Category: Climate Act Costs & Benefits

In a recent article I noted instances where Governor Hochul and Public Service Commission Chair Rory Christian have raised the possibility for limited changes to the Climate Leadership & Community Protection Act (Climate Act) interim targets primarily because of affordability concerns. This is a real problem and I agree that it needs to be addressed.  However, this article explains why I believe the total costs of the Climate Act are far higher than the Administration admits.  I believe the total cost will exceed $1 trillion.  It’s not that “we don’t know yet” – the Climate Act was built to avoid a real cost number.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. 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 a draft of this article. 

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  The Climate Action Council (CAC) was responsible for preparing the 2022 Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” In 2025, the State Energy Planning Board approved the 2025 Energy Plan that “provides broad program and policy development direction to guide energy-related decision making “.  Neither document provided a complete, transparent accounting of the total costs to achieve the Climate Act mandates.

On February 26, 2026 the Hochul Administration “leaked” a New York Energy Research & Development Authority (NYSERDA) memo that said that “full compliance with New York’s 2019 Climate Leadership and Community Protection Act could cost upstate households more than $4,000 a year – on top of what they are already paying today”. A recent article by Emily Pontecorvo summarizes the Green Energy Blob take on affordability.  Neither acknowledges the total costs of the Climate Act.

Total Costs

Supporters of the Climate Act often wave away cost questions with a shrug: “We don’t know yet,” “it’s complicated,” or the Scoping Act slogan that “the cost of inaction exceeds the cost of action.” That line would be more believable if the Hochul administration and its agencies were trying to calculate and document a true, all‑in cost.

They are not.

The core problem is not a temporary information gap while plans mature. The problem is that the statute, the implementation machinery, and the official analysis framework are all set up in ways that make a genuine, auditable total cost calculation impossible.

This is a design feature, not a bug.

My Total Cost Guess

Following this section, I will show how the total costs of the Climate Act have been buried.  But first I will provide my estimate.

My analysis is exclusively based on State Energy Plan Volume II – Plan Analyses and Impacts Pathways Analysis information.  There are five analysis scenarios described in Table 1 on page 3. 

On page 62 the text notes that:

Regardless of the specific future pathway for New York’s energy system, continued investment to maintain and modernize existing infrastructure, replace aging equipment, and purchase fuels to meet energy needs will be necessary. The analysis found that the No Action scenario requires annual system-wide spending (including on supply- and demand-side fuel and equipment) of approximately $150 billion (in 2024$) every year through 2040. These funds support replacing end use equipment at end of useful life and constructing new and replacement natural gas generators to meet electricity needs, which are being transformed by new large loads and other needs.

The Hochul Administration has never admitted how much they think the Federal and legacy policies in the “No Action” scenario contribute to meeting the Climate Act mandates.  We know the reference “Business as usual plus implemented policies” baseline scenario in Scoping Plan and Energy Plan modeling includes the following legacy programs:

• Growth in housing units, population, commercial square footage, and GDP
• Federal appliance standards
• Economic fuel switching
• New York State bioheat mandate
• Estimate of New Efficiency, New York Energy Efficiency achieved by funded programs: HCR+NYPA, DPS (IOUs), LIPA, NYSERDA CEF (assumes market transformation maintains level of efficiency and electrification post-2025)
• Funded building electrification (4% HP stock share by 2030)
• Corporate Average Fuel Economy (CAFE) standards
• Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030)
• Clean Energy Standard (70×30), including technology carveouts: (6 GW of behind-the-meter solar by 2025, 3 GW of battery storage by 2030, 9 GW of offshore wind by 2035, 1.25 GW of Tier 4 renewables by 2030)

The Societal Costs of the Plan section in the Summary of Findings includes figures 55 and 56 that list the annual net costs and benefits by scenario in (Billion 2024$) for 2030 and 2040.  I assumed the “current policies” scenario costs conservatively represent the legacy program costs necessary to achieve Climate Act mandates. 

My Table 2 extracts the 2030 and 2040 costs from these figures.  I used that range of years to calculate a rate of cost increase that I used to interpolate annual values from 2031 to 2039 and to extrapolate from 2041 to 2050.  I assumed that the 2026 to 2029 annual costs were the same as 2030.  I assume that the total Climate Act costs equal the current policy scenario (assumed to equal the legacy program costs) plus the Net Zero scenario costs.  Summing the net zero scenarios and the “current policy” estimate of legacy program costs over all the years yields a total cost for the Climate Act of 1.58 trillion dollars for the Net Zero A scenario and 1.56 trillion dollars for the Net Zero B scenario. 

Table 2: Annual Costs for Pathways Analysis Scenarios

This estimate of the total costs is flawed because it depends on the State Energy Plan modeling that only outlined a control strategy and suffers from other deficiencies as described below.

The Law Sets Targets Without Defining the Work or Its Price

The Climate Act hard‑codes numerical emission‑reduction percentages and deadlines but the Scoping Plan and the State Energy Plan never defined a complete technology pathway for how those goals must be met. That sounds flexible, but it means the actual portfolio of required measures is a just an outline list of potential strategies that their analysis claims will achieve the goals.

Because the plan do not specify which mix of generation, transmission, storage, building electrification, industrial changes, and behavioral mandates should be used, there is no fixed bill of materials to price out. Instead, agencies can continually swap in new mandates, subsidies, and bans, each with its own cost, while still claiming to be “implementing the Climate Act.”

On top of that, the statute’s cost language is soft. Agencies are told to “consider” costs and “minimize” them where practicable, but affordability is not an enforceable constraint in the same way the emission targets are. When goals are legally binding and costs are not, the structure guarantees that hitting the targets will always trump price transparency.

