New Yorkers for Clean Power Testimony Ignores the Costs

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

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 680 articles about New York’s net-zero transition.

The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone. I acknowledge the use of Perplexity AI to generate summaries and references included in this document.

Overview

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

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

What is Affordable?

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

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

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

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

Health Benefits Claims Are Weak

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

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

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

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

What Caused the Unaffordability Crisis

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

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

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

Sustainable Future Program and Cap-and-Invest

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

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

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

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

Two Million Homes by 2030

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

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

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

Sunshine is Not Free

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

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

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

Conclusion

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Source: The World is running out of Ore

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

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

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

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

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

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

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

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

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

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

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

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

Stay tuned.

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

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

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

Overview

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

Running Out of Easy Ore

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

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

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

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

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

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

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

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

New York Cannot Count on Its Neighbors

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

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

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

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

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

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

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

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

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

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

Show the Math

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

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

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

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

Discussion

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

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

Conclusion

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

Horseshoe Solar – Unacceptable Solar Project Impacts

On September 29, 2026, the New York State Senate Minority Conference’s Energy Roundtable focused on Solar, Wind and ORES was held at the Onondaga Town Hall. One of the speakers, Janet Glocker, talked about the Horseshoe Solar project and graciously agreed to share her presentation with me. Horseshoe Solar is another example of a project that I think has unacceptable environmental impacts.

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 coupled with the cumulative environmental impacts of those resources. These comments are based on those concerns. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with; these comments are mine alone. I acknowledge the use of Perplexity AI to research and organize the material summarized in this article. The numbers, calculations, and sources behind this post are documented in a Supporting Details attachment.

Horseshoe Solar

Horseshoe Solar was originally proposed under Article 10, so documents are available in the Article 10 permit docket. When the Office of Renewable Energy Siting (ORES) option became available, Invenergy switched, so additional documents are in the ORES permit docket.

According to Invenergy, the Horseshoe Solar Energy Center (accessed on 9/30/2026) is “a proposed 180-megawatt solar power generation facility in Livingston and Monroe Counties” that will deliver “reliable, affordable energy.” Of course, the developer’s description is optimistic. The Public Involvement Program plan claims that the project will produce enough electricity for 50,000 New York households. That is an annual-energy comparison, not a claim that the facility can power 50,000 homes around the clock. It also assumes a 23.4% capacity factor, which is higher than the 18%–19% NYISO reported for New York’s solar fleet in 2024 and 2025. At those observed rates, the household equivalent drops to about 39,000–42,000, and none of those homes would be served at night.

To its credit, Horseshoe Solar has made a permit-backed commitment to agricultural co-use, principally sheep grazing. I believe agrivoltaics commitments like this are appropriate, but I am not sure this one will ever come true. New York has about 83,000 sheep, and grazing every solar project in the interconnection queue would need about 127,000. The 2050 buildout would need about 1 million.

Janet Glocker’s Presentation

Janet Glocker lives in the Town of Rush, where part of Horseshoe Solar is being built. Her full presentation is worth reading. Her refrain throughout was “All this for less than 2 MW?” I expand on five of her points below.

Prime Farmland Conversion

Glocker described her town:

We are primarily rural and agricultural- 19,600 acres of which 50% is farmed. Soils in Rush are characterized as 60% prime farmland, 7.8% prime if drained, 12.5% soils of statewide importance; only 19.6% is not prime farmland.

The Department of Agriculture and Markets has had a goal for solar projects: limit the conversion of agricultural areas within the Project Area to no more than 10% of the soils it classifies as prime farmland that has never been made a requirement. The Department described this goal in testimony in the Trelina Solar case. Horseshoe Solar does not meet that goal. The project area is 3,748 acres, and 552 acres of prime farmland, or about 15%, will be converted to industrial solar use. To be fair, the developer removed arrays from some prime farmland during permitting. Even so, ORES approved a project that exceeds the State’s own agricultural guideline by half. My Solar Development Prime Farmland Scorecard found that most approved projects exceed it. That is a cumulative impact the Climate Act implementation process ignores.

The Genesee River Crossing

The second point is that the project is on both sides of the Genesee River, and the risks of the river crossing exceed the value of the added solar capacity. Glocker explains:

Horseshoe plans to build 8.4MW (name plate) in Rush. We all know that with Great Lakes cloud coverage and the earth’s curvature, we’re lucky if 20%, or 1.68 MW will be produced. Please remember this number- less than 2MW!

Glocker mixes capacity and energy here. Nameplate capacity is the panels’ maximum output under ideal conditions. Her 1.68 MW is the average output over a year, which is really a measure of energy. Using the capacity factors discussed above, the Rush panels would average 1.5 to 2.0 MW, so “less than 2 MW” is a fair description.

For reliability, what matters is effective capacity: how much the resource can be counted on when the system needs it. NYISO’s capacity accreditation factors credit upstate solar at only 13.85% to 15.33% of nameplate. By that measure, the Rush panels are worth about 1.2 to 1.3 MW of reliable capacity, and the entire 180 MW project is worth about 25 to 28 MW. Glocker’s “less than 2 MW” actually overstates the reliability value.

Glocker goes on:

During the Article 10 process… engineers from DPS warned Invenergy about horizontal directional drilling, karst soil, the “swiss cheese, limestone material” that underlies much of Rush. We use springs and wells in the part of Rush near Horseshoe…

The plan was to drill 7 holes under the Genesee. After hitting an aquifer in early February and having holes fill with water, new holes had to be drilled- a 42.8% failure rate. Six residences, immediately across the river from the drilling site had their springs and well water affected…

Six homes, damaged springs and wells, water totes still visible. Not knowing what is happening underground, now or in the future, would you buy one of these houses? All this for less than 2MW.

The record supports her account. 13WHAM reported that groundwater began surfacing on February 3, 2026 at 50 to 100 gallons per minute. The company told News10NBC that five homes had low water levels and that it supplied drinking water. The seepage required two rounds of chemical grouting. On August 26, 2026, ORES asked Invenergy for a plan to monitor the bore area for at least 12 more months. Nearly eight months after the aquifer was punctured, nobody can say for sure that the problem is fixed.

In fairness, the crossing is not just for the Rush panels. According to ORES, the project connects to the grid at National Grid’s Golah Substation in Rush, so power from the Caledonia arrays must also cross the river. Nonetheless, Glocker’s point stands. Rush residents bear the risks of the crossing, but their town hosts panels that are credited with only about 1.2 MW of reliable capacity. That is not a reasonable trade-off for people who depend on springs and wells.

Subsidies and Local Costs

The third point compares the subsidies from COMIDA, the Monroe County Industrial Development Agency, to the supposed benefits. Glocker explains:

IDAs are supposed to grant subsidies to promote job creation. Monroe County’s IDA, COMIDA, gave Invenergy $19 million in subsidies. In the COMIDA application, Invenergy wrote “Large scale renewable energy systems are not financially viable absent financial assistance from IDAs…”

I checked her number. The COMIDA application lists a “Total value of incentives” of $19,354,096 for the Monroe County portion of the project. However, the cost-benefit analysis in the same application puts the total cost of the exemptions at $4.9 million. The difference comes from two very different sales tax figures that I cannot reconcile. Either way, the economic benefits are small. The Horseshoe Solar website claims only $3 million in total economic investment, 300+ construction jobs, and 3 full-time jobs for the entire project. That works out to between $1.6 million and $6.5 million in tax breaks for each permanent job. The point is clear: large subsidies and little economic gain.

Glocker went on to explain that because Invenergy pays less, her county, school, and town taxes may go up. Over the 25-year payment-in-lieu-of-taxes agreement, Horseshoe will pay about $471,000 instead of $3.8 million in full taxes. Local taxes are set by budgets, so the abatement does not automatically raise anyone’s bill. However, it does mean that the new industrial facility will not carry its full share of local costs, and residents carry that burden instead. Residents also pay some of the highest electricity prices in the country. The Empire Center found that New York’s residential price was 29.93 cents per kilowatt-hour in May 2026, third highest in the nation.

Archaeological Impacts

The fourth point is archaeological impacts. Glocker states:

Honeoye Creek intersects the Genesee River at a place called Golah. The State Office of Historical Preservation (SHPO) identified the rich, alluvial soils along the Genesee and particularly at Golah as one of western NY’s most culturally rich areas. It is quite simply sacred land.

Indeed, a bone found there in 2020 during the archaeological evaluation was described by Seneca experts as human; Invenergy’s expert identified it as either a bear or a heron bone… Thousands of steel beams will be pounded into the ground to support the solar panels- what will they destroy?

The sensitivity of this area is not in dispute. A bone analysis report filed in the docket concluded that the bone was a human foot bone from an adult, not a heron or bear bone. The Seneca Nation was cited as identifying 46 known archaeological sites within 500 feet of the project and asked for further investigation using ground penetrating radar. Instead, ORES required a plan to monitor construction and deal with unanticipated discoveries. In other words, the plan is to find out whether there are graves when the construction crews hit them. I agree with Glocker that this is not an acceptable way to treat land the Seneca consider sacred.

Different Rules for Utilities and Developers

The fifth point is the difference in requirements for the utility, Niagara Mohawk Power Corporation d/b/a National Grid, and the developer. Glocker explains:

A new substation is potentially to be built at Golah by Niagara Mohawk. But utilities must undergo careful cultural investigations…

We do this for substations, but not for solar panels? All this for less than 2MW?

