Category: Climate Act

PowerNYC: Public Project Development Is Not a Substitute for Power-System Planning

A new proposal would establish PowerNYC Development Corporation, a publicly owned developer of distributed batteries, solar installations, and thermal energy networks. Its headline claim deserves scrutiny: an initial 200 MW battery portfolio could save New York City ratepayers at least $170 million annually. The authors recommend $100 million in initial state capitalization.

Affordable electricity, reduced environmental burdens, and better infrastructure are worthwhile objectives. But agreement on those objectives does not establish that this particular institutional model will deliver them.  PowerNYC should be judged by the electric services its projects actually provide, their complete costs, and their performance during difficult operating conditions—not simply by installed capacity or public ownership.

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. 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 and references included in this document.

Start with the savings calculation

The October 28 paper by Jason Kowalski and Johanna Bozuwa presents the $170 million savings figure prominently. Appendix 1 provides an important qualification: the estimate represents potential reductions in capacity-market costs, not a demonstrated, comprehensive net benefit after accounting for the proposed battery portfolio’s costs.

The calculation has two parts. First, the authors estimate how additional battery capacity would lower prices along NYISO’s 2025–2026 capacity demand curve. They explicitly acknowledge that this simplified calculation does not model the capacity supply stack or fully simulate realized market savings. They then calibrate the result using NYISO’s 2018 energy-storage consumer-impact analysis.

That is a starting point for investigation, not sufficient evidence for a dependable annual savings commitment. The underlying spreadsheet, assumptions, and calculations are available upon request rather than published with the report. Independent reviewers therefore cannot reproduce the headline estimate from the document alone.

The original NYISO consumer-impact study also distinguishes short-term price reductions from long-term outcomes. Its discussion on page 29 warns that initial capacity-cost effects may not persist as retirements and other supply changes occur.

PowerNYC’s proponents should publish their workbook, identify which historical results they used, and explain how they account for changing supply, demand, market rules, and resource retirements. Potential distribution savings should remain separate until specific projects establish which investments can actually be avoided. The paper appropriately acknowledges that those benefits have not yet been quantified.

Lower capacity payments can benefit consumers. But a modeled price reduction is not automatically a permanent reduction in the physical cost of maintaining reliable service.

What problem does ownership solve?

The proposal is more substantial than a call for additional subsidies. PowerNYC would originate projects, aggregate sites, arrange financing, manage construction, and own operating assets. Its intended advantages include standardized procurement, public-site access, coordination, and recycling development capital through refinancing or asset transactions.

Those possibilities deserve consideration. Schools, housing organizations, and other institutions should not have to become energy-development specialists to evaluate worthwhile projects.

However, institutional barriers and engineering constraints are different problems. Lower financing costs do not establish that a battery has adequate duration, that a feeder can accommodate charging, or that electricity will be available when needed.

The report recognizes this distinction in Appendix 2. It discusses coordinated charging schedules and enforceable operating limits to address Con Edison’s concern that simultaneous battery charging could create new local peaks. It also acknowledges that such arrangements could reduce project revenues.

That qualification belongs in the financial analysis. If operating restrictions are necessary for reliability, projected revenues must reflect them.

The relevant question is not whether public development can build projects. It is whether this model can deliver required services more effectively than utility procurement, existing public institutions, private development, or targeted efficiency investments.

Specify what the batteries provide

The most conspicuous technical omission is the absence of a defined energy-storage requirement. The paper proposes 200 MW of batteries but does not specify the portfolio’s usable energy in MWh or discharge duration.

Megawatts describe how much electricity a battery can deliver. Megawatt-hours describe how much it can deliver before requiring recharge. A power rating alone cannot establish the portfolio’s reliability contribution.

NYISO’s own accreditation factors demonstrate why duration matters. For the 2025–2026 capability year—the year cited in PowerNYC’s methodology—the New York City factor was 78.53% for four-hour energy-duration-limited resources and 96.12% for eight-hour resources. These historical factors are not guarantees of future accreditation.

Before accepting the savings calculation, reviewers need to know the assumed duration class, availability, degradation, charging restrictions, and market-participation arrangements. They also need to know whether the same stored energy is implicitly committed to multiple services.

Energy arbitrage, peak reduction, ancillary services, distribution support, and customer resilience should be evaluated separately. A credible operating schedule must demonstrate that the portfolio can meet its combined obligations.

Greg Harkenrider’s guest analysis published on this blog examines how storage requirements depend on the assumed generation portfolio and weather sequence. Its statewide seasonal-storage estimate should not be presented as the requirement for PowerNYC’s limited portfolio. The relevant lesson is methodological: storage must be evaluated against the conditions and services it is intended to address.

Reliability before retirement

The paper argues that distributed clean-energy development could help eliminate New York City’s dependence on local fossil generation. It also describes battery capacity as displacing higher-cost fossil capacity in the capacity market.

Those statements require careful interpretation. Reducing a market-clearing price is not the same as demonstrating that a particular generating unit can retire without compromising reliability.

The Independent Intervenors’ September NYPA conferral overview establishes the appropriate principle: dependable resources should remain available until replacement resources and supporting infrastructure are operational, deliverable, and demonstrated under stressed conditions.

PowerNYC does not have to solve New York’s entire dispatchable-emissions-free-resource problem to justify a useful battery installation. Nor must every distributed project supply electricity through a prolonged statewide renewable shortfall.

But any generation-replacement claim must identify the services being replaced and demonstrate equivalent performance. That requires chronological analysis of demand, generation, battery state of charge, recharge opportunities, imports, and credible equipment outages.

The analysis should address individual projects and the combined portfolio. What happens during consecutive high-demand days? What if local and bulk-system needs occur at different times? Which resources sustain service after batteries discharge?

A useful project is not necessarily a complete replacement resource.

Location matters in New York City

PowerNYC correctly recognizes that strategic siting is essential to securing distribution benefits. It proposes screening public properties for available grid capacity and locating batteries where they can relieve constraints.

But available land, an economical interconnection, and maximum reliability value may not coincide. Candidate sites should be assessed against actual network needs, rather than assuming that a large public-property inventory establishes a viable portfolio.

The Independent Intervenor NYPA conferral overview comments distinguishes bulk-power adequacy from distribution-system performance. Adequate statewide capacity does not establish that a particular transformer or feeder can serve additional demand. Conversely, relieving a neighborhood constraint does not necessarily resolve a bulk-system deficiency.

The 2022 peaker-replacement discussion on this blog also distinguishes purpose-built combustion turbines from larger steam-electric units operating infrequently. Calling both “peakers” does not establish identical replacement requirements.

Any retirement proposal should identify the affected units, their locational services, required operating duration, and the applicable reliability review. Older battery-footprint estimates should not substitute for current project designs.

Solar and thermal energy networks likewise require project-specific evaluation. Their contribution should be assessed alongside the electricity demand, infrastructure requirements, and customer obligations they create.

Count all costs and risks

The distinction between project economics and reliable-system economics underlies my discussion of inexpensive renewables. My affordability-standard comments similarly call for complete, transparent accounting rather than selectively defined costs.

For PowerNYC, that accounting should include financing, charging electricity, losses, degradation, replacement, interconnection, network upgrades, insurance, administration, and decommissioning. It should distinguish host savings, wholesale-market effects, total system costs, and retail-bill impacts.

The report’s promise of projects without upfront costs must also be understood alongside its request for public capitalization and subsequent revenue-backed financing. Moving expenditures away from a project host does not eliminate them.

Who bears overruns, unsuccessful development expenses, revenue shortfalls, and stranded assets? After those risks are allocated, whose bills fall, by how much, and for how long?

Evaluate environmental performance

Environmental evaluation should distinguish avoided emissions from demonstrated reductions in neighborhood exposure and health effects. Plant-specific emissions, dispersion, and source-apportionment evidence are preferable to assuming that proximity alone determines benefits—a concern raised in my earlier peaker discussion.

Directly emitted pollutants and secondary pollutant formation should be evaluated separately. Closing a plant may provide local benefits but their magnitude should be demonstrated rather than dismissed or presumed.

The same discipline should apply to charging emissions, battery chemistry, fire protection, emergency response, and lifecycle impacts. Historical battery incidents should not be generalized to every contemporary installation but they should also not be ignored.

A better development standard

PowerNYC should begin with a reliability-and-affordability investment screen:

  • Define the specific system or customer problem.
  • Compare technically credible alternatives providing equivalent services.
  • Publish complete costs, operating assumptions, and environmental outcomes.
  • Establish enforceable performance requirements and independent verification.
  • Expand only after demonstrating results.

The Independent Intervenors’ Con Edison testimony, particularly pages 20–22, proposed subway traction-energy recovery, targeted improvements for steam-system customers, and preservation of distribution headroom. They provide cost-effective emission reductions.  These are candidates for comparative evaluation—not established savings that should be accepted without scrutiny.

Public development could have a constructive role. However, public ownership should not exempt projects from the engineering, financial, and environmental tests demanded of any other investment.

Before committing public capital, require a reproducible savings calculation, a defined battery portfolio, location-specific reliability evidence, and clear accountability for outcomes. Developing projects is a means. Reliable, affordable electricity is the objective.

How Some Electricity Grids Are Walking on Tightropes

When people you respect all recommend the same thing, it deserves to be passed on.  In this case it is a video about how a United Kingdom blackout starts.  Tom Shepstone brought it to my attention first, Meredith Angwin recommended its clarity, and Richard Ellenbogen explained how the conditions described occurred last summer in Downstate New York.  It describes the risks we are facing and what a blackout means.

Video Overview

Paul Burgess describes the video as follows:

This is an in-depth video, but hopefully very easy to understand, with a lot of graphics to explain everything. By the time you watch this video, you’ll have a very good understanding of how our national grid works and what peril it is in. Basically, our grid is being run by ideology, not by engineers and we are risking national blackouts like never before.

Tom Shepstone said that “the 39-minute video addresses how the UK grid really works, or doesn’t work, as the case may be. The lessons apply to all grids and Burgess explains everything in detail in ways easily understood”.  Meredith Angwin said that it is a “clear video showing how grids fail and what it takes to start them again” and that “everyone should watch this”. Richard Ellenbogen said: “It explains in simple terms how the electric utility system works.” 

The mechanics of grid stability

If you only watch the first 5 minutes, you will understand a lot about the complexities of operating the electrical grid and  the challenges that are being introduced by adding wind and solar.  Ellenbogen knows it will also explain what happened on the downstate NY system in early July and why they had to load shed, blacking out portions of Westchester, the Bronx, and Brooklyn.

A couple of things to keep in mind.  The video is based upon the UK utility system where they use a 50 hertz (Hz) standard.  North America uses a 60 hz standard.  The grid delivers alternating current, or AC electricity. Rather than flowing steadily in one direction, the current repeatedly flows one way and then the other. One complete back-and-forth pattern is a cycle. Frequency tells us how many of those complete cycles occur each second: at 60 Hz, the pattern repeats 60 times per second. It describes the rhythm of the electricity, not the amount of electricity being delivered.  Also note that when he says “gas stations”, he is referring to natural gas generating plants,  not somewhere to fill up a car.

Burgess explains that a reliable grid must control frequency.  He explains that for the frequency to remain stable the supply and demand must be in balance.

Source: The Anatomy of a UK Blackout – The UK Electricity Grid Walking On A Tightrope!

Burgess explains that if the generators produce less power than the demand the frequency goes down and if the generators produce more power than demand the frequency goes up.  The key point is that “The grid must continuously balance generation and load to keep the frequency inside the narrow safe band around 50 Hz in Europe and 60 Hz in the USA.  If the frequency goes outside the safe band the grid operators must take action.

Burgess uses graphics to illustrate the principles of the grid.  He shows that grid frequency is like a tight rope and then goes on to describe what happens when the frequency starts to wobble.  The key point is that there are automatic load shedding triggers to protect the grid.  Figure 2 lists reasons why equipment must disconnect.

Figure 2: Why Equipment Must Disconnect

Burgess goes on to explain how adding wind and solar changes the grid and make frequency control more difficult.  In the old system coal, gas, and nuclear provided dispatchable power that could be controlled to control frequency.  Those systems also provided inertia that kept the system stable.  Wind and solar do not provide inertia and changes in the weather affect power output significantly over short periods.  All this makes the system even more difficult to manage.

