Category: Climate Act Costs & Benefits

Last December the Empire Center did a poll that asked questions about the Climate Leadership & Community Protection Act (Climate Act).  I missed it at the time, but the results are striking. This post describes the results and takes a deeper look at the willingness to pay question. 

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the proposed green energy programs are crimes against physics.  The energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources. If this reality is not acknowledged soon and these policies paused, then the enormous costs of this futile gesture to control the climate will bankrupt the state. 

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 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. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

Poll Overview

The Empire Center, based in Albany, is an independent, not-for-profit, non-partisan think tank dedicated to promoting policies that can make New York a better place to live, work and raise a family.  In the interests of full disclosure, I am an adjunct fellow of the Empire Center. 

They sponsored a survey late last year. The Empire Center announcement of the survey says it canvassed 1,021 New York registered voters (margin of error: 3 percent) and was conducted by Morning Consult in mid-December 2024. The toplines and crosstabs can be viewed here.  For survey neophytes like me the topline lists the questions and the overall results.  Crosstabs breakdown the responses by the characteristics of the people polled.  There were 38 questions in the survey and 16 questions about the demographics of the respondents.  The crosstabs provides the breakdown of questions by the demographic categories.

Questions about the Climate Act were in the minority.  Most of the questions were related to the value of taxes paid – “New Yorkers by a margin of more than two-to-one said they aren’t getting their money’s worth from taxes they pay in the state”.  Other questions addressed the education system

There were six questions about the Climate Act.  I will address the first two questions in this article but will only list the others below.

Climate Act Awareness

Knowing what I understand about this law it is frustrating that there is so little pushback associated with it.  The only reason I could think of is that the majority of New Yorkers are unaware of it.  The question “How familiar are you, if at all, with the provisions of the Climate Leadership and Community Protection Act (also known as CLCPA or the Climate Act) that was signed into law in New York in 2019?” confirms my suspicion.

The survey found that 45% of the people polled had never heard of it and another 24% had heard of it, but didn’t know what it is.  In my opinion, if they only have a general sense what it is (another 19%) then they are probably unaware of how much it will cost.  That means 88% of the people polled do not know what is coming in enough detail to understand its impacts on affordability, personal choice, reliability, and environmental impacts.

I believe that the biggest trigger for demands to pause this will be the costs so let’s talk about those results.

Willingness to Pay

I have never seen any poll regarding a willingness to pay that did not find most people are unwilling to pay very much.  This is proof of Roger Pielke’s Iron Law of Climate “While people are often willing to pay some price for achieving climate objectives, that willingness has its limits.”

This poll is no different.  One third of the respondents are not willing to anything on their monthly energy bill for cleaner energy.  Another 28% are only willing to pay up to $20 a month for cleaner energy while another 20% would pay up to $40 a month.  Nineteen percent are willing to pay up to $200 a month but only 3% are willing to pay more than $200 per month. Another 7% did not know or had no opinion.

I recently submitted comments about affordability in Proceeding 22-M-0149 “Assessing Implementation of and Compliance with the Requirements and Targets of the Climate Leadership and Community Protection Act”.  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.  The Mager letter from the Multiple Intervenors pointed out that the DPS and New York State Energy Research & Development Authority (NYSEDA) were supposed to provide an annual report describing Climate Act implementation costs.  No report was produced in 2024 and the letter asked when the next report would be provided.  Waldorf’s response made no commitment.  Given the politicization of all New York agencies and the willingness to pay results I don’t think that it is surprising that the Hochul Administration is stonewalling those estimates because I am sure that they will probably exceed $200 a month.

National Grid Long-Term Gas Plan

In a recent post I described the comments I submitted on Case 24-G-0248 Review of the Long-Term Gas System Plan for National Grid.  That plan describes how the three National Grid operating companies intend to transition away from natural gas out to 2050. 

