generation by 2040 regardless of the costs, feasibility or how it jeopardizes energy reliability for families and businesses. In addition, the All- Electric Buildings Act will deny new home construction as of January 2026 the ability to use natural gas or propane and be fully electrified. Then there is the mother of all unfunded mandates, the Electric School Bus Mandate, which is as much as three times more expensive than a near-zero emission-free diesel school bus, which is estimated by the Empire Center to increase replacement costs by as much as $15 billion for school property taxpayers, not to mention the billions of dollars in charging infrastructure and energy grid upgrades. New York is requiring school districts to convert their entire bus fleets to electric by 2035, a full five years before the state is required to convert its fleet. In what world does this make any sense? Why should school districts be the guinea pig for this social experiment? There is Cap and Invest (or Carbon         Tax), which is estimated to increase gas prices at the pump by 62 cents per gallon and natural gas home heating by 80%, according to former DEC Commissioner Basil Seggos. The new electric vehicle purchase requirements, including the Advanced Clean Truck Rule and Advanced Clean Car II rule that mandate electric vehicle and truck purchases regardless of the lack of infrastructure in place, range issues, costs or preferred choice of New Yorkers, just to name a few. In addition, for perspective, the residential electricity rate for New Yorkers in 2019 was 17 cents/kw hr. Today, it is 25 cents/kw hr. or 40% higher than the national average. This is completely unsustainable for New York families and businesses.

To make matters even worse, this plan will barely impact global emissions. New York is already one of the cleanest energy producers in the world; in fact, we contribute just 0.4% of global emissions while China contributes 30%, has 1,000 coal plants and is building more every week. We could literally cut our emissions to zero and have no effect on worldwide global emissions. All this shows that Gov. Hochul is more worried about looking good to her far-left base ahead of next year’s gubernatorial election rather than doing the right thing to advance policies that actually protect ratepayers while ensuring an energy plan that is affordable, reliable, feasible, safe and protects fuel diversity and energy choice. That is what New Yorkers want. 

In fact, there was a poll this past summer where 71% of New Yorkers strongly indicated they did NOT want a ban on natural gas, including 76% of independents. In addition, 66% of New Yorkers indicated they want a balance between renewable energy resources and natural gas, including 74% of Democrats. The decision is clear. New Yorkers want energy choice and the use of natural gas to cook and heat their homes.

It’s long past time for Gov. Hochul and Democrats in Albany to finally listen to New York families and businesses when it comes to our state’s energy plan and policies instead of virtue signaling for votes.

Conclusion

One politician gets it.  I do not know what it will take for enough politicians to accept the inevitable that the Climate Act will adversely affect affordability, reliability, and personal choice for no tangible benefits.  At some point the perceived political benefit of supporting the Climate Act will become an inescapable liability.  To achieve this goal New Yorkers need to know what is happening and then speak up.  Palmesano’s op-ed is a good contribution to that goal.

On April 28, 2025, a problem at a photovoltaic plant in Spain triggered a blackout over the Iberian Peninsula.  I believe that this event should be considered in the New York Draft State Energy Plan.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 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

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  The Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda” was based on an Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA). 

The Draft State Energy Plan is being updated for the first time since the Climate Act was promulgated. According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.”  I have provided more background information and a list of previous articles on my Energy Plan page.  Because of the importance of this process on the future energy system of New York I am following it closely and have been developing comments. 

Blackout

The authors of the Climate Act had a very superficial knowledge of the electric system.  The presumption in the academic energy studies that guided the Climate Act is that generation and load are sufficient aspects of the electric system for projecting electric system changes.  They believe that if there is enough generation, no matter the source or where it is located, to balance the load then the system will work.  Meredith Angiwn authored an entire book Shorting the Grid – The Hidden Fragility of Our Electric Grid  devoted to the unacknowledged difficulties associated with wind, solar, and energy storage resources shortcomings related to maintaining voltage and overall system reliability not considered in the Climate Act.  The Spanish blackout should be a wakeup call to New York politicians that the technical experts at the New York Independent System Operator and New York State Reliability Council should be fully integrated into the Energy Plan process.  They are trying to resolve the myriad technical issues associated with integrating wind, solar, and energy storage into the grid and I am uncomfortable that the NYSERDA Draft Energy Plan addresses all their concerns.