Burgess points out that these problems can be addressed with more infrastructure.  However he concludes that solving a problem that didn’t exist before costs money.  Proponents that argue that renewables save money do not include those added costs that make them more expensive than the existing generators.

He goes on to describe how these issues could cause a blackout.  Then he walks through a scenario that explains what it would take to recover from the blackout.

Batteries and Energy

Burgess also raises an important point about battery energy storage systems.  There are two roles for batteries: storage needed to address intermittency and micro-balancing to address frequency inertia.  You cannot use the same batteries to address both problems. 

Burgess also explains how the batteries support inertia.  It turns out that the addition of wind or solar systems needs inertia support close to those systems and distance matters.  That means that battery storage systems will have to be located near wind and solar or synchronous generators will have to be added which of course adds costs.

The remainder of the video describes blackouts.  First, he explains what is needed to recover from a blackout.   Then he does a simulation of a blackout caused by a lightning strike on a transmission line.  In his scenario the grid goes down in seven minutes but takes a week to recover.  He states that there can be laws to mandate recovery targets but “they cannot change the laws of physics or engineering limits”

Burgess estimates that in his simulated blackout excess deaths could be as many as 3,000.  He concludes with a list of the impacts of a blackout that contribute to the excess deaths:

Hospitals

Emergency generators last only limited hours (often 24-72 hrs depending on fuel).

Only critical care continues temporarily. Non-critical patients, surgeries and wards are at risk. Ventilators, monitors, dialysis and cold-chain medicines eventually fail.

Fuel & Transport

Petrol stations and diesel pumps stop — no electricity means no fuel.

Trains stop. Electrified lines and signalling fail. Passengers are stranded.

Traffic lights fail. Roads become chaotic. Airports and ports are disrupted.

Electric vehicles cannot charge. Diesel generators eventually run out of fuel.

Food & Cold Storage

Your freezer and fridge stop — food melts and spoils.

Massive warehouse and supermarket cold stores fail. Vast quantities of food are lost.

Food distribution and logistics collapse once fuel and power are gone.

Water & Sanitation

Water treatment and pumping stations stop. Clean water supply faiIs

Sewage systems back up. Hygiene and public health risks rise quickly.

Communications & Payments

Mobile networks fail as battery backups drain. Internet and data centres go down.

Cash machines, card payments and banking systems stop. Cash becomes hard to obtain.

Emergency services communications are degraded.

Heating, Lighting & Safety

Electric heating fails. Many gas boilers need electricity for pumps and controls. Lighting goes out. Accidents, falls, and crime increase in the dark. Elevators trap people. Security systems, alarms and CCTV fail.

Industry & Cascading Effects

Factories, chemical plants and continuous processes halt — some dangerously.  Refrigerated medical supplies (vaccines, blood, insulin) spoil.  Livestock farming, milking and food processing stop.  Once fuel runs out, even backup generators fail. Recovery becomes much harder.

Ellenbogen Description of the July Downstate Blackouts

In an email, Richard Ellenbogen explained what happened on the downstate NY system in early July and why they had to load shed, blacking out portions of Westchester, the Bronx, and Brooklyn.

Incidents described by Burgess in the video explain the power issues that were responsible for the Yonkers sewage treatment plant spill, a 350% increase in Fire Department elevator calls across the region, numerous issues with air conditioning,  and solar array or other inverter shutdowns.

Ellenbogen goes on:

Notice the plus and minus 0.2 hertz frequency band required for system stability that is mentioned in the video.  In the graph below, which is real time data collected at the factory during the early July time period, you will see 0.5 hz  and larger variations because the downstate system had insufficient generation and became frequency unstable.

In Figure 3, there was a dip down to 47.7 hz and then a rise to 60.5 hz for an extended period.  Both are well out of the allowable plus or minus 0.2 band of acceptable frequency.  Solar inverters were logging frequency issues for two days and shutting down taking their power off-line.

Figure 3: Con Edison System Frequency at Ellenbogen Home, July 3, 2026

As the downstate generation further ages and becomes more unreliable, generation failures will become more likely which will result in even worse and more widespread blackouts than the rolling blackouts of this past summer.

This is our new reality.  Biologists, climate activists, and politicians have interceded as utility system planners in what should have only been an engineering process.  Those parties don’t know how much they don’t know and the fragile state of the downstate utility system is falling victim to their incompetence.

For complex reasons that they do not understand because they have no training, intermittent renewables and batteries cannot solve the problem.  The video makes that clear.  Further, the frequency issues documented in the graph and explained in the video will make all of that technology shut down and become useless.

The video and our reality in downstate NY speak for themselves.  It is no longer just the warnings that several of us have been issuing for the past seven years.  It will now be a fact of our daily lives every time the temperature rises.

Unfortunately, seven years ago the improvements would have taken two to three years to implement and could have already been in operation.  Now, with the huge demand for electrical energy across the US, the lead times for equipment have gotten much longer and this might not be repairable for four to seven years, at a minimum.

The downstate NY system is not just walking on the tightrope mentioned in the video.  It is a severely frayed tightrope and we may be stuck on it for nearly a decade.

If you get to the 27 minute mark of the video, you will see the number of deaths that can be expected from the energy system failures.

I hate to be a voice of doom and gloom, but ignoring reality doesn’t make it go away.

Conclusion

Burgess draws a comparison between the root cause of the Chernobyl disaster and what we are facing today: “The people in charge in 1986 were indeed primarily Communist Party officials operating within a system that prioritized political loyalty, and propaganda over technical competence and safety.”  Sadly, I believe there is a parallel to New York.  The Climate Leadership & Community Protection Act transition plan is disconnected with engineering reality because ideological political appointees are toeing the Administration’s line on implementation rather than listening to the experts who run the electric system.

Finally, after watching the video and reading Ellenbogen’s comments in the back of my mind I heard the lyrics to Send in the Clowns:

Don’t you love farce?
My fault, I fear
I thought that you’d want what I want
Sorry, my dear
But where are the clowns?
Quick, send in the clowns
Don’t bothеr, they’re herе

Oswego’s Big Machine

The New York Energy Alliance recently posted an article on Facebook about the Oswego Harbor Power Plant.   There are a few issues with the article and some misconceptions in the comments that I want to address in this post because this facility is not well understood and is under-appreciated.

I am a retired air pollution meteorologist who has worked on New York energy and environmental policy issues since 1981.  I was responsible for reporting emissions for various programs for decades for plants in New York State including Oswego.  I have extensive experience with air pollution control theory, implementation, and evaluation and supported the air permitting for the Oswego facility from 1981 to 2010.  Also, I had an office at the plant from 2000 to 2010.  Finally, before I joined the utility industry, I worked for consultants who supported air quality analyses for the EPA.  Bottom line is that on this particular topic, I have the background and experience to explain the air quality impacts of the Oswego Steam Station.

This post consists of three parts: summary of the post itself, a summary of the comments through 4:45 PM on 10/18/26 or about seven hours after it was posted and a description of some points that I want to clarify and address.

Post Summary

The post includes the following graphic (Figure 1).

Figure 1: New York Energy Alliance Oswego Harbor Power Plant

The New York Energy Alliance portrays the Oswego Harbor Power Plant as an aging but important reliability resource: two 902-megawatt oil-fired units that operate infrequently but can generate for days during periods of high electricity demand. According to the text, the plant produced just 84 gigawatt-hours in 2025—roughly a 0.5% capacity factor—but remains available to help meet demand during extreme weather, providing sustained generation that the author contrasts with short-duration battery storage.

The description of the unit capacity caught my attention.  In my submittals I always listed the two units as 850 MW each and I am not sure why there is a difference.  My capacity factor estimates using the EPA Clean Air Markets Program Data information in Table 1 use those values.  I found two different estimates of the total energy produced in 2025  Those are minor points.  The key is that these two units provide enormous value as backup capacity when there are problems in the system or peak loads. 

Table 1 Emissions and Operating Data from the EPA Clean Air Markets Program Data website

The Facebook description explains that units 5 and 6 were developed by Niagara Mohawk in the 1970s to replace the old coal-fired units 1-4.  As shown in the bar chart in Figure 1 the plant became a major electricity supplier.  It also was the cornerstone of Oswego’s property-tax base. Its role diminished as cheaper natural-gas generation entered the market, but Units 5 and 6 survived and passed through successive owners. The text describes another proposed ownership transition involving ArcLight, DigitalBridge, and SoftBank, placing the plant within investors’ growing interest in electricity supplies for artificial intelligence and data centers.

I fully support the key point that this plant is a textbook example of the tension between New York’s 2040 zero-emission electricity requirement and the continuing need for dependable, dispatchable generation. The New York Energy Alliance argues that Oswego illustrates why rarely used fossil-fuel plants remain valuable even as the state pursues decarbonization.  I agree completely.

I want to comment on the closing paragraphs:

No one has filed to retire it. The grid operator leans on it. And its next owners are buying it because AI needs power. 99% of the plant’s capacity is unused, and AI is the only source of investment that will keep it available for those critical cold and heat waves.

Ben Green’s coal plant is gone. The one that dwarfed it is fifty years old, and a few evenings a year, it is the reason the lights stay on.

I think the plant survives because of capacity payments.  The investors bought the plant because the NYISO recognizes the value as backup to keep the lights on a few times a year and provides a payment approach that pays to keep this resource available.  It may be that the owners think that it will become more valuable as AI demand increases.  In theory, it could be operated enough to supply an AI data center by itself.  However, the offsite oil tank farm necessary for the historical high-capacity factors has been torn down and there is an annual operating limitation so I am not sure how feasible Oswego would be to power a data center directly.

Comments

I have a prepared a list of the comments that includes highlighted topics I want to address.  The following responds to those topics.

Justin Fedder (apparently subscribes to the belief that any air quality impact is unacceptable:

And I’m sure that building is the reason this area has a higher rate of lung cancers and breathing problems compared to all the areas around us. 

I mean, what would you expect when you have a heavy oil burning power station right in the middle of a city.

In my experience the power plant complies with all air quality standards.  In another comment Andy Arthur states “Isn’t the tall stack to distribute the sulfur high into the atmosphere to maximize dispersion?”.  He is right that the “solution to pollution is dispersion”.  The facility was designed when tall stacks were an acceptable way to reduce impacts but by the time it was permitted this was no longer allowed. The air quality modeling used a lower stack height and showed compliance but the actually impacts are lower.  All the modelling I did over nearly 30 years showed that the air quality impacts were far below the National Ambient Air Quality Standards (NAAQS) and that the highest projections were well beyond the city limits.  Furthermore, there is not just modeling evidence. My first responsibility at Niagara Mohawk was to submit data from air quality monitoring sites around the plant.  All the monitoring data confirmed the modeling impacts that showed compliance with the NAAQS.  In fact, the highest observed value occurred when you could smell chocolate.  In other words, the impacts of the Nestle plant in Fulton were greater.

I am not sure where Fedder’s claim of higher health impacts in the city comes from.  Oswego County’s 2022–2024 Community Health Assessment reports that its age-adjusted lung-cancer incidence in 2016–2018 was the highest in Central New York. It also reports elevated chronic respiratory-disease mortality and hospitalization rates, but asthma hospitalization rates were below regional and statewide rates. These county-level findings do not establish that the City of Oswego has higher lung-cancer and respiratory-disease rates than every surrounding community or identify the cause of the differences.

Finally, note that Table 1 shows that when comparing 2000–2005 with 2020–2025:

  • NOₓ emissions fell approximately 89%.
  • SO₂ emissions fell approximately 94%.
  • Gross generation fell approximately 89%

I maintain that there was no air quality problem even when the units were operating much more but today they run so infrequently that this claim is baseless.

Philip Wilcox made a persuasive argument that the future transition should “emphasize ‘cost-effective and reliable’, but should not abandon fossil fuels – primarily natural gas, unless and until the renewables can be counted on without bankrupting NY”.  In a subsequent reply said:

I don’t think anyone can make a coherent argument that it is renewables that are bankrupting New York.

David Haarman objected to the bankrupting claim saying it was an exaggeration.  Affordability is the one of my primary concerns.  Bankrupting may be an overestimate but my question to Haarman is what is an acceptable cost for the transition?  I believe that we already exceed any reasonable cost threshold and we are only getting started on the costs.

