Update: My presentation is available on Youtube

On August 8, 2026 I gave an affordability presentation at the Stop Energy Sprawl Conference “Connect Across the Lines”.  This post documents my presentation as promised to the attendees. Although it just provides bullet points with links others may find it useful as a summary of my Climate Leadership & Community Protection Act (Climate Act) affordability concerns.

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 risks, unacceptable costs, and adverse environmental impacts.  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

Stop Energy Sprawl is a coalition of  community groups, municipalities, and elected officials from localities in New York State targeted by land-wasting, large-scale wind and solar projects located far from where that energy is needed. This year’s conference, aims to inform on the affordability, legality, feasibility, and community impacts of New York’s energy policies. 

The post reproduces the slides with references included.  I acknowledge the use of Perplexity AI to find and summarize my articles documenting this presentation.  I used Perplexity AI to prepare a list of links to my articles related to specific topics that I linked to my web site. Those links are labeled as (Perplexity AI Summary).

Introduction

• Personal Concerns
  • Ideological purity over pragmatic tradeoffs
  • Insufficient documentation (Perplexity AI Summary)
  • Flawed implementation process (Perplexity AI Summary)
  • More harm than good
• Primary personal concern has always been affordability

Affordability Presentation Topics

• Climate Leadership & Community Protection Act (CLCPA or Climate Act) energy transition
• “Cheap” renewables myth
• Affordability Messaging in State plans
• Ratepayer Impacts per Kris Martin

Climate Act Premise

• Academics premise of CLCPA transition (Perplexity AI Summary)
• Energy Transition build plan (Perplexity AI Summary)
• Feasibility

Source: Climate Act Scoping Plan

• Scoping Plan
  • Goal
  • Completion
  • Affordability slogan (Perplexity AI Summary) “The costs of inaction are more than the costs of action”

• State Energy Plan
  • Requirement
  • Goal
  • Same failure to include a base case without all the CLCPA costs Draft NYS Energy Plan Pathways Scenario Scam
  • Affordability message (Perplexity AI Summary):
    • Future energy costs necessarily will increase substantially and the costs to comply with the CLCPA are relatively small

•  Public Service Law § 66-p
  • Public Service Law 66-p (Perplexity AI Summary) Implications
  • Section 66-p (4) includes an affordability safety valve if “there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.
  • PSC may “temporarily suspend or modify the obligations” of the CLCPA after conducting a hearing
  • Two petitions requested that the PSC address this
  • On 1/28/2026 the PSC asked for comments
  • Comment deadline was the end of April
  • No action taken yet

• Why Affordability Matters Now
  • Nearly 1.3 million households were 60+ days behind on utility bills in 2025
  • Total arrears exceeded $1.8 billion at the end of 2025
  • The biggest costs are still ahead of us

• There is No Clear CLCPA Affordability Limit –  No references needed
  • CLCPA does not define acceptable consumer cost impacts
  • Without a clear affordability boundary, there is no real cost constraint.
  • That makes affordability a political slogan instead of a measurable requirement.

Source: Adapted from figure by Charles Rotter at Watts Up With That

• But What About Cheap Renewables? (Perplexity AI Summary)
  • Energy storage
  • Transmission Upgrades
  • Backup generation
  • Grid ancillary support
  • Dispatchable, firm generating resources

These issues are addressed in a subsequent presentation.

• Cheap Renewables – Only Half the Story
  • The “cheap renewables claim usually refers to low project-level Levelized Cost of Energy (LCOE), not total system cost.
  • LCOE measures the cost of producing electricity when available, not the cost of running a reliable grid.
  • Consumers pay for a full electric system, not just low-cost megawatt-hours.
  • The grid must work on the worst day of the year – high load low, renewables
  • Cheap electricity is not the same as dependable electricity.

Source: NYISO 2025-2044 System and Resource Outlook Appendix J: Renewable Generation Pockets

• Hidden Cost – Transmission (Perplexity AI Summary)
  • Large-scale renewable development requires major transmission upgrades to move power from Upstate to New York City and Long Island
  • Simple project-level cost claim do not include interconnection and grid reinforcement costs
  • Consumers ultimately pay for wires, substations, and congestion relief through rates.

• Hidden Cost – Reliability Backup (Perplexity AI Summary)
  • A weather-dependent grid still needs firm resources for cold, snowy, dark, and low-wind periods.
  • Short-duration batteries can help with ramps and short peaks, but not long-duration system stress.
  • Long-duration periods require special resources that are not commercially available at this time so costs are unknown.  This is the Dispatchable Emissions Free Resource (DEFR) technology

• Hidden Cost: Electrification (Perplexity AI Summary)
  • Affordability impacts extend beyond utility bills to building conversions, appliance replacement, and vehicle transition costs.
  • Households face upfront capital costs even before any promised fuel savings appear.
  • Low- and middle-income customers are least able to absorb these transition costs.
  • A true affordability review should count economy-wide household energy burdens, not just electric rates.

Another Way to Look at “Cheap” Myth

• Weather-dependent electric grid needs four systems for reliable power per Scott Grout
  • Base wind and solar fleet
  • Battery system for diurnal and short-term backup
  • Additional wind and solar to power the battery systems
  • Dispatchable firm resources during the doldrums
• Each system makes for a larger, more complex, and more expensive electric grid.