Two recent posts at the Watt-Logic blog describe the blackout this spring on the Iberian peninsula that affected Spain, Portugal, and France that I think needs to be considered in the Draft Energy Plan.  The first article looked at the physics of power grids and the general behavior of both synchronous generation (gas, hydro and nuclear) and inverter-based generation (wind, solar and batteries).   Watt-Logic gives an overview explanation of the “importance of voltage control and reactive power” that were the root cause of the Spanish blackout.  In short, the existing system depends upon synchronous generators that convert mechanical energy (spinning turbines) into electrical energy, producing alternating current  that matches the frequency of the electric grid.  These generators inherently provide important electric grid functions that are difficult to replicate with inverter-based resources like wind, solar, and energy storage.  The problem is that not only do inverter-based resources not perform many of these functions, but they can also de-stabilize the grid in certain, poorly understood circumstances.

The second post addressed what we know about the Iberian blackout. Watt-Logic explains that the blackout “demonstrated the importance of voltage control and reactive power, and how a weak grid, with poor controls, was brought down by a single faulty solar inverter.”  The basis of the blog post was a “concise but informative report produced by Red Eléctrica de España (“REE”), the Spanish Transmission System Operator (“TSO”), which is more accessible than the much longer government report (available only in Spanish – rough English translation here).”

Watt-Logic lists the key messages from the REE report:

• The blackout was triggered by a PV inverter–induced voltage oscillation
• Inappropriate disconnections of wind and solar generation, and widespread failure of reactive power support, escalated the disturbance
• REE relied on static controls and failed to deploy dynamic response assets
• Grid code non-compliance was widespread among renewables, conventional generators, and even REE itself (via non-compliant transformers)
• The collapse exposes systemic risks in low-inertia grids with high levels of inverter-based resources (“IBRs”) and inadequate voltage control
• It is notable that, despite confident denials from some renewables advocates in the immediate aftermath, it was in fact a malfunctioning solar installation that triggered the voltage oscillation initiating the collapse. Wind and solar generators failed to meet fault ride-through obligations, and both inverter-based and conventional generators failed to provide the required reactive power support. Crucially, conventional generators did not trip prematurely – they remained online until system conditions breached their design tolerances.

If you want more information about this event then I recommend reading the post.  For the purposes of this article, there are no references in the Draft Energy Plan to the blackout.  That is understandable given that the blackout occurred a couple of months prior to the release of the document.  On the other hand, the consequences of this event have serious implications to New York’s 2040 zero-emissions mandate.

Solar Costs

The second reason that the Spanish blackout should be considered in the Draft Energy Plan is because of the cost implications.  Most of the public still believes the charlatans who claim that solar is the cheapest form of energy.  A recent Doomberg blog explains that after the blackout in Spain earlier this year “the true cost of solar can no longer be hidden from the public.”

The Doomberg post describes the blackout and the attempts by Spanish authorities to deflect blame away from the possibility that the problem was due to the solar facilities.  Their post goes on: “As the results of the investigation became undeniable, responsibility was pinned not on solar but on the grid operators who had failed to make the necessary investments to handle the rapid influx of green electricity.”  They stated that:

Last week, an expansive article in Bloomberg Green—confessionally titled “The Fix For Solar Blackouts Is Already Here”—captured this sentiment. It lamented that the penetration of solar and wind has outpaced the buildout of stabilization technologies such as synchronous condensers and grid-forming inverters. In other words, the renewables worked as designed, but the infrastructure to integrate them safely at such high percentages of supply lagged far behind:

“The result is huge spending on new wind and solar capacity, but not enough on grids. The 27 members of the European Union and the UK invest on average $0.7 in grids for every dollar spent on renewables, according to BloombergNEF. Spain ranks the lowest, with only $0.3 spent for every dollar.

Blackouts are causing political backlash against renewables that politicians cannot afford right now. ‘Here’s the problem: Investments in the right infrastructure are not keeping up,’ said António Guterres, head of the United Nations, in a July speech. ‘That ratio should be one to one.’”

When you hear someone claim that solar is cheaper than natural gas, tell them that the head of the United Nations says that for every dollar spent on solar capacity, another dollar must be spent on transmission upgrades to prevent blackouts.  Then point out that because of night, another dollar must be spent on energy storage. 

Doomberg sums it up:

In reality, while the marginal cost of sunlight is zero, the true system cost of integrating solar into a modern grid includes the heavy and ongoing capital expenditures needed for transmission, stabilization, balancing services, and energy storage. Without those, the electricity produced cannot be delivered reliably, making it far less “cheap” than advocates claim.