Haarman also claimed that there are tariff costs when we import from Canada.  I did some research and found that electricity has an unusual customs status. In a FERC proceeding, NYISO noted that electrical energy carried a 0% rate under the Harmonized Tariff Schedule, was exempt from ordinary merchandise-entry requirements, and had historically been treated as outside U.S. tariff laws. Those were arguments against applying the new duties—not a definitive ruling that electricity could never be taxed.  This is not to say that someday a tariff may be applied but at this time there is no extra tariff cost.

Haarman apparently supports renewables.  He said:

It is bewildering to me that the loss of farmland is even considered. New York ranks in the lower 50% in agriculture output at 27th in the US. Not to mention, the reduced tax revenue, subsidies, and the fact that <10% of cropland is prime farmland. This is a separate issue altogether.

I have been on both sides of permitting applications.  There is one enormous difference between my decades of experience trying to get air quality permits for power plants and permitting for wind and solar projects under the Office of Renewable Energy Siting.  My permits had to meet specific quantifiable limits that could be checked by the Department of Environmental Conservation.  The current policies do not include permitting standards.  For example, prior to the Office of Renewable Energy Siting permitting authority, the Department of Ag and Markets recommended that no more than 10% of a solar project’s developed area could be on prime farmland.  That was never established as a requirement and now is routinely ignored.  The state agency expert recommendation is not a requirement.  That is true across all the agencies where conditions that they felt were necessary during the previous permitting regime have been ignored.

Philip Wilcox responded to the costs discussion by pointing out that storage is necessary:

The CLCPA theorists claim that battery storage will be the panacea, but both the costs and proven reliability at utility scale is sketchy at best. So if you rely on batteries and have an extended outage that does not provide voltage support beyond the 24 hour or so battery capability will be a disaster. Zero carbon nuclear in an amount necessary to compliment intermittent wind and solar is decades away.

Figure 2 from the New York Independent System Operator (NYISO) presentation titled Winter 2025-2026 Cold Weather Operations lists the Real-Time Dispatch schedule of alternative fueled units during the January 23- February 9 2026 extreme winter weather episode.  This describes the use of oil-fired units.  Two fuels stand out: Ultra Low Sulfur Oil (ULSO) and Oil #6.  ULSO is burned in New York City at several peaking power plants.  The #6 oil-fired energy is primarily from Oswego.  Clearly Oswego provided critically needed energy when the system needed it the most.

Figure 2: Alternative Fuel Mix Plot for January 23 – February 9, 2026

Source: Winter 2025-2026 Cold Weather Operations Presentation to NYISO Operations Committee March 19, 2025 ©Copyright NYISO 2026. All rights reserved.

Andy Arthur said “My guess is it doesn’t run much due to Acid Rain trading system, expensive to run due to the need to purchase sulfur dioxide credits to pollute.”  Actually, the Acid Rain Program has been so successful that SO2 allowances are worthless.  However, Oswego is subject to the Regional Greenhouse Gas Initiative and must purchase CO2 allowances.  Because there is a cost differential between oil and natural gas I don’t think it markedly affects how much the units run.  What it does do is make the energy produced more expensive and that directly impacts consumers.

Ivan Prock said “Are you actually celebrating the existence of a plant which burns a fossil fuel? Are you unfamiliar with the climate crisis?”  The authors responded “If this plant didn’t exist, far more people would die from the climate. Hot days with no AC, cold nights with no heat kill people. This plant is a beast.”  Prock responded:

The plant’s history and current existence are contributing factors to the worsening of the climate crisis. Right, so we need to be aggressively deploying non-CO2-emitting sources of electricity generation, which include solar and wind power. The plant is a relic from the past when people didn’t care about the climate.

Richard Perkins responded to him:

That seems overly critical. While the transition to solar/wind/nuclear is clearly important for climate, we can still acknowledge the historical facilities that provide needed reserve electricity for our people – powering lighting, hospitals, industry, and homes.

Prock responded:

It’s as overly critical as New York Energy Alliance’s post is overly fawning.  We can acknowledge historical facilities while still acknowledging the damage that they caused and continue to cause to the climate.  Reserve electricity can be acquired from a number of sources including grid-scale and residential batteries, and improved grid interties to neighboring jurisdictions.

Catskill Weather replied to that: “The lie is that we are transitioning to a world without fossil fuels. Humanity is actually on a quest to utilize all energy sources in order to maintain and build the future. Prock responded:

There is absolutely no lie since the majority of all new electricity power generation, worldwide, has come from solar and wind power. Humanity is actually on a quest to transition to avoiding the use of fossil fuel sources. Do better research before commenting further.

As I have argued repeatedly on this blog, Ivan Prock confuses the desirability of reducing emissions with the engineering requirements for keeping the lights on. The critical issue is reliability: wind and solar provide electricity when the weather cooperates, batteries store energy rather than create it and cannot sustain output beyond their available charge, and additional interties do not guarantee that neighboring systems will have surplus electricity during a widespread weather-driven shortage. These are precisely the concerns I have raised about prolonged periods of low wind and solar production and the need for dependable, dispatchable resources. Prock’s appeal to the share of new generation coming from renewables also fails to distinguish installed capacity, actual electricity production, and total energy consumption; growth in one does not, by itself, demonstrate the displacement of fossil fuels across the energy system, a distinction explored in my comparison of New York’s transition with global trends.

Conclusion

I responded to this post and the subsequent comments because I believe it addresses some important things about the existing fossil fired generators in New York.  The appropriate test is not whether a plant can be dismissed as a “relic,” but whether its replacement can demonstrably provide the necessary electricity, when and where it is needed, at an affordable

Over time Oswego and other generating stations have changed how they operate as fuel costs have changed.  Their ability to generate electricity when needed provides valuable support to the grid and that is why they have continued to operate.  All generating facilities comply with ambient air quality standards proven both by modeling but also by measurements.  I believe the existing NAAQS are sufficient to protect human health and welfare.  Many environmental advocates claim that there are impacts below those levels.  However, I have not seen analyses that show observed health benefits consistent with the reductions in emissions observed at all the power plants that have operated for decades. 

I commend the New York Energy Alliance for a well written explanation of the value of the Oswego Harbor Power Plant.

New Yorkers for Clean Power Testimony Ignores the Costs

On October 19, 2026 New Yorkers for Clean Power released a video of testimony it submitted at the Joint Legislative Public Hearing on the 2026 Executive Budget Proposal for Environmental Conservation and Energy held in Albany on January 28, 2026. The testimony summarizes the arguments Climate Act advocates make about affordability, health, funding, building electrification, and distributed solar. This post responds to six claims in that testimony using analyses I have already published. It is a condensed version of the first draft that was too long but I have provided a link to the full version that provides more detail and documentation.

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. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 680 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 and references included in this document.

Overview

The testimony argues that “affordability is the dominant theme of today’s energy zeitgeist” but that “the fossil fuel industry and their business partners are deceptively exploiting this to stall New York’s progress towards a clean, sustainable, and ultimately more affordable energy future.” It blames high bills on “the fossil fuel status quo and an aging energy infrastructure,” and asks the Legislature to renew the $1 billion Sustainable Future Program, fund building electrification, and lower the hurdles for distributed solar and batteries.

The testimony was given before the FY2027 budget was enacted. The final budget included another $1 billion for the Sustainable Future Program, but it also included major rollbacks to the Climate Act. The advocates got their money, but the Hochul Administration admitted that the original schedule was unaffordable.

What is Affordable?

I agree that affordability is the dominant energy issue. The problem is that the Hochul Administration has never documented the costs of the Climate Act and the State has never defined what is affordable. It is rich to claim critics are exploiting affordability when the State has yet to establish an affordability metric for the Public Service Law (PSL) §66‑p(4) safety valve.

PSL §66‑p(4) allows the Public Service Commission (PSC) to suspend or modify the renewable energy program if it finds “a significant increase in arrears or service disconnections.” As I explained in my Climate Act affordability status article, the PSC has never defined that phrase, and the 2026 Draft Clean Energy Standard Biennial Review does not advance the issue. The only metric in use is the PSC target that the low-income energy burden should be at or below 6 percent of household income, which excludes fuel oil, propane, and transportation costs.  I have been unable to find any documentation of how many customers meet this standard.

Meanwhile the evidence of an affordability problem keeps growing. As of December 2025, more than 1.3 million households were at least 60 days behind on their energy bills, owing more than $1.8 billion. The State Energy Plan estimated $120 billion in annual energy-system investments through 2040, or $1,282 per month per household. NYSERDA’s own analysis shows that Climate Act compliant equipment adds about $594 per month for an upstate moderate-income household heating with natural gas. My estimate of the total cost of the Climate Act exceeds $1 trillion through 2050.

I have proposed objective safety valve triggers, such as a low-income energy burden above 8.6 percent or a 15 percent year-over-year increase in arrears or disconnections. Those numbers can be debated, but having no numbers at all cannot be defended. Until the State defines affordability, tracks it, and reports on it, New Yorkers for Clean Power cannot claim that their vision is “ultimately more affordable” because that claim cannot be checked.

Health Benefits Claims Are Weak

The testimony claims that “prolonging our dependence on fossil fuel sets the stage for costlier and more volatile energy, not to mention higher pollution and healthcare costs.” My analysis of the Draft State Energy Plan found that the health benefits claims are not supported by the observed data.

The Draft Energy Plan claimed nearly $65 billion in societal value between 2025 and 2040 from health benefits. If those benefits were substantial, past air quality improvements should show up in the health records. They do not. When I compared observed PM2.5 concentrations with county asthma emergency department visit rates, only two of 16 comparisons showed a positive relationship. Correlation does not prove causation, but no correlation means there cannot be causation.

The projected improvements are also lost in the noise. The largest projected reduction of 3,600 asthma emergency room visits is only 24 percent of the standard deviation and 7.6 percent of the range of observed visits. If the projections are correct, nobody will be able to see the benefit.

I am not saying reducing air pollution has no benefits. However, New York’s air quality has already improved dramatically and the remaining benefits are small relative to natural variation. There are cheaper fixes. NYISO found that old New York City gas turbines produced about 2.5 percent of in-city energy but 28 percent of the NOx emissions during the June 2025 heat wave, and modern combined-cycle replacements would cut those emissions 89 percent.  That kind of practical fix is not possible in a policy framework that treats any new fossil investment as off limits.

What Caused the Unaffordability Crisis

The testimony states that “our energy unaffordability crisis is the product of the fossil fuel status quo and an aging energy infrastructure.” Natural gas prices did increase wholesale prices in 2025, and there is an aging infrastructure problem. However, state climate policy is a cause of both.

My article on what Blakeman could do and what Hochul did to New York utility costs documents that the System Benefit Charge and related charges total about $1.3 billion a year, and that total RGGI ratepayer costs are $1.6 to $2.2 billion a year. The RGGI allowance price was $9.30 when Governor Hochul took office and Auction 73 cleared at $37.65. The typical residential RGGI cost is now $91 to $125 a year, nearly quadruple the 2021 level.

The aging infrastructure problem is also a product of state policy. There have been 3.7 GW of fuel-secure retirements since 2019, while the 12 GW of 40-plus-year-old fossil units still in service are being run harder. The testimony notes that “New York has seen little reduction in fossil fuel pollution since the enactment of the CLCPA.” One reason is the decision to close Indian Point. New York RGGI source emissions had been reduced 47 percent until Indian Point closed, and the reduction dropped to 39 percent afterwards.

Sustainable Future Program and Cap-and-Invest

The testimony says “it is absolutely critical that the $1 billion sustainable future program is renewed each year with at least the same level of funding until the cap and invest regulations go into effect.” Where is this money coming from, and why should we expect emission reductions?

The money comes from New Yorkers. The program is a capital appropriation, and State capital spending is funded from bonds, pay-as-you-go taxes and fees, and federal funds. When I reviewed the FY2026 Executive Budget climate funding, there were no specifics about expected results. The second $1 billion installment allocates $500 million to building decarbonization and $300 million to renewables, but there is no accounting of tons reduced or cost per ton.

New York’s experience investing RGGI revenues is not encouraging. In Hochul and RGGI affordability I estimated that RGGI-funded investments cost about $583 per ton reduced and account for only about 4.7 percent of New York electric-sector reductions. Regionally, my June 2026 RGGI investment review found investments accounted for only 8.7 percent of observed reductions. The main reason for the reductions was fuel switching to natural gas that would have happened anyway.