NYSERDA’s Own Memo Admits the Accounting Is Distorted

NYSERDA’s February 2026 memo, leaked finally admits what critics have said for years: the law’s own greenhouse gas accounting system drives up measured “emissions” and, therefore, required actions and costs.  The memo acknowledges that:

• The Climate Act’s statutory accounting approach differs from internationally accepted methods and attributes more emissions to the same activities than “accepted science” would.
• Combined with inflexible near‑term targets, that accounting “would yield high costs to New York households and businesses” if carried through as written.
• In other words, the underlying metric that defines “success” is itself under active reconsideration because the costs have become politically explosive. When the rulebook that defines the problem is unstable, any attempt to calculate a final, all‑in cost is building on quicksand.

Popular accounts of the implications of this memo rarely acknowledge that the costs described are only for the economy-wide New York Cap-and-Invest (NYCI) program that only addresses fuel costs.

The Required Cost Evaluation Was Never Properly Documented

The statute requires the Climate Action Council to “evaluate … the total potential costs and potential economic and non‑economic benefits of the plan” and “make such evaluation publicly available” in the Scoping Plan. I showed that never happened in the Scoping Plan in a way that would satisfy any utility commission rate case, let alone a serious public works program.

The Scoping Plan’s integration analysis offers high‑level bar charts and net‑cost ranges, but the underlying calculations are undocumented. There is no public bill of quantities tying specific measures to specific costs and no auditable backup that would allow an outsider to reproduce the results. When costs are summarized in a single bar labeled “net direct cost” with no line‑item breakdown, the intent is concealment, not clarity.

Worse, the benefits side was constructed with a major error: avoided greenhouse gas benefits were counted multiple times, which flipped the analysis from large net costs to large net benefits. Correcting that one mistake alone turns the claimed 90–120 billion dollars in net benefits into tens of billions in net costs. If the “cost of inaction” narrative depends on that kind of numerical sleight of hand, it is not a serious basis for budgeting trillions.

The PSC Admits It Cannot Isolate “Climate Act Costs”

The Scoping Plan is a black box.  I hoped that the Department of Public Service (DPS) could have cleared things up in its Climate Act Informational Reports. Those reports were specifically ordered to track what ratepayers are being billed to support Climate Act programs.

However, buried in the Second Informational Report is a remarkable confession: DPS staff state that, “in several instances, [it is] difficult to clearly delineate program costs and outcomes directly related to the Climate Act as there are decades of overlapping programs.” In plain English: the Commission cannot cleanly separate “Climate Act costs” from everything else.

The reports:

• Focus on “direct effects” of Climate Act implementation only, leaving out large categories of indirect or prerequisite spending.
• Explicitly warn that many costs were authorized before the law and will be recovered over many years, so the totals in the tables “should not be considered as entirely incremental costs.”

Even so, outside analysts looking at the first report have tallied roughly 43.7 billion dollars in Climate Act‑related spending or commitments through 2022, without a detailed public accounting of where the money went or what benefits were achieved. If the state’s chief utility regulator cannot even define the denominator—what counts as Climate Act spending—then the idea of a precise, final total cost is a fiction.

The “No‑Action” Baseline Ensures Systematic Understatement

NYSERDA and the Climate Action Council rely on a “no‑action” baseline that conveniently excludes large pre‑existing clean‑energy and efficiency programs that are in fact necessary to hit the Climate Act targets. This lets them present Climate Act costs as smaller “incremental” add‑ons, rather than part of a cumulative, decades‑long policy stack that ratepayers are actually funding.

As NYSERDA itself now concedes, using this kind of baseline means their cost analyses systematically understate what full Climate Act compliance will really cost New Yorkers. The baseline is rigged, so every dollar number derived from it is misleading by design.

Household Numbers Are All Over the Map for a Reason

The recent NYSERDA memo and accompanying press coverage acknowledge that compliance with the current law could raise costs for an average household by roughly 3,000 to 3,500 dollars per year, with higher impacts for upstate gas and oil customers. I have shown that using the state’s own State Energy Plan data shows much larger figures when:

• The full cost difference between conventional replacements and “high‑efficiency” electrification equipment is included.
• Cap‑and‑invest allowance costs and other Climate Act‑driven charges are added in.

My analysis points to an annual cost burden for an upstate gas household on the order of 7,200 to 11,200 dollars once all Climate Act‑related requirements are counted. When official and independent estimates diverge by factors of two or three, the issue is not “we need more time to refine the model.”  These numbers are included in the State Energy Plan Pathways Analysis costs described earlier.  The issue is that the state’s chosen framework is not designed to expose the full number.

The “Total Cost” Cannot Be Calculated

Put these strands together and a pattern emerges:

• The statute hard‑codes targets but not a concrete implementation package, so the scope of work keeps changing.
• The greenhouse gas accounting system is non‑standard and now acknowledged by NYSERDA to inflate apparent emissions, which in turn inflates required actions and costs.
• The Scoping Plan’s integration analysis does not provide documented, reproducible cost calculations, and even its benefit estimates are numerically flawed.
• The PSC’s own reports admit that Climate Act costs cannot be cleanly separated from decades of overlapping programs, and that their tabulations are only partial.
• NYSERDA relies on a “no‑action” baseline that excludes necessary existing programs, systematically understating the real burden.
• Household‑level cost estimates swing wildly depending on whether you accept the state’s narrow accounting or incorporate the full suite of required measures and charges.

This is not an innocent case of “we don’t know yet because it’s early” or “we need better models.” It is a structural outcome of how the Climate Act is written, how agencies have chosen to interpret it, and how the analysis has been framed.

Conclusion

It is not unreasonable to think that the total cost for Climate Act compliance will exceed $1 trillion between now and 2050.  If my estimate is wrong, then it is incumbent upon the State to provide the correct value.  However, the law’s architecture, the accounting choices, and the reporting practices all point in the same direction: avoid ever putting a defensible, fully documented total cost number in front of voters.  Until those foundations are rebuilt—starting with honest accounting, a realistic implementation plan, and full documentation of methods—New Yorkers will not get the basic information they were promised: what this experiment will cost, and who is going to pay. 