Discussion

This post provides more reasons why solar is not the solution that many believe it to be.  It is time that New York politicians insist that the technical experts at the New York Independent System Operator and New York State Reliability Council be fully integrated into the Energy Plan process.  The experts responsible for providing reliable electricity are working to resolve the myriad technical issues associated with integrating wind, solar, and energy storage into the grid.  I am uncomfortable that the NYSERDA Draft Energy Plan addresses all their concerns.

The Draft State Energy Plan is being updated for the first time since 2017.  While the mandate for the Energy Plan calls for more frequent updates there is no need to rush this update.  This is the first update since the Climate Act was promulgated in 2019, so it is more important that this edition get it right than to meet an arbitrary deadline.  Therefore, the fact that this consequential event is not addressed in the Draft is an important reason to delay the deadline for comments on the draft. 

In my opinion, addressing this event and the changes to Federal support for renewable deployment are important enough that there should be a second draft prepared for comment.  The NYSERDA response to the extremely uncertain current situation could result in a significantly different energy plan.  New Yorkers should have the opportunity to address a draft that addresses these issues.

Conclusion

The Spanish Blackout has important implications for New York’s electric energy plan.  The issues raised here should be addressed and resolved before the Energy Plan is finalized.

This post documents the oral comments I submitted at the Draft State Energy Plan Public Hearing on September 4, 2025 in Rochester, NY.  The New York State Energy Research & Development Authority (NYSERDA) only allocated two minutes per person, so this article documents the statements that I made.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 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. 

Net-Zero Aspirations

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.

According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.”  The New York State Energy Planning Board is a “multi-agency entity established under Article 6 of the Energy Law, playing a core role in the State Energy Plan process”. Among its responsibilities is adopting the State Energy Plan: The Board has the authority to adopt the comprehensive statewide energy plan, and the stakeholder process should be an important component of that responsibility.

The driving factor for the updated Energy Plan is net-zero ambitions of the Climate Act.  This is the first update of the Energy Plan since the Climate Act was passed in 2019.  I have provided more background information and a list of previous articles on my Energy Plan page.  Because of the importance of this process on the future energy system of New York I am following it closely and will be submitting oral and written comments. 

Comments

This section documents the comments I made on August 4, 2025.  I used bullets to differentiate my comments from the explanations. 

• My name is Roger Caiazza.  Documentation for my comments will be posted on my Pragmatic Environmentalist of NY blog

As noted in the introduction I am convinced that implementation of the New York Climate Act will do more harm than good.

• The Overview for the Draft State Energy Plan states that it is “Advancing abundant, reliable, affordable, and clean energy for all New Yorkers.”

The Overview for the Draft State Energy Plan explains that “the State Energy Plan provides broad policy direction that guides energy-related decision making within New York State”, and includes “an outlook through 2040 with recommendations for meeting future energy demands that prioritize an energy system that is reliable, clean, and affordable while supporting economic development, equity, and a healthy environment.” The Overview also describes broad planning goals including:

Delivering abundant, reliable, resilient, and clean energy through a diverse mix of energy sources and supply infrastructure, while supporting energy efficiency and load flexibility. As clean energy resources ramp up over time, the State will maintain adequate supplies of all major energy sources.

Clearly this is a public relations statement checking all the politically sensitive topics.  There is an interesting statement in the preceding paragraph: “the state will maintain adequate supplies of all major energy sources.”  This hints at the possibility that fossil fueled resources will still be used in 2040.  Another broad planning goal is described:

Providing affordable energy to households and broad clean energy benefits to support continued prosperity, community and economic development, and an equitable energy transition. Policy and market solutions that help New Yorkers make energy-efficient choices and cut energy costs, matching programs to community needs, and inclusive engagement can help ensure that all communities benefit from the energy transition, including disadvantaged communities.

As before, this is just a public relations slogan.

• Affordability, reliability, and clean energy need to be defined.

All the slogans in the Overview are meaningless unless these terms are defined.  I have long argued that Public Service Law (PSL) Section 66-P, “Establishment of a renewable energy program”, includes bounds on implementation that have not been considered to date.  I have shown that one of the provisions of that regulation and other circumstances warrant the PSC commencing a hearing process to “consider modification and extension” of New York Renewable Energy Program timelines.  Clearly this has an impact on the Draft Energy Plan and must be considered. 

• The first prerequisite to considering affordability is a clear and transparent accounting of all the projected costs to meet the Climate Act mandates, not just the Climate Act mandated programs.