There is no reason to expect New York cap and invest to do better just because it has a declining cap. RGGI’s new trajectory cuts allowances by more than 10 percent of the 2025 budget each year from 2027 through 2033, even though emissions have been flat since 2019, and the allowance bank could run out as early as 2032. A cap does not create zero-emissions alternatives. Without them, it only raises prices until the allowances run out. The NYSERDA memo that led Governor Hochul to postpone cap and invest projected allowance prices of $179.80 per ton in 2031 and upstate household cost increases over $4,000 a year.

Two Million Homes by 2030

The testimony claims that with adequate funding for EmPower+, weatherization, and Clean Heat programs “we can lower energy bills and meet our target of 2 million electric or electric ready homes by around 2030.” This is not a reasonable expectation.

The goal is one million electrified and one million electric-ready homes by 2030, which required increasing heat pump installations from about 20,000 to more than 200,000 units a year. In 2025, the Clean Heat Program and LIPA supported 28,608 heat pump projects. NYSERDA’s own Pathways analysis projects about 1.4 million residential heat pumps in 2040 under current policies. The State’s own planning agency does not think the target will be met.

Heat pumps make sense for homes heated with oil, propane, or electric resistance, and weatherization lowers bills. However, most New York homes heat with natural gas. Converting a home costs $14,600 to $46,200, and Richard Ellenbogen found that downstate heat pump customers pay about 35 percent more per therm than gas customers, and 56 percent more on the coldest days. Subsidies do not change the total cost; they shift it to taxpayers and ratepayers.

Sunshine is Not Free

The testimony claims that lowering hurdles for distributed solar and batteries “will reduce grid strain, unleash much needed new electricity generation fueled by free instate sunshine, and lower electricity costs for all New Yorkers.” Calling sunshine free is misleading, and when all the support costs are included it will not lower costs for everyone.

As I pointed out when NYSERDA used the same argument, sunlight may be “free” but there are costs to collect and use that energy. Someone else pays for the storage and backup needed when the sun does not shine, and those support costs are more than half the total cost of a zero-emissions grid. Ellenbogen showed that solar at $40 to $60 per MWh rises to $110 to $150 per MWh with storage. The claimed $1 billion in annual ASAP Act savings ignores net metering cost shifts to non-participants.

Distributed solar does not reduce grid strain when it matters most. Winter peaks occur after dark. During the January 2026 cold snap, solar produced virtually nothing from January 25 until early February, and wind and solar provided less than 10 percent of total energy for 17 consecutive days. In fairness, rooftop solar on large downstate buildings that use all their output can be cost-effective without subsidies. That is a far cry from lowering costs for all New Yorkers.

Conclusion

What is missing from the testimony is documentation. The concerns I raise come from the State’s own documents. The Comptroller found that PSC and NYSERDA plans did not project costs or assess what ratepayers can bear, the State argued in court that meeting the 2030 target would impose “insurmountable upfront costs”, and the Legislature rolled back Climate Act targets this year.

My analyses show the testimony’s claims do not hold up. The State has not defined what is affordable. The health benefits are not supported by observed data. The Climate Act and RGGI have increased costs. Cap-and-invest revenues do little to reduce emissions. The two million homes target will not be met. Sunshine is not free.

Before New Yorkers are asked to spend another dollar on these programs, the PSC should define the PSL §66‑p(4) affordability criteria, the State should publish a full accounting of Climate Act costs, and every program should report verified emission reductions and their cost per ton. Until then, the “clean, sustainable, and ultimately more affordable energy future” promised in this testimony is a slogan, not a plan. More detail is available in the full version.

What Blakeman Could Do and What Hochul Did to New York Utility Costs

Updated 10/18/2026 grid plan consistent with NYISO reliability planning

New York Focus recently published a fact check titled Can Blakeman Cut Utility Bills in Half on Day 1? It concluded that the Republican candidate for governor has offered “next to no detail” about how he would keep that promise. I agree that no governor can cut electric bills in half on the first day in office. However, the article treats the question as if the only levers are the clean-energy surcharges on the bill. This post describes what a governor serious about affordability could actually do, and what Governor Hochul has already done that has driven costs up.

As a retired air‑pollution meteorologist who has spent a career worrying about both the air people breathe and whether the lights stay on, 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. 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 and references included in this document.

Overview

Bruce Blakeman has said, “On day one when I become governor, I will cut your electric bills in half.” His campaign told New York Focus it would credit ratepayers with $2.4 billion from what it called Hochul’s “Energy Tax slush fund,” permanently eliminate the System Benefit Charge, and scrap “radical carbon mandates.” That is a slogan, not a plan. But the choice is not between a slogan and the status quo. A governor can act through appointments, agency direction, and the regional programs the state participates in. Those actions will not halve bills overnight, but they would stop the policy-driven cost increases Hochul has imposed or allowed and address the reliability problems NYISO keeps warning about.

What the Fact Check Missed

The article makes fair points. The System Benefit Charge and related clean-energy charges total about $1.3 billion a year, 5 to 9.5 percent of an average household bill, so eliminating them alone would not halve bills. Reversing the fracking ban requires the Legislature. And Charles Hua of PowerLines correctly notes that the governor appoints all seven Public Service Commission (PSC) commissioners.

What it misses is the full cost of state climate policy. It says the Regional Greenhouse Gas Initiative (RGGI) costs New Yorkers “more than $500 million a year.” That counts only auction proceeds. I estimate direct allowance costs in New York at $0.7 to $1.1 billion a year at current prices, and total ratepayer costs including the wholesale price effect at $1.6 to $2.2 billion. Whenever a fossil unit sets the clearing price, the allowance cost is paid to every generator, and that money never becomes auction revenue that can be rebated.

The article also repeats NYSERDA’s claim of $6 in customer savings for every $1 spent. I evaluated that claim and found it uses a projected lifetime savings claim for participants, not verified savings for all ratepayers. My review of RGGI investment reports found that RGGI-funded programs explain only about 8.7 percent of observed power-sector reductions, and that cost-effectiveness deteriorated from about $949 per ton in 2022 to about $3,200 per ton in 2024.

Finally, the NYISO market monitor agrees that retail bills are rising mainly because of transmission and distribution charges. The article never asks how much of that spending exists because of Climate Act mandates. The same presentation identifies RGGI compliance costs, along with gas prices, as the primary reasons wholesale charges have risen.

What Hochul Did

The Climate Act

The Climate Act was signed by Governor Cuomo in 2019, but Governor Hochul has owned its implementation since August 2021. Her administration finalized the Scoping Plan, approved renewable and transmission procurements charged to ratepayers, and defended unattainable targets but has never provided a feasibility analysis that shows the total system costs of the net-zero transition, The 2026 Draft Clean Energy Standard Biennial Review projects only 40 percent of 2030 load will be met by renewables against a 70 percent mandate.

This year’s budget replaced the 40 percent by 2030 reduction target with 60 percent by 2040, changed the emissions accounting, and extended the DEC regulatory deadline to December 31, 2028. Those changes improve the numbers on paper but leave the 70 percent renewable by 2030 and zero-emissions electricity by 2040 mandates in Public Service Law §66‑p that drive electric-sector costs.

RGGI

New York remains in RGGI, and the Hochul administration supported the tighter cap that is driving prices up. The first auction after she took office, in September 2021, cleared at $9.30. Auction 73 in September 2026 cleared at $37.65, and all Cost Containment Reserve allowances were sold, so none will be available at Auction 74. The revised cap calls for cuts of more than 10 percent a year from 2027 through 2033, which could exhaust the allowance bank as early as 2032. DEC and NYSERDA adopted the implementing amendments in August without adequately addressing consumer costs or emissions leakage.

Cap and Invest

Hochul proposed cap and invest in 2023, then repeatedly delayed the regulations. In February, NYSERDA’s own memo estimated that compliance with the original law would push allowance prices to [$179.80 per ton in 2031, raise upstate gas and oil household costs by more than $4,100 a year, and add $2.23 per gallon to gasoline](). She used that memo to justify postponing the program, but she did not kill it. At $120 per ton, I estimate it would add 6 to 7 cents per therm to gas and 1 to 2 cents per kWh upstate and 4 to 5 cents per kWh downstate to electricity.

The Safety Valve She Never Used

PSL §66‑p(4) allows the PSC to “temporarily suspend or modify the obligations” of the renewable program after a hearing and a finding that it impedes safe and adequate service, impairs existing obligations, or has significantly increased arrears or disconnections. Hochul’s PSC has never defined criteria for those findings or held that hearing.

Credit Where It Is Due

Her administration approved the Northeast Supply Enhancement (NESE) pipeline’s water quality certification in November 2025, and a federal appeals court upheld it in August. Her campaign also cites a billion-dollar rebate package, the Excelsior Power thermostat program, and making data centers pay for their power. But rebates return a fraction of what policy costs ratepayers, and her DEC is opposing the Constitution Pipeline at FERC.

What Blakeman Could Do

Get out of RGGI or cap the allowance price

Ken Girardin of the Manhattan Institute told New York Focus that New York could leave RGGI, as Pennsylvania and Virginia did. New York’s participation is implemented through DEC and NYSERDA regulations, giving a governor an administrative path, although Virginia’s experience shows an exit will be litigated. If leaving is not feasible, New York should use the RGGI program review to insist on a hard ceiling of $10 or less, roughly where prices were when Hochul took office. Scaling my direct-cost estimate suggests savings on the order of $0.5 to $0.8 billion a year before wholesale effects. New York cannot impose a cap unilaterally, but as one of the largest participants its threat to leave carries weight.

Direct the PSC to address the §66‑p(4)  safety valve

A new governor can direct the PSC to open a §66‑p(4) proceeding, define objective affordability and reliability criteria, and decide on the record whether program obligations should be suspended or modified. No new legislation is needed.

Require a grid plan consistent with NYISO reliability planning

The PSC should develop an electric system plan that starts from NYISO’s reliability findings, not renewable targets, and then decide the most competitive way to get needed units built. The market monitor describes a “planning-market gap” in which the capacity market does not pay enough to keep or build what planners say is needed, and states there is a “critical need for policy to allow fossil fuel generation on the horizon.”

Update 10/18/2026:  Marie French said that NYISO president and CEO Rich Dewey  at the Multiple Intervenors conference for large energy users on 10/15/2026 “made it clear that Gov. Kathy Hochul’s administration will have to play a role in addressing projected reliability problems”.  She quoted him as saying:

We have no authority to compel anybody or actually finance those projects to come forward.  We’re going to try to create the market constructs so that developers and projects will come forward and want to invest in New York, but it’s really going to involve cooperation on the part of New York state.

Get NESE, Constitution, and other pipelines in services by 2028

Williams targets fourth-quarter 2027 service for NESE, but the Third Circuit vacated New Jersey’s water quality certification. A New York governor can publicly support prompt reissuance. For Constitution, the governor can withdraw DEC’s opposition at FERC and review a complete application on the merits; Williams targets fourth-quarter 2028 service. New York should also support neighboring states pursuing similar projects.

Pipelines matter for electricity too. During Winter Storm Fern, cold weather tightened regional gas markets, limited generator flexibility, and increased reliance on oil-fired generation. The market monitor attributed most of the 66 to 79 percent increase in 2025 energy prices to higher gas prices, especially in winter.

Strategically locate new and repowered units

New generation should go where NYISO says it is needed to minimize new transmission and congestion. I suggest two facilities on Long Island, one or two in New York City, one in the Hudson Valley, and two upstate:

Repowering also improves air quality. During the June 2025 heat wave, old New York City gas turbines produced about 2.5 percent of in-city energy but 28 percent of NOx emissions.

Immediate Action is Necessary

No matter who is Governor the existing market outcomes show how fragile the system is:

High energy prices hurt households and discourage the manufacturers and data centers the state wants to attract. A system with 417 MW of operating margin cannot absorb large new loads without new supply. Consumer affordability and future economic development are at risk.

Conclusion

Blakeman’s promise to cut bills in half on day one is a slogan, not a plan, and he should explain “the how, not just the what,” as Girardin put it. But Blakeman can enact a credible plan that puts affordability and reliability ahead of political targets: leave RGGI or cap allowance prices, use the §66‑p(4) safety valve, plan the grid from NYISO’s reliability findings, get the pipelines built, and site new and repowered generation where it is needed. Most of it can start immediately through appointments and agency direction.