National Grid’s Article VII case includes a New Golah Substation in Rush. I could not find the specific Staff request Glocker quoted, but the record shows the difference she describes. National Grid’s project has gone through four phases of archaeological work, including a Phase III Data Recovery Work Plan. That plan was required after SHPO found an Indigenous site eligible for the State and National Registers. The Horseshoe arrays on the same culturally sensitive land were approved after only the first two phases. If utilities must do this for a substation, why don’t solar developers have to do it for roughly 1,260 acres of panels?

Conclusion

I think Horseshoe Solar is another solar project with unacceptable impacts. It converts more prime farmland than the State’s agricultural goal allows. The river crossing punctured an aquifer and left Rush residents on delivered water. The local subsidies are large relative to three permanent jobs. The project was permitted on land the Seneca consider sacred without the archaeological investigation required of the utility next door. All of this is for panels in Rush that NYISO credits with only about 1.2 MW of reliable capacity.

The Horseshoe Solar story is a microcosm of what is wrong with Climate Act implementation. The State is so focused on meeting arbitrary targets that it does not consider the cumulative environmental impacts on host communities. Until the State develops responsible siting requirements that protect prime farmland, water supplies, and cultural resources, I expect we will hear more stories like the one Janet Glocker told at the roundtable.

Thanks again to Janet for sending me her notes.

Independent Intervenors Tell NYPA: Reliability Must Come First in New York’s Clean-Energy Transition

On September 2, 2026, the five Independent Intervenors—Roger Caiazza, Morris Cox, Richard Ellenbogen, Francis Menton, and Constantine Kontogiannis—participated in the New York Power Authority’s annual Climate Leadership and Community Protection Act (“CLCPA”) conferral process.

New York Power Authority’s (NYPA’s) conferral process is intended to collect information and stakeholder views on the State’s progress toward CLCPA goals and to help inform NYPA’s renewable-development strategies. The Independent Intervenors’ presentation was titled “Reliability-first implementation of New York’s clean-energy transition.” Our message was straightforward: New York should not retire dependable electricity resources or assume that future technologies will solve known reliability problems before replacements are actually available, deliverable, and proven under stressed system conditions.

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 coupled with cumulative environmental impacts of those resources. These comments are based on those concerns.  The opinions expressed in this article do not reflect the position of any of my previous employers or the personal opinions of the Independent Intervenors, these comments are mine alone. I acknowledge the use of Perplexity AI to research and organize the material summarized in this article.

This is the first in a series of posts describing our NYPA presentation. This overview summarizes the central message and major issues raised at the conferral session. Subsequent posts will examine the supporting evidence and specific policy questions in greater detail.

The reliability-first message

The CLCPA requires New York to obtain 70 percent of its electricity from renewable resources by 2030 and to move to a zero-emissions electric system by 2040. Those goals are being pursued while electric demand is expected to increase because of building and transportation electrification, economic development, and other new loads.

The issue is not whether New York should reduce emissions. The issue is whether the State has developed a credible plan to do so without compromising reliable and affordable electricity service.

At present, the State’s energy strategy relies heavily on weather-dependent wind and solar generation, battery energy storage systems, new transmission, imports, demand-side resources, and a future resource category called Dispatchable Emission-Free Resources, or “DEFRs.” The problem is that “DEFR” is a planning category, not a resource. New York State has not identified a specific technology that has been built, financed, permitted, interconnected, tested, and demonstrated at the scale New York needs.

The basic principle presented to NYPA was therefore simple:

Dependable generation should remain available until replacement resources, transmission facilities, fuel arrangements, operating reserves, and distribution-system upgrades are physically in service, deliverable to load, and proven under stressed operating conditions.

This is not a rejection of nuclear power, hydropower, transmission improvements, or renewable development. It is an argument that those resources must be evaluated according to whether they can provide the electric system services that New Yorkers need.  This need is especially acute during the difficult hours and days when demand is high, weather-dependent generation is low, equipment fails, or imports are limited.

New York has two different grid challenges

Much of the State’s energy-policy discussion focuses on the New York Independent System Operator NYISO’s “Tale of Two Grids”: the difference between upstate and downstate system conditions. That distinction is important. Upstate New York generally has more existing generation and opportunities for renewable development, while the downstate area has large load centers, constrained transmission interfaces, and special locational reliability requirements.

However, our presentation emphasized a second distinction that deserves much more attention: the difference between the bulk-power system and the distribution system.

The bulk-power system includes generation, high-voltage transmission, resource adequacy, operating reserves, imports, fuel availability, system frequency, and NYISO’s responsibility for operating the grid. A bulk-system reliability issue asks whether sufficient dependable resources are available and deliverable to load, including after credible equipment outages and during adverse weather.

The distribution system includes the substations, transformers, feeders, local circuits, voltage equipment, and utility infrastructure that physically deliver electricity to homes, businesses, hospitals, elevators, water and wastewater facilities, and other customers. The question of distribution-system resilience is whether local facilities can accommodate growing loads without compromising delivered electric quality (e.g. voltage) or service reliability.

These are related but separate challenges. A NYISO conclusion that New York has adequate statewide generating capacity does not mean that a particular substation, feeder, or transformer bank can serve growing local electric-heating and electric-vehicle load. Conversely, a local outage or voltage-quality problem should not automatically be attributed to NYISO bulk-system operations.

New York needs transparent accountability. NYISO, the Public Service Commission (PSC), NYPA, transmission owners, distribution utilities, local governments, and State agencies all have roles. The public should be able to determine which entity is responsible for identifying, planning for, funding, and correcting a particular reliability deficiency.

“The Grid Is Already Broken”

A central part of our presentation was the argument that recent events should be treated as warning signs. The grid does not have to experience a statewide blackout before reliability problems are real. Voltage reductions, localized brownouts, unstable frequency, equipment overheating, impaired restoration, and local system failures can cause significant damage and disruption.

The presentation referenced reported distribution-level problems during the June 2025 period and voltage and frequency concerns during the July 2026 heat wave. The purpose was not to claim that every incident has the same cause, or to assign responsibility before complete factual investigation. It was to explain why actual system performance should inform energy policy.

Figure 1: July 1 – July 7, 2026 Voltage Measured at the Ellenbogen Factory Showing Con Edison Voltage Instability

Source: Data provided by Rich Ellenbogen

The July 2026 experience is particularly important because modern electricity use differs from the system conditions of previous decades. Much of today’s equipment contains power electronics, electronic controls, variable-frequency drives, LED lighting, elevator-control systems, and other loads that can respond poorly to abnormal voltage conditions. In some cases, constant-power devices draw greater current as voltage falls, which can add stress to already overloaded distribution equipment.

Similarly, solar inverters, battery inverters, and generator transfer equipment cannot be assumed to provide the same support during abnormal voltage or frequency conditions that they provide during routine grid operation. These are engineering and operational questions that require transparent investigation, not assumptions based solely on nameplate capacity or annual energy estimates.

The presentation also discussed information from the late-June and early-July 2026 heat-wave period. At peak load, imports reportedly supplied roughly 10 percent of actual generation; fossil generation averaged approximately 59 percent; and wind generation ranged from roughly 1 percent to 4.6 percent. Solar-generation information should be examined with the relevant NYISO operational data when it is available.

A future post will examine these events and what can and cannot be concluded from them. The central point for this overview is that New York’s energy policy should be based on evidence from the conditions that challenge the system—not just average annual performance.

The unresolved DEFR question

New York’s planning framework assumes that a large quantity of dispatchable emission-free capacity will be necessary as fossil generation retires and electrification increases demand. Our presentation argued that this may be the most important unanswered question in CLCPA implementation.

The presentation cited a potential need for more than 10 GW of yet-to-be-identified DEFR capacity within the next several years. If that scale of dependable capacity is necessary, State policymakers and NYPA should answer basic questions now:

  • What technologies will provide the capacity?
  • Where will projects be located?
  • What will fuel, charge, or otherwise sustain them?
  • How long can they operate continuously?
  • Can they be permitted, financed, supplied, interconnected, and built in time?
  • Can their electricity be delivered to the locations where it is needed?
  • What will they cost customers?
  • How will they perform when weather-dependent generation is low, demand is high, and imports are constrained?

The State should not presume that a future technology will be available simply because planners have assigned it a useful name. Before existing dependable resources are retired, replacements should be specific, operational, and stress-tested.

This does not mean that every current fossil facility should operate indefinitely. Some older units may be inefficient, costly, or environmentally undesirable. But the correct question is whether a unit’s capacity, locational value, voltage support, fuel flexibility, and restoration contribution can be replaced by resources that are actually in service and deliverable to customers.

Wind, solar, batteries, and difficult weather

Wind, solar, and battery energy storage all have valuable roles. They can reduce fuel use and emissions, provide energy when available, assist with balancing, offer rapid response, and—in suitable locations—improve local reliability.

But a resource that is useful is not necessarily a substitute for multi-day firm capacity.

The presentation highlighted the importance of planning for weather conditions sometimes described as “dark doldrums”: prolonged periods with low wind generation, limited solar generation, and high or rising demand. These periods can be particularly difficult when combined with equipment outages, limited imports, and fuel constraints.

The July 1, 2026 example cited in the presentation showed wind generation below two percent of nameplate capability should have referred to June 29 (Table 1). It is important to note that even though July 1 wind resources were better the average generation was only 1,000 MW which represents 35% of the total NYS wind capacity of 2,858 MW. The presentation also raised concerns about smoke haze reducing solar production and referred to a January 2026 low-renewable-output period associated with critical grid risks and high consumer energy costs.