I was frankly surprised with the costs for just this component of Climate At transition plan.  The scenarios include a reference case, CEV or “clean energy vision”, and AE or “accelerated electrification”.  The difference between the reference case and the CEV scenario represents the minimum cost of the Climate Act.  The following tables are from the Long-Term Gas System Plan document.

The 2030 average monthly increase for National Grid customers in the former Niagara Mohawk service territory ranges from a 50% increase to a 96% increase.  The Climate Act cost by 2030 is $57 additional per month.

Table 12-11: Niagara Mohawk Bill Impacts by Scenario

The 2030 average monthly increase for National Grid customers in the former Brooklyn Union Gas service territory ranges from a 65% increase to a 148% increase.  The Climate Act cost by 2030 is $43 additional per month.

Table 12-12: Brooklyn Union Gas Company Bill Impacts by Scenario

The 2030 average monthly increase for National Grid customers in the former Key Span service territory on Long Island ranges from a 41% increase to a 90% increase.  The Climate Act cost by 2030 is $44 additional per month.

Table 12-13: KeySpan Gas (LILCO) Bill Impacts by Scenario

Willingness to Pay for National Grid Long-Term Gas Plan

In the National Grid Long-Term Gas Plan, the expected increase in price to implement the “clean energy vision” exceeds $40 per month for all three service companies.  Table 1 lists the willingness to pay $40 per month for selected demographics of the survey participants.  Note that 71% of respondents when polled said that they were unwilling to pay more than $40 per month.  I am not going to discuss the demographic breakdowns but present them for your edification.

Table 1: Empire Center Willingness to Pay for Increased Energy Costs Relative to National Grid Expected Gas System Transition Costs of at least $40 per Month Additional by 2030

Discussion

The electric and gas utilities must invest in programs that will implement the Climate Act mandates and those costs are starting to show up in their rate case proceedings.  The National Grid long-term plan to transition the gas system out of existence which is necessary to comply with the Climate Act is but one example.  The expected cost increase by 2030 to fulfill the clean energy vision is more than $40 per month.  Only 22% of the people polled were willing to pay that much.

That is only one cost component for New Yorkers.  Electric bills will need to increase by at least the same amount to pay for the infrastructure necessary to electrifying everything.  The New York Cap-and-Invest program is nothing more than a tax on carbon that will necessarily increase the cost of gasoline and heating fuels.  To electrify homes and transportation individual investments will be necessary.  I believe that when people finally figure out that there is law in place that will markedly increase their energy costs that there will be a reckoning.  I also believe that the Hochul Administration is fully aware of the ramifications of Climate Act costs on the next election.  Consequently, they are slow walking the mandates to provide cost information.

In the meantime, the politicians will be more than willing to let the utilities take the heat for the inevitable major cost increases.  No doubt they will simultaneously forbid the utilities to explicitly break out the Climate Act costs in their bills and demand that they lower their rate case proposals.

Conclusion

Any way you look at the willingness to pay question response, the Empire Center survey confirms Roger Pielke Jr’s Iron Law of Climate.  People polled are not willing to pay much for the net-zero aspirations of the Climate Act if 50% are unwilling to pay more than $10 per month for cleaner energy.  It is troubling that 88% of the New Yorkers polled had no more than a general sense of the Climate Act and many had never heard of it.  This is setting up a reckoning for all the politicians that foisted the Climate Act on New Yorkers.  It is inevitable that the politicians will reconsider and give up on it or be voted out for utter stupidity.  The only question is whether political reality will occur before the electric and gas system is destroyed and costs bankrupts the state.

I have argued that Climate Leadership & Community Protection Act (Climate Act) affordability would become a political issue.  I also argued that when Governor Hochul assigns Climate Act responsibilities to the New York Power Authority (NYPA)and then says “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs” when NYPA proposed raising rates to cover those costs it is hypocritical.  This post looks at utility rate impacts.  Those costs are already increasing dramatically.