Governor Hochul’s record is the baseline. Her appointees to the Climate Action Council have addressed affordability with slogans not actionable plans. As an aside, I believe there is a world of difference between Blakeman’s campaign slogans and Hochul’s program implementation slogans that directly impacted New Yorkers.  She implemented the Climate Act until its costs became politically impossible to ignore, kept New York in RGGI as allowance prices quadrupled, and postponed but did not kill cap and invest. Her 2026 rollback admitted the original plan was unaffordable but left the electric-sector mandates that drive costs in place.

Because of its importance, I repeat – No matter who is Governor, the winnder must address the issues soon, because the current system is fragile and New Yorkers cannot afford more of the same.

Shepherd’s Run Solar Permit Denied

On October 14, 2026 the New York State Office of Renewable Energy Siting and Electric Transmission (ORES), part of the Department of Public Service, denied the permit (decision and press release)  for Hecate Energy’s 42 MW Shepherd’s Run solar project in the Town of Copake, Columbia County (ORES DMM Matter Number 24-03041). In June 2024 I wrote about this project in Solar Developer “Disinformation” Reality after Hecate’s project director blamed fossil-fuel funded disinformation for local opposition. At that time I concluded that the first application was rejected only because of a last-minute loss of land control and that, but for that technicality, it would have been approved despite well-founded local concerns. This time the application was denied on the merits. This post describes what happened since my earlier post and Hecate’s options.

I have followed the Climate Leadership and Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.  I acknowledge the use of Perplexity AI to research the material summarized in this article and prepare an initial draft.

Overview

ORES was created in 2020 to speed permitting of large renewable facilities and can override local laws it finds “unreasonably burdensome” in view of the Climate Act targets. According to the DPS press release, ORES has issued permits for 38 renewable facilities totaling more than 5,400 MW since 2020. This is only the third time a large renewable project has been denied through a state permitting process, and two of the three denials are Shepherd’s Run.

From Dismissal to Second Application

The project was first proposed in 2017 as a 60 MW facility near the intersection of Routes 23 and 7 in Copake, NY. Note that in my 2024 post I described the earlier project as 42 MW but the original application was for 60 MW. ORES issued a draft permit on October 24, 2023 but in January 2024 Hecate lost control of 59.77 acres when a parcel was sold, as described in a letter from State Senator Michelle Hinchey. On February 6, 2024 the ORES Executive Director dismissed that application without prejudice to a new application for a modified facility.

Hecate did not walk away. According to an ORES ruling on a Town motion, Hecate began pre-application filings for a downsized project on February 27, 2024 and filed the new 42 MW application on December 23, 2024. A Town motion to reject the application was denied. The redesigned project would occupy about 215 non-contiguous acres of a 723-acre site of farmland, forest, streams, and wetlands, part of which lies in a FEMA Zone A flood hazard area, according to a Hodgson Russ summary.

ORES issued two notices of incomplete application in 2025, the second on June 27, 2025 listing eleven deficiencies, as reported by The Millerton News. That summer a Hecate lender that had loaned the company $82 million asked the Delaware Chancery Court for a restraining order, claiming “Hecate Holdings is woefully insolvent, strapped for cash, and drastically overleveraged.” A second creditor followed with a similar motion. Hecate denied the claims. Sensible Solar for Rural New York asked ORES to hold the application pending due diligence on Hecate’s finances.

ORES nonetheless deemed the application complete on September 19, 2025 and published draft permit conditions on November 18, 2025, finding that the project “avoids, minimizes, or mitigates, to the maximum extent practicable, potential significant adverse environmental impacts,” according to The Millerton News. Importantly, draft permit condition 3(b) required Hecate to comply with Copake’s floodplain law, Chapter 135. Public comment hearings were held in Copake on January 21 and 22, 2026, with a virtual hearing on January 27, where speakers were overwhelmingly opposed.

The Issues Ruling and Interim Decision

Hecate asked to be exempted from the Town’s floodplain code. On June 25, 2026 administrative law judges (ALJs) Maureen Leary and Dawn MacKillop-Soller issued a 225-page ruling that refused the waiver and found that Hecate relied on outdated wetlands delineations from 2019 and 2020, as reported by Mid-Hudson News. They ordered new field studies and an evaluation of whether any wetlands qualify as “wetlands of unusual importance.” However, they concluded these problems could be fixed through post-permit compliance filings.

Both Hecate and the Town appealed. On August 13, 2026 Interim Executive Director Jason Zehr disagreed on that key point. According to Hodgson Russ, he found that “where record evidence is absent, the use of compliance filings is inadequate, inasmuch as the information obtained in such filing may result in a major project modification, the imposition of additional site-specific conditions, or even permit denial.” He remanded the wetlands and floodplain issues for an expedited adjudicatory hearing and ordered a revised draft permit put out for comment. Hecate agreed to extend the decision deadline to October 19, 2026.

The Hearing and Recommended Decision

The adjudicatory hearing was held at Copake Town Hall on September 14, 2026. ORES staff, Hecate, and the Town were the parties, and the Department of Environmental Conservation (DEC) provided evidence. After the hearing ORES staff still recommended that the draft permit be made final with “further analysis of wetlands” and said no further conditions were needed to address Chapter 135.

The ALJs disagreed. Their October 5 Hearing Report recommended denial. According to Hodgson Russ the ALJs found:

  • The wetlands delineation relied on 2019/2020 fieldwork and used the Army Corps of Engineers manual rather than the DEC manual with New York-specific vegetation criteria.
  • Several wetlands, including some beneath proposed arrays, were treated as unregulated even though they connect to a Class I wetland.
  • Hecate did not look for wetlands of unusual importance.
  • Hecate never provided a base flood elevation, and its hydrology study used a 100-year, 24-hour storm depth of 5.29 inches rather than the NOAA value of 7.96 inches, without explanation.
  • Even on its own estimates, an inverter and several posts would need to be moved or raised, but those changes were not in the application, nor was a plan to stow panels during a power loss.

As a meteorologist I find the rainfall input telling. A design storm one-third smaller than the NOAA standard is not a minor choice in a flood zone.

The ALJs also wrote that “Hecate’s actions during the adjudicatory phase were not in good faith,” according to The Millerton News. Hecate limited the Town’s experts to already-delineated areas and did not provide access until the day before the hearing.

The Final Decision

The Final Decision adopts the ALJs’ ultimate recommendation but departs from some of their reasoning. It rests on two independent grounds.

First, on floodplains, the Interim Executive Director concurred with DEC that Chapter 135 implements the National Flood Insurance Program under Environmental Conservation Law Article 36, that the Town has exclusive authority to determine compliance, and that ORES cannot waive it. Article VIII still requires ORES to make an affirmative finding that the project can comply. He found the evidence absent on base flood elevations, the reliability of the hydrology inputs, whether components would be inundated, how panels would be controlled during a flood, and siting near or within a floodway.

Second, on wetlands, he found the record “not clear as to the full extent of wetland resources in the project area.” The Legislature amended the freshwater wetlands law in 2022 to protect smaller wetlands of “unusual importance,” including those in floodways or in watersheds prone to severe storm flooding. The delineation report was labeled “Updated January 2023” but never mentioned the amended definition. He also called Hecate’s site access restrictions “inexplicable and unacceptable.”

However, the decision defends ORES staff. The ALJs had found the April 2024 wetlands jurisdictional determination invalid because it reissued the 2021 determination without new data, a site visit, or the DEC consultation it claimed. The Interim Executive Director held that the burden of producing accurate information “unequivocally falls on the Applicant” and that staff’s reliance on the earlier determination was a reasonable exercise of professional judgment. In a footnote he conceded that in the future “ORES best practice should be to conduct a site visit to determine whether changes in law may change the impacts analysis.”

Hecate’s Options

Hecate now has a few options:

  • Hecate can walk away, which would be the most rational response. After nine years and two failed applications, with lenders claiming it is insolvent, it is hard to see the business case for continuing.
  • Hecate can appeal the permit denial to the Appellate Division, Third Department, in the form of an original Article 78 proceeding. Under the siting statute, now Public Service Law § 146 as noted in a recent Third Department decision, the petition must be filed within 90 days of the final decision. If that happens the town should be a necessary party. Because the denial rests on missing evidence that Hecate had the burden to provide, that would be an uphill fight.
  • Hecate can complete updated wetlands delineations and flood zone analysis, and attempt to file a third application. If that happens the town could file an immediate motion to dismiss based on caselaw indicating administrative permit denials should be final. A third application would also have to meet DEC’s 2025 wetland regulations, and any new delineation would have to cover the wetlands of unusual importance that Hecate never looked for.

Discussion

The press release emphasizes that the Town used $42,000 in local agency account funds to hire experts and that “the Town’s participation, including expert evidence concerning wetlands and flood protection, contributed to the record.” That is true, but it understates what happened. ORES staff found the application complete, issued a draft permit, and recommended issuance even after the hearing. DEC’s position on Chapter 135, the ALJs’ findings, and the Town’s experts are what produced the denial. Copake has been fighting this project with its own attorneys and engineers since 2020, and I would be surprised if $42,000 covered more than a small fraction of those costs. Most towns do not have Copake’s resources.

ORES accepted a wetlands determination based on 2019 and 2020 data that ignored a 2022 change in state law, and only adversarial review exposed the problem. Had a town without Copake’s resources faced this application, I believe the permit would have been issued.

It is worth returning to the “disinformation” claim. In 2024 Hecate’s project director argued that opponents relied “on false or misleading claims about farmland being permanently destroyed, adverse impacts to nearby watersheds, and reduction in property values.” The watershed concerns turned out to be the reason the permit was denied. The record showed that Hecate’s own analysis understated the wetlands and flood risk on the site.

Finally, the issue I emphasized in 2024 was not addressed. Representative Josh Riley says the project would have converted roughly 215 acres of productive farmland. My earlier analysis showed the project exceeded the Department of Agriculture and Markets guideline of no more than 10% conversion of the best soils. The denial turned on wetlands and floodplains, not farmland. The Hochul Administration still does not require utility-scale solar developers to meet the Agriculture and Markets prime farmland guidelines.

Conclusion

Shepherd’s Run was denied because Hecate could not show that its project would avoid wetland impacts or comply with a floodplain law tied to federal flood insurance. That is the right outcome. But it took nine years, two applications, a determined and well-funded town, a DEC intervention, and two judges willing to make what one observer described as the first recommendation by DPS judges to deny a solar permit since ORES was created. The real lesson is that the ORES process approves projects unless someone with the money and expertise to build an evidentiary record proves the developer wrong. Siting standards that protect farmland, wetlands, and host communities should be built into the rules, not left to local governments to enforce by litigation.

Grid of the Future Rate Petition

A coalition of environmental organizations wants the Public Service Commission (PSC) to use its upcoming Grid of the Future plan to lower electric delivery rates for customers who heat with electricity. I agree that utility rates should reflect the costs customers impose on the system. However, this petition is a narrowly targeted rate change designed to accelerate heat pump adoption, and it never asks the question that Governor Hochul’s new Energy Infrastructure Development Plan (EIDP) is supposed to answer: what electric system will serve all that new winter load reliably and affordably? This post explains the petition, how it fits with the EIDP, and why I think the order of operations is backwards.

I am convinced that implementation of the Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed and have written extensively about New York’s net-zero transition. I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available technology. 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 research the material summarized in this article and prepare an initial draft.

Overview

The Climate Act established a New York “net-zero” target (85% reduction in greenhouse gas emissions and 100% carbon neutral by 2050) and requires a zero-emissions electric system by 2040. Electrifying building heat is central to the state’s strategy, which means the electric system must handle a large new winter heating load. That is why rate design for electric heat customers matters, and why it cannot be separated from the question of what resources will serve that load.

On October 6, a coalition of advocates held a press conference urging the PSC to reform electric rates before the Department of Public Service (DPS) releases its updated Grid of the Future plan. That plan is now due October 30, 2026, after the deadline was extended from June 30. The press conference publicized a May 5 petition filed by the Environmental Defense Fund, Alliance for a Green Economy, Building Decarbonization Coalition, Earthjustice, New Yorkers for Clean Power, Rewiring America, and Sierra Club hat argued that a special electric rate for heat pumps was appropriate.