New Yorkers are starting to see their utility bills increase because of the Climate Act.  The Hochul Administration talks about energy cost concerns but as described in my August 19 comments the Draft Energy Plan continues to hide the costs by cherry picking their Pathways Analysis scenarios.  This should be corrected.

• The PSC has an affordability metric appropriate for utility costs but that is inadequate for the energy plan that considers other energy costs such as personal transport and heating in homes that do not use electricity or natural gas.  A new metric is needed.

I have been arguing for this in many venues.  I described my search for an affordability metric and I submitted a comment in the Niagara Mohawk/National Grid rate case that also summarizes my concerns.  In short, despite the obvious need, nothing exists.

• Two aspects of reliability must be addressed.  An electric system that relies on wind and solar is dependent upon weather variability.  The Integration Analysis, Pathways Analysis, PSC, NYISO, and independent work by Cornell’s Lindsay Anderson all agree new dispatchable, emissions free resources (DEFR) will be required to backup wind and solar during dark doldrums.  The relevant reliability question is how much is needed? The second reliability aspect is safety.  What happens to an all-electric energy system when there is an ice storm?

On August 12, 2025 Richard Ellenbogen, Constatine Kontogiannis, Francis Menton, and I submitted a filing to the Public Service Commission that argued safety valves need to be defined that address reliability challenges of a the proposed wind, solar, and energy storage electric system described in the Draft Energy Plan.  The filing included an exhibit that described the resources needed and the challenge associated with determining how much is needed. A recent post summarized the concerns that should be addressed in the Draft Energy Plan.

• Clean energy needs to be defined too.  The Scoping Plan failed to compare the environmental and life cycle impacts of wind and solar relative to existing alternatives.  In addition, the last update of the cumulative environmental impact statement was completed in 2020 before future energy projections called for many more solar panels and wind turbines. 

The Scoping Plan considered every possible environmental impact associated with fossil fuels but ignored all the environmental impact associated with the manufacture of wind turbines, solar panels, and energy storage batteries.  That means that there hasn’t been a direct comparison of impacts.  In addition no environmental impact accounting addressed the shorter expected lifetimes of those technologies.  There also is a serious deficiency regarding cumulative environmental impacts.  Consistent with 6 New York Codes, Rules and Regulations (NYCRR) §617.9(a)(7), a Generic Environmental Impact Statement was released on September 17, 2020 .  This Final Supplemental Generic Environmental Impact Statement (SGEIS) for the Climate Leadership and Community Protection Act was released that claimed to evaluate the environmental impacts associated with the incremental resources expected to be needed to comply with the Climate Act.  It built upon and incorporated by reference relevant material from four prior State Environmental Quality Review Act (SEQRA) analyses. 

As I documented in the August 12, 2025 PSC filing, the problem is that the original expectations of renewable capacity for the Climate Act falls far short of the renewable capacity requirements in more recent assessments.  The following table compares the capacity (MW) in the 2021-2040 NYISO Outlook Scenario 1, the Scoping Plan Strategic Use of Low-Carbon Fuels Scenario and six scenarios in the July 2025 Draft State Energy Plan.  There are inconsistencies in the categories but the massive increase in renewable resources is obvious.  Onshore wind is projected capacity is 145% higher than analyzed, offshore wind expected capacity is 62% higher than analyzed, and solar is 241% higher than the maximum scenario expectation.  In addition, no previous analysis considered the environmental impacts of massive energy storage facilities or the “zero-carbon firm resource” that the integrated analysis presumes will be provided by hydrogen resources.  The Draft Energy Plan needs to address this failing.

CLCPA Implementation 2040 Fuel Mix Capacity (MW) Compared to 2020 SGEIS Exhibit 2-5 Expected Renewable Capacity

• If these terms are not defined, then they are just meaningless slogans.

New Yorkers deserve a complete affordability, reliability, and environmental impact accounting.

Discussion

There is no sign to date that NYSERDA is changing anything in its stakeholder process from the unresponsive approach used in the Scoping Plan.  There is another aspect concerning that process and the current outreach.  The public gets slick promotional information and carefully crafted slogans promising abundant, reliable, affordable, and clean energy for all New Yorkers.   These terms are vague enough that the Hochul Administration can continue to avoid responsibility for the impacts of the Climate Act.  The Draft Energy Plan is too important to rely on emotion and political pandering to specific constituencies to not do this process right.