Table 1: Hourly Data for June 29, 2026

The presentation used an illustrative worst-case planning scenario involving more than 110 continuous hours with combined wind and solar output below 25 percent of nameplate capacity. The exact duration and assumptions must be documented and evaluated carefully, but the broader reliability point is indisputable: New York must be able to serve demand during prolonged periods when weather-dependent generation is unavailable.

A four-hour battery cannot provide 72 hours of firm electricity. An eight-hour battery cannot carry the grid through a 110-hour shortage. A storage plan must address not only discharge capacity but also the energy required to recharge batteries, the generation needed for charging, transmission capability, degradation, replacement costs, backup resources, and the ability to restore the batteries after a prolonged system event.

Nuclear and the transition gap

The Independent Intervenors support the State’s renewed attention to nuclear generation. Nuclear energy is a proven zero-emission source of large-scale, dependable electricity. It is not dependent on daily wind conditions or solar irradiance, and it can contribute to the long-term energy needs associated with electrification and economic growth.

However, nuclear development takes time. The presentation noted that new large-scale nuclear generation may not be available for 15 to 20 years and that the proposed 5 GW nuclear increase could be largely offset by expected resource retirements and load growth during the same period.

New nuclear generation should therefore be treated as a necessary long-term element of New York’s resource strategy, not as a near-term solution to the immediate DEFR and resource-adequacy challenge. Small modular reactors and other advanced designs should be researched and demonstrated, but should not be counted as commercially available capacity until their licensing, supply-chain, financing, construction, and operational challenges are resolved.

The State must answer a practical interim question: how will it maintain reliable service between now and the time that substantial new nuclear capacity can realistically enter service?

A constructive role for NYPA

NYPA should help answer that question. Its role should not be limited to supporting renewable projects in isolation. NYPA has financing capability, development experience, familiarity with complex infrastructure, and a public-interest mission that can be used to advance reliability as well as emissions reductions.

The presentation identified several areas for NYPA consideration:

  • Retaining and repowering needed downstate dispatchable generation, including evaluation of modern CCGT opportunities at Newburgh, Island Park, Northport, Port Jefferson, and East River locations.
  • Supporting long-term nuclear development with realistic schedules and procurement practices suited to major infrastructure projects.
  • Evaluating floating solar at Schoharie and Upper Blenheim-Gilboa reservoirs in coordination with the existing pumped-storage facility.
  • Improving the Central East interface with the CHPE converter station at New Scotland.
  • Evaluating transmission development using existing transportation corridors where practical, including an NYS Thruway route from Leeds to Dunwoodie and a possible Athens-to-Buchanan path.
  • Identifying additional hydroelectric and pumped-storage opportunities.
  • Supporting a reliability-focused planning process involving NYPA, NYISO, NYSRC, the PSC, utilities, local governments, and affected stakeholders.

Every option should be assessed transparently. The relevant questions are not simply whether a project is renewable, zero-emission, or consistent with a target. The questions are whether it is reliable, affordable, feasible to build, environmentally defensible on a lifecycle basis, and acceptable to affected communities.

Conclusion

New York needs a transition strategy based on engineering reality, transparent costs, demonstrated technology, and accountability for reliability. The State can reduce emissions, but it cannot do so responsibly by assuming away the resources and infrastructure necessary to keep electricity dependable.  That is the central message we brought to NYPA: reliability must be the binding constraint on CLCPA implementation.

Explaining the Grid Does Not Acknowledge the Need for DEFR

Matt Estes’s recent Explaining the Grid Substack post, “Wind and Solar will always, without exception fail us when we need electricity the most,” correctly objects to an overly broad claim about renewable generation. Existing wind and solar facilities plainly do produce useful energy and can reduce fuel use, emissions, and—at some times—system stress.  But the post misses the central reliability problem facing a future grid designed around weather-dependent generation: wind and solar do not have to fail all the time to create an unacceptable reliability risk. They need only fail together, for long enough, during a severe system peak to exhaust energy storage and overwhelm the remaining dispatchable resources.

For New York, that is not an abstract issue. It is the fundamental unresolved flaw in the Climate Leadership & Community Protection Act (Climate Act) transition strategy and in plans that presume wind, solar, storage, transmission, and some undefined category of “dispatchable emissions-free resources” (DEFR) can replace the dependable capacity now provided by fossil generation.

The more accurate warning is not that wind and solar “will always, without exception fail us when we need electricity the most.” It is this:

  • Wind and solar will eventually fail catastrophically during a prolonged period when electricity is needed most unless the grid has enough dependable, fuel-secure, dispatchable capacity to carry the system through the event.

That distinction matters. It explains why simply pointing out that solar and wind help during many peak-demand hours does not answer the reliability question.

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 coupled with cumulative environmental impacts of those resources. These comments are based on those concerns.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone. I acknowledge the use of Perplexity AI to research and organize the material summarized in this article.

What Estes Gets Right

Estes responds to David Blackmon’s reference to Winter Storm Uri in Texas by noting that the 2021 Texas disaster was not exclusively a wind-and-solar failure. The University of Texas assessment found that all major types of generation experienced outages or reductions during the event. In particular, roughly 25,000 MW of natural-gas capacity went offline when Texas most needed it.

That is an important point. Fossil-fueled generation is not automatically reliable merely because it is dispatchable. Generators can fail because of inadequate winterization, fuel-supply interruptions, frozen equipment, maintenance failures, transmission constraints, or poor market incentives. Texas’s failure to require adequate cold-weather preparation was a preventable institutional and engineering failure.

But that lesson does not mean weather-dependent generation has no unique reliability limitation. A gas turbine that fails because its fuel supply froze, its equipment was not winterized, or its operator did not prepare for foreseeable weather conditions has options to be made more reliable. The remedial actions are well understood:

  • Winterize equipment and gas infrastructure.
  • Firm up fuel supplies and delivery arrangements.
  • Test cold-weather performance.
  • Establish reliability standards.
  • Pay generators for availability during extreme conditions.
  • Retain sufficient reserve capacity.

Those measures may be costly, but they are technically straightforward. They address a failure of equipment, fuel delivery, regulation, or market design.

The problem with wind and solar is different. Their low-output periods are not primarily a maintenance or regulatory problem. They are an inherent feature of the underlying resource.

No amount of winterization can make the sun shine at night, increase winter solar irradiance, remove snow from every panel during a regional snow event, or make the wind blow during a persistent high-pressure system. Wind and solar output can be improved at the margin by better siting, diversity, transmission, maintenance, forecasting, and geographic dispersion, but there are inherent limitations to those resources in New Yok.  Moreover, none of those measures eliminates the possibility of an extended period of low wind and low solar output across a broad region.

That is why the appropriate question is not whether renewables ever provide useful electricity. Of course they do. The question is whether a system that relies on them can remain reliable during the rare but consequential weather conditions when their output is low for days or weeks.

The New York Reliability Problem

The Climate Act requires a transition to an economy increasingly dependent on electricity. Building heating, transportation, industrial processes, and other end uses are supposed to shift away from direct combustion of fossil fuels. As a result, New York’s electric system will have to serve a much larger share of total energy demand.

That transition changes the reliability stakes.

Today, New York’s most serious system challenges often occur during hot summer afternoons, when air-conditioning demand is high. Solar generation can be useful during those periods because its output tends to coincide with daytime cooling demand. Estes is correct that solar output can be particularly valuable during sunny summer conditions when electricity use is elevated.

However, the Climate Act’s all-electric end-state changes the planning problem. Widespread electrification of heating means that the most consequential peak-demand events are likely to occur during severe winter cold spells, particularly in the early morning and evening hours.

Those are precisely the periods when solar output is weakest or nonexistent.

New York’s winter solar resource is limited by several factors:

  • Winter days are shorter than summer days.
  • The sun is lower in the sky.
  • Peak heating demand often occurs before sunrise and after sunset.
  • Cloud cover can materially reduce output especially downwind of the Great Lakes in NY.
  • Snow cover can reduce photovoltaic production sharply or reduce it nearly to zero until panels are cleared or conditions change.
  • The coldest weather often occurs during high-pressure systems that can also suppress wind generation over broad areas.

Earlier this year I documented the impact of these factors on wind and solar availability in New York during an extended cold snap (here, here, and here).

The geography matters. New York is not Texas, California, Arizona, or Florida. General claims about solar output during hot summer days cannot be transferred automatically to an upstate New York winter reliability analysis.

Nor is it enough to say that wind output is variable but geographically diverse. There are documented weather patterns in which low wind generation extends across large areas for prolonged periods and New York wind resources are highly correlated. New York’s reliability concern is not a short-lived dip in renewable output that can be covered by a few hours of battery discharge. The concern is a multi-day—or potentially longer—period of low wind and solar generation coinciding with high electric demand.

The relevant reliability question is  therefore:

  • Can New York supply demand throughout the worst plausible extended wind-and-solar drought?  If the answer depends on unspecified future resources, then the Climate Act transition plan has not yet demonstrated that it can meet its statutory reliability obligation.

Storage Does Not Eliminate the Problem

Battery storage is valuable. It can shift solar output from midday to evening, provide frequency support, reduce ramping requirements, respond quickly to contingencies, and help cover short-duration capacity needs.

But batteries are energy-limited resources. They can discharge only until their stored energy is exhausted.

A 1,000 MW battery with four hours of duration can provide approximately 4,000 MWh of energy. That may be highly useful for managing a four-hour evening peak. It cannot, by itself, supply 1,000 MW for several days of low renewable output.