In May, I published a guest post by Scott Endler that addressed an earlier iteration of the proposal from these organizations.  He made a persuasive argument that carving out a special rate class for heat pumps is the wrong fix; a capacity‑based, technology‑neutral delivery charge tied to real‑time grid conditions would be fairer, more durable, and far more honest about who actually drives system costs.  I think this issue needs to be addressed again.

What the petition asks for

The supporting filing includes letters from heating equipment and HVAC businesses, including Mitsubishi Electric and Daikin Northeast; a letter signed by 78 advocacy organizations; comments from the NYU Institute for Policy Integrity; and a letter from state legislators led by Senator Liz Krueger and Assemblymember Anna Kelles. The legislators’ letter explicitly ties the request to the state’s electrification goals.

At the press conference, advocates added two more ideas. New Yorkers for Clean Power claimed that virtual power plants (networks of household batteries, smart thermostats, and electric vehicles) could avoid almost $3 billion a year in grid costs, based on a Brattle Group study estimating 8.5 GW of flexible resources by 2040. The Solar and Storage Industries Institute promoted “flexible interconnection,” where solar projects connect without expensive upgrades in exchange for curtailing output when local lines are overloaded. In May I addressed this gimmick.  In brief it has no value during extended periods of light winds, low solar availability, and snow-covered solar panels.   It simply cannot provide necessary power to replace an existing peaking power plant during these periods.  I do not think we cannot afford to invest in these “solutions” that do not work when needed most.The petition’s core claim is based on an analysis by the nonprofit Switchbox. It says that households that heat with heat pumps have an electric delivery cost of service only 2% higher than gas-heated households, but their delivery bills are 109% higher. The result, according to the petitioners, is that heat pump customers overpay about $855 per year and electric resistance customers about $873 per year. Statewide, the petition estimates overpayments of about $170 million for heat pump customers and $570 million for electric resistance customers, or about $740 million per year in total.

Their argument is straightforward. Residential delivery rates recover much of the fixed cost of poles and wires through a flat per-kilowatt-hour charge. Heat pump customers use a lot more electricity in the winter, when the system currently has spare capacity, so they pay more than the costs they cause. The petition asks the PSC to:

  • Include a directive in the Grid of the Future plan to offer rate options for electric heating customers, followed by a technical workshop within 60 days;
  • Direct utilities to implement cost-of-service-based delivery rates for electric heating customers by December 31, 2027; and
  • Require customer outreach and public reporting of rate and participation data.

What the Petition Gets Right

I want to be fair about this. Cost causation is a sound ratemaking principle, and I have consistently argued that policies should be judged by the full costs customers actually pay. If a customer class is paying substantially more than the cost to serve it, that deserves examination.  However, ratepayers deserve the full accounting for the future energy system not just cost estimates from organizations with vested interests.

The petition also makes a legitimate equity point. Electric resistance heat is common in older rental units, and those tenants usually have no ability to switch heating systems. If they are overpaying by hundreds of dollars a year, that is a real affordability problem regardless of anyone’s climate goals.

Where the petition falls short

It shifts costs; it does not reduce them

The delivery system costs the same no matter how rates are designed. The petition itself explains that when revenues from electric heat customers exceed their cost of service, the excess is returned to all ratepayers. Lowering rates for electric heat customers therefore means raising them for everyone else. If the $740 million estimate is right, that is the amount that would move onto the bills of gas-heated households and homes that use propane and fuel oil, many of whom are also struggling with affordability. The petition models “other customers on adjusted default rates” but does not commit to a revenue-neutrality test or show the bill impact on the customers who would pay more. Any honest description of this proposal has to say that someone else picks up the tab.

It assumes a winter grid that will not last

The whole overpayment argument depends on the grid being “generally less constrained” in winter. The petition does not discuss what happens when that is no longer true. The news coverage of the press conference itself notes that NYISO expects New York to become a winter-peaking system by the mid-2030s. Heat pump load is the main reason why.

In other words, if the discounted rates succeed in their purpose, they eliminate their own justification. Once winter becomes the peak, cost-based rates for electric heat customers would have to go up, not down. Any discounted rate approved now should include an automatic review tied to the seasonal peak so that customers are not promised savings that cannot be sustained.

It ignores supply and the dark doldrums

The petition addresses delivery rates only and says supply charges are a separate matter. From a reliability standpoint, though, supply is the hard part. As a meteorologist I know that the coldest periods are typically associated with high pressure, light winds, and short days with low sun angles, i.e., dark doldrums. During those conditions heat pump efficiency drops, backup resistance heat kicks in, wind and solar output can be minimal, and natural gas is in highest demand for both heating and power generation. Pushing more heating load onto the electric system without a plan for dependable generation during those periods moves risk from the gas system to the electric system.  In my opinion, that increases risk because the gas system is less likely to be impacted by weather related outages.

Virtual power plants do not solve this problem. Shifting a thermostat setting or a battery charge by a few hours helps on a summer afternoon peak. It does not provide energy through a multi-day arctic outbreak. The $3 billion savings figure is a modeled estimate that depends on future customer participation, not a verified result.

The savings claims do include capital costs

The petition says that under its proposed seasonal rate, 72% of gas-heated households would save money by switching to heat pumps, compared with 27% under current rates. As far as I can tell, these are comparisons of annual energy bills. They do not appear to include the installed cost of heat pump equipment, ductwork, electrical service upgrades, or building envelope improvements, which are the major barriers for most homeowners. A rate discount that improves the bill comparison does not make the capital cost go away. It is also worth noting that several supporters of the petition sell the equipment that would benefit.

How this fits with Hochul’s EIDP

Governor Hochul announced the EIDP on September 22 as a state-led integrated planning process to identify the generation, transmission, storage, and distributed resources needed to serve growing load reliably while controlling costs. As I noted in my earlier post, the EIDP is a process, not a plan: an interim plan is due in 2027 and the first comprehensive plan by December 2029.

IssueRate PetitionEIDP
ScopeDelivery rates for electric heat customers onlyIntegrated generation, transmission, storage, and distributed resources
Load growthDesigned to accelerate electrification loadSupposed to plan for that load
Winter peakAssumes the winter grid has spare capacityMust plan for a winter-peaking system
Supply and reliabilityNot addressedCentral purpose, but firm-capacity needs not yet quantified
TimingNew rates in place by end of 2027Interim plan 2027, comprehensive plan December 2029

Both efforts fit under the Governor’s affordability-and-electrification messaging, but they pull in different directions. The EIDP is supposed to decide what system New York needs. The petition would lock in rates designed to increase winter demand on that system before the planning is done. That is the same problem I have raised about the Climate Act transition as a whole: New York keeps adopting policies to drive the transition before deciding what energy system it wants and confirming that it can be built and operated reliably.

Recommendations

If the PSC takes up this petition, I recommend the following conditions:

  • Require revenue neutrality and full disclosure. Any new electric heat rate should come with a public estimate of the bill impact on every other customer class.
  • Build in a sunset tied to the seasonal peak. Discounted winter delivery rates should be reviewed automatically as the system approaches winter peaking.
  • Address electric resistance customers on their own merits. The equity case for low-income renters is stronger than the case for subsidizing new heat pump installations and should be considered separately.
  • Tie electrification incentives to EIDP resource adequacy findings. The state should not use rate design to accelerate winter load growth until the EIDP identifies the dependable resources that will serve it during extended cold weather.

Conclusion

The petition does not address the issues Scott Endler raised last May.  

I agree with the principle behind this petition: customers should pay rates that reflect the costs they cause.  However, the petition applies that principle selectively, to a system condition that its own success will change, and only to delivery costs. It shifts hundreds of millions of dollars onto other ratepayers and says nothing about how the electric system will keep the heat on during the coldest days of the year. The Grid of the Future plan should not put rate incentives for electrification ahead of the Energy Infrastructure Development Plan’s job of determining what system New York actually needs. Once again, the state is being asked to accelerate the transition before it has a plan that shows it will work.

NY Energy Infrastructure Development Plan: The Chickens Are Coming Home to Roost

On October 9, 2026 Doreen Harris announced that the New York State Energy Planning Board (Board) will convene on December 9, 2026 to kick off the new Energy Infrastructure Development Plan (EIDP) process.  Earlier this week I characterized it here as process commitment, not the planning commitment I think is needed.   I also had a description posted at the Empire Center for Public Policy. Richard Ellenbogen also responded to the EIDP this week in an email.  This post reproduces his email modified only for posting format. 

Ellenbogen is the President [BIO] of Allied Converters and frequently comments on various issues associated with the New York Climate Leadership and Community Protection Act (Climate Act). I have published other articles by Ellenbogen.  He is an engineer who truly cares about the environment but understands the practicality of clean energy solutions based on his experience as an early adopter of renewable technologies at both his home and business two decades ago.

After Seven Years of NY State’s Failing Energy Policies, The Chickens Are Coming Home to Roost

NY State has been chasing impractical energy goals since they passed the CLCPA in 2019.  Several of us warned the state about the shortsightedness of their policies at that time.   This week, NY State announced the Energy Infrastructure Development Plan (EIDP), while stating, ” The EIDP will complement New York’s existing energy planning process, with the goal of better coordinating how and when new clean energy sources come online.  We’re going to have to build out just a tremendous amount of all of these resources, and we want to make sure that we do it in the most cost-effective way, and we think that’s going to require, effectively, integrated resource planning.  The new initiative comes as the state’s independent grid operator, the New York Independent System Operator (NYISO), announced they are expecting a reliability shortfall in the next decade without state intervention.”

The reason that NY State has the reliability shortfall in the first place that the NYISO is documenting are the very policies that the Hochul Administration now seems to be doubling down on with the EIDP.  They have been focused on shutting down firm generation and putting all of their eggs in the renewable basket.  After seven years those eggs are hatching, and the chickens are coming home to roost as will be clearly documented below.  

The EIDP complementing Energy policies that aren’t working won’t make them work any better.  It will only throw good money after bad and raise costs.  That is currently happening with NYPA’s purchasing solar arrays that the private developers can’t afford and ultimately dumping the costs onto the backs of ratepayers and taxpayers while claiming to perform a public service.

A large reason for the debacle is that whenever engineers propose a plan, one of the first steps is to ensure that the resources exist to make the plan work.  However, NY State’s Energy Plan wasn’t designed by engineers.  It was designed by a biologist and some climate activists and  NY State skipped the resource adequacy step with their energy planning.  The state has evidently been hoping for the past seven years that a fairy godmother would step in to fix the mess because nothing in the current planning coming out of Albany is going to address the issues.  In August 2023, I wrote a document for the PSC as part of 15-E-0302 explaining why the CLCPA would not work.  On page 4 of the filing, the following five issues are documented.  Note the issues documented in number 2, below.

In the last week, two documents have been published.  One was sent out by Robert Bryce on his Substack titled “The Great Grid Hardware Shock“, and clearly documents the rapid rise in equipment costs, much of it due to shortages.  For example, there has been an acute transformer shortage for many years.  A second document published on October 4, titled “The World is Running Out of Ore“, shows that the world is running out of copper.  The use of renewable generation compounds the problem.  Why is that?  

The following table shows the land areas and annual energy outputs of 500 Megawatt generators in solar, wind, gas, and nuclear.  

As the power capacities are all the same, the electrical conductors will have to be similarly sized for the peak power output but as can clearly be seen, the solar array is 230 times larger per Terawatt-hour than the equivalent sized gas plant (5070 acres vs. 22 acres) and only produces 30% of the annual energy of the gas plant  (740 GWh vs. 2492 GWh).  The full comparison uses numbers based on EIA documentation for NY State.  The vastly larger area will require far more transmission capacity for 30% of the energy output. 

For wind in NY State, the numbers are worse.  The wind farm is 1800 times larger per terawatt-hour than the gas plant.  The nuclear plant is five times larger per terawatt-hour than the gas plant, but it generates 62% more energy.  These numbers clearly explain why so many renewable projects are failing in NY State.  They are just too expensive so if NY State truly wants to be “Cost effective”, as they claim, they are going to have to rethink their policies. 