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 500 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 two 2030 targets: an interim emissions reduction target of a 40% GHG reduction by 2030 and a mandate that 70% of the electricity must come from renewable energy by 2030. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

Personal Experience

This post was prompted by an email from a friend who sent along screen shots of his most recent and last year’s electric supply bills from New York State Electric & Gas (NYSE&G).

NYSE&G current bill screen shot:

NYSE&G electric bill from a year ago:

I looked up my electric bills.  Here are screenshots of current Niagara Mohawk Power Corporation, dba– National Grid electric rates

Here is a screenshot of the same information from a year ago:

I compared the cost increases in Table 1.  NYSE&G electric supply rates have increased sharply.  National Grid went up but not nearly as much. 

Table 1: New York Electric Supply Rate Increases Examples

New York State Electric Utility Rate Cases

The differences between the two utility rates in Table 1 is striking.  Particularly because the service territories overlap so much (Figure 1).

Figure 1: NYS Electric Utility Service Territories

I suspected that the differences at this time are due to the status of New York State electric utility rate cases.  NYSE&G has recently settled their rate case whereas National Grid is in a pending case.  National Grid rates will go up as soon as a new rate case is settled and the only question is how much.  I checked the Public Service Commission (PSC) Pending and Recent Electric Rate Cases web pages and found the following information.

Niagara Mohawk Power Corporation dba National Grid:

NMPC is requesting an increase in annual electric revenues of approximately $525 million (20 percent increase in delivery revenues or 11 percent in total revenues) for the rate year ending March 31, 2026. NMPC estimates that the requested increase in delivery revenues will result in a monthly bill increase of $18.92 (23.4 percent increase in delivery bill or 15.3 percent increase in total bill) for a typical residential customer using 625 kilowatt-hours (kWh).

For the record here is information on other rate cases listed at the PSC website.

Central Hudson:

Central Hudson Gas and Electric Corporation is requesting an increase in annual electric delivery revenues of approximately $47.2 million (8.8 percent increase in base delivery revenues, or 4.6 percent increase in total system revenues), compared to the revenues approved by the Commission for the Company’s current Rate Year. The requested increase in electric delivery revenues results in a monthly bill increase of $9.19 (8.6 percent increase on the delivery bill, or 5.3 percent increase on the total bill) for an average residential customer using 630 kilowatt-hour per month.

Consolidated Edison:

Con Edison is requesting an increase in annual electric delivery revenues of approximately $1,612 million (an 18.0 percent increase in base delivery revenues, or an 11.4 percent increase in total revenues). The requested increase in delivery revenues results in an average residential monthly delivery bill increase of $26.60 (a 19.1 percent increase on the delivery bill, or a 13.4 percent increase on the total bill) for a 600 kilowatt-hour/month customer. 

The primary drivers of the requested electric increase are local property taxes (which account for an overall electric bill increase of 3.1 percent), new infrastructure investment (2.6 percent) and operating expenses (2.6 percent). Con Edison purports that its filing will help accommodate demand growth, especially with clean energy options and substation investments, while maintaining reliability with investments in feeder replacements. The Company is also enhancing its system resiliency for more frequent and severe storms, as well as warmer temperatures.

In addition, the Company’s filing purportedly includes a focus on improving customer outreach and accessibility, enhancing customer support and the customer experience, and promoting energy efficient programs. The Company plans to expand outreach efforts to enroll eligible customers in the Energy Affordability Program.

I also did a Perplexity AI search asking the question: What is the status of New York State electric utility rate cases.  The results noted that “as of February 17, 2025, there are no pending or recent electric rate cases for New York State Electric & Gas (NYSEG). However, there are some notable developments in the New York electric utility landscape”.  The response stated:

Con Edison’s proposed rate hike: Governor Hochul has directed the state agency to reject Con Edison’s proposed rate increase, which would have raised electricity rates by 11.4% in 2026.