Source: Healthy Skeptic “Energy Subsidies”

If renewables are so cheap why do they need subsidies?

• Kevin Roche argues that the total taxpayer subsidy per energy produced shows that renewable wind and solar require subsidies

Source of Graph: Scoping Plan Chapter 10: Benefits of the Plan

Scoping Plan Affordability

• Costs of inaction are more than the cost of action (Perplexity AI Summary)
  • Benefits are societal but costs are real
  • Avoided GHG benefits calculated incorrectly
  • Costs are incomplete – do not include all funds needed to achieve CLCPA mandates
• Affordability References
  • Climate Act Costs and Benefits
  • Scoping plan analyses of costs
  • Scoping plan analysis of the benefits

State Energy Plan Affordability

• State Energy Plan Affordability (Perplexity AI Summary)
  • The energy affordability analysis in the Energy Plan shows that “the use of new, efficient equipment and electrification can cut energy spending by $100 to over $300 every month for many New York households, across energy costs for transportation and heating and utility bills.”

Source: NYS Energy Planning Board Meeting Presentation Slide 40

• State Energy Plan Affordability Claim
  • Equipment Costs Implications Article on the NYSERDA Energy Plan Fact Sheet

I developed this figure to summarize the changes needed to electrify households

Source: NYS Energy Planning Board Meeting Presentation Slide 43

• Energy Affordability with equipment costs
  • The December 2025 Energy Affordability Data Annex spreadsheet (Annex Spreadsheet)  and the Energy Affordability Impacts Analysis (Perplexity AI Summary) document provide the supporting documentation for the Fact Sheet.

Source: NYS Energy Planning Board Meeting Presentation Slide 43

• Bottom Line Climate Act Household Cost
  • Difference between Conventional and High Efficient is cost of CLCPA
  • $1,968 minus $1,374 or $594 per month (43%)

Feasibility Warnings

• State Agencies Feasibility Warnings and Affordability (Perplexity AI Summary)
  • State reviews have acknowledged inflation, supply chain problems, permitting barriers, siting opposition, and interconnection delays.
  • The State Energy Plan indicates current deployment trajectories are not sufficient to meet statutory ambitions.
  • Feasibility problems increase affordability risk because delay almost always increases cost.

Direct Ratepayer Costs

• Kris Martin NY Solar Divide Substack
  • September 20, 2025: “Where the money comes from”
• October 18, 2025: “What it costs – How solar and wind buildout affects NY electric bills”

Ratepayer Costs – What is Included

• Renewable projects are supported through Renewable Energy Credits (RECs) and Offshore wind Renewable Energy Credits (ORECs) purchased by NYSERDA and passed through to utilities.
• Zero Emission Credits (ZECs) support nuclear plants undermined by renewable subsidies
• Utilities recover those costs from customers through electric bills.
• Climate Act charges also include related items such as EV incentives and transmission upgrades that are buried in utility bills.
• Commercial and industrial customers face even higher Climate Act bill percentages than residential customers.

Source: NYS DPS Second CLCPA Informational Report on Overall Implementation of the CLCPA

• Current Bill Impacts Look Smaller Than They Really Are
  • The PSC says Climate Act costs are still a small portion of the typical residential bill.
  • That is true only because the forecasts include contracted Tier 1 projects awarded through 2024, not the much larger future buildout needed to meet the law’s targets.
  • In other words, today’s bill impacts reflect only part of the program cost.
  • The larger REC and OREC obligations are still ahead.

• Charges Reflect an Incomplete Buildout
  • Kris Martin notes that the 2029 forecast includes existing and already-contracted capacity, but not the additional capacity still needed for the 2030 renewable mandate.
  • Those omitted resources represent considerable added cost.
  • If Climate Act costs remain “modest,” that is evidence that buildout is falling short, not that the transition is cheap.
  • Ratepayers will eventually be asked to fund the missing capacity if the mandates stay in place

• REC Costs Could Rise Sharply
  • At roughly similar REC pricing, wind and solar generation growth from about 6.5 million MWh in 2024 to more than 63 million MWh in 2030 would raise REC costs from about $220.9 million to above $2.1 billion.

• NYISO Key Findings Affecting Affordability
  • NYISO 2025-2044 System & Resource Outlook
  • Policy stringency
  • Hydrogen dependency is a cost & reliability risk to avoid
  • New resources and retirement planning
  • Transmission bottlenecks
  • Siting large loads matters

• Affordability Key Findings
  • Climate Act “affordability” is a political slogan
  • “Cheap” renewables is a myth
  • Affordability messaging in state plans is misleading at best
  • Ratepayer impacts are significant and will get worse

• Affordability Recommendations
  • Define affordable
  • Do not mandate technology
  • Do not mandate a schedule
  • Do not try to go to zero – lower is good enough
  • NYS GHG emissions are less than one half of one percent of global emissions
  • Global emissions have been increasing more than one half of one per cent per year for decades

Conclusion

New York should replace inflexible Climate Act mandates with an affordability-first, technology-neutral strategy that delivers practical emissions reductions without imposing costs on ratepayers that are disproportionate to the State’s limited influence on global emissions

The New York Independent System Operator (NYISO) released its 2025-2044 System & Resource Outlook (Outlook on July 22, 2026.  The report is framed as a reliability and resource planning document — not an affordability study — but the cost implications buried in its findings are hard to miss. NYISO never uses the word “affordability” as a headline, but the numbers do the talking. Here’s what jumped out at me, and why I think it validates concerns I’ve been raising for years about the Climate Act’s implementation trajectory and associated costs.