Conclusion

It is troubling that New York energy policy has been dominated by political mandates that ignore physical reality.  I am convinced that nothing from the energy experts responsible for the electric system can say will change the disastrous path of the Draft Energy Plan.  It is going to take a political policy shift to avert disaster.  If you are concerned, demand accountability from the NYSERDA energy plans and please speak out to your elected officials.

This post is part of my continuing coverage of the draft New York State Energy Plan (Draft Plan).  In late July the United States Department of Energy (DOE) published a draft report titled “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate”.  This post describes differences between that report and the Draft Plan Climate Change, Adaptation and Resiliency chapter.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 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. 

Net-Zero Aspirations

The Climate Leadership & Community Protection Act (Climate Act) established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda” was based on an Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA). 

The rationale of New York’s net-zero transition plan is that climate change is a threat to society that must be addressed by eliminating the use of fossil fuels. Because I believe that the climate change threat narrative has become religious dogma for many, I have not addressed this position much.  However, I believe that climate change is an exaggerated problem that is diverting attention away from other serious environmental and societal issues to the detriment of us all.

The Draft Energy Plan Climate Change, Adaptation and Resiliency (Climate Chapter) document represents the extreme “consensus” view of climate change.  In my opinion, New York’s climate change position represents the extreme end of the consensus because there have been instances (e.g. sea level rise projections) where state policy is based on a more extreme position than that taken by the Intergovernmental Panel on Climate Change.

Critical Review

On July 29, 2025 the Department of Energy released the Critical Review report.  Rather than drafting a summary of the report I am going to quote the Background and Overview from the Federal Register Notice of Availability: A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate (NOA).  I am also going to highlight differences in the review relative to statements in the Draft Energy Plan chapter on climate change

The draft report was prepared by independent scientists, assembled by Energy Secretary Chris Wright with diverse expertise in physical science, economics, climate science and academic research. The authors are John Christy, Judith Curry, Steven Koonin, Ross McKitrick, and Roy Spencer.  The press release describes their backgrounds.  In my opinion, they are all first-rate experts.  The Background in the Notice of Availability (NOA) states that:

The draft report titled “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate” was developed by DOE’s 2025 Climate Working Group, a group of five independent scientists assembled by Energy Secretary Chris Wright with diverse expertise in physical science, academic research and climate science. The landing page for the CWG Report, including a press release, can be found here.

The following quotations are from the NOA “Overview of the CWG Report”. 

The report reviews scientific certainties and uncertainties in how anthropogenic carbon dioxide (CO2) and other greenhouse gas emissions have affected, or will affect, the Nation’s climate, extreme weather events, and selected metrics of societal well-being. Those emissions are increasing the concentration of CO2 in the atmosphere through a complex and variable carbon cycle, where some portion of the additional CO2 persists in the atmosphere for centuries.

Increasing concentration of CO2 is uncontroversial.

Elevated concentrations of CO2 directly enhance plant growth, globally contributing to “greening” the planet and increasing agricultural productivity. They also make the oceans less alkaline (lower the pH). That is possibly detrimental to coral reefs, although the recent rebound of the Great Barrier Reef suggests otherwise.

Many of the other statements are controversial.  The Climate Chapter does not mention any potential benefits to increased CO2 concentrations.  I suspect that the only reason coral reef threats are not mentioned is because New York does not have any coral.

Carbon dioxide also acts as a greenhouse gas, exerting a warming influence on climate and weather. Climate change projections require scenarios of future emissions. There is evidence that scenarios widely-used in the impacts literature have overstated observed and likely future emission trends.

The Climate Chapter references the 2024 New York State Climate Impacts Assessment (NYSCIA).   It claims that it “offers a thorough evaluation of historical climate data”.  The Draft Review reference to a widely-used scenario refers to the use of Representative Concentration Pathway 8.5.  That scenario was used extensively in the NYSCIA apparently because it provided the biggest potential impacts.  In my opinion, that approach invalidates projections in the assessment because the scenario is impossible.

The world’s several dozen global climate models offer little guidance on how much the climate responds to elevated CO2, with the average surface warming under a doubling of the CO2 concentration ranging from 1.8° C to 5.7° C. Data-driven methods yield a lower and narrower range. Global climate models generally run “hot” in their description of the climate of the past few decades. The combination of overly sensitive models and implausible extreme scenarios for future emissions yields exaggerated projections of future warming.

NYSCIA used the “hot” models and the implausible extreme scenarios to claim that “in order to limit the global average increase in temperature to 2°C (if possible, 1.5°C) and minimize the risk of the most severe climate impacts, substantial reductions in GHG emissions by mid-century are required.”  In my opinion, the models that used are not fit for policy decisions.