Orange & Rockland Utilities: There is a pending case (Case 24-E-0060) for Orange and Rockland Utilities, Inc. The company is requesting a 7.3% increase in electric delivery revenues for the rate year ending December 31, 2025.

National Grid: The company filed a request in May 2024 for new electric and gas rates in upstate New York, proposing to reset prices beginning in Spring 2025.

Previous rate increases: Con Edison has already implemented rate increases of 9% in 2023, 4% in 2024, and 1.4% in January 2025.

Discussion

The Perplexity AI response also noted that “It’s worth noting that Governor Hochul has also directed the Department of Public Service to conduct a statewide audit of utility company salaries and compensation, which may impact future rate cases.”   The referenced article notes that Governor Hochul “pushed back against proposed rate hikes from Con Edison, directing the state’s Department of Public Service to reject the company’s request for approval.”  I believe that there should be a line on bills that documents the Climate Act costs.  That transparency could be politically damaging so that will never happen.

I am also concerned about the Public Service Commission.  Given that all the Commissioners are partisan political appointees when she directs them to reject the rate case, that is what will happen.  Furthermore, most of the board has ties to green energy.  This will certainly lead to biased outcomes that I think will not be in the best interests of New York.

I asked Perplexity AI another question – Are the commissioners of the New York Public Service Commission partisan appointees of the governor. It responded that was true.  The response was based primarily upon New York Public Service Law Section 4 and stated that:

The governor appoints the commissioners with the advice and consent of the New York State Senate.

However, there are restrictions on partisan composition:

• The commission consists of up to seven members.

• No more than three commissioners may be members of the same political party if there are five commissioners.

• If the number of commissioners is increased to seven, no more than four may be from the same political party.

These rules ensure some level of bipartisan representation on the commission, despite the commissioners being appointed by the governor. The commissioners serve six-year terms on a full-time basis.

However, the current composition is anything but bipartisan.  Technically there are only three Democrats and one Republican but four members have direct experience with green energy non-governmental organizations.  The Public Service Commission website for the Commissioners lists the backgrounds of the seven members. 

• Rory M. Christian, Chair of the Commission – Chairs of New York agencies are chosen for political allegiance to the party of the Governor so I count him as a Democrat.  He also was the Director of New York Clean Energy at Environmental Defense Fund.
• James S. Alesi – Held an office as a Republican.
• David J. Valesky – Held an office as a Democrat.
• John B. Maggiore – Worked in Democrat administrations.             
• Uchenna S. Bright – Has not held political office but worked with environmental non-governmental organizations include the Natural Resources Defense Council (NRDC).
• Denise M. Sheehan has not held political office but has “30 years of experience in government and non-profit sectors” and currently serves as Senior Advisor to the New York Battery and Energy Storage Technology Consortium (NY-BEST).
• Radina R. Valova has not held political office.  Served as Vice President of the Regulatory Program at the Interstate Renewable Energy Council (IREC), a national non-profit organization that builds the foundation for clean energy and energy efficiency.  Prior to joining IREC, Ms. Valova served as Senior Staff Attorney and Regulatory Affairs Manager for the Pace Energy and Climate Center in White Plains.

I make that one Republican, three Democrats, and three that could conceivably be called non-partisan but certainly could also be called environmentalists.  As a result, I think the makeup of these Commissioners will acquiesce to anything the Governor wants.  At the top of that list is the Climate Act green energy narrative that transitioning away from fossil fuels to “free” solar and wind will lower prices.  If that does not happen it must be because of the greedy utility companies.

There is only one problem with that approach – reality.  In the real world, providing reliable wind and solar energy is expensive.  The utility companies will be on the hook to provide the distribution and transmission system upgrades necessary to get the diffuse solar and wind power from where it is generated to where it is needed.  The utility companies have also been told to develop infrastructure for electric vehicle charging. If Hochul’s grandstanding disapproval of rate cases continues, then how are those necessary components of the net-zero transition going to get built?