The distinction between power and energy is critical:

  • Power capacity determines how much electricity can be delivered at one time, measured in MW.
  • Energy capacity determines how long that delivery can continue, measured in MWh or GWh.

New York’s future resource planning must address both.

Short-duration batteries may help meet a resource adequacy metric based on a few peak hours. They do not necessarily solve the problem of surviving an extended period when wind and solar output remain low, demand remains elevated, and batteries cannot be fully recharged.

A grid reliant on wind, solar, and batteries has a circular vulnerability during a renewable drought:

  • Wind and solar output falls.
  • Storage discharges to meet demand.
  • Low renewable output prevents storage from recharging adequately.
  • The renewable lull continues.
  • Storage is depleted.
  • The system must depend on dispatchable generation, imports, demand reductions, or outages.

The Unanswered DEFR Question

New York energy-planning documents frequently refer to “dispatchable emissions-free resources,” but that label is not a resource plan. It is a placeholder.  A credible reliability strategy must specify:

  • What the DEFR technologies are.
  • How much capacity will be needed.
  • How much energy they can provide.
  • How long they can operate continuously.
  • What fuel or energy source they will use.
  • Whether that fuel can be stored on site or delivered reliably during extreme weather.
  • Whether the technology can be deployed at scale in New York.
  • What it will cost to build, maintain, and use.
  • Who will pay for capacity that may run very infrequently.
  • Whether the resource remains available during the same weather conditions that reduce wind and solar output.

The last point is especially important.

If New York’s DEFR solution is hydrogen manufactured with surplus wind and solar power, then the state still must demonstrate that it can produce, store, transport, and retain enough hydrogen to carry the system through the worst relevant wind-and-solar drought. Calling hydrogen “dispatchable” does not make the upstream energy problem disappear.

The system must have enough renewable energy and electrolyzer capacity to make hydrogen during favorable conditions, enough storage to preserve it until an extreme event occurs, enough generating capacity to convert the hydrogen back into electricity, and enough infrastructure to ensure that the fuel is available when needed.

That could mean maintaining a very large and very costly resource that operates only during rare events.

There is also a difficult economic problem. Suppose the weather event that establishes the planning requirement has a return period longer than the useful economic life of the DEFR facility. A resource built specifically to protect against an event expected only once every several decades may reach the end of its life before it is ever called upon to perform its defining function.  The resource still must be financed, maintained, inspected, fueled, staffed, and tested. 

That raises the unavoidable affordability question:

  • How can New York finance dependable capacity that may be essential for reliability but is used so rarely that it cannot recover its costs from energy sales?

The answer is capacity payments, regulated cost recovery, or some comparable reliability obligation. But that means the costs of a wind-solar-storage-DEFR system cannot be evaluated only by comparing the energy cost of wind and solar with the energy cost of conventional generation. The full cost must include the dependable backup system, long-duration energy storage, new transmission, distribution-system upgrades, fuel infrastructure, reserve margins, and the cost of maintaining resources for rare but severe weather events.

Nuclear Is the Obvious DEFR

Nuclear power is a proven dispatchable emissions-free resource. It can provide dependable electricity through New York’s winter peaks without relying on wind or sunlight, and its fuel can be stored on site. However, new plants face substantial costs, long construction timelines, and financing risks, but those challenges are better understood than the performance and cost of the still-undefined resources the Climate Act Scoping Plan expects to replace fossil generation.

If New York builds nuclear capacity, it should use it as a primary source of reliable zero-emission electricity—not merely as rarely used backup for a wind, solar, battery, and hydrogen system that still needs dependable generation during prolonged renewable shortfalls.

Conclusion

Estes’ issues with Blackmon’s statement is overly absolute. Wind and solar do not always fail when electricity is needed most. At many times they provide useful, and sometimes very valuable, electricity.  But Estes’s response does not address the more consequential problem for New York’s Climate Act transition.

Wind and solar are weather-dependent resources. There will eventually be extended periods when both are insufficient, particularly during winter conditions when an electrified New York may face its greatest demand. Batteries can help for hours and, with enough investment, perhaps longer. They cannot solve the problem indefinitely unless there is enough energy available to recharge them.  That means New York must have sufficient dependable, fuel-secure, dispatchable capacity to supply electricity through the worst credible periods of low wind and solar production.  Failure to provide that resource in an electric  system overly reliant on wind and solar will create an unacceptable reliability risk.

The state calls that resource category DEFR. Yet it has not demonstrated what technology will provide it, how much will be required, how it will be fueled, whether it can operate for the full duration of the worst case renewable drought, or how ratepayers can afford a resource that may be used only rarely.  Until those questions are answered, claims that wind, solar, and storage can provide an affordable and reliable all-electric energy system are premature.  I do not think that Este’s Substack post adequately addressed DEFR and its necessity for reliability.

New York should stop treating DEFR as an undefined future technology and recognize that nuclear generation is the proven scalable zero-emission resource capable of providing the dependable electricity the state will need when wind and solar cannot.  New York must address this issue as soon as possible.

New York Nuclear Reliability Backbone: Potential and Probability

Governor Kathy Hochul’s proposal for a 5-GW advanced-nuclear “Reliability Backbone” is a welcome acknowledgement of an issue that New York’s electric-sector planning has too often avoided: a system increasingly dependent upon weather-dependent wind and solar resources still requires firm, dispatchable generation when the wind is not blowing, the sun is not shining, demand is high, and transmission is constrained.  However, it is not clear whether New York is prepared to make the durable financial, regulatory, and political commitments that a real nuclear program requires.

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 coupled with cumulative environmental impacts of those resources. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone. I acknowledge the use of Perplexity AI to research and organize the material summarized in this article.

Comment Submittal

The Independent Intervenors — Roger Caiazza, Richard Ellenbogen, Constantine Kontogiannis, and Francis Menton — have submitted comments in Case 26-E-0335 supporting important elements of Terra Praxis’s proposal for a Nuclear Reliability Backbone. However, our support is conditional. New York should not simply add nuclear generation to the enormous renewable-energy, battery-storage, hydrogen, backup-generation, transmission, and distribution buildout already contemplated under the Climate Leadership and Community Protection Act. If the State builds substantial quantities of new nuclear generation, it must reassess what other infrastructure can be avoided.

That is the critical point. Nuclear should be evaluated as an alternative to part of the renewable-heavy resource plan, not as one more costly mandate layered on top of it. The appropriate question is not whether New York can add 5 GW of nuclear to its existing plans. The appropriate question is whether 5 GW or more of dependable, dispatchable, zero-emission generation could reduce the need for wind, solar, battery storage, hydrogen-fueled generation, transmission lines, distribution upgrades, land conversion, and fossil-fuel backup.

The Terra Praxis comments cite a Coordinated Grid Planning Process scenario in which 5.5 GW of nuclear-like firm capacity enables New York to meet load with roughly 100 GW of installed capacity rather than approximately 130 GW in the State Scenario. The implications are obvious. A portfolio with sufficient firm generation may require substantially less weather-dependent generation and much less supporting infrastructure.

That comparison must be made transparently and using total system costs. It is not enough to compare the nominal levelized cost of energy from a wind turbine, a solar installation, a battery, a hydrogen turbine, and a nuclear plant. A reliable electric system must also pay for transmission, energy storage, backup capacity, interconnection upgrades, curtailment, fuel supply, land use, and the capacity necessary to survive low-wind and low-solar periods during winter peaks. The relevant metrics include accredited capacity, winter reliability performance, forced-outage risk, fuel security, construction and schedule risk, and the effect on customer bills.

The Independent Intervenors’ comments recommend that the Commission compare at least four alternative portfolios:

  • A renewable-intensive portfolio using the currently assumed buildout of wind, solar, storage, transmission, and dispatchable emissions-free resources.
  • A portfolio in which new nuclear provides a meaningful share of dispatchable emissions-free generation and thereby permits a reduction in renewables, storage, backup generation, and transmission.
  • A portfolio focused on maintaining or expanding existing zero-emission nuclear generation, with new nuclear added only when it is the least-cost, risk-adjusted alternative.
  • A portfolio that relies on other prospective dispatchable emissions-free resources only after those technologies demonstrate commercial maturity, sufficient duration, fuel security, accredited capacity, and competitive cost.

Consumer Protection is Essential

I support advanced nuclear because it is the only demonstrated large-scale, dispatchable, long-duration, zero-emission resource available today. Hydropower and storage are valuable, but New York cannot expand them enough to meet the entire need for firm capacity. Hydrogen, renewable natural gas, and long-duration storage may eventually contribute, but they have not yet demonstrated that they can be deployed at the scale, cost, and duration necessary to replace fossil generation throughout New York’s system.

However, supporting the concept of nuclear is not the same thing as accepting an open-ended commitment by electric customers. New York has a long history of expensive energy-policy mistakes, and large nuclear projects have particular cost and schedule risks. A nominally “fixed-price” engineering, procurement, and construction contract does not eliminate risk if the design is incomplete, the scope changes, the contractor lacks the financial capacity to absorb losses, or political pressure ultimately makes cancellation impossible.