The response and counter-response to a Syracuse Post Standard article by Tim Knauss explaining energy costs illustrates the common over-simplification of this complex topic.  State senate candidate James Corl argued in his response to the article that state energy policies were the cause of the observed high prices.  Energy transactional attorney Chris Reagen responded to Corl stating that “Rising electricity costs are a genuine concern that merits an honest policy discussion grounded in facts rather than convenient scapegoating of renewable energy mandates”.  I agree we need honest policy discussions but will show that Reagen’s support of renewable energy is flawed.

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, submitted comments on the Climate Act implementation plan, and have written over 600 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.  A recent recommendation by Governor Hochul to adjust the deadlines has spurred conversations about the schedule and ambition of the Climate Act.  A primary concern is affordability.

Why is New York Electricity Expensive

New York currently has an energy affordability crisis because as of December 2024, over 1.3 million households are behind on their energy bills by sixty-days-or-more, collectively owing more than $1.8 billion.  At the same time, when new electric utility rates are becoming effective this winter’s weather has been so cold that people are using more energy.  The result is sky rocketing costs. I believe that this was the impetus for the Knauss article,  He outlined the following reasons in his article:

We wanted to find out why Upstate New Yorkers pay so much for power. Syracuse.com’s analysis found:

• State officials tout electric power as an efficient heating alternative to natural gas. But in New York, power production relies heavily on gas. That fuel is burned in decades-old power plants that are inefficient, expensive to run, promote climate change and at times are unreliable.
• This winter’s price shocks signal trouble ahead. New York’s electric grid needs to be shored up to avoid worse bills – or even blackouts – in the years to come. Demand will only grow.
• There’s no cheap or quick fix. Politicians and some consumer groups are clamoring for relief this winter. But the underlying issue will require years of work and investments in the billions to beef up electricity production and expand the transmission grid.
• State leaders are getting the message. It’s an election year. But a clear and effective commitment from Albany has been elusive. The most likely immediate answers are one-shot financial help.

Other than a few quibbles I agree with these general reasons for the high costs.

His article is also consistent with a January 2026 New York Independent System Operator (NYISO) white paper.  Impact of National & Global Conditions on Electricity Prices in New York attributed rising wholesale electricity prices to several factors:

• Natural gas price increases: Average 2025 gas prices at the Transco Zone 6 hub were roughly 120% higher than 2024, at $4.64/MMBtu compared to $2.10/MMBtu. Wholesale electricity prices averaged $74.40/MWh in 2025 versus $41.81/MWh in 2024.

​Growing LNG exports: U.S. LNG exports increased roughly 26% in 2025, and the U.S. now exports more natural gas than residential customers consume. This has reconnected domestic gas prices to volatile global markets.

​Rising electricity demand: Data centers, semiconductor manufacturing, building electrification, and EV adoption are projected to add more than 9,000 MW of new demand by winter 2034–35.

​Shrinking supply margins: Since 2019, 4,315 MW of capacity have left the system while only 2,274 MW have been added. Of 106 projects that completed the interconnection process, just seven have begun construction.

​Aging generation fleet: New York’s gas-fired generators rank among the oldest nationally, with NYC steam turbines averaging 65 years old, driving up maintenance and fuel costs.

NYISO states that New York energy policy affects rising electricity demand and shrinking supply margins.  In addition, the NYISO white paper does explicitly acknowledge Climate Act-related costs on retail bills. In its section on retail bills, it states: “Utilities are investing heavily to upgrade aging infrastructure, expand transmission capacity, and modernize the grid to support New York’s clean energy goals under the Climate Leadership and Community Protection Act, signed into law in 2019. While such upgrades are essential for long-term reliability and sustainability, they result in near-term cost increases that are passed on to consumers through higher retail rates”

Albany’s Energy Policy is to Blame

State Senate candidate James Corl argued that Albany’s energy policies were to blame in a letter to the editor.  He argued:

In 2019, Albany passed legislation creating unrealistic renewable energy mandates. To meet these, New York had to take power offline — and a lot of it. Seven years later, our state’s power capacity has decreased by 2,000 megawatts, primarily due to the closure of Indian Point Energy Center. Less energy and increasing demand means higher costs for ratepayers.

The worst part about this is that the state is nowhere near completing these goals. On several metrics, New York is falling behind. Unless we repeal or heavily amend these laws, utility bills will continue to climb.

Instead of reconsidering this trajectory, Senate Democrats have doubled down. Leaders of the Senate have indicated they will not revisit changing these laws. It is disappointing to see that even though these policy failures are on full display, lawmakers will not change course for our own good.

Many people talk about climbing bills; I want to do something about it. Let’s put more nuclear power online. We need to protect access to natural gas, which 60% of New Yorkers use to heat their homes. And Albany should pass legislation to return unspent climate investment account funds to ratepayers.

Corl managed to generally address things that concern me within the word limit of a letter to the editor.  However he was required to leave out details to meet the word limit. 

State power capacity has gone down.  The New York Independent System Operator (NYISO) has documented a systematic deterioration of grid reliability since the Climate Act was enacted. NYISO data show a net loss of 2,041 MW of dispatchable capacity (4,315 MW retired versus 2,274 MW added).  Indian Point closure was the largest closure but just as important, State agencies refused to authorize re-powering several natural gas units because of the Climate Act.

There is no question that the state is falling behind its Climate Act goals.  That is one of the reasons that Governor Hochul recently proposed delaying the interim  targets.  However, as Corl mentioned Democrats in the Legislature have not indicated whether they would support changes.

Finally, Corl listed three ways to address the high costs: consider nuclear, protect natural gas, and return unspent climate investment account funds to ratepayers.  I agree with the first two, but think that  unspent climate investment funds have simply not made their way through the bureaucracy to get to the climate projects so this will not be very impactful.