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 risks, unacceptable costs, and adverse environmental impacts.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 650 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.  I acknowledge the use of Perplexity AI to generate an initial draft of this article. 

Background

The NYISO is responsible for electric resource planning for New York State.  The Comprehensive System Planning Process (CSPP) consists of four components: the Local Transmission Planning Process (LTPP), the Reliability Planning Process (RPP), the Economic Planning Process, and the Public Policy Transmission Planning Process. I discussed this process in my earlier article about the Outlook.  On August 3, 2026 the NYISO hosted a public information briefing on the document and the slide presentation gives a good overview.

Capacity Needed for Full Zero-Emissions

The Outlook evaluates 20 scenarios (up from just five in the prior 2023-2042 Outlook), varying demand growth, resource availability, and policy stringency. I think the most striking finding is that futures requiring a 100% zero-emissions grid by 2044 require roughly 105 GW of new resources under higher demand conditions, compared to just 30-60 GW for “policy-relaxed” futures that allow continued operation of repowered and new dispatchable fossil generation. Scenarios with no clean energy targets at all land at just 10-35 GW.

For context, New York has added less than 15 GW of new resources to the entire system in the last 25 years. NYISO is telling us, in its own understated way, that the full Climate Act pathway demands a buildout of a scale this state has never attempted — and that relaxing the emissions target by even a modest amount cuts the required build by two to three times.

That is not a subtle distinction. Every gigawatt of new capacity must be paid for by somebody, and in New York that somebody is ratepayers. When NYISO says policy design “significantly impacts scale of new resource development,” what they’re really saying is policy design significantly impacts your electric bill.

Hydrogen: The Expensive Bet NYISO Wants to Avoid

Here’s a detail that deserves more attention than it’s getting. The place holder Dispatchable Emissions Free Resource (DEFR) necessary to keep the lights on during extended periods of low renewable resource availability in the Scoping Plan was hydrogen-fueled generation.  In the fully zero-emissions scenarios, NYISO’s modeling leans on up to 30 GW of hydrogen-fueled generation to provide firm capacity during peak periods — capacity that renewables can’t reliably deliver on their own. The catch: hydrogen-based generation “is not currently available at commercial scale and would require significant investment in infrastructure for fuel production, storage, and transportation, which does not exist today.” It’s the only technology in the entire study that isn’t commercially available now.

Dark doldrums are a significant challenge for a wind and solar dependent electric system but are rare.  NYISO’s report notes hydrogen would be expected to run infrequently, at low utilization, because of high operating costs. So we’re talking about building tens of gigawatts of a generation type that’s unproven, expensive to fuel, and would sit mostly idle waiting for the infrequent periods when it is actually needed. Policy-relaxed pathways eliminate this requirement entirely by letting existing and repowered fossil units continue providing that same firm capacity function. This is about as clean an illustration as you’ll find of the tradeoff between chasing a zero-emissions label and containing costs.

Downstate Ratepayers Are Already Feeling the Squeeze

Figure 8 in the report — “Tightened Supply Conditions Drive Higher Downstate Load Payments” — is the closest thing in this document to a real affordability chart, even though NYISO doesn’t call it that. Under the Contract Case (which assumes only currently-committed resources come online, with no additional buildout), modeled load payments in New York City and Long Island climb sharply between 2030 and 2044, dramatically outpacing every other zone in the state. The report’s own explanation: as generator retirements outpace new firm capacity, downstate load centers become increasingly reliant on imports and “higher-cost resources,” and NYISO explicitly ties this to “increased energy prices.”

Outlook Figure 8: Tightened Supply Conditions Drive Higher Downstate Load Payments

Source: 2025-2044 System & Resource Outlook

This isn’t a hypothetical far-future problem, either. The report states system conditions could become “increasingly susceptible to constrained conditions as early as the mid-2030s” — well within a decade. Note that the costs increase in every region, but if you’re a downstate ratepayer, the Outlook is telling you that the bill for current state energy policy starts arriving in less than ten years. 

Even Current Commitments Aren’t Enough

Maybe the most sobering line in the whole report: “Current resource commitments alone, even assuming all resources that have been awarded Renewable Energy Credit (REC) contracts come into service, are insufficient to meet future system needs over the Outlook horizon.” Read that again. Even in the best case where every renewable energy credit contract signed to date actually gets built on time — which, given New York’s track record of delayed offshore wind and slowed renewable development that this same report acknowledges, is itself optimistic — the system still falls short of what’s needed. That’s before you even get to the question of whether ratepayers can absorb the cost of closing that gap.

The report also quietly concedes that under Higher Demand conditions, the Climate Act-aligned scenario does not achieve the 9 GW offshore wind target by 2035 or the 70% renewable-by-2033 requirement, citing real-world constraints reflected in NYSERDA’s own Large-Scale Renewables Supply Curve. I’ve written about this gap between statutory targets and physical/economic reality before — it’s good to see NYISO’s modeling now says so explicitly.