For that reason, the Independent Intervenors argue that no project should receive customer-funded support unless the Commission first finds that it:

  • Has a demonstrated reliability need, including during winter peaks and periods of low wind and solar output.
  • Has a feasible site, cooling-water arrangement, deliverable transmission, and credible environmental and licensing pathway.
  • Uses commercially mature technology or places first-of-a-kind risk on developers and vendors rather than customers.
  • Has completed and independently reviewed engineering, constructability analysis, cost estimation, and schedule development.
  • Is competitive on an all-in, risk-adjusted basis with alternatives that provide equivalent reliability value.
  • Has enforceable cost, schedule, availability, and performance obligations.
  • Includes a hard project-cost cap, a customer-bill-impact cap, private-sector first-loss obligations, and clawback provisions for nonperformance.
  • Identifies the renewable, storage, transmission, hydrogen, or other investments that can be avoided because the nuclear project is built.

The comments also recommend that all revenues be counted. Customer support should decline if a project receives capacity-market revenues, energy-market revenues, ancillary-service revenues, federal tax credits, federal loan support, private offtake revenues, or other government assistance. Otherwise, customers could end up paying overlapping subsidies for the same facility.

The uncomfortable financing question

A reader asked me to review Rod Adams’s interview with New York State Energy Research & Development Authority (NYSERDA) President and CEO Doreen Harris.  It raises the most important practical question: is New York’s apparent nuclear enthusiasm real, or is it merely a political gesture designed to appeal to pro-nuclear Upstate constituencies while avoiding the difficult financial choices required to build reactors?

I do not believe the State’s interest is necessarily insincere. Harris described a serious set of planning activities: a 5-GW target for incremental advanced nuclear capacity, a direction to New York Power Authority (NYPA) to pursue at least 1 GW, a State master-plan process, site and technology evaluations, workforce and supply-chain efforts, and examination of financial and commercial mechanisms. She also explicitly acknowledged that nuclear projects will involve complex commercial arrangements among the State, the federal government, developers, vendors, communities, and private investors.

But planning, studies, memoranda of understanding, and policy-option papers are not the same thing as financial close, a construction notice to proceed, or commercial operation.

Harris was commendably candid that the State is exploring three broad roles: pre-development support such as early site work; possible State investment or ownership; and new forms of revenue support comparable in concept to the Zero Emission Credit program for existing nuclear facilities. She did not commit New York to any particular ownership model, cost-overrun guarantee, or customer-support mechanism.

That uncertainty is understandable at this early stage, but it is also the core problem. Nuclear plants require extraordinarily large, patient, and risk-tolerant capital commitments. A private developer cannot invest billions of dollars based only on the hope that a future administration, Commission, Legislature, or public campaign will continue to support the project through permitting, construction, cost escalation, and eventual operation.

My own experience in the deregulated electric-generating business makes me skeptical that private developers will undertake that risk in New York without unusually strong guarantees. I supported applications to replace old simple-cycle turbines at NRG Astoria. Those applications were completed, but the company ultimately chose to invest elsewhere. The projects did not proceed because the company could deploy its capital with less risk in other opportunities. After I left, the remaining permit application was denied because it was inconsistent with the Climate Act confirming their fears.

That experience involved conventional natural-gas repowering projects, not multibillion-dollar nuclear stations with long construction schedules, specialized supply chains, federal licensing, political risk, and the potential for major cost overruns. If a competitive generator developer would not commit capital to a conventional repowering project in New York, why should anyone expect a private investor to commit the much larger sums required for new nuclear generation without firm and durable protections against regulatory and political reversal?

New York’s credibility problem

Rod Adams opened his interview with an accurate description of New York’s mixed nuclear record. The State has four operating nuclear units with strong performance and high capacity factors. Yet it also has

the legacy of West Valley, Shoreham, and Indian Point.

The Shoreham experience is particularly relevant. The Long Island plant was completed after immense expense, but it never generated commercial electricity. According to Adams’s introduction, Shoreham had cost roughly $6 billion before it was sold and shut down at the direction of government. Whether one agrees with every decision involved in the Shoreham saga is not the point. The point is that investors remember that New York has demonstrated a willingness to change the rules after capital has been committed.

Indian Point presents a more recent version of the same credibility challenge. Two reactors with years remaining on their operating licenses were closed because of a political agreement, despite their role as large sources of dispatchable zero-emission electricity within the New York City contr. The State has preserved the upstate nuclear fleet through Zero Emission Credits, while simultaneously allowing Indian Point to close. That history creates an obvious concern for anyone asked to finance a new reactor: what assurance is there that New York’s support will persist when the project becomes controversial, expensive, or politically inconvenient?

The answer cannot simply be that today’s leaders support nuclear power. Nuclear projects take longer than election cycles, gubernatorial terms, PSC appointments, and changes in legislative priorities. Investors need credible, enforceable, durable commitments. Ratepayers, however, deserve protection against an open-ended obligation to pay for a project that is late, over budget, or abandoned.

Those two requirements are in tension.

My conclusion

I support the Nuclear Reliability Backbone as an acknowledgement that New York cannot operate a reliable zero-emission electric system using wind, solar, and short-duration batteries alone. If New York is serious about electrification, rising load, data centers, semiconductor manufacturing, winter reliability, and the retirement of aging fossil generation, it needs firm generation that can operate regardless of weather.

But I am not optimistic that New York will build out 5 GW of new nuclear generation easily.

The State’s energy-policy history, the structure of deregulated generation markets, the enormous capital requirements of nuclear construction, and the lingering political risk from Shoreham and Indian Point all make private investment difficult. A viable project likely will require a substantial State role: early site development, revenue certainty, possible NYPA participation or ownership, access to federal financing and tax credits, and a credible long-term contractual framework.

At the same time, that support cannot become a blank check. The State cannot reasonably promise developers enough protection to induce private investment while also guaranteeing that customers bear no risk. Something has to give. The likely outcome is that New York will have to choose openly among three imperfect options:

  • A primarily public or public-private project with significant taxpayer or ratepayer exposure.
  • A heavily subsidized private project with long-term revenue guarantees and carefully limited, but still real, customer risk.
  • Continued studies and policy announcements without a reactor actually reaching construction.

The Independent Intervenors’ comments take the proper position. New York should preserve the nuclear option and pursue the reliability benefits of dispatchable emissions-free generation. However, it should do so only after comparing nuclear honestly with the full system cost of the renewable-heavy alternative, identifying what redundant infrastructure nuclear can avoid, assigning construction and performance risk to the parties best able to manage it, and imposing firm limits on customer exposure.

The next step is not simply to procure nuclear. The next step is to decide whether New York is prepared to make the durable financial, regulatory, and political commitments that a real nuclear program requires. Until that question is answered, the Nuclear Reliability Backbone remains an important planning concept rather than a credible construction program.

New York Energy Policy BESS Disconnect

People send me things that are often topics for this blog.  When Greg Harkenrider sent an email describing the disconnect between New York energy policy “renewable” generation goals and its storage goals I asked him if I could publish it as a blog post.  It is a good independent analysis of yet another challenge of the Climate Leadership & Community Protection Act (CLCPA) transition away from fossil fuels.

Greg is a retiree from the New York state Department of Transportation and the vice president of Stop Energy Sprawl, a coalition of local groups opposing large-scale wind and solar projects.

The Problem

A principal state energy goal is a zero-emissions electric grid by 2040. This requires eliminating all fossil fuel generation, maintaining existing hydro and nuclear power, and vastly increasing wind and solar power. (Recently there has been discussion of additional nuclear generation, but for now that is just in the talking stage.)

Wind and solar have two main problems: 1) their productivity is low — solar produces on average less than 20 percent of its capacity in New York state, and wind about 25 percent; and 2) they are erratic (aka “intermittent”), varying substantially by time of year and from day to day, depending on wind speed and cloud cover.  New York’s policy has been to build its way out of problem #1 by massive deployment of wind and solar facilities and store its way out of #2 with batteries.

A critical question is the amount of storage needed to run the New York State grid by 2040 on wind, solar, batteries, no fossil fuels and no increase in hydro because there are no additional resources available for development or nuclear generation because the CLCPA authors thought it was unnecessary. This is not just a matter of powering up the batteries during the day, then using their power after sundown, important as that is. An electric grid powered substantially by wind and solar will have to rely on batteries for extended periods.

Battery Requirements

The analysis here uses a year’s worth of cloud cover and wind speed data from the National Weather Service to estimate how “substantial” and “extended” we are likely to get. I used current hydro and nuclear generation and added enough wind and solar power to match the New York Independent System Operators estimated demand for the year 2040. I created a spreadsheet where days of excess wind and solar production have energy added to storage, and days of deficit production have energy withdrawn from it.

When we examine electric generation and consumption on this day-to-day basis, the critical factor is not just the seven to ten consecutive days of cloudy skies and still winds that occur two or three times a year, but the three-month period from early November to early February, when bad days for wind and solar far outnumber the good days. Getting through this period with the wind/solar resource mix we are pursuing now would require 8,800 GWh of battery production capacity. 

To illustrate the problem, Table 1 below uses National Weather Service daily wind speed and cloud cover data for one week of December 2023, and calculates the generation that would have been provided by the predominantly wind and solar grid described above:

Table 1: Daily Generation & Battery Need for One Week in December

I deliberately picked a week that had both good and bad days for wind and solar. For the first three days, weather was good and we would have generated more electricity than we needed, enabling a fairly significant net increase in battery charging. It was followed by dense cloud cover and calm circulation that would have required about 1,000 GWh of battery discharge in just four days. And the problem does not last just four days. A wind/solar grid will face a shortfall for two to three months every year.

This table is based on weather conditions in December 2023, and generation totals would differ from one year to the next. But the variability of wind and solar production, and consequently the need for storage, would be the same.