Conclusion

Hochul was quoted as saying “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs.”  I can’t believe that the Hochul Administration does not understand that the transition will cost enormous amounts of money and is a major reason for those “astronomical” costs.    In my opinion, the political solution is to stop the transition and blame someone else.  I expect that the Trump Administration’s slow down of offshore wind, cancellation of electric vehicle mandates, and the cut back on components of the Inflation Reduction Act will provide the political cover for Hochul to say we tried but evil Trump makes it impossible.   Stay tuned to the political theater as this unfolds.

I recently evaluated the New York Affordable Energy Future proposal for revenues generated by the New York Cap-and-Invest (NYCI) program.    Their report includes a perfect example of New York State Energy Research & Development Authority (NYSERDA) mal-information created by NYSERDA’s intentional misrepresentation of their cost estimates for the Climate Leadership & Community Protection Act (Climate Act) implementation plan. 

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 490 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 2030 reduction target of a 40% GHG reduction by 2030.  The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022. 

NYSERDA claims that there was “robust public input” during the draft Scoping Plan process that “included 11 public hearings across the State and more than 35,000 written comments” that supposedly were read, summarized, and presented to the CAC.  However, the summary was a slide presentation.   The public comment period for the Draft Scoping Plan closed on July 1, 2022.  The CAC reviewed the feedback received from stakeholders over a series of five meetings from August 23, 2022 to October 25, 2022.  The presentations for all CAC meetings are posted and all public comments received by the CAC are available. However, NYSERDA did not summarize the comments or provide a response to them.

False Information

There is a bigger problem with the Scoping Plan implementation process than the lack of documentation.  The Hochul Administration and NYSERDA are guilty of peddling false information.  Media Defence defines three false information terms:

• Disinformation: Disinformation is information that is false, and the person who is disseminating it knows it is false. “It is a deliberate, intentional lie, and points to people being actively disinformed by malicious actors”.
• Misinformation: Misinformation is information that is false, but the person who is disseminating it believes that it is true.
• Mal-information: Mal-information is information that is based on reality, but it is used to inflict harm on a person, organization or country.

I am not going to assign motives to the agencies and staff responsible for the Scoping Plan component of Climate Act implementation, so I am not going to accuse anyone of disinformation.  However, there are examples of misinformation and mal-information on the record in the Scoping Plan process.

Misinformation

At the May 26, 2022 Climate Action Council meeting the topic of misinformation came up as I documented here.  CAC Co-Chair Basil Seggos discussed his thoughts starting at 19:50 of the recording and brought up the subject of public engagement.  He admitted that when they got out into public that they gained a better appreciation of the scale of the challenge.  He said it was tough to communicate the challenges but when on to say there is lots of “misinformation and misunderstanding but also lots of excitement and support”. 

One topic for misinformation according to CAC member comments was concerns about the reliability of an electric system that relies on wind and solar.  Paul Shepson (starting at 23:39 of the recording said:

Mis-representation I see as on-going.  One of you mentioned the word reliability.  I think the word reliability is very intentionally presented as a way of expressing the improper idea that renewable energy will not be reliable.  I don’t accept that will be the case.  In fact, it cannot be the case for the CLCPA that installation of renewable energy, the conversion to renewable energy, will be unreliable.  It cannot be.

Robert Howarth, starting at 32:52 of the recording) picked up on the same issue.  He said that fear and confusion is based on misinformation, but we have information to counter that and help ease the fears.  He stated that he thought reliability is one of those issues: “Clearly one can run a 100% renewable grid with reliability”, although he did admit it had to be done carefully. 

Since then, the claims that the conversion to renewable energy had no reliability challenges that could not be overcome with existing technology have been shown to be false.  The CAC members who dismissed anyone who disagreed as purveyors of misinformation were clearly wrong.  I have documented that experts, including those that are responsible for electric system reliability, agree that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary during extended periods of low wind and solar resource availability.  The fact that this requirement was included in the Integration Analysis and Co-Chair Seggos did not call out the CAC members who claimed that no new technologies would be needed and allowed them to enter those statements in the record is clear misinformation.