Transmission Fixes: The Cheap Insurance Policy

To its credit, NYISO does flag some lower-cost opportunities that any policymaker serious about affordability should prioritize. Chief among them: targeted dynamic voltage support upgrades at the Central East interface, which constrains the flow of power from upstate generation to downstate load. NYISO frames this as a way to “increase transfer capability and better utilize existing infrastructure” — bureaucratic language for “get more out of the wires we already have instead of building new ones.” Similarly, bulk transmission upgrades in Northern New York are recommended to prevent curtailment of low-cost renewable output that would otherwise get stranded behind transmission constraints — power that ratepayers already paid to develop but can’t use.

These are the kind of targeted, relatively low-capital investments that should be the easy, no-regrets wins in any planning conversation. Compare that to the cost of building 30 GW of hydrogen infrastructure from scratch, and the contrast couldn’t be sharper.

Discussion

Strip away NYISO’s carefully neutral “objective, fact-based planning insights” framing, and here’s what the 2025-2044 Outlook is actually telling New York’s policymakers:

• The stringency of the zero-emissions mandate is the single biggest cost lever available. Relaxing it, even partially, cuts required new capacity by two to three times.
• Betting on hydrogen to fill the capacity gap is a bet on an unproven, expensive technology — and one that policy-relaxed pathways don’t need to make at all.
• Downstate ratepayers are on track for materially higher costs starting as soon as the mid-2030s, driven by tightening supply and increased reliance on higher-cost generation.
• Even full delivery on today’s contracted renewable projects won’t be enough, meaning more spending is coming no matter what.
• The cheapest wins are transmission fixes, not new generation — squeezing more capacity out of existing infrastructure at Central East and unlocking stranded renewable output in Northern New York.

Conclusion

I have long wished that the “independent” NYISO would be more explicit in its analyses about the dangers of political interference in the electric system. They are not in the business of telling Albany politicians what New York climate policy should be, but when their numbers show that the most ambitious version of the Climate Act costs two to three times more in new infrastructure, relies on a technology that doesn’t commercially exist, and hits all New Yorkers with rising bills especially Downstate with its already high prices within the decade — that’s a set of facts policymakers ignore at their own, and ratepayers’, peril.

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.  Proponents disagree insisting that renewables currently provide cheapest electricity.  I addressed this myth based on an article by Matt Jacobson at Matt’s Substack. I promised to follow up with more details.  This article is based on a series of articles at the Science of Doom blog by Steve Carson.  It is a long post documenting all the reasons cheap renewables is misinformation.

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

Carson’s series of articles provided the supporting arguments for a detailed rebuttal of the myth of cheap renewables.  An article by Emily Pontecorvo summarizes the Green Energy Blob take on decarbonization and affordability if you are interested.

The Seductive “Cheap” Story

The primary basis of the myth that wind and solar are now the “cheapest” sources of electricity is  Lazard’s Levelized cost of energy (LCOE).  This parameter claims renewables beat coal, gas, and nuclear on a dollar-per-megawatt-hour basis. This underpins the narrative that renewable energy should translate into lower electricity bills for consumers.  However, LCOE project-level costs are junk.

Steve Carson explains that the reality of jurisdictions trying to transition tells a different story than the LCOE theory. Germany has massively expanded wind and solar while shutting down coal and nuclear, but German households face some of Europe’s highest electricity prices. The United Kingdom’s coal phaseout and wind surge haven’t delivered cheap power. South Australia, with the world’s highest penetration of rooftop solar and substantial wind capacity, maintains some of the developed world’s highest retail electricity rates.

This disconnect between “cheap renewables” and expensive electricity isn’t a coincidence or a policy failure in implementation. It reflects that the LCOE narrative obscures the fundamental truth that the cost of a reliable electricity system is not the same as the cost of intermittent generation. As Science of Doom’s comprehensive series demonstrates, when you need electricity every hour of every day, the system must pay for flexibility, backup capacity, grid stability services, and expanded transmission infrastructure—costs that persist regardless of how low the marginal cost of wind and solar generation falls.

What “Cheap Renewables” Actually Means – Blind Spots in the LCOE Metric

The levelized cost of electricity is the net present value of the unit-cost of electricity over the lifetime of a generating system. It divides total lifetime costs (capital, operations, maintenance, fuel) by total expected lifetime electricity output. LCOE is useful for comparing similar technologies under similar conditions, but it has significant limitations when applied to system planning or comparing dispatchable and intermittent resources.

LCOE looks attractive for wind and solar because these technologies have:

• High upfront capital costs but near-zero marginal operating costs
• No fuel expenses
• Relatively predictable maintenance schedules
• Declining capital costs due to manufacturing scale and technological improvements

In New York’s electric dispatch system, renewables with zero fuel cost naturally displace higher marginal-cost fossil generation when available. This creates the appearance of “cheap” electricity—wind and solar bid low or even negative in wholesale markets, setting clearing prices near zero during periods of abundant renewable output.

What LCOE Doesn’t Capture

The critical problem is what LCOE excludes from its calculation.