When we do the math on a day-by-day basis, the result with this combination of generation is that batteries need to supply more than 6,000 GWh of power between early November and early February, when solar generation begins to improve. Batteries cannot be charged up to their full capacity, nor discharged to zero. Hence the need for 8,800 GWh of capacity.

November, December and January are the worst months for solar power. This critical factor is masked by annual averages. For instance, the Energy Information Administration (part of U.S. Dept. of Energy) reported the average 2024 capacity factor for solar facilities in New York at 17 percent. However the average for November to January was just 7 percent. And, as seen in the table, monthly averages mask daily variability.

The battery quantity would depend on their average duration. Those currently deployed are almost all four-hour duration. It is optimistic, but possible, that that could double to eight hours by 2040. Even if it did, we would need more than 1,000 GW of batteries. Contrast that with the Governor’s aspiration to get to six GW– less than 1 percent of need.

Considering that one 40-foot shipping container-sized battery unit has a capacity of about four megawatts, we would need 275,000 such units to provide that amount of storage (optimistically assuming eight-hour duration). Put another way, the largest battery storage in the country, the Moss Landing facility in California, has a capacity of three GWh. We would need to build 3,000 Moss Landings to back up a wind/solar grid, with only the existing amount of hydro and nuclear generation.

The assumption here is that the state’s future mix of wind and solar remains close to the three-fourths solar/one-fourth wind that is in process now. A grid of 14 GW of land-based wind, 7 GW of off-shore wind, 47 GW of solar and the current 4.3 GW of hydro and 3.3 GW of nuclear would (with Quebec Hydro imports), over the course of a year, provide enough power to meet 2040 demand, as projected by the New York Independent System Operator. But it would do so by over-producing at some times and under-producing at others.

Alternatives

This result is so implausible that we need to look at alternatives. If we shift the future wind/solar mix closer to half and half, the storage need is less — about 6,400 GWh — but still impossible. (There is about a two-month dry spell rather than three, as November is usually a good month for wind.)

Trying a third alternative, the story gets better, but not much. Assume roughly doubling nuclear capacity from the current 3,300 MW to 7,000, while still eliminating all fossil fuel generation. Under this scenario, the December-January battery need would remain, but at a smaller level — about 4,900 GWh. Wind, solar and hydro would provide about 68 percent of generation, close to the state’s policy goal.

Under any scenario, battery charging/discharging would have to be managed, not only centrally, but perfectly. Batteries would have to be discharged in succession, not at the discretion of private operators as they are now. Just getting averages to work does not get every kilowatt to exactly the right place at exactly the right instant. I cannot imagine this working anywhere other than on a spreadsheet.

Caiazza Comment:  This is an important point because experience in Australia showed that battery system applications are more complex than generally assumed.  In addition to storage backup a battery can earn revenues and justify investment by selling power capacity, speed, and availability into ancillary-service markets.  This means that more batteries will be needed because the batteries will not be dedicated to energy storage applications and they cannot service both applications.

The cost of such battery deployments would be astronomical. We cannot expect the current unit costs to prevail if we attempt to procure such a quantity. Estimates range from the hundreds of billions to more than a trillion dollars, just for New York state.

Practical Scenario

So, if the current wind/solar mix is impossible, and shifting to more wind is impossible, and supplementing 70 percent “renewable” with nuclear is impossible, we need to ask what zero emission scenario could work.

The best way to answer this is to reverse our process and start with a realistic estimate of battery deployment, then manipulate the generation sources to model a functioning 2040 grid. I used 300 GWh of storage. If average battery duration improves to eight hours by 2040, that would require 37.5 GW, about six times the current goal.

Making this work requires increasing New York’s nuclear capacity by nearly five times its current level to more than 15 GW. Wind and solar were limited to the projects currently operating or in the state’s application process — about 12.9 GW of solar and 4.5 GW of wind. Empire and Sunrise were the only new off-shore wind assumed.

The key point is that to get storage needs to a realistic level, we must curtail the amount of wind and solar generation. Put another way, renewable generation and storage must be in balance. Without fossil fuels, that can only happen at a far smaller deployment of wind and solar energy than is planned now.

With this mix, 30 percent of New York’s electricity is produced by “renewable” sources. When the landmark CLCPA was passed in 2019, 26 percent was “renewable.” The 2040 New York’s Climate Act goal is “zero emissions” so this approach is compliant.  What we do have is at least the possibility of a functioning, zero-emission electric grid, with an achievable amount of battery storage and the likelihood of being a net electricity exporter.

Is this any more realistic than the “impossible” alternatives? New York has four large nuclear plants operating now. This would require us to build 12 to 15 more of them, or a larger number of small, modular reactors. If the state reached a consensus to do that today, it would take a crash effort to get it done by 2040. Public and political opinion on nuclear power is beginning to shift, but we are far from resolved on such a change in policy. The resolute opposition to nuclear power that has prevailed among politicians, regulators and the public since the 1970s will take years, not months, to change. And even if it does change, we must remember that nuclear power has many good points, but speedy design and construction has never been one of them.

Table 2 summarizes the 2040 electricity production in GWh by generation type for the four alternatives discussed in this narrative.

Table 2: NYS Generation & Storage Needs for Zero Emissions in 2040 (GWh)

Any such analysis must pile assumptions upon assumptions. A few of mine are listed below:

  • Projected demand is from the 2026 NYISO Gold Book, which is only an educated guess. Note that the 2025 Gold Book projected 2040 demand at 201,870 GWh; the 2026 version reduced that to 183,800. The 2025 book projected winter peak would exceed summer by 2039, then the 2026 version pushed that back 10 years, to 2049. It is not only meteorologists who have difficulty forecasting.
  • Except for being unavailable in winter, Hydro Quebec imports would be available when needed.
  • Batteries can be charged up to 85 percent of capacity and discharged to no less than 15 percent.

Conclusion:

For too long, New York state has had a policy for “renewable” energy generation that conflicts with its policy for energy storage. The state’s policy makers who are on a sprint to develop wind and solar energy have no clue how much battery storage that will require, and they don’t particularly want to learn. This paper is an attempt to show that numerically.

Comments are welcome. Greg can be contacted at stopenergysprawl@gmail.com

How Neighboring Electric Systems  Handled the July 2026 Heat Wave

This is the fourth post in my series on the electric system impacts of the late-June/early-July 2026 heat wave. The first two posts (here and here) covered the New York Independent System Operator (NYISO) system, and the third covered data that Rich Ellenbogen shared from his home and factory on the Con Edison system. This post looks outside New York, at how nearby regional transmission operators PJM, ISO New England, Midcontinent Independent System Operator (MISO), Ontario’s Independent Electricity System Operator (IESO), and Hydro-Québec handled the same event, with the focus on whether wind and solar were available when the grid needed them most.

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. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone. I acknowledge the use of Perplexity AI to research and organize the material summarized in this article.

Overview

My first post in this series found that the heat dome that stressed New York’s grid was, for most of the event, centered close enough to New York to leave a decent pressure gradient — and therefore decent wind — over the state on most days, with June 29 the exception. A rapid-attribution analysis found that the anticyclone driving the heat wave was centered over the northeastern United States and southeastern Canada and stayed nearly stationary for about a week, with light-to-moderate winds across eastern North America.  Note, however that I completely disagree with the analysis claim that human driven climate change had a greater impact than natural variability.  The weather pattern affected operators sitting under or immediately downwind of the ridge core — PJM, MISO, and Ontario’s IESO — had significant wind shortfalls, while ISO-NE, helped by offshore wind on the maritime margin, did not. U.S. weekly electricity output for the week of June 28 – July 4, 2026 reached 100,996 GWh — the first week ever above 100,000 GWh, up 7.73% year over year. This was a continental event, and the country’s largest grid operator came closer to real trouble than New York did.

PJM: The Most Acute Stress in the Country

PJM Interconnection, serving 13 mid-Atlantic and Midwest states plus D.C., ran through the entire emergency ladder, making the New York Independent System Operator (NYISO) Energy Watch look mild. PJM issued Hot Weather Alerts starting June 29, escalated to a NERC EEA1 on July 1, then to EEA2 with a “Deploy All Resources” action at 5:36 p.m. on July 2, along with a Low Voltage Alert and Heavy Load Voltage Schedule Warning (PJM Operating Committee presentation; Sunairio). The U.S. Department of Energy issued two emergency orders under Federal Power Act section 202(c) to PJM on June 30, and a third effective July 2 that ran through July 6.

PJM served an estimated all-time peak of 168,158 MW between 5 and 6 p.m. on July 2, breaking the prior record of 165,563 MW set in August 2006. Forced generation outages ran between 18,100 and 19,400 MW on July 2–4, versus an average of only 12,800 MW on the top-10 summer peak days of the prior three years, and operating reserves collapsed from 10,996 MW on July 1 to just 5,091 MW on July 2 (PJM Inside Lines; mgrid). PJM’s Senior Manager of Dispatch put it bluntly: PJM “used every single generator available on July 2,” calling it the highest peak ever served, and adding that “our capacity position continues to be an area of concern” (PJM Inside Lines).