Most extreme weather events in the U.S. do not show long-term trends. Claims of increased frequency or intensity of hurricanes, tornadoes, floods, and droughts are not supported by U.S. historical data. Additionally, forest management practices are often overlooked in assessing changes in wildfire activity. Global sea level has risen approximately 8 inches since 1900, but there are significant regional variations driven primarily by local land subsidence; U.S. tide gauge measurements in aggregate show no obvious acceleration in sea level rise beyond the historical average rate.

NYSCIA concludes that “New York State’s climate has already changed, with impacts evident across economic sectors, industries, natural systems, communities, and regions.”  The Critical Review directly contradicts these claims. 

Attribution of climate change or extreme weather events to human CO2 emissions is challenged by natural climate variability, data limitations, and inherent model deficiencies. Moreover, solar activity’s contribution to the late 20th century warming might be underestimated.

Ditto.

Both models and experience suggest that CO2-induced warming might be less damaging economically than commonly believed, and excessively aggressive mitigation policies could prove more detrimental than beneficial. Social Cost of Carbon estimates, which attempt to quantify the economic damage of CO2 emissions, are highly sensitive to their underlying assumptions and so provide limited independent information.

The Climate Act is based on a fundamentally different outlook.  The Preamble to the Climate Act legislation claims that: “Action undertaken by New York to reduce greenhouse emissions will have an impact on global greenhouse gas emissions and the rate of climate change.”  The NYSCIA document is completely consistent with the law and there isn’t even a suggestion that there might be uncertainties.

U.S. policy actions are expected to have undetectably small direct impacts on the global climate, and any effects will emerge only with long delays.

This point is not addressed in the Climate Act, NYSCIA, or any New York GHG emission reduction regulation.  Nothing that the United States can do will have a detectable impact on the global climate so anything New York does is going to have an even less detectable impact.  There is no justification whatsoever for the Climate Act schedule even if we must “do something”.

Discussion

In my opinion, the Critical Review is long overdue. I appreciate the commitment of the authors.  An interview with Steven Koonin by John Robson from the Climate Discussion Nexus makes the important point that we don’t know nearly as much as proponents claim and that consideration of what we know and what we don’t know should be reflected in policy approaches.  Roy Spencer and Judith Curry both wrote blog posts explaining why they got involved in the report.  All five authors provided a joint written response to Nature magazine, stating they are “committed to a transparent and fact-based dialogue on climate science” and that they will respond publicly “to all serious scientific comments” during the NOA public comment period.

The usual suspects response has been outrage that anyone could possibly question their “settled science”.   They are demanding systematic fact-checking efforts and a public debate.  All the while hey are oblivious to the point that all five of the authors have been asking for just such an approach for years.  I agree with the need for an open debate of the climate science.

Conclusion

The key point for New York is that we have the same situation here.  The Draft Energy Plan stakeholder process has no forum for public debate.  I believe that the arguments that make the case that the net-zero transition ambition and schedule will result in an affordable and reliable energy system are much weaker than the arguments that GHG emission reductions are necessary to control the climate.  The failure to openly discuss the differences between the Draft Energy Plan and New York Independent System Operator projections is unacceptable.  If the stakeholder process for the Draft Energy Plan continues to ignore public input, then I think New York will be saddled with a false solution that will take years to fix.

As part of my continuing coverage of the draft New York State Energy Plan.  I recently explained how the analyses for the Draft Energy Plan are hiding the true costs to meet the Climate Act targets.  Energy Bad Boys Mitch Rolling and Isaac Orr recently published an article that describes a similar evaluation that has the same flaw that does a better job explaining the problem.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 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. 

Net-Zero Aspirations

The Climate Leadership & Community Protection Act (Climate Act) established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda” was based on an Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA).  The Climate Act is not the only legislation or regulation that was promulgated to achieve reductions in greenhouse gas emissions to address climate change.  That fact has a major bearing on the NYSERDA Draft Energy Plan analyses.

According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.”  The driving factor for the Energy Plan is the net-zero ambitions of New York’s ruling political party.  This is the first update of the Energy Plan since the Climate Act was passed in 2019.  I have provided more background information and a list of previous articles on my Energy Plan page. 

Costs

In my article about Energy Plan costs, I mentioned that NYSERDA President and CEO Doreen is the Chairperson the Energy Planning Board.  After a presentation regarding the Transmission and Distribution Reliability Study she said.