• Dispatchability and timing: LCOE treats all megawatt-hours as equal, whether generated at 2 PM on a sunny summer afternoon when demand is moderate and supply is abundant, or at 7 PM on a windless winter evening when demand peaks and solar is unavailable. The market value of these megawatt-hours is radically different, but LCOE treats them identically.
• Capacity value degradation: The first wind farm in a system has significant capacity value—it can reliably displace fossil capacity. But as wind penetration grows and multiple wind farms experience correlated low-output periods, the system cannot count on wind for reliability. Capacity value falls toward zero at high penetration, even as LCOE remains constant.
• Integration and system costs: LCOE does not account for the costs of integrating intermittent generation into a reliable grid. These expenses include: transmission upgrades and expansion to connect remote renewable resources; grid stability and frequency control services (increasingly needed as synchronous generation declines); backup and flexible capacity to cover renewable output variability; energy storage or other time-shifting mechanisms; and curtailment costs when renewable generation exceeds instantaneous demand
• Correlation with demand: Solar generates during midday but not during evening peak hours. Wind output is weather-dependent and poorly correlated with demand patterns. LCOE cannot capture the system cost of this mismatch.

The Merit-Order Illusion

New York’s electric system dispatches on merit order, but when renewables set the wholesale clearing price at near-zero during sunny, windy periods, it creates a misleading signal. Yes, wholesale prices fall—sometimes into negative territory. But the system still requires dispatchable capacity for the hours when renewables cannot generate. That dispatchable capacity must recover its fixed costs from fewer operating hours at higher prices, leading to extreme price volatility. Retailers must price their offerings to survive the high-price periods, so negative wholesale prices do not translate into lower retail bills.

Germany provides a clear test case. From 2010 to 2025, Germany dramatically reduced coal generation, phased out nuclear entirely, and massively expanded wind and solar capacity. Renewable generation now regularly exceeds 50% of domestic production on favorable days. If cheap renewables meant cheap electricity, German consumers should be celebrating.  Instead, German households pay among the highest electricity prices in Europe—often 30-35 euro cents per kilowatt-hour, more than double the rates in France

The merit-order cost stack includes far more than energy and is the reason for the high prices:

• Grid charges: Massive transmission expansion to connect offshore wind in the north to demand centers in the south, plus distribution upgrades to handle distributed solar,
• Capacity payments: Gas plants kept available for reliability despite operating far fewer hours,
• Interconnector costs: Germany now relies heavily on electricity imports from neighbors during low-renewable periods, requiring expensive cross-border infrastructure
• Renewable subsidies: Feed-in tariffs and other support mechanisms recovered through consumer surcharges, and
• Ancillary services: Frequency control, voltage support, and system strength services previously provided “free” by synchronous generators now are procured separately.

The Power Grid as Extended Grid Storage

Steve Carson highlights a critical but often invisible function of grid interconnections: they act as “extended grid storage” by allowing regional transmission operators to share both cheap generation and backup capacity. For example, when German wind and solar are abundant, exports flow to neighbors. When German renewables underperform, imports flow back—often from French nuclear, Scandinavian hydro, or even Polish coal.

This flexibility is valuable, but it isn’t free. The infrastructure costs billions, and Germany effectively outsources reliability to its neighbors’ dispatchable capacity. The neighboring countries must maintain that capacity, and those costs ultimately appear in electricity prices across the interconnected system.  This is an inevitable result in North America.

South Australia  -The World’s Renewable Laboratory

South Australia offers the clearest real-world experiment in high-renewable electricity systems. This small state (1.8 million population) transformed its grid faster and more completely than almost any comparable jurisdiction:

• Extremely high rooftop solar penetration—over 40% of households with solar panels,
• Substantial utility-scale wind capacity,
• Tight interconnection to the rest of Australia’s National Electricity Market (NEM),
• Aggressive renewable energy targets and supportive policies, and
• Near-complete exit from coal generation

If cheap renewables automatically produced cheap electricity, South Australia should have the lowest power bills in the developed world. Instead, it consistently ranks among the highest.

The Canyon Curve: Free Solar, Expensive Evenings

South Australia has better solar resource potential than New York.  Carson’s analysis reveals the “pricing paradox” at the heart of South Australia’s solar experience. The wholesale price pattern creates a dramatic “canyon curve”, i.e., a more intense duck curve load and generation pattern:

• Midday (high solar output): Wholesale prices regularly fall to zero or go negative. In 2025, nearly half of all trading intervals saw negative prices during midday hours. Generators literally pay to produce electricity because they cannot or will not curtail output.
• Evening ramp (solar fades, demand peaks): Prices spike dramatically, often reaching several thousand dollars per megawatt-hour. Extreme spikes to $15,000/MWh (the market price cap) occur dozens of times per year during tight supply conditions.

This extreme volatility creates a counterintuitive result: even though wholesale prices are “free” or negative for many hours, retail bills remain very high. Several mechanisms drive this outcome:

• Scarcity pricing sets clearing prices for everyone: In the NEM’s energy-only market, the last, most expensive generator needed to meet demand sets the wholesale price for all generators in that interval. Even if 95% of electricity comes from “cheap” wind, batteries, and gas, if the final 5% requires an expensive gas peaker bidding $10,000/MWh to cover its costs in limited operating hours, everyone gets paid $10,000/MWh for that interval.
• Retailers must survive the spikes: Retail electricity providers offer customers flat-rate contracts, but they purchase wholesale power at volatile spot prices. To avoid bankruptcy during extreme price events, retailers must build a substantial risk premium into their retail tariffs. A few hours per year at $15,000/MWh can exceed the cost of thousands of hours at negative prices.
• Time-of-use tariffs have limited adoption: Most residential customers remain on flat-rate tariffs and cannot respond to price signals. Even customers with solar panels typically don’t have battery storage to arbitrage the price differential, so they export at negative prices and import at extreme prices.