Wind was scarce almost exactly the way New York’s wind was scarce on June 29, except PJM never got the reprieve New York got on the other days. Independent fuel-mix analysis found that nuclear, coal, and gas together supplied 88% of PJM generation during the heat wave, while solar and wind combined were flat at just 7.5 GW, unchanged from the prior week; coal output rose 69% and gas rose 26% to cover the gap (EPRINC). The Department of Energy stated that during the 5 p.m. peak hours of July 2 and 3, 82% of available wind power failed to produce, and when the sun goes down solar goes offline (DOE, via Shore News Network) — a political characterization rather than a PJM operational metric, but consistent with the underlying meteorology and the independent fuel-mix data. Solar did perform well during daylight, reaching over 11,000 MW at the record hour (Grid Strategies), but when the sun goes down it does not help with the post-sunset net-load peak, exactly the deliverability problem PJM itself flagged.

PJM leaned hard on demand response, deploying an average of 6,113 MW on July 2 and 5,037 MW on July 3 (PJM Operating Committee presentation — essentially its entire contracted demand-response fleet and then some (Grid Flexibility case study). Imports offered little cushion: PJM was actually a small net importer at the record hour, drawing roughly 900 MW total from MISO, NYISO, LG&E, and TVA — a rounding error against a 168 GW peak (Grid Strategies). West Hub on-peak day-ahead prices averaged $479.27/MWh on July 2, the highest for any July or summer day on record (S&P Global). PJM avoided firm load shed, but a record peak, near-record outages, collapsing reserves, and near-total demand-response deployment is about as close to the edge as an operator can get without a blackout.

ISO New England: Tight, But Wind Actually Helped

ISO-NE issued a precautionary Abnormal Conditions Alert effective 5 p.m. on July 1, explicitly stating “this is not a system emergency,” and lifted it at 10 p.m. on July 3 (ISO-NE event record; ISO-NE newswire). ISO-NE warned that “there is little surplus generating capacity available to deal with unanticipated events,” and flagged that heat “affecting systems to the west and the north, including New York and Quebec” was “increasing uncertainty regarding energy imports to New England” (ISO-NE newswire) — a direct acknowledgment that its reliability depended on neighbors who were themselves under stress.

The July 2 peak of 25,351 MW was ISO-NE’s 2026 high, below the all-time summer record of 28,130 MW from August 2006, though behind-the-meter solar brought it within roughly 500 MW of that record (Central Maine / Portland Press Herald; Grid Status). Unlike PJM and MISO, ISO-NE’s wind performed well throughout: roughly 57 GWh generated, a 78% increase over 2025, never below 400 MW, and strongest during the afternoon and evening peak, driven largely by offshore wind (Grid Status). American Clean Power says offshore wind alone met almost 12% of total demand on July 2 (American Clean Power). That is geography and luck, not evidence that wind can be counted on generally because if the center of the heat dome was more to the northeast the wind would have failed.

MISO: High Load, Weak Wind, No Emergency

MISO declared no maximum generation emergency during this window; its first Energy Emergency Alerts of the summer came two weeks later, on July 15 (Grid Status), despite peaking at roughly 121–125 GW on June 30, within about 2 GW of its all-time record of 127 GW set in 2011 (Politico).

MISO’s wind was the second clear shortfall of the event. Grid Status reported that MISO wind was weak across the entire footprint and “particularly underperformed the forecast during the evening peak period” (Grid Status), which directly conflicts with a claim from American Clean Power, an industry trade group, that MISO wind delivered roughly five times more electricity than forecast at the peak hour (American Clean Power). The operational synopsis — wind underperforming forecast at the evening peak, when it matters most — deserves more weight than a trade-group framing.

MISO’s solar reached a peak of 18.6 GW on July 1, coal hit its highest output of 2026 to date, and batteries discharged only about 1 GW at peak, which Grid Status called “still well below the level required to cover the net load peak” MISO got through the event without an emergency and was even a net exporter, but did so on the back of coal and gas, not wind (Grid Strategies).

Ontario and Québec: The Same Ridge, the Same Wind Drought

Canada’s two largest eastern grid operators sat under the same stalled ridge as PJM and MISO, and Ontario’s experience is arguably the most direct confirmation of this series’ thesis. Ontario’s Independent Electricity System Operator (IESO) set its highest demand day of 2026 to that point on July 2, peaking at 24,734 MW during hour ending 18:00 (IESO Power Data) and July 1 and June 30 both landing in the 23,500–23,900 MW range (load-record compilation); Ontario natural-gas generation was tracking 7% above July 2025 levels for the broader event (Grid Status). Wind was nearly absent. A watchdog site tracking IESO’s public power-data feed reported that with Ontario demand above 18,000 MW, wind power was providing barely 300 MW province-wide, noting flatly that “wind is absent during most heat waves” (Ottawa Wind Concerns). A separate Ontario energy-policy blog found that industrial wind turbines generated just 9.9% of rated capacity on July 4 and only 7.2% on July 5 during the tail of the same ridge, while gas generation covered the gap — in the author’s words, gas “saved us from blackouts” (Parker Gallant Energy Perspectives). That is the same wind drought PJM and MISO experienced, documented independently on the other side of the border.

Storms tied to the heat wave also knocked out power to as many as 168,000 Hydro One customers in Ontario on July 1–2 (CityNews Montreal), and to as many as 140,000 Hydro-Québec customers on the night of July 2, with 30,000 to 50,000 still without electricity as of July 3 (CTV News; The Montreal Greek Times).

Québec matters here too: New York and New England leaned on Hydro-Québec’s hydro-based system as a backstop, and that backstop had complications of its own. NYISO drew a daily average of about 1,400 MW per hour from Hydro-Québec and 800 MW per hour from Ontario’s IESO on July 3, together covering 9% of NYISO’s demand (U.S. Energy Information Administration). But the new 1,250 MW Champlain Hudson Power Express tie line sat out entirely from July 1 through midday July 2 because of an outage on the Québec side of the border, reached full output only by mid-afternoon July 2, and then tripped into another unplanned outage on July 4 — right as the heat wave was peaking.  Net flows from Hydro-Québec into NYISO ended up down nearly 14 GWh compared with the June 2025 heat event, despite the new line (Grid Status). Even that hydro-heavy backstop could not fully deliver during the worst days of this event.

Comparing the Regions

  • PJM — all-time record peak (168,158 MW); NERC EEA2 and two DOE orders; wind and solar flat at 7.5 GW; reserves fell by more than half in a day.
  • ISO-NE — 2026 peak (25,351 MW), below the all-time record; precautionary alert only; wind up 78% year over year, never below 400 MW.
  • MISO — within 2 GW of its all-time record (121–125 GW); no emergency; wind underperformed forecast at the evening peak; solar and coal covered the gap.
  • IESO (Ontario) — 2026 high (24,734 MW); wind fell to a few hundred MW against 18,000+ MW of demand; gas covered the gap; storms cut power to 168,000 customers.
  • Hydro-Québec — storms cut power to 140,000 customers; the CHPE tie to NYISO sat idle for a day and a half, then tripped again July 4; net exports to NYISO fell from previous episodes.

Conclusion

The pattern across this heat wave was not that renewables failed everywhere — it is that wind availability tracked the weather system’s geography almost perfectly. New York, PJM, MISO, and Ontario all sat inside or near the ridge’s weak-gradient zone and paid for it in scarce wind; offshore New England did not.

That is exactly the concern I raised in my first post in this series: the weather conditions that produce the highest electricity demand — a stalled summer ridge trapping hot, humid air over a broad region — are frequently the same conditions that suppress wind output over that same region, and that region can be enormous. PJM’s dispatch manager said the capacity position “continues to be an area of concern” after setting an all-time peak with almost nothing from wind and solar combined. Ontario’s independent observers watched the same story play out with their own wind fleet, entirely independent of anything happening in the U.S. grids. New York avoided the worst of it this time only because the ridge sat somewhat south of the state for most of the week, and even then, the Canadian hydropower it counts on as a backstop had its own outages and tie-line failures at the worst possible moments. There is no meteorological law guaranteeing any of these systems will be so fortunate next time. A future grid that depends more heavily on wind, solar, and short-duration storage needs to be planned for exactly this kind of correlated, region-wide shortfall.  If all New York neighbors transition to similar weather-dependent electric systems then the New York system cannot count on any imported power.

Ellenbogen’s Data From the July 2026 Heat Wave

I have been documenting the electric system impacts of the late-June/early-July 2026 heat wave in a series of posts (My take and NYISO take) that relied on New York Independent System Operator (NYISO) system-wide data. This post is different. Rich Ellenbogen, an engineer who runs a factory in Westchester County that is about 1.4 miles from his home in New Rochelle, on the Con Edison system, shared measured voltage, frequency, generator, and solar array data he collected at both locations during the heat wave. His data illustrate at the distribution system level exactly the kind of electric system stress that the NYISO documents describe in the bulk-energy system.

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. 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 used Perplexity AI to process commentary and data that Rich Ellenbogen shared with me and prepare a draft article. 

Overview

Rich Ellenbogen owns Allied Converters, a factory in Westchester County, and lives in New Rochelle, both served by Con Edison. His home and factory are instrumented with data-logging systems — in his words, computers that have recorded operating parameters about twice a minute for the past 22 years — plus a behind-the-meter solar array at each site and a backup generator at the factory. Those systems captured voltage, frequency, solar output, and generator operation throughout the heat wave, giving a distribution system view of the same stress that shows up in NYISO’s system-wide numbers.

Ellenbogen’s observations line up with what I found in my own analysis and with what NYISO reported to its Operating Committee: narrow reliability margins, unavailable generation and transmission capacity in the downstate region, and heavy reliance on demand response and imports will impact the New York electrical grid. His data add something the system-wide numbers cannot: what those stresses actually looked like at the meter, at a home and at a factory, in real time.