Mal-Information

The authors of the New York Affordable Energy Future proposal were tricked by mal-information in the Scoping Plan.  The report notes that “NYSERDA has estimated that decarbonizing the state will cost $11 billion in 2030, counting both private and public spending.  That statement was document with the following reference: “According to p. 131 of the NY Climate Action Scoping Plan (NYS Climate Action Council 2022).”  The Scoping Plan states “In 2030, annual net direct costs relative to the Reference Case are around $11 billion per year, approximately 0.5% of GSP; in 2050, costs increase to $41 billion per year, or 1.3% of GSP. 

Lest you think this is an isolated reference, Governor Hochul’s executive budget described in the FY2026 NYS Executive Budget Book included the following paragraph:

From the beginning of her administration, Governor Hochul has made it clear that responding to climate change remains a top priority for New York State. Acknowledging that the cost of inaction greatly outweighs the cost of any actions we can take together, New York will continue to pursue an aggressive agenda in transitioning to a sustainable green energy economy, in a way that is both environmentally effective and economically affordable for all New Yorkers.

Unfortunately, the statement is deliberately misleading.  The Hochul Administration wanted to be able to say that implementing the Climate Act would be beneficial.  NYSERDA provided support for the sound bite “The costs of inaction are more than the costs of action” that has been the mantra of the Administration.  However, that statement is misleading and inaccurate as I documented in my verbal comments and in my written comments on the Draft Scoping Plan.  I described the machinations based on reality used to mislead and harm New York as a shell game in a summary post.

The reason that this claim is a shell game is that the cost estimate everyone wants to know is how much it is going to cost to achieve the New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and all the other targets in the Climate Act. The “New York Affordable Energy Future” authors said “NYSERDA has estimated that decarbonizing the state will cost $11 billion in 2030, counting both private and public spending” I believe that they presumed that number included all the costs of all the decarbonization programs needed to achieve the Climate Act targets.

The NYSERDA gimmick used to support the narrative picks and chooses what control strategies are included in the costs of de-carbonization.  To evaluate the effects of different policy options, this kind of modeling projects future conditions for a baseline case.  The evaluation analysis makes projections for different policy options, and then the results are compared relative to the baseline.  The standard operating procedure is to use a business-as-usual or status quo case for the baseline. 

NYSERDA did not do that.  In my review of the Draft Integration Analysis supplement, I showed that NYSERDA conjured up a Reference Case to fulfill their imperative to “prove” Climate Act benefits.  Instead of a typical baseline case, the Reference Case used in the scenario excluded programs that are needed to meet the Climate Act targets but were implemented before the Climate Act was passed.  I think it is troubling that this approach was hidden.  I identified the problem only after I searched the Scoping Plan documents for the phrase “reference case” to try to determine what “already implemented” decarbonization programs were included in the Reference Case.  The following figure reproduces the page with the documentation on page 12 in Appendix G Integration Analysis Technical Supplement Section I. The documentation is buried in the footnote for the circled reference for the blank caption to Figure 4. 

Given its importance to the cost/benefit claim, my Draft Scoping Plan comment noted that this reference case caveat should have been clearly described in the text rather than in a footnote.  The Final Scoping Plan document included explanatory text in section 5.3 of the document.  However, that text was not even included in the draft document!  

The appropriate descriptive text is in the final Appendix G section 5.3: Scenario Assumptions chapter and lists the “already implemented” programs.  It states:

The integration analysis evaluated a business-as-usual future (Reference Case) a representation of recommendations from CAC Advisory Panels (Scenario 1), and three scenarios designed to meet or exceed GHG limits and carbon neutrality (Scenarios 2 through 4). Scenarios 2, 3, and 4 all carry forward foundational themes based on findings from Advisory Panels and supporting analysis but represent distinct worldviews. A detailed compilation of scenario assumptions can be found in Annex 2.