Invisible Costs: Flexibility, Backup, and Wiring

Carson’s detailed analysis of South Australia’s battery deployments reveals a critical misunderstanding in public discourse about energy storage. Large-scale batteries are not being built to store “a day” or even “several hours” of electricity for later use. They’re being built because the market pays premium prices for fast response in specific narrow windows.  I have never seen this distinction mentioned relative to New York but suspect that we are not there yet.

Two articles (Batteries in SA: The Market in Operation and Batteries and the Market Machinery — How the Grid’s ‘Invisible Hand’ Rewards Speed)  describe the  actual function of grid batteries in South Australia (Table 1).

Table 1: Grid battery revenue streams in South Australia

Batteries are valuable and economically rational investments given current market design, but they don’t fundamentally solve the integration challenge. Their limited duration (typically 2-4 hours) means they cannot address multi-day weather events or seasonal renewable output variations.

Transmission: The 1,500km Relay Race

Carson’s analysis of European transmission interconnections illustrates another hidden cost: transmission infrastructure operates as a multi-decade, multi-billion-dollar “relay race” to move power across vast distances.  Green energy advocates in New York universally ignore the challenges of supplying renewables across great distances but claim that this is a solution to local renewable lulls.

Carson describes the challenge for jurisdictions further along the transition to renewables,  Spain, for example, often experiences weather patterns opposite to Germany—sunny and windy when Germany is calm and cloudy. In principle, Spanish renewable generation could supply German demand. In practice, moving that power requires it to flow through France, with each border crossing representing a constrained bottleneck. Expanding these interconnectors requires massive investment and decades of planning and construction.

Even within countries, transmission expansion represents a substantial cost. Renewable resources are often located far from demand centers (offshore wind, remote solar farms, high-altitude wind sites). Connecting them requires new high-voltage transmission lines, substations, and grid reinforcements. These infrastructure costs are recovered from consumers through grid charges, separate from energy prices.  Upstate New York electric rates are increasing because of this..

Reliability Problems in a Renewable-Based Grid

Most electricity markets were designed around a specific paradigm: generators with controllable output and marginal costs that rise with fuel consumption compete to supply demand, with the market clearing at the marginal cost of the last generator needed. This “energy-only” market design works reasonably well when most generation is dispatchable.  New York’s market also includes a capacity component but problems remain. These references (one and two) describe how intermittent renewables change electric resource planning in several ways:

• Zero marginal cost undermines investment signals: When wind and solar set clearing prices at or near zero during periods of abundant output, dispatchable generators cannot recover their fixed costs. This discourages investment in the backup capacity the system requires for reliability during low-renewable periods.
• Capacity value diverges from energy value: A generator that produces cheap energy when it’s not needed has low system value. A generator that reliably produces energy during scarcity periods has high system value. Energy markets struggle to properly value this difference, leading to underinvestment in dispatchable capacity[.
• The “missing money” problem: Dispatchable plants kept available for reliability but operating only during scarcity periods cannot earn sufficient revenue from energy-only markets. This creates a “missing money” problem where economically necessary capacity cannot be sustained under market rules.

The Fat Tail Problem

Renewable-dominated systems face what can be called the “fat tail” reliability problem. It’s relatively easy and cheap to supply electricity 90-95% of the time using wind, solar, and short-duration storage. But guaranteeing supply for the remaining 5-10% of hours—when demand is high and renewables are unavailable—becomes disproportionately expensive.

These tail events include:

• Multi-day periods of low wind across a broad geographic region (wind droughts),
• Winter evenings with high heating and lighting demand but no solar output,
• Heat waves with high air conditioning demand and reduced wind, and
• Cold snaps that strain both electricity and gas systems simultaneously.

Current market designs systematically undervalue the capacity needed to address these tail events. The result is either reliability problems (as seen in Texas and California) or out-of-market interventions and capacity payments that add to consumer costs but don’t appear in LCOE calculations and proponent claims of cheaper renewables..

Conclusion

LCOE is the commonly used proof that renewables are cheapest. Steve Carson’s series of articles demonstrates a fundamental point that policy discussions too often overlook: cheap intermittent megawatt-hours are not the same as cheap electricity systems. LCOE measures the former, but consumers pay for the latter.

A reliable electricity system operating 24/7/365 requires:

• Sufficient generation capacity to meet peak demand plus reserves,
• Dispatchable resources or storage to cover periods when intermittent resources underperform,
• Transmission infrastructure to connect generation to load,
• Grid stability services (frequency control, voltage support, inertia, system strength),
• Market mechanisms to ensure adequate investment in all necessary resources, and
• Coordination across time (energy storage), space (transmission), and technology (diverse generation portfolio)

Intermittent renewables with low LCOE can supply cheap megawatt-hours during favorable conditions, but they don’t eliminate or substantially reduce most of these system requirements. In many cases, high renewable penetration increases system complexity and cost:

• More transmission is needed to connect remote resources and balance geographic diversity,
• More flexibility is needed to manage output variability,
• More grid services are needed to replace functions previously provided by synchronous generators, and
• More sophisticated market designs are needed to maintain reliability incentives.