The CleanPath Project (Renewable Transmission Cable and Generation) that failed in late 2024 is an example of the issues.  It was too expensive for the amount of energy that it would provide.  The following graph, copied from “The World is running out of Ore” document, shows the relative ore costs per terawatt-hour of generation for various generating technologies.  It shows exactly what was explained previously.  The energy systems with a lower power density occupy much larger areas, generate less energy,  and have far higher costs per unit of energy generated.  

Source: The World is running out of Ore

It isn’t just copper that is in short supply.  Aluminum is also in short supply because several smelters have closed over the past several years due to high energy costs.  

Beyond the material shortages are the labor shortages. It requires far more labor to interconnect a 40,000 acre generating plant  than a 22 acre or a  100 acre generating plant.

In addition to the costs of the interconnections are the costs of the associated equipment needed to make renewables functional on the utility system.  That includes synchronous condensers needed to add grid inertia to a  renewable system.  Also needed will be large amounts of energy storage for times of low wind and sun.  Based upon NYSERDA’s 6 GW Energy Storage report, the required energy storage could cost between $2 Trillion and $3 Trillion to achieve the same functionality as the Combined Cycle Gas plants or the Nuclear Plants.  No one at the state level has ever explained where the trillions of dollars are going to come from.

The state government is talking about reducing energy costs while adopting policies that are going to increase costs and are simultaneously  impossible to implement due to resource inadequacy.

If NY State can’t build what they are planning, they will never solve the generation shortfall we are currently living with.  What the facts are showing is that there is no cost-effective way to build out the renewable resources that they seem determined to inflict upon the State’s ratepayers in opposition to math, physics, and economics.

It will only get worse as the older, existing firm generation plants fail because of age.  We will all be living in the dark and paying more for the privilege.

State Energy Planning Board to Kick Off New Energy Infrastructure Development Plan Process

In closing for my reader’s attention I enclose the text of the Doreen Harris announcement.  Ellenbogen and I agree that there is no suggestion that the State is really willing to address the challenges he has described here because there is no acknowledgement that there are issues.

I’m pleased to share that the New York State Energy Planning Board (Board) will convene on December 9, 2026. The meeting will kick off the new Energy Infrastructure Development Plan (EIDP) process as part of the ongoing New York State Energy Plan work to provide an actionable plan for the infrastructure that New York needs to modernize its power grid and keep pace with the energy demands of economic growth. Importantly, the plan will guide the State’s energy infrastructure investment decisions over the coming decades and supports Governor Hochul’s Climate Week directive as part of her Clean, Highly Affordable, Reliable Grid Expansion (CHARGE) agenda to advance affordable, abundant, reliable, and clean energy within New York State.

The Board and supporting State agency staff will establish a transparent process to release an interim plan in 2027 and to finalize the first comprehensive Energy Infrastructure Development Plan by December 2029. The forthcoming EIDP process will include multiple opportunities for energy industry stakeholders and the public to engage and provide input.

I invite you to attend the meeting to be held at the Albany Capital Center, Meeting Room 2B/2C at 55 Eagle St, Albany, New York beginning at 2:00 p.m. ET. This meeting is open to the public for listening, both virtually and in-person with registration.

I look forward to reconvening the Board to address New York’s energy needs through an expanded planning framework.

Stay tuned.

Hochul’s Energy Infrastructure Development Plan: Rhetoric, Not a Plan

My most recent post argued that  it is time for New York to decide what the future energy system should look like.  On September 22, 2026, Governor Hochul announced an Energy Infrastructure Development Plan (EIDP) as part of her Clean, Highly Affordable, Reliable, Grid Expansion (CHARGE) agenda. The announcement says the EIDP will provide “an actionable blueprint” for the infrastructure New York needs to meet surging electricity demand. In this post I describe what was announced and compare it to the recommendations I have made here for a reliability-first, affordability-driven approach to New York energy planning. My bottom line is that the EIDP gets the diagnosis right but, so far, it is more political rhetoric than a possible solution to the unfolding energy crisis.

I am convinced that implementation of the Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed and have written extensively about its implementation. I have spent over 50 years in the electric generation industry analyzing the effects of air pollution control policies on operations. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with; these comments are mine alone.  I acknowledge the use of Perplexity AI to research the material summarized in this article and prepare an initial draft.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes a requirement that all electricity generated be “zero-emissions” by 2040. The 2022 Scoping Plan outlined how to “achieve the State’s bold clean energy and climate agenda.” Since then, the gap between the Climate Act transition and reality has become hard to ignore, and the Hochul Administration has increasingly framed its energy messaging around affordability and reliability. The EIDP is the latest example.

What was Announced

According to the Governor’s press release, the Governor is “directing the New York State Energy Planning Board to engage in comprehensive integrated planning to ensure the State has a clear and actionable perspective on the infrastructure it needs to reliably meet demand.” The release says the plan “will guide the infrastructure investment decisions by the State over the coming decades.”

The announced approach “leverages the tools available to the State including neighborhood-scale alternatives, distributed solar, and energy storage, and coordinates the development of new utility-scale clean generation and transmission.” The stated outcome is that “the EIDP will ensure the lights stay on and that progress towards a zero-emission grid continues all while controlling costs.”

The schedule is the part that caught my attention. The release states that “the EIDP process kicks off this year as part of the State Energy Plan, with an Interim Plan due in 2027 and the first comprehensive plan finalized by December 2029.” The American Public Power Association and Harris Beach Murtha summarized the announcement the same way.

The EIDP builds on the 2025 State Energy Plan that the Energy Planning Board approved on December 16, 2025. That plan provides “broad program and policy development direction” with an outlook through 2040. I see the EIDP as an attempt to add an infrastructure-specific layer to that high-level policy document. Unfortunately it still proposes no feasibility analysis.

What the EIDP Gets Right

I want to give credit where it is due. For years I have argued that New York energy planning is poorly coordinated. Climate Act targets, Scoping Plan implementation strategies, NYISO reliability analyses, utility rate cases, NYSERDA procurements, transmission proceedings, and local siting decisions all proceed on separate tracks with no one responsible for making sure the pieces fit together. The EIDP announcement acknowledges that problem.

There are four points I can support:

  • The State now accepts that load growth from manufacturing, electrification, and data centers requires a different planning response than the flat-load assumptions of the past.
  • Generation, storage, transmission, distributed resources, and demand-side alternatives are being considered together in one infrastructure discussion.
  • The announcement says grid development must address reliable service and customer costs, not just emissions targets.
  • The state needs to reconcile the work of NYISO, the Public Service Commission, NYSERDA, NYPA, and the utilities.

Those are not trivial changes. The language is closer to the premise of a pragmatic system plan than anything that came out of the Scoping Plan process or the latest Energy Plan.

Where it Falls Short

The problem is that the announcement offers words like “reliably” and “controlling costs” without any commitment to the decision rules that would make those words mean something. The following table compares the EIDP announcement to the recommendations I have made.

IssueEIDP AnnouncementMy RecommendationMy Assessment
Planning philosophyComprehensive integrated planning by the Energy Planning BoardReplace siloed, target-driven planning with one integrated plan that reconciles load, retirements, generation, transmission, siting, and costsStrong agreement in principle
ReliabilityPromises to “keep the lights on”Use NYISO and New York State Reliability Council resource adequacy standards, including multi-day wind and solar lulls in winterNo reliability standard is defined
Load growthCentral motivation for the planSeparate committed load from speculative data center announcements and make new large loads pay for their own infrastructureRight diagnosis, no cost-allocation commitment
Resource mixDistributed solar, storage, “utility-scale clean generation,” transmissionProcure enough firm, dispatchable capacity; keep existing reliable units until replacements are proven.  This includes repowering existing and building new natural gas generation.Firm capacity is not mentioned
Dispatchable emissions-free resources (DEFR)Not mentionedQuantify the need, set milestones, and identify off-ramps if the technology does not show upThe biggest gap
NuclearNot mentioned in the EIDP announcementRetain and expand nuclear as the proven zero-emissions firm resourceUnresolved
Affordability“Controlling costs”Publish full-system costs and customer bill impacts for each pathwayAn aspiration, not a test
Siting“Cut through red tape”Make land use and community impacts real planning constraintsPotential conflict
TransparencyNot addressedPublish assumptions, models, and data; provide independent reviewUnproven
ScheduleInterim plan 2027, comprehensive plan December 2029Act now on known reliability risks and economic development risks.Too slow

The DEFR Problem is Still Being Ignored

Regular readers know that I consider the dispatchable emissions-free resource (DEFR) problem to be the central risk of Climate Act implementation. The NYISO 2023-2042 System & Resource Outlook projects that “at least 20 GW of DEFR capacity would be needed by 2040 to replace the current 25.3 GW of fossil generation,” and that “upwards of 40 GW” could be required. The NYISO lists candidate technologies such as long-duration batteries, small modular nuclear reactors, hydrogen-powered generators, and fuel cells. None of them is commercially available at the scale needed today. 

The EIDP announcement does not use the term DEFR. It does not acknowledge that quantifying how much firm capacity New York will need and when it will be needed is an enormous challenge but most of all it does not recognize the Immediate need for an off ramp if it does not arrive on time or the interim need for firm, dispatchable resources that must include natural gas repowering and new builds and fuel delivery pipeline expansion to address observed problems. Any infrastructure plan that leaves those issues out is not addressing the hardest part of the problem. Wind, solar, storage, and transmission do not substitute one-for-one for dependable capacity during an extended winter cold snap with low wind and little sunlight.

Affordability Needs a Number

“Controlling costs” is not a standard anyone can check. If the Administration is serious, the EIDP should publish, for each major pathway, the capital costs, interconnection and transmission costs, backup and balancing costs, distribution upgrades, land requirements, RGGI carbon costs, and resulting customer bill impacts. It should also say how much of the cost of serving new data centers and other large loads will be paid by those customers rather than existing ratepayers. Until those numbers are on the table, affordability claims are just claims.

“Cutting Red Tape” Works Both Ways

I support faster approval of projects that are demonstrably needed. However, the “cut through red tape” language worries me. My work on utility-scale solar projects such as Horseshoe Solar shows that the permitting process is often the only place where local land-use, agricultural, and community impacts get any consideration. Streamlining without siting safeguards could simply accelerate energy sprawl. The EIDP should compare alternatives by energy density and land use, and consider rooftop and parking lot solar, brownfields, existing transmission corridors, repowering, and low-footprint firm generation.

The Schedule Does Not Match the Risk

An interim plan in 2027 and a first comprehensive plan in December 2029 provides little comfort because there are problems now. During January and February 2026, New York energy consumers were forced to bear $800/MW energy prices, Special Case Resource Winter Dispatches, and high system uplift because our aging generation portfolio was stressed. Decisions about retaining existing generation, starting natural gas and nuclear development, adding new natural gas fuel delivery capability and committing to transmission need to be made now, not 2029 if new resources are going to be in service in time to meet growing load requirements and attempt to meet the 2040 zero-emissions mandate.

What a Credible Interim EIDP Should Include

If the EIDP is going to be more than another politically-driven policy document, I believe the 2027 interim plan must include the following:

  • A reliability-first planning standard based on NYISO and New York State Reliability Council resource adequacy criteria that explicitly addresses extreme winter weather and multi-day renewable lulls.
  • Load forecasts by location and season that separate existing, committed, probable, and speculative large loads.
  • An explicit firm-capacity balance by zone and season that does not count wind and solar at nameplate capacity or assume DEFR will arrive on schedule.
  • A DEFR and nuclear strategy with a definition, capacity targets, in-service milestones, and contingency actions if the technologies do not materialize.
  • A rule that no dispatchable unit retires until its replacement is operating and has demonstrated dependable performance, not merely been contracted or permitted.
  • Recognition of the risk of the aging dispatchable units in the system and support to deploy fossil generation resources that can provide firm capacity where needed to bridge the transition until the Nuclear Backbone is deployed.
  • A full-system affordability test with published customer bill impacts and cost allocation to large loads.
  • A land-use and siting screen that compares alternatives on their environmental and community impacts.
  • Strategies must manage economic development, energy needs, and environmental mandates in unison not separate silos.
  • Transparent governance with published assumptions, models, and data, and formal opportunities for NYISO, consumer advocates, municipalities, and independent analysts to challenge the results.