You may recall during our last meeting in which we discussed the pathways modeling for this plan. And to remind you, the analysis showed that New York’s citizens and businesses will need to invest over one hundred billion dollars each year in the energy system, no matter which future path we take.

I have one immediate response.  There is no future net-zero transition path that would not cost much more than $100 billion.  NYSERDA, ever beholden to the Hochul Administration’s political plans, has prepared a “comprehensive” roadmap using a misleading limited assessment  As was the case with the Integration Analysis and Scoping Plan, NYSERDA is interpreting the “No action” scenario as one that includes all legacy programs in place prior to the passage of the Climate Act.  This reduces the implementation costs.  The appropriate baseline scenario is one that excludes all programs that were promulgated to reduce GHG emissions. 

After publishing my article, I found an analysis of a similar situation by Energy Bad Boys Mitch Rolling and Isaac Orr describing the Environmental Protection Agency (EPA) analysis of its regulations on greenhouse gas (GHG) emissions from existing coal and new natural gas plants.  They describe the same problem with that evaluation as the NYSERDA Energy Plan evaluation.   I think the article does a better job than I did explaining the problem, so this post features their excellent work and its implications to NYS..

B,S. Baseline Modeling

In the Introduction to their article the Rolling and Orr describe the challenge of modeling future energy possibilities.  It is entirely applicable to New York.

Whenever you see a regulatory agency like the Environmental Protection Agency (EPA) or a utility company crow about how much an energy proposal or regulation will save or cost Americans, the first thing you should do is ask: “Oh yeah? Compared to what?”

It’s important to ask this question because these entities never report the true cost of a proposal compared to today’s costs, but instead, they compare the costs to some imaginary future baseline scenario that is often even more expensive.

This deceptive bait-and-switch tactic allows utilities and regulatory agencies to hide the true costs of their onerous regulations or integrated resource plans in a B.S. baseline. It also allows these entities to dishonestly claim their preferred policies will save energy consumers money—when in reality, they won’t.

In New York this tactic was used in the Scoping Plan analysis and is being used again in the Draft Energy Plan analysis.  In my description of the Scoping Plan I referred to this as a shell game.  The Rolling and Orr call it “bait and switch” and describe it thusly:

Imagine you were at Best Buy browsing around, and you saw an advertisement for two TVs—the one on the left has a price tag of $800, and the other on the right has a price tag of $500. The sign reads: “Save $300 by choosing the one on the right!”

Sure, you can save $300 by buying the TV on the right, compared to buying the one on the left, but ultimately, you understand that you’re still spending an extra $500. You could save even more ($500) by not buying a new TV in the first place. These are the kinds of bait-and-switch shenanigans used by regulatory agencies and utilities to sell their energy proposals to the public.

To help understand how this relates to energy modeling, it helps to look at another example involving a government budget.

Let’s say the federal government currently spends $200 billion per year on government programs, but some lawmakers want to increase spending to $1 trillion to pay for more government programs. Ultimately, Congress agrees to spend a total of $700 billion per year instead of $1 trillion.

Most people would probably look at this budget and agree that it increases spending by $500 billion per year, but spending advocates would argue that this bill saves $300 billion per year. This is only true if you read the fine print that says, “compared to the baseline cost estimate that assumed a total of spending $1 trillion.”

In New York, NYSERDA is claiming that the costs of the net-zero transition are a small increment of the one hundred billion annual investments in the energy system, “no matter which future path we take.”  Much to the chagrin of NYSERDA, they have not been able to torture the numbers to the point where they can claim that the net-zero transition will save money so they are left with arguing that it is a small increment.  For New Yorkers the key point is that NYSERDA has not provided a detailed breakdown of costs per emission strategy future path.  As a result, we do not know how the expected costs are allocated so that we cannot check their claim.

Rolling and Orr evaluated the costs of the GHG emission reduction regulations implemented by the Biden Administration

Ordinarily, it would seem reasonable to assume that the benefits of reversing a regulation could be determined by reversing the estimated cost of complying with said regulation.

When the Biden EPA finalized its regulations, they claimed the rules would only cost Americans $19 billion in additional costs, and that these compliance costs would be far outweighed by the benefits of fewer emissions of criteria pollutants and greenhouse gases.

But there was a major problem with their claim: Almost all of the actual compliance costs of the rules were buried in a B.S. Baseline.