These costs appear in consumer bills as transmission charges, capacity payments, ancillary service costs, and renewable support mechanisms—not in LCOE calculations. Germany’s high consumer prices reflect genuine system costs of operating a high-renewable grid. South Australia’s price volatility reflects the challenge of balancing supply and demand with weather-dependent generation. The UK’s persistent high bills reflect the need to maintain dispatchable backup despite growing renewable capacity.  New York’s transition to a renewable-based electric system will inevitably follow these examples.

Policy Implications

Serious energy policy planning must start from total system cost, not headline LCOE numbers. This means:

1. Evaluate technologies based on system value, not just LCOE. A dispatchable low-carbon resource available on demand may provide more value than a cheaper intermittent resource, even if its LCOE is higher.
2. Account for all integration costs. Transmission expansion, grid stability services, backup capacity, and storage requirements must be included in cost comparisons.
3. Design markets to properly value reliability. Energy-only markets systematically undervalue the capacity needed to maintain reliability in high-renewable systems. Market reforms or capacity mechanisms are necessary.
4. Be honest about cost trade-offs. High renewable penetration may be desirable for emissions reduction, but it comes with real system costs. Pretending these costs don’t exist or can be eliminated through further renewables deployment undermines public trust and leads to poor planning.
5. Diversify the resource portfolio. No single technology provides all necessary grid services. A mix of resources—including dispatchable low-carbon generation, energy storage, demand flexibility, and transmission—produces a more reliable and likely more cost-effective system than over-reliance on intermittent renewables.

The goal should not be the “cheapest” generation on an LCOE basis, but rather the least-cost pathway to a reliable, low-emission electricity system. As the Science of Doom series convincingly demonstrates, these are not the same thing. Until policy discussions and planning processes grapple honestly with this distinction, consumers will continue to face the disconnect between promises of “cheap renewables” and the reality of expensive electricity bills.

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.  The main driver for the proposal to make Climate Act changes is affordability.  Proponents insist that renewables currently provide cheapest electricity.  I address this myth based on an article by Matt Jacobson at Matt’s Substack.

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

I have long been meaning to address the myth that renewables can provide cheap electricity.  I was working on an article today and ran across Jacobson’s article.   My goal was to put something together that was simple and his article does better than the one I was working on so I am publishing this.  Not to worry I will beat the myth to death when I publish the other draft.

Matt Jacobson writes about energy markets, infrastructure, and policy in New England. He is a business development executive at Summit Natural Gas of Maine, a Naval Academy graduate, and a former U.S. Air Force pilot.  A quick review of his articles shows that he is fighting the same nonsense that I am addressing in New York.  I highlight his arguments below with my comments.

The Chart Behind the Claim

Jacobson describes the problem.

For years now, we’ve been told that solar and wind are the cheapest sources of electricity. That claim shows up everywhere—in headlines, policy discussions, and investor decks—and it’s usually backed by some version of a simple cost comparison like this.

On its face, the conclusion is obvious. Solar and wind appear to be the lowest-cost options, while gas looks more expensive.  The chart isn’t wrong—but it’s incomplete. And when incomplete math drives policy, the system ends up costing more than advertised.  It measures the cost of producing electricity when it’s available—not the cost of running a grid. Those are very different things.

It’s also worth noting that rooftop solar doesn’t operate in a vacuum. Net energy billing ties compensation to retail rates rather than system value, so deployment follows customer economics—not grid needs. The result is more distribution upgrades, more complex power flows, and costs that don’t always line up with system benefit—all while the grid still has to be built for peak demand.

This is great – simple, direct and spot on.

What the Chart Misses

Jacobson points out the biggest flaw in the analyses that supported the Climate Act transition plan.

The grid doesn’t run on averages. It runs on the worst day of the year—cold, dark, and still.

That’s the moment the entire system is tested, and the moment that determines what it actually costs.

Wind and solar can be cheap when they produce power, but that’s not the same thing as delivering power when it’s needed. Cheap electricity isn’t the same as dependable electricity.

A power system has to be built to meet demand at all times, not just when conditions are favorable. That means having enough capacity available to carry the load even when intermittent resources aren’t producing. It also means maintaining the infrastructure, fuel supply, and operational flexibility to respond when conditions change.

Once you look at it that way, the gap becomes obvious. The cost of producing electricity is only one piece of the puzzle. The cost of making sure it’s there when you need it is what actually defines the system.

What This Looks Like in the Real World

One of the biggest failures of the Climate Act is ignoring what is happening in other jurisdictions that are further ahead in their net-zero transition.

If this still feels theoretical, you can see it play out in real time in places that have leaned heavily into solar.

California now produces so much solar power at midday that electricity prices can collapse to near zero—or even go negative, because supply exceeds demand. That sounds like a success until a few hours later, when the sun sets and demand is still high. At that point, the system has to replace a large amount of lost generation very quickly. Dispatchable plants ramp, imports increase, and prices rise as the system scrambles to maintain balance.

Nothing about that is free. The system still has to be built to handle both conditions—the oversupply in the middle of the day and the shortfall in the evening. That means maintaining capacity that sits idle for part of the day and then runs hard when it’s needed most.