Voltage and Frequency at the Ellenbogen Factory

Ellenbogen described a sustained period of degraded power quality at his factory covering roughly three days. In his words:

The voltage was ‘browned out’ from about 4 AM on July 2 until 3 AM on July 4, a period of about 47 hours, and it was system wide, not isolated to New Rochelle. The fluctuations throughout the day on July 4 indicate that the system wasn’t truly stable until about 4 AM on July 5, which increases the time frame to nearly 72 hours.

Figure 1 is Ellenbogen’s graph of the voltage measured at his factory from July 1 through July 21. All three phases sag well below the normal ~120 V band for extended periods around July 2–4, with a brief excursion down toward 104–108 V on one phase before recovering. He also noted a sharp voltage dip around 5 PM on July 2 that he says “scrambled” the inverters on his backup generator, his factory solar array, and his home solar array, shutting them all down — the same behavior that produced the widespread blackout in Spain and Portugal earlier in 2025, when grid parameters pushed inverters out of their operating window and they disconnected at one time.

Figure 1: Voltage Measured at the Ellenbogen Factory, July 1–21, 2026

Source: Data provided by Rich Ellenbogen

Ellenbogen drew a pointed conclusion about battery storage from this experience, responding to a news article in which a battery-industry representative argued that current Public Service Commission rules do not reflect batteries’ ability to turn on and off at short notice when the grid needs it:

Theoretically, they can be turned on and off at will, but that assumes that you have the energy to charge them. These battery systems are all rated for four-hour storage. Peak load periods run from 4 PM until 11 PM, or about 7 hours. So what happens after 8 PM? … How is a 4 hour or even the new 8 hour battery system going to bridge a 47 hour event? After the first eight hours, they will be useless and at other times, there is sufficient generation and the batteries aren’t needed.

He also argued that trying to recharge more batteries on an already overloaded, low-voltage grid would have made conditions worse, because at lower voltage the current — and the charging losses — both increase, and that a grid heavily reliant on battery inverters could have blacked out entirely when the July 2 voltage dip pushed those inverters out of their operating range all at once.

The July 2–4 Event at the Factory

Ellenbogen also shared minute-by-minute data logged at the factory, about 1.4 miles from his house, covering the 72-hour period from July 2 through July 4. Figure 2 is his annotated graph of the three-phase voltage recorded there, with the July 2, 3, and 4 periods marked. He described it this way:

From looking at the graph, it is apparent that the system had major issues over a 51-hour period during the heat wave. From the first voltage dip at about 2 AM on July 2 until 5 AM on July 4.

Figure 2: Annotated Three-Phase Voltage at the Factory, July 2–4, 2026

Source: Data provided by Rich Ellenbogen

Figure 3 and Figure 4 are the corresponding factory frequency and solar output graphs for the same period. Ellenbogen noted that the power stayed stable enough to keep the factory’s inverters running through most of the event, and that the visible drops in solar output were due to clouds rather than any grid-side event.

Figure 3: Factory Grid Frequency, July 2–4, 2026

Source: Data provided by Rich Ellenbogen

Figure 4: Factory Solar Array Output, July 2–4, 2026

Source: Data provided by Rich Ellenbogen

The factory’s own logged data confirm the extent of the disturbance independently of Ellenbogen’s narrative. The 72-hour dataset for July 3 alone that he shared shows three-phase voltage swinging from a normal band near 118–122 V down to single digits — essentially a momentary loss of service — around 5:07 PM, with frequency simultaneously collapsing to about 47.65 Hz before recovering. The factory’s backup generator data show it running intermittently between roughly 1:11 PM and 5:11 PM that day, exactly the window when voltage and frequency were most unstable, which is consistent with the utility service becoming unreliable enough that the facility needed to generate its own power to ride through the disturbance.

Con Edison System Voltage on July 3

Figure 5 is Ellenbogen’s chart of Con Edison system voltage on July 3, again showing all three phases at his home.  Voltage drifts down through the low 110s for most of the day — already below the nominal 120 V level — before a sharp collapse toward 100 V and below in the late afternoon, followed by a spike as high as roughly 130 V on recovery. He wrote:

You can see the voltage dropping throughout the day and the voltage dip that knocked out the solar array at 4:38 PM and then the spike to 130 volts. Then the blackout at 5:07 PM.

Figure 5: Con Edison System Voltage at Ellenbogen Home, July 3, 2026

Source: Data provided by Rich Ellenbogen

Figures 6 and 7 show the corresponding frequency data for that day, first at full scale and then “magnified” to show the deviation more clearly. Ellenbogen described normal system frequency variation as a thin, fuzzy line hovering near 60 Hz, but noted a roughly 0.5 Hz swing after 4:40 PM that he called “a lot of deviation,” culminating in the reading of 47.5 Hz that marks the moment the system failed at 5:07 PM.

Figure 6: Con Edison System Frequency at Ellenbogen Home, July 3, 2026

Source: Data provided by Rich Ellenbogen

Figure 7: Con Edison System Frequency at EllenbogenHome, July 3, 2026 (Magnified)

Source: Data provided by Rich Ellenbogen

Ellenbogen connected the voltage collapse to a growing reliance on inverter-based resources — solar and batteries — that disconnect from the grid when voltage or frequency moves outside their operating range:

Compounding the issues is that the system is getting so unstable that the Behind the Meter Solar (BTM) is shutting down, as it did at my home after the large spike … As the system is becoming reliant on the output of the BTM Solar, those shutdowns further compromise the system by reducing generation. Inverters on batteries will suffer the same fate so as the system becomes more reliant on these inverter-based technologies, it’s going to become even more compromised than it is now.  The events of July 2 and 3 show how bad it has already gotten.

Home Solar Inverter Fault Log

Ellenbogen also provided the fault log from one of the inverters on his home solar array, which has more detailed logging than the older inverters at the factory. Of 353 total log entries recorded since the inverter was installed in January 2024, 54 — 15% of all entries logged over nearly 940 days of operation — occurred in just the 54-hour span between 11:26 AM on July 2 and 6:22 AM on July 4. As he put it, “the inverter was not happy.”

The fault log itself shows two distinct clusters of grid disturbances at the house. The first ran from about 11:26 AM to 1:01 PM on July 2 and logged repeated “Grid undervoltage very fast,” “Grid overvoltage fast,” and “Grid frequency disturbance” events, along with several “Phase(s) or neutral conductor not connected” faults as the inverter repeatedly disconnected and attempted to reconnect. The second cluster ran from about 4:39 PM on July 3 to 6:22 AM on July 4 — matching the timing of the voltage collapse Ellenbogen documented in Figure 5 — and shows the same pattern of undervoltage and frequency-disturbance events.  There was a “Phase(s) or neutral conductor not connected” fault sequence, and finally a “Reconnection fault grid” entry at 6:38 PM on July 3 that did not clear until 6:22 AM the next morning. Each of these events represents the inverter automatically taking the solar array offline because grid conditions had moved outside the range it is designed to tolerate — exactly the behavior Ellenbogen warned would become more disruptive as the system leans more heavily on inverter-based solar and battery resources.

Broader Consequences

Ellenbogen argued that the July 2–3 power quality problems reached well beyond his own property. He pointed to a Lohud report (also archived here) that documented a failure at the Yonkers sewage treatment plant coincident with the power issues on July 2 and 3, which released 39 million gallons of raw sewage into the Hudson River over a holiday weekend and forced cancellation of numerous river events because of the resulting pollution. He noted the irony that the state Department of Environmental Conservation (DEC) cited the plant for violating its discharge permit, while, in his view, DEC’s own permitting decisions blocking new generating capacity have contributed to the grid conditions that caused the failure in the first place. A county spokesperson quoted in the article said there had been no prior issues with the plant’s emergency generators, adding: “This situation never occurred before, but also we never had [Con Edison] dip the power like that before.”

Ellenbogen reported that the same voltage surges and dips damaged equipment at his own home — destroying surge suppressors on his battery backups, frying an elevator controller, and knocking out a communications module for his light switches, for roughly $1,450 in direct repair costs — and that neighbors in the area reported having to replace air conditioners damaged during the same period. He said that in 22 years in his home, he had never previously experienced power quality problems of this severity.

Conclusion

Rich Ellenbogen’s measured data provide ground-truth confirmation, at the level of an individual home and factory, of the system-wide stress that NYISO reported to its Operating Committee for this heat wave. Where NYISO’s presentation described unavailable generating capacity, thin operating reserves, and reliance on emergency demand response in aggregate terms, Ellenbogen’s voltage and frequency traces show what those conditions actually did to power quality on the Con Edison system: sustained under-voltage for tens of hours, a sharp voltage collapse and frequency excursion to roughly 47.5–47.65 Hz on the afternoon of July 3, and a cluster of inverter faults that took behind-the-meter solar offline at the exact moments the grid needed it most.  He also noted that his electrical systems had worked for 23 years but this heat wave caused something new on the electric system that had adverse impacts.

His central point is one I share: a fleet of four-hour or eight-hour battery systems cannot bridge a 47- to 72-hour period of degraded grid conditions, and inverter-based resources — solar and batteries alike — are prone to disconnecting from the grid precisely when voltage and frequency swing outside their normal operating range, removing generation at the worst possible time. As New York leans more heavily on these technologies to meet Climate Act mandates, this event is a warning that deserves serious engineering attention rather than the political dismissal Ellenbogen believes it has received so far.