Next-Decade Solutions to Today’s Energy Prices

Chris Reagen responded to Corl in an extensive opinion piece.  He is an energy transactional attorney who “works for an international law firm with expertise in all aspects of energy, power and natural resource development.”  He stated that Corl “offers convenient but costly and ultimately ineffective solutions to curb rising utility bills. Cost, speed and efficiency, not politics, should guide discussions on addressing New York’s energy infrastructure.”

Reagen correctly notes that cost increases are driven by “rising natural gas prices, aging infrastructure (generation, transmission and distribution), extreme weather events and significant costs for grid modernization and reliability improvements”. However, his statement that “electricity cost increases are driven by factors far beyond state-level renewable energy policies” insinuates that renewable energy policies have not had any effect is wrong.  Kris Martin published a post that found that the Department of Public Service projected 2023 Climate Act portion of electric bills ranged between 8.5% and 13.7%.  Because agency staff are under pressure to minimize costs and the estimates for future costs don’t include all the Renewable Energy Credits (REC) and OREC (offshore wind REC) costs that would be required to reach Climate Act targets, those estimates are certainly biased low.  New York energy policies may not be the only driver, but they certainly do influence prices.  Importantly, those costs will certainly rise in the future.

Reagen discounted Corl’s  proposals to put more nuclear power online and build new gas plants citing cost and timing issues.  There is no question that nuclear power is expensive and will not be available for many years.  I also do not dispute Reagen’s comments about gas plant supply chain constraints and surging costs.  However, he does not acknowledge that New York State has never completed a feasibility analysis for the wind, solar, and battery storage mandates of the Climate Act.  The biggest unacknowledged affordability risk is that the renewable solution requires new Dispatchable Emissions-Free Resource (DEFR) technologies to make a solar and wind-reliant electric energy system viable during extended periods of low wind and solar resource availability.  I believe the only likely viable DEFR backup technology is nuclear generation despite its costs because it is the only candidate resource that is technologically ready, can be expanded as needed, and does not suffer from limitations of the Second Law of Thermodynamics.

If the only viable DEFR solution is nuclear, then the wind, solar, and energy storage approach cannot be implemented without nuclear power.  Reagen’s argument that cost, speed and efficiency, not politics should drive the transition ignores the potential that renewables could be a false solution.  Nuclear power works best as a baseload resource so using it solely as DEFR backup is inappropriate.  Developing baseload nuclear eliminates the need for a huge DEFR backup resource and means that the “build as much as we can as fast as we can” wind and solar buildout currently in progress and supported by Reagen is unnecessary.  When all the costs associated with the proposed Climate Act wind, solar, and energy storage approach are compared to an electric system based on nuclear and gas, I believe that it will be cheaper when equipment life expectancies are considered. 

The primary impetus for this post is Reagen’s solution to energy affordability.

If we are serious about electricity affordability, we must focus on solutions that can actually deliver results: continued deployment of renewables; investments in energy efficiency that reduce demand; grid modernization that reduces waste; and battery storage that provides flexibility. Use and improve existing infrastructure that ratepayers already paid for.

The slogan that more renewables, efficiency, grid modernization, and batteries will “deliver” affordability in New York reverses cause and effect. My work shows these are primarily cost drivers under Climate Act mandates, not targeted affordability tools. New York’s mediocre wind/solar resource, severe siting and transmission constraints, and required storage make each additional “clean” megawatt disproportionately expensive, even before reliability backstops are added. Agencies now project about $120 billion per year in energy-system investments through 2040, equal to roughly $1,282 per month per household, while over a million households are already in arrears. Battery storage is being politically framed as a cheap peaker replacement, but detailed analysis shows that at the scale and duration needed in New York City it is not technically or economically a one-for-one substitute and would sharply raise costs. “Grid modernization” and aggressive efficiency are likewise being deployed to support a far more capital-intensive, weather-dependent system, with diminishing returns relative to the cost of the measures. The line about “use and improve existing infrastructure that ratepayers already paid for” is especially misleading because Climate Act implementation is deliberately sidelining or stranding much of that infrastructure while forcing customers to finance replacement equipment and vehicles that State Energy Plan modeling suggests could add nearly 600 dollars per month for a typical upstate household

Discussion

Reagen concludes:

There are no quick fixes to rising electricity costs but the solutions that Corl proposes — new gas and nuclear power plants — will increase your electricity bills without delivering a single electron to you until the next decade. Rising electricity costs are a genuine concern that merits an honest policy discussion grounded in facts rather than convenient scapegoating of renewable energy mandates. There are no red or blue electrons. Central New Yorkers deserve honest engagement with the tradeoffs and challenges ahead, not false promises about ineffective solutions that would result in substantially higher utility bills.

The claim that Corl is scapegoating renewable energy mandates is rich considering that Reagen scapegoats gas and nuclear plants.  The reality is that we know that a clean and reliable energy system can be built around gas and nuclear power, but there is no proof that renewable energy can provide reliable energy when needed most.  The lack of any solar and reduced wind resources during the coldest weather this winter is an enormous challenge that renewable energy advocates like Reagen ignore.  Claims that energy efficiency will reduce demand during similar episodes sufficient to eliminate the need for DEFR or to eliminate the need for peaking power is demonstrably false, especially in the future net-zero system envisioned by the Climate Act where everything is electrified.  The real false promise is that renewable energy can replace fossil fuels and nuclear as the backbone of New York’s energy system.