The B.S. Biden Baseline is a scenario created by the Biden EPA in 2023 that assumed almost all of the changes to the power generation fleet in the next two decades would be due to the subsidies in the Inflation Reduction Act (IRA), and state wind and solar mandates, not the Biden administration’s greenhouse gas regulations.

Based on our evaluation (let’s be real, Mitch did this part) of the EPA’s slew of Excel spreadsheets, the Biden Admin’s B.S. Baseline accounted for 95 percent of the changes in generation capacity from the MISO grid in 2025 through 2055, compared to the final rules, which you can see in the table below.

Because the Biden administration hid almost all of the new generation capacity in its B.S. Baseline, nearly all of the costs associated with building and operating this generating capacity were hidden, as well.

NYSERDA has not provided sufficient information in their documentation to develop a similar table.  Rolling and Orr went on to explain how the true EPA plan costs were buried.

The Biden administration claimed that its final power plant wrule ould only increase costs by $19 billion over a 24-year period, spanning from 2024 through 2047, using a 2 percent discount rate. However, this modest compliance cost is entirely due to the fact that most of the expenses for the modeled MISO grid in the Biden Final CPS Rules IPM output files are incurred in the Biden Base Case.

The graph below shows the costs of building and operating the MISO grids outlined in the Biden administration’s B.S. Baseline and final regulations. Our modeling indicates that the modeled MISO grid in the Biden Baseline would cost $362.1 billion, using the subsidy phaseout timeline established in the One Big Beautiful Bill Act, and the final Biden regulations would cost $404.1 billion.

As a result, the true cost of building and operating the MISO grid under the Biden rules envisioned in Biden’s regulatory impact analysis would be $404.1 billion, but the administration would only consider $42.9 billion as compliance costs.

Ideally at this point I would prepare a similar chart describing New York’s energy cost breakdown and illustrating my point that NYSERDA is using a similar bait and switch tactic.  In theory, I could emulate Mitch Rolling and prepare my own estimate of costs but that would require an enormous amount of time that I do not have for this post.  The NYSERDA Pathways Analysis projects that energy system investments will total $120 billion per year out to 2040.  In my opinion, that is an extraordinary claim that should be justified with transparency that identifies the choices and assumptions made to arrive at that number, including the numbers needed to make a similar chart.

Rollings and Ord concluded:

Long story short, the B.S. Baseline used by the Biden administration hid 90 percent of the costs of its regulations. Because the Biden Base Case is responsible for the vast majority of the changes observed in the modeled MISO grid in the Biden Final CPS Rules, it is responsible for driving the vast majority of the cost of the changing resource portfolio.

Therefore, it is incredibly misleading to suggest that the Final CPS Rules would be cost effective, since the 90 percent of the costs are hidden in its baseline modeling. This is called a Bait & Switch—and it’s completely B.S.

It is impossible to provide a similar breakdown of costs associated with the NYSERDA Draft Energy Plan’s claim that energy system investments will total $120 billion per year out to 2040 whatever future energy path because there insufficient documentation.  I believe that full disclosure would lead to the same conclusion.

Discussion

The Energy Plan Pathways Analysis defines the “No Action” pathway scenario as “reflecting outcomes in the absence of the Climate Act and energy policies enacted from 2019 onwards”.  It includes federal energy incentives and legacy New York State policies (i.e., those in place as of 2019), but it explicitly excludes any state and local climate, decarbonization, or efficiency policies put in place since 2019.  NYSERDA insinuates that this represents the world without New York State driven climate action.  However, as shown in my earlier post, there are many projects in the “No Action” pathway scenario that when included underestimate the cost of achieving net-zero.

For illustrative purposes, the “No Action” scenario includes the Federal electric vehicle mandate emission reduction program.  Switching to electric vehicles is necessary to achieve the Climate Act emission reduction targets but the costs for this program are buried in the $120 billion annual investment because the federal mandate was in place before the law was passed.  The current uncertainty of Federal electric vehicle mandates will affect the implementation ramp rate. 

Conclusion

New York’s B.S. Baseline of the bait and switch tactics described in the Rollings and Orr post improperly includes “no action” projects that only exist because of the Climate Act.  I believe that the majority of New Yorkers agree with me that we want to know the total cost, irrespective of which regulation requirement, of the Energy Plan projects that will be necessary to meet the net-zero and electric system mandates of the Climate Act.  In my opinion, there is no question that those costs would be enormous and no question that that fact is being hidden by NYSERDA in its own B.S. Baseline.