Batteries can shift some of that midday solar into the evening, but only within limits. Most grid-scale batteries today are designed to discharge for a few hours, not to carry a system through multi-day weather events or extended winter peaks. Batteries don’t know where electricity comes from—they respond to price. And in many hours, that price is set by a grid still dominated by natural gas.

To rely on them as a full solution, you would have to build enough excess generation to charge them and enough storage to carry the system when that generation isn’t there. That means building significantly more capacity than you otherwise would, and then maintaining a system that is both larger and more complex.

Also note that New York agencies agree that traditional storage is insufficient for multi-day dark doldrums and have recommended developing a new technology for those periods.

The Simple Reality Check

I agree completely with this:

There’s a simple way to test the claim that wind and solar are now the cheapest sources of electricity. Look at the places that use the most of them. If the claim were true, those places should have the lowest electricity prices.

They don’t. States like California, which have invested heavily in solar, consistently have some of the highest electricity prices in the country, while many lower-cost regions rely more heavily on power plants that can run when needed.

At some point you have to decide whether to trust the model or what’s actually happening.

What It Actually Takes to Run a Grid

In my next post on the myth of cheap renewables I will provide more detail about this topic.

What’s missing from that original chart is everything required to make the system work. A power system doesn’t just produce electricity—it has to deliver it reliably, at all times, under all conditions.

That means maintaining backup generation for when the sun isn’t shining and the wind isn’t blowing. It means building storage to shift energy across hours or days. It means expanding transmission to move power from where it’s produced to where it’s needed. And it means carrying enough redundancy in the system to ensure it doesn’t fail under stress.

None of that is free, and none of it is optional.

Once those requirements are included, the economics change. The question is no longer which resource produces the cheapest electricity in isolation, but what combination of resources can meet demand reliably. That’s a very different problem—and a much more expensive one.

Additional Complications

I prepared this post to address the myth of cheap renewables.  Jacobson goes on to discuss other topics.  He describes the Myth of “Transition” as the idea that we are switching from one energy system to another. He makes a persuasive argument that historical energy transitions added more energy to the system and did not substitute for the one before it.  “ Wind and solar are being added to the grid, but the underlying system that ensures reliability—power plants that can run when needed, fuel supply, and infrastructure—has not gone away.”

I have followed the Climate Act since 2019 and when I tell people about it that usually have never heard about it but their response is invariably what about reliability.  Jacobson explains: “In colder regions, people rely on fuels that work when it matters—natural gas, oil, propane—because they can deliver heat on demand.” 

What This Means for New England and New York

Jacobson’s description of what is happening in New England is apropos to New York.

On the coldest winter evenings, solar output is effectively zero, wind is often unreliable, and demand is at its highest. The system has to meet that demand regardless of conditions, which means relying on power plants that can run when needed and the fuel supply required to support them.

But the issue isn’t just winter. Solar production is concentrated in the middle of the day, while demand often peaks in the early morning and evening. It also varies by season, producing far more energy in the summer than in the winter, when the system is under the most stress.

That mismatch matters. Even when solar is producing, it often isn’t producing when the system needs it most.

In those moments, the grid isn’t running on what was cheapest to build—it’s running on what is available. And in New England, that often means natural gas, supplemented by oil and imports when the system is tight.

That reality drives cost. The region has to maintain the infrastructure and fuel supply to meet peak demand while also building out additional resources that may or may not be available when needed. The result is a system that is more expensive to operate, not less.

Complexity and Risk

Jacobson points out we are changing how the electric grid operates.

As we push toward more wind, solar, and battery systems, we’re not just changing where electricity comes from—we’re changing how the grid operates.

The traditional system relied on large, predictable power plants that provided stability as a byproduct of how they ran. The newer system relies far more on power electronics, software, and coordination to keep everything in balance. That can work, but it’s inherently more complex.

In pilot training, you learn that the best flights are boring. That only happens with preparation, simplicity, and margin for error. As complexity increases, so does the chance something goes wrong. Power systems aren’t that different.

There’s also a dimension here that gets far less attention: risk. Building out these systems increases reliance on global supply chains for critical materials and components, and much of that supply chain runs through China. China dominates the refining of many key minerals and manufactures the vast majority of the world’s solar panels. Producing those panels is energy-intensive, and much of that energy comes from coal.

None of that makes the technology unusable, but it does change the risk profile. We’re shifting part of our energy system—from fuel we control domestically to supply chains we don’t—while making long-term decisions about infrastructure that will be in place for decades.

The Bottom Line

Jacobson’s bottom line will also serve as my conclusion.

The original chart isn’t wrong. It’s just incomplete.

It tells you what it costs to produce electricity under ideal conditions, but it leaves out what it takes to run a system that has to perform under real ones. Once you account for reliability, timing, infrastructure, and risk, the picture changes.

We haven’t built a cheaper system. We’ve built a larger one—one that layers intermittent resources on top of the infrastructure required to keep the lights on when wind and solar aren’t producing.

And that cost doesn’t disappear. It shows up in higher rates, more complexity, and a system that is harder to operate and more fragile.

My thanks to Matt Jacobson for a clear explanation why wind and solar are not the cheapest form of new generation.

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.