The EIDP is Not Enough

I think that in addition to the EIDP the Hochul Administration must champion legislative and regulatory changes that recognize that reliability is paramount and that affordability controls the rate of spending are required. The EIDP will only be successful with changes to the current rules including revising the Climate Act 2040 zero emission requirement, changing any regulatory limits on deploying dispatchable generation such as natural gas fired units, and expanding the natural gas fuel delivery infrastructure to support them. Anything less is the default to our current death spiral that is impacting every NY consumer and making NY a hard choice for new economic opportunities.

Conclusion

Governor Hochul’s Energy Infrastructure Development Plan is a welcome acknowledgement that New York cannot meet unprecedented load growth, maintain reliable service, pursue its zero-emissions goals, and protect customers from rising costs through disconnected planning and procurement processes. The EIDP could provide the integrated framework New York needs.

But the announcement is a process commitment, not a reliability plan. Moreover, its timing and vagueness reeks of campaign politics.  Its value will depend on whether the State identifies firm-capacity requirements, evaluates nuclear and other dispatchable resources honestly, plans generation and transmission against actual rather than aspirational load forecasts, protects communities from unnecessary energy sprawl, and publishes a transparent full-system cost test. If the EIDP relies on hoped-for DEFR technologies, vague affordability claims, and renewable nameplate capacity instead of demonstrated dependable resources, it will simply repackage the existing planning deficiencies under a new name.  Done incorrectly risks continuing consumer affordability concerns, and missed “economic opportunities” especially for upstate New York.

I support the integrated-planning premise. I will be watching to see whether the interim plan becomes an engineering-based resource adequacy and affordability plan or just another document that assumes the Climate Act schedule can be met without saying how and delays reality through rhetoric vs actionable and timely steps forward.

Time to Decide What New York’s Energy Future Should Look Like

I have not updated my Reasons to Pause the Climate Act page in months. In the meantime, the evidence that the Climate Leadership & Community Protection Act (Climate Act) approach is unworkable keeps piling up and has reached the point that I think it is time to decide what New York’s energy future should look like. This post covers three overarching reasons New York should pause the net-zero transition until it decides what it wants the future energy system to look like: mineral supply constraints, the risk of depending on our neighbors when we need power most, and the lack of honest numbers about the cost of electrifying everything.

I have followed the Climate Act since it was first proposed and am convinced its implementation plan will adversely affect affordability and reliability. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with; these comments are mine alone.  I acknowledge the use of Perplexity AI to research the material summarized in this article and prepare an initial draft.

Overview

The Climate Act implementation plan relies on wind, solar, and energy storage, plus a yet-to-be-developed category of dispatchable emissions-free resources (DEFR) to keep the lights on during extended periods of low wind and solar output. Nearly seven years after passage, the State still has not answered the fundamental question: what will the electric system look like when the transition is complete, and what will it cost?

Running Out of Easy Ore

Stu Turley at Energy News Beat recently published The World Is Running Out of Easy Ore. Stop Building Two Grids. His argument is that geology and manufacturing capacity, not political schedules, will determine how fast the energy system can change.

Turley, drawing on Peter Clack, explains that copper ore grades have fallen sharply since the early 1990s, so miners move far more rock, using more energy and water, for the same metal. At the same time, a new copper or lithium mine takes 12 to 17 years to develop, while net-zero mandates run on five-to-ten-year clocks. He cites the International Energy Agency’s 2025 outlook projecting a roughly 30 percent copper shortfall by 2035, lithium deficits in the 2030s, and rare-earth magnet processing concentrated in a single dominant supplier.

The mineral intensity of different resources matters. According to the IEA and World Nuclear Association figures he cites, coal and gas use roughly 7 to 8 tonnes of critical minerals per lifetime terawatt-hour, nuclear about 12, and solar and wind 124 to 200. An offshore wind plant can require about 13 times the minerals of a comparable gas plant. When the resource that uses the scarcest minerals is also the one that needs the most backup, transmission, and storage, costs are going to go up.

He also documents a grid hardware bottleneck: the United States makes only about a fifth of the large power transformers it needs, and lead times now run two to five years. Turley cites a 2026 National Center for Energy Analytics study of PJM that estimated a wind-solar-battery build would cost ratepayers more than $4 trillion over 20 years, about six times a gas-and-nuclear path, because it needs roughly ten times the nameplate capacity to ride through multi-day renewable droughts.

His central point is that we are paying for “two grids”: the physical grid that obeys physics and the policy grid that pays for mandates. The intermittent approach requires duplicate capacity, extra transmission copper, and storage that does not yet exist at scale. That describes the Climate Act plan, which needs wind, solar, storage, and DEFR.

His recommendations deserve emphasis because they describe a practical alternative. He proposes a priority test: firm megawatt-hours per ton of copper, nickel, and rare earths, and per dollar of full system cost, with supply chains under allied control. He recommends:

  • Restart sound nuclear units.
  • License new large reactors and small modular designs consistent with the Department of Energy’s goal of moving from about 100 GW toward 400 GW by 2050.
  • Build gas plants for the years before reactors are available, because they are the lowest-mineral, fastest dispatchable option.
  • Treat transformers, electrical steel, and high-voltage equipment as defense production and standardize designs that pays off in cost, licensing, operations and safety.
  • Let data centers connect when they bring firm power and hardware, not just a queue position.
  • Mine and refine copper, uranium, and rare earths on U.S. and allied ground, recognizing that recycling helps but cannot close a 30 percent copper gap.
  • Stop building the “second grid” of intermittent resources that require duplicate capacity.

New York’s plan does almost the opposite. It prioritizes the most mineral-intensive resources, phases out the fossil-fired generation that keeps the system reliable today, and treats DEFR as a problem to solve later rather than acknowledging that DEFR is necessary for the wind and solar system proposed.

New York Cannot Count on Its Neighbors

Meredith Angwin’s A Tale of Two Transmission Lines compares the two new high-voltage direct current lines that bring Québec hydropower to the Northeast. The New England Clean Energy Connect (NECEC) line to Maine is designed for 1,200 MW and the Champlain Hudson Power Express (CHPE) to Astoria in Queens is designed for 1,250 MW.

The NECEC is a comparatively simple overhead line. However, during a cold snap shortly after it went into service in January, Hydro-Québec stopped sending power for almost two days because it needed the electricity for its own customers. Angwin describes that as a policy decision: Québec is winter-peaking, and when it gets cold, Québec takes care of Québec first.

The CHPE is a 339-mile underground and underwater line. When Angwin wrote in late July, it had been down most of the month because of two physical failures. The Daily Gazette reported that a July 1 problem at a Canadian substation was fixed the next day, but a damaged cable splice in New York knocked the line out on July 4, during a heat wave. She notes that burying the line for aesthetic and ecological reasons made it more fragile because faults are harder to find and fix.

The line returned to service on July 25, but its performance since then reinforces her point. Modo Energy found that CHPE’s first-summer capacity factor was 13 percent, with 25 percent in August and 30 percent in September. That compares with the roughly 95 percent implied by the contract for 10.4 TWh a year. Since early August, the line has delivered power in an afternoon-to-evening block and sat at zero overnight. Modo also found that New York was a net exporter to Québec across the three Hydro-Québec ties this summer. Energy News Beat reported that at the 3 PM peak on August 26, the Hydro-Québec ties, including CHPE, delivered zero megawatts. Meanwhile, CBC reported that Hydro-Québec expects 2026 energy reserves of 86 TWh, down from 97 TWh in 2024 and below the 100 TWh it considers comfortable. Hydro-Québec says Québec’s needs remain the priority.

Her most important point is that this is ultimately a resource adequacy issue, not a transmission issue. Today, Québec has surplus power in the summer and the U.S. can help Québec in the winter. Electrifying vehicles in Québec and heating in the United States could eliminate the “extra” capacity both sides now share. In her words, “you need to produce the electricity before you can move it.”

The NYISO Summer 2026 Operating Study shows how much New York already depends on imports. NYISO concluded that the system can be operated reliably this summer, but look at the numbers. The Installed Capacity requirement was 39,315 MW, based on a 24.5 percent reserve margin. In-state generation capacity was 38,027 MW, so New York could not meet its own reserve requirement without the 3,168.5 MW of net external capacity purchases that were secured. The study assumed 6,164 MW of capacity would be unavailable because of forced outages and derates. NYISO notes that 1,225 MW of generation retired, including Gowanus, Narrows, and Danskammer, are scheduled to be retired, while only 225 MW was added. Gowanus and Narrows are treated as necessary resources under the short-term reliability process  through May 1, 2029. The study models CHPE at a maximum delivery of 1,250 MW into New York and 0 MW in the other direction. For comparison, the largest single generator contingency NYISO plans for is Nine Mile Point 2 at 1,310 MW. Losing CHPE is like losing one of the largest power plants in the state.

My concern is not that PJM or ISO-NE will necessarily be unable to export power. It is that their ability to provide dependable assistance is most questionable precisely when New York needs it most:

  • A Northeast-wide heat wave.
  • A prolonged winter cold spell.
  • Widespread generator derates or fuel constraints.
  • Transmission outages that reduce interface capability.

In each case our neighbors will face the same weather, the same fuel constraints, and their own customers first. Québec already showed us what happens during a cold snap. Retiring fossil generation while increasing reliance on imports and weather-dependent resources makes New York more exposed to exactly these correlated risks.

FERC’s current large-load proceedings make this a timely issue. As described by Sheppard, on June 18, 2026, FERC issued show-cause orders to six RTOs and ISOs, including NYISO, PJM, and ISO-NE, preliminarily finding their tariff treatment of large loads unjust and unreasonable. The orders call for improved load forecasting, large-load impact studies, and cost recovery agreements to protect other ratepayers, and each RTO had to report on the status of resource adequacy within 30 days. FERC recognizes that new large demand requires clearer planning, interconnection, and cost-allocation treatment in each region. If every neighboring RTO is scrambling to serve its own data centers, it is even less likely they will have spare capacity for New York during a regional emergency.

Show the Math

Matt Jacobson’s Before You Electrify Your State, Do the Math is about Maine, but every point applies to New York. After seven Maine winters with heat pumps, he likes them, but when it gets really cold they are expensive to run, so he switches to his oil furnace or wood stove. As he puts it, “My house has choices.”

Jacobson walks through the arithmetic. Central Maine Power customers pay about 25 cents per kWh. A fully electrified home using 15,000 to 20,000 kWh a year would pay roughly $3,700 to $4,900 a year for electricity. If rates stay the same and usage doubles, the bill roughly doubles, but rates will not stay the same because the system has to be bigger to generate and deliver more power. Remote wind and solar need a “very expensive extension cord,” and neighborhoods need bigger substations and lines.

He also notes that Maine’s Net Energy Billing solar program cost about $313 million in 2025, and that subsidies create a “reverse Robin Hood” effect where those who can afford solar lower their bills while renters and struggling families help pay for it. “A subsidy doesn’t reduce the cost. It changes who pays it.”

His conclusion is that before Maine makes the electrification decision for someone else, “it should have to show us its math.” New York should do the same. After nearly seven years, there still is no clear, transparent, and well-documented description of the costs, emission reductions, and realistic schedules for the Climate Act strategies.

Discussion

These topics reinforce each other. Mineral constraints mean the resources the Climate Act depends on will be more expensive and slower to deploy than planned. Import dependence means New York cannot assume its neighbors will fill the gaps when wind and solar fall short. Electrification will increase demand in summer and winter, when the system is already stressed, and the State has never shown ratepayers what it will all cost.

New York already has a mechanism to address this. Public Service Law § 66-p(4) allows the Public Service Commission to temporarily suspend or modify renewable energy program obligations if the program impedes safe and adequate electric service or causes a significant increase in arrears or disconnections. At the end of April 2026, the Commission ended a comment period regarding these safety valve provisions.  The Commission has not responded to the comments received or defined how those conditions would be tested, so there is no meaningful safety valve.

Conclusion

The Climate Act approach depends on the most mineral-intensive resources that will get more expensive as. minerals get harder to find, imports that are least dependable when we need them most, and electrification without disclosed costs. In addition, there is no deployment plan for DEFR needed to implement a renewable-dependent system.  New York needs to pause implementation and decide what it wants its future energy system to look like. That decision should be based on a priority test like the one Turley proposes: firm, reliable power per dollar of total system cost. It should include a realistic assessment of how much New York can count on its neighbors. And, as Jacobson says, the State should have to show us its math before making the decision for everyone else.