Conclusion

The public must understand that there are no easy solutions to increasing electric costs.  Knauss summarized energy affordability issues well.  While Corl may have over emphasized the effect of New York energy policies on observed rate increases, Reagen’s suggestion that the policies had no effect is incorrect.  The Department of Public Service has determined that the Climate Act portion of electric bills in 2023 ranged between 8.5% and 13.7% of the total bill.  Gas and electric bills are not the only source of Climate Act costs.  It does not account for the carbon tax cap-and-dividend cost on fossil fuels, the household equipment costs to achieve Climate Act goals or the costs for the yet unidentified DEFR technologies.

It is time to hold the Legislature and Governor Hochul accountable for Climate Act costs.  What is their definition of  acceptable affordability impacts?  What are the total costs to achieve the Climate Act mandates?  Can we afford to try to solve global warming when we are such a small component of total global emissions and are facing an energy affordability crisis?  If senate candidate James Corl addresses these questions and his opponent does not, then I think the choice for affordability is clear.

In my opinion the biggest problem with the Climate Leadership & Community Protection Act (Climate Act or CLCPA) is that it will inevitably lead to extraordinary cost increases.  My last article described the recent rate case decisions that have markedly increased residential customer electric bills. These rate increases arrive amid an escalating affordability crisis, as of December 2024, over 1.3 million households are behind on their energy bills by sixty-days-or-more, collectively owing more than $1.8 billion.  This article documents unresolved affordability issues associated with the Climate Act.

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 600 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone. 

Background

There is a fundamental Climate Act implementation issue.  Clearly there are bounds on what New York State ratepayers can afford and there are limits related to reliability risks for a system reliant on weather-dependent resources.  The problem is that there are no criteria for acceptable affordability bounds.

Proponents of the Climate Act argue that the transition strategies in the law must be implemented to meet the net-zero mandates.  However, they do not acknowledge that Public Service Law (PSL) Section 66-P, Establishment of a Renewable Energy Program, is also a law. PSL 66-P requires the Commission to establish a program to ensure the State meets the 2030 and 2040 Climate Act obligations.  It includes provisions stating that the PSC is empowered to temporarily suspend or modify these obligations if, after conducting an appropriate hearing, it finds that PSL 66-P impedes the provision of safe, adequate, and affordable electric service.  This requirement has been noted but, unfortunately, establishing a methodology to resolve the mandate has been ignored.

Petitions for a Hearing

The first unresolved affordability issue is the petitions by the Coalition for Safe and Reliable Energy and the Independent Intervenors submitted to PSC Proceeding Case 22-M-0149 that called for a hearing.  There has been no indication by the PSC that they will respond to those petitions.

The recent filings argued that the PSC should convene a hearing. On August 11, 2025 “Independent Intervenors” Roger Caiazza, Richard Ellenbogen, Constatine Kontogiannis, and Francis Menton petitioned  the  PSC arguing that safety valve provisions for customers in arrears trends in PSL  66-p(4) have been exceeded  which should trigger a hearing.  On January 6, 2026 the Coalition for Safe and Reliable Energy filed a petition with the Public Service Commission (PSC) requesting that the Commission act expeditiously to hold a hearing pursuant to Public Service Law § 66-p (4).  Both filings make similar arguments.  The Independent Intervenors argued that there was an explicit requirement for the hearing because the customers in arrears threshold has been exceeded.  The Coalition makes a persuasive argument that there are sufficient observed threats to reliability that a hearing is necessary to ensure safe and adequate service.

In addition, last summer two members of the Climate Action Council, Donna DeCarolis and Dennis Elsenbeck, sent a letter to Rory Christian, Chair & Chief Executive Officer of the New Yok State Public Service Commission (PSC) that made a similar argument that there are more than sufficient circumstances to warrant the PSC commencing a hearing process to “consider modification and extension of New York Renewable Energy Program timelines pursuant to Public Service Law § 66-p (4).

Agency Affordability Findings

There also have been New York Agency findings that argue that observed issues with schedule and costs suggest a pause to reconsider the mandates is appropriate.

The Draft Clean Energy Standard Biennial Review prepared by Department of Public Service (DPS) Staff and NYSERDA  “details the numerous factors, including inflation, transmission constraints, shifting federal energy and trade policies and interconnection and siting challenges that have adversely impacted renewable development and the state’s trajectory towards achieving the Program’s 2030 target.”  The Biennial Review “concludes that a delay in achieving the 70% goal may be unavoidable.”

The recently completed New York State Energy Plan (SEP) found that “current renewable deployment trajectories are insufficient to meet statutory targets, and that external constraints continue to impede progress.”  Volume 2 “Our Energy Systems” explains that “Considering resource build limitations and increased loads, the model aligns with the CES Biennial Review, projecting the procurement schedule of CES resources through 2035.”  In other words, the SEP acknowledges that the Climate Act schedule is impossible to meet.  The SEP found that Climate Act costs are expected to require $120 billion in annual energy system investments through 2040, equivalent to $1,282 per month per household. This baseline includes what the authors of the SEP characterizes as costs “no matter which future path we take” but I believe that framing is fundamentally deceptive because that scenario includes substantial greenhouse gas reduction programs implemented before 2019 that are necessary to meet the Climate Act goals.

The July 2024 New York State Comptroller Status report “Climate Act Goals – Planning, Procurements, and Progress Tracking” audited PSC and NYSERDA efforts to achieve the Climate Act mandates.  It found that “While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and CES, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs.”  The report recommended that the agencies begin the comprehensive review of the Climate Act, “continuously analyze” existing and emerging risks and known issues, conduct a detailed analysis of cost estimates, and “assess the extent to with ratepayers can reasonably assume the responsibility” of the implementation costs.  This is the information necessary for the PSL 66-P hearing.

My last article summarized recent residential electric utility customers rate case decisions approved between March 2025 and January 2026.  The New York Public Service Commission (PSC) “approved new multi-year rate plans for five major utilities—Con Edison, National Grid, Central Hudson, and Orange & Rockland—while two additional utilities (New York State Electric & Gas (NYSEG) and Rochester Gas & Electric (RG&E) have pending rate cases seeking significantly larger increases”.