For the record Annex 2 refers to a massive spreadsheet that is certainly detailed but most certainly does not provide an easily accessible compilation of scenario assumptions.  In particular, the documentation does not provide explicit information to determine what costs are specifically included in the Reference Case relative to the other scenarios.

The Reference Case described as “Business as usual plus implemented policies” includes the following:

• 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)

Mal-information is information that is based on reality, but it is used to make misleading statements that improperly convey a false narrative.  In this case, the uncommon definition of the base case used for the implementation cost modeling led most New Yorkers to believe that annual net direct costs to achieve the Climate Act targets were around $11 billion per year.  The Scoping Plan mentions that those costs are “relative to the Reference Case” but the draft Scoping Plan did not document what programs were included in the Reference Case.  This is why I believe that the “costs of inaction and more than the costs of action” narrative is mal-information. 

Discussion

This post was prompted by my realization that the authors of the New York Affordable Energy Future report were misled by NYSERDA mal-information related to the expected annual net direct costs needed to achieve the Climate Act mandated targets.  When I did some background research I found Media Defence definitons of three false information terms and realized that NYSERRDA was guilty of two out of three.

NYSERDA is guilty of misinformation because the Scoping Plan was approved because information fundamental to the implementation schedule was known to be false.  The only way to justify the Climate Act schedule is to believe that no new technology is needed so the only constraint is deployment.  CAC member Dr. Robert Howarth is the primary source of that presumption, and I am sure he believes that no new technology is needed.  However, the Integration Analysis recognized that during extended periods of low wind and solar resource availability that a new DEFR technology is needed.  The leadership of the CAC should have addressed this fundamental issue.  That they didn’t was likely because acknowledging the problem is tantamount to admitting that the Climate Act law was deeply flawed. 

NYSERDA and Governor Hochul are guilty of peddling mal-information.  Their oft-repeated sound bite that the “costs of inaction are more than the costs of inaction” is based on reality but mis-leads and harms New Yorkers because it does not include all the costs necessary to meet the Climate Act mandates.  No one cares which regulation, or law mandates a specific portion of the total costs necessary to meet the goals.  The total costs are all we care about.

NYSERDA claims that there was “robust public input” during the draft Scoping Plan process that “included 11 public hearings across the State and more than 35,000 written comments” that supposedly were read, summarized, and presented to the CAC.  The problem is that NYSERDA and DEC staff screened the comments and only presented generalities and not specific comments that questioned any of the narrative that the Administration wanted pushed. I specifically addressed this issue in my verbal and written comments but have never seen any evidence that anyone on the

I recently found an example of how a stakeholder process should work.  The Santa Clara County Rapid Transit Development Project includes a master plan for transportation for Silicon Valley.  An interview with the founding manager notes: “Part of the plan is a four-year public stakeholder review process.  In the reviews, if the public came up with good ideas, the ideas went into the plan.  If an idea wasn’t good, we had the responsibility of explaining why.”[1] 

That commitment to responding to comments is sorely needed in New York.  In my opinion, the CAC should have been informed about this issue.  A summary describing what I claimed, their response to my concern, and a recommendation for the CAC is necessary to assure public confidence in Climate Act implementation.  If NYSERDA is to have any credibility regarding their stakeholder process, then they must provide better documentation showing that all the comments were considered and addressed.

Conclusion

The Hochul Administration has been the first to pitch a fit and throw around the misinformation label when anyone says something contrary to their narrative.  They are not only guilty of pushing misinformation but worse, they spout egregious mal-information whenever they claim the costs of inaction are more than the costs of action.

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[1] “California’s High-Speed Rail Visionary” Bill Buchanan, Trains, Volume 85, No. 1, January 2025, pages 30-37.