Kris Martin from NY Solar Divide pointed out:

When we look at those modest Climate Act (CLCPA) percentages on “typical” electric bills, it’s important to understand that we have incurred only a small fraction of Climate Act expenses to date. The bulk of those expenses will really start to impact us in another 5-10 years as we start to seriously build out onshore and offshore wind and grid-scale solar, implement policy changes (e.g., school bus electrification), and deal with increases in demand.

Department of Public Service (DPS) staff is supposed to provide Climate Act information. On September 18, 2025 the PSC announced that they “received an update from DPS staff regarding progress toward the clean energy goals of the Climate Act”.  The Second Informational Report prepared by Department of Public Service (DPS) staff “focuses on Commission actions from January 2023 through August 2025, and includes the estimated costs and outcomes from 2023 through 2029 to provide the most up to date information.”  According to the Summary of Ratepayer Impact for Electric Utilities table, residential impacts of the Climate Act range from 4.6% to 10.3% of 2023 total monthly electric bills.  In my opinion, those estimates are conservative because there is immense pressure on agency staff to minimize the costs of the Climate Act.  In addition, the costs necessary to implement the Climate Act were ramping up in 2023.  As Martin notes these costs are just the tip of the iceberg.

Affordability Metrics

PSL law Section 66-p (4) states that the hearing could “temporarily suspend or modify the obligations” of the Renewable Energy Program if the PSC makes a finding that “there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.   This refers to affordability limits, but they are not specific enough.  I believe the PSC must establish specific affordability limits.

This issue was also raised to the DPS last year.  On March 26, 2025, Jessica Waldorf, Chief of Staff and Director of Policy Implementation for the Department of Public Service (DPS) posted a letter responding to a letter from Michael B. Mager Counsel to Multiple Intervenors that had been submitted earlier in March to Chair of the Public Service Commission Rory Christian regarding the affordability standard.       I agreed with the comments submitted by Multiple Intevenors and was disappointed with the DPS response so I submitted a letter to Christian.

As described in my article My Comments on the NYS Affordability Standard: I believe that as part of the Scoping Plan the Climate Action Council should have developed criteria for the PSC to consider affordability and reliability.  That did not happen.  Based on issues observed with the transition it is incumbent upon the Commission to define “safe and adequate electric service” and “significant increase in arrears or service disconnections” as part of this Proceeding.  My letter stated that this is necessary so that there is a clearly defined standard for the temporarily suspending or modifying the provisions of Section 66-p (4).

The Public Service Commission has an existing target energy burden set at or below 6 percent of household income for all low-income households in New York State.  Reviewing it raises questions about its suitability for defining energy affordability acceptability.

The six percent target was included as part of Public Service Commission (PSC) Case Number: 14-M-0565, the Proceeding on Motion of the Commission to Examine Programs to Address Energy Affordability for Low Income Utility Customers.  According to the PSC: “The primary purposes of the proceeding are to standardize utility low-income programs to reflect best practices where appropriate, streamline the regulatory process, and ensure consistency with the Commission’s statutory and policy objectives.”  On May 20, 2016 the Order Adopting Low Income Program Modifications and Directing Utility Findings adopted “a policy that an energy burden at or below 6% of household income shall be the target level for all 2.3 million low income households in New York.” 

The order notes that:

There is no universal measure of energy affordability; however, a widely accepted principle is that total shelter costs should not exceed 30% of income. For example, this percentage is often used by lenders to determine affordability of mortgage payments. It is further reasonable to expect that utility costs should not exceed 20% of shelter costs, leading to the conclusion that an affordable energy burden should be at or below 6% of household income (20% x 30% = 6%). A 6% energy burden is the target energy burden used for affordability programs in several states (e.g., New Jersey and Ohio), and thus appears to be reasonable. It also corresponds to what U.S. Energy Information Administration data reflects is the upper end of middle- and upper-income customer household energy burdens (generally in the range of 1 to 5%). The Commission therefore adopts a policy that an energy burden at or below 6% of household income shall be the target level for all low-income customers.  The policy applies to customers who heat with electricity or natural gas. 

The utility companies submit quarterly reports documenting the number of low-income customers receiving discounts and the amount of money distributed.  However, I have been unable to find any documentation describing how many customers meet the 6% energy burden criteria, much less any information on how those numbers are changing.  The biggest problem with this energy burden program is that it only applies to electric and gas utility customers.  Citizens who heat with fuel oil, propane, or wood are not covered.  Moreover, it only considers utility costs but the economy-wide provisions of the CLCPA include transportation energy burdens.

Clearly, if this parameter is to be used for a CLCPA affordability standard, then defining what is acceptable and what is not acceptable is necessary.  Whatever affordability standard is chosen a clear reporting metric must be provided and frequent updates of the status of the implementation relative to the affordability standard provided.

It is also notable that Assistant Attorney General Meredith G. Lee-Clark submitted correspondence related to the litigation associated with Climate Act implementation.  The State’s submittal  to the petition addressed “two categories of new developments: (1) the publication of the 2025 Draft New York State Energy Plan by the New York State Energy Planning Board on July 23, 2025 and (2) additional actions by the federal government that impede New York’s efforts to achieve the Climate Leadership and Community Protection Act’s (the Climate Act) goals in a timely manner.” 

The submittal means that the State of New York argued that it was inappropriate to implement regulations that would ensure compliance with the 2030 40% reduction in GHG emissions Climate Act mandate because meeting the target is “currently infeasible”.  The following paragraph concedes that there are significant upfront cost issues that out-weigh other benefits.

Ordering achievement of the 2030 target would equate to even higher costs than the net zero scenarios and would affect consumers even sooner. Undoubtedly, greenhouse-gas reducing policies can lead to longer-term benefits such as health improvements. This does not, however, offset the insurmountable upfront costs that New Yorkers would face if DEC were forced to try to achieve the Legislature’s aspirational emissions reductions by the 2030 deadline rather than proceeding at an ambitious but sustainable pace.

The letter concluded that the Climate Act is unaffordable:

Petitioners have not shown a plausible scenario where the 2030 greenhouse gas reduction goal can be achieved without inflicting unanticipated and undue harm on New York consumers, and the concrete analysis in the 2025 Draft Energy Plan dispels any uncertainty on the topic: New Yorkers will face alarming financial consequences if speed is given preference over sustainability.

Conclusion

It is impossible to ignore that multiple independent analyses, audits, litigation findings, and party filings in DPS proceedings document that the Climate Act transition will exacerbate energy affordability issues at a time when more than a million New York households are already in arrears on their energy bill.  Unfortunately, the Hochul Administration and Legislature have not adopted clear affordability metrics, a transparent tracking system, or mandatory corrective actions when affordability thresholds are exceeded.  Of course, these are bright line accountability metrics, and no political supporter of the Climate Act wants to admit their role in the New York affordability crisis.

In my opinion the biggest problem with the Climate Leadership & Community Protection Act (Climate Act) is that it will inevitably lead to extraordinary cost increases.  This post summarizes recent residential electric utility customers rate case decisions approved between March 2025 and January 2026. I do not discuss gas rate cases.  The New York Public Service Commission (PSC) “approved new multi-year rate plans for five major utilities—Con Edison, National Grid, Central Hudson, and Orange & Rockland—while two additional utilities (New York State Electric & Gas (NYSEG) and Rochester Gas & Electric (RG&E) have pending rate cases seeking significantly larger increases”. These rate increases arrive amid an escalating affordability crisis, as of December 2024, over 1.3 million households are behind on their energy bills by sixty-days-or-more, collectively owing more than $1.8 billion.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 600 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone. 

Background

There is a fundamental Climate Act implementation issue.  Clearly there are bounds on what New York State ratepayers can afford and there are limits related to reliability risks for a system reliant on weather-dependent resources.  The problem is that there are no criteria for acceptable affordability bounds.

Trying to decipher rate case decisions is a difficult task because of the volume of materials associated with each rate case. The PSC maintains a database that compiles all the filed documents and public comments for each rate case.  The Matter Master file for the current NYSEG rate case lists 913 filed documents and 1967 public comments.  To compile this summary, I acknowledge the use of Perplexity AI to generate summaries and references included in this document.  Assume all the results shown are referenced to the original Perplexity response.

Rate Case Results

Figure 1 summarizes the recent rates cases for Con Edison, National Grid, Central Hudson, and Orange & Rockland that have been completed since 2025.  NYSEG and RG&E have pending rate cases, so their results shown are not directly comparable.

Figure 1: New York Utility Rate Cases Impact on Residential Customer (2025-2026) – Perplexity

The NYSEG and RG&E cases are pending and the results shown represent their initial offer.  All the results shown for the other utilities had much higher initial rates. For example, Con Edison initially requested annual revenue increases of $1.612 billion for electric service (18.0 percent increase in base delivery revenues) and $440 million for gas service (18.8 percent increase in base delivery revenues). Following intense public opposition, intervention by Governor Kathy Hochul, and even comments by President Trump, and extensive settlement negotiations, the PSC approved a dramatically reduced three-year rate plan on January 22, 2026.   The approved joint proposal represents an 87 percent reduction from Con Edison’s initial request.

Utility Summaries

Con Edison’s service territory covers New York City and Westchester County with 3.6 million residential customers.  For typical NYC residential customers using 280 kilowatt-hours monthly, electric bills will increase by approximately $4 per month (3.9 percent) in 2026, $3.55 per month in 2027, and $4.22 per month in 2028, resulting in a cumulative 10.4 percent increase over three years. Westchester County residential customers using 425 kWh monthly face increases of $5.25 (2.6 percent) in year one, $4.84 (2.3 percent) in year two, and $4.95 (2.2 percent) in year three, totaling 10.1 percent over the period

National Grid’s rate case was approved on August 13, 2025.  The service territory covers 1.7 million electric customers across 25,000 square miles in Upstate New York. For residential electric customers using an average of 625 kilowatt-hours per month National Grid’s three-year upstate rate plan includes a $14.32 per month increase in year 1, a $6.44 per month increase in year 2, and a $4.34 per month increase in year 3 with an expected total increase over three years of 31%.

Central Hudson 315,000 residential customers in its Hudson Valley and Mid-Hudson region service territory.  Central Hudson’s rate case followed a unique trajectory, proceeding through litigation rather than settlement, ultimately resulting in a one-year rate plan approved on July 18, 2024, followed by a subsequent multi-year joint proposal filed on May 13, 2025, and approved on August 14, 2025.  Typical residential electric customers will experience total bill increases of approximately 7.85 percent, equating to approximately $12.65 per month.

Orange & Rockland serves 233,000 residential electric customers in Rockland, Orange, and Sullivan counties.  On March 19, 2025, the PSC adopted a three-year rate plan for Orange & Rockland that substantially reduced the utility’s initial request, keeping electric revenue flat for the first year while authorizing incremental increases in subsequent years. For residential electric customers using 600 kilowatt-hours per month the 2025 total bill increase will be 4.6 percent, in 2026 the total bill increase will be 3.3 percent and in 2027 the total bill increase will be 3.5 percent total bill increase.

New York State Electric & Gas (NYSEG) and Rochester Gas & Electric (RG&E) filed rate case proposals on

June 30, 2025.  The case is currently under review.  I am an active party in the rate cases and am unsure what I can say about the status.  I don’t think it is inappropriate to note that an evidential hearing is scheduled for early February.  The service territories of the two utilities are all over the state but is primarily located in Central and Western New York.  NYSEG serves 921,000 customers and RG&E serves 392,00 customers. The initial NYSEG electric request asked for an amount that works out for a typical residential customers (600 kWh electric usage) to a $33.12 per month increase (23.7 percent increase to total bill).  The initial RG&E electric request asked for an amount that works to a $33.01 per month increase (26.0 percent increase to total bill).

 Climate Act Impacts

It is unfortunate that the utilities fail to provide a breakdown of how much implementation of the Climate Act adds to these rate case costs.  I used a Perplexity AI search of the National Grid rate case to provide Climate Act cost estimates.   It found that the approved rate plans do not contain explicit breakdowns of specific dollar amounts or percentages of the rate increases allocated specifically to the Climate Act projectsand state mandated programs. The query response included the following:

CLCPA-Related Investments Identified

While specific cost breakdowns are not provided, the orders identify several CLCPA-related investment categories within the approved rate plans:

Electric System CLCPA Investments

Transmission Infrastructure:

• CLCPA Phase 2 Transmission Projects
• Smart Path Connect
• Grid Modernization

Distribution System Enhancements:

• Enhanced grid capabilities for solar, wind, and energy storage interconnection
• Smart grid technologies to manage intermittent renewable resources
• Electric vehicle infrastructure support programs

Historical CLCPA Investment Context

Previous utility filings and planning documents provide context for CLCPA-related costs across New York utilities:

Statewide CLCPA Transmission Investments:

• Phase 1 Projects: Approximately $4.16 billion in transmission investments and $2.64 billion in distribution investments across all New York utilities
• Phase 2 Conceptual Estimates: $7.62 billion in transmission and $2.16-$2.85 billion in distribution investments (conceptual estimates)

National Grid’s Historical CLCPA Share:

• Phase 2 Transmission: $1.37 billion estimated for National Grid transmission projects
• Phase 2 Distribution: $510 million to $1.2 billion estimated for National Grid distribution projects

Department of Public Service (DPS) staff is supposed to provide Climate Act information. On September 18, 2025 the PSC announced that they “received an update from DPS staff regarding progress toward the clean energy goals of the Climate Act”.  The Second Informational Report prepared by Department of Public Service (DPS) staff “focuses on Commission actions from January 2023 through August 2025, and includes the estimated costs and outcomes from 2023 through 2029 to provide the most up to date information.”  According to the Summary of Ratepayer Impact for Electric Utilities table, residential impacts of the Climate Act range from 4.6% to 10.3% of 2023 total monthly electric bills.  In my opinion, those estimates are conservative because there is immense pressure on agency staff to minimize the costs of the Climate Act.  In addition, the costs necessary to implement the Climate Act were ramping up in 2023.  I expect that these costs will continue to climb.

Discussion

The Perplexity summary of the rate cases raised some overarching issues.  New York residential utility bills consist of two primary components, each subject to different pricing mechanisms and contributing to overall cost increases through distinct channels.

Delivery Charges account for approximately two-thirds of bills. These charges represent what customers pay utilities to build, maintain, and operate the physical infrastructure that transmits electricity and natural gas to homes and businesses. Delivery charges remained relatively stable historically but have increased substantially in recent years to fund:

• Infrastructure Modernization and Replacement: Utilities must replace aging equipment that has reached the end of its useful life, including transformers, substations, transmission lines, and distribution networks.
• Grid Hardening and Storm Resiliency: Utilities must enhance system resiliency to manage severe weather events. This includes vegetation management, reinforced poles and wires, and backup systems.
• Clean Energy Integration Infrastructure: The Climate Act mandates necessitate substantial transmission and distribution system upgrades to connect renewable energy resources, accommodate distributed generation, manage bi-directional power flows, and handle increased electrification of transportation and heating.
• Property Taxes: Utility companies pay significant property taxes on their infrastructure, which are passed through to customers. Note that the clean energy infrastructure increases the property tax burden.
• Return on Equity (Profit Margin): Regulated utilities earn a PSC-approved rate of return on their capital investments. Approved returns on equity in recent cases range from 9.4 percent (Con Edison) to 9.5 percent (National Grid).

Supply Charges  account for approximately one-third of bills.  They represent the actual cost of purchasing electricity or natural gas in wholesale markets. These charges fluctuate based on market conditions and are typically adjusted monthly. These have increased for the following reasons:

• Explosive Demand Growth: New York and the broader Northeast region are experiencing unprecedented electricity demand growth driven by several factors that are fundamentally reshaping the supply-demand balance. The New York Independent System Operator (NYISO) reports that the pace of new energy sources coming online is insufficient to keep pace with demand growth.
• Wholesale electricity prices have responded predictably to this supply-demand imbalance. The average monthly wholesale electricity price in New York soared by 67 percent over the past year according to NYISO data.
• Thermal Generation Fuel Costs: Natural gas remains the marginal fuel setting electricity prices in New York’s wholesale markets during most hours. Natural gas commodity prices have increased due to growing domestic demand (particularly for heating during cold winters), export demand for liquefied natural gas, and supply constraints.
• Weather-Driven Consumption: The 2025-26 winter has proven particularly severe, with temperatures 15-20 percent colder than the prior year. Colder weather increases heating demand, driving up both consumption (measured usage) and market prices due to heightened competition for available supply.

Conclusion

These rate case results are unsustainable.  For all the noise made by politicians about affordability, the fact remains that the New York State Legislature or Administration has not defined affordable energy.  The Public Service Commission has an existing target energy burden set at or below 6 percent of household income for all low-income households in New York State.  I have been unable to find any documentation describing how many customers meet the 6% energy burden criteria, much less any information on how those numbers are changing.  The biggest problem with this energy burden program is that it only applies to electric and gas utility customers.  Citizens who heat with fuel oil, propane, or wood are not covered.  There is a clear need for an affordability metric that can be tracked.