Category: Climate Act Feasibility

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.

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.

Roger Pielke Jr. recently published an update of his annual review of the status of global energy transition away from fossil fuels based on the 2026 Energy Institute Statistical Review of World Energy (“2026 Energy Review”).  This post examines how well New York is doing relative to the transition results described by Pielke.

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.

Overview

It is ancient history now, but in August 2009 New York Governor Paterson issued Executive Order 24 formally establishing a state goal of reducing GHG emissions from all sources 80 percent below 1990 levels by 2050.  The  Climate Action Plan was never implemented in a meaningful, binding way because it remained a non‑statutory planning exercise and was then effectively sidelined by political, economic, and administrative priorities. The political calculus changed and in 2019 the Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  This year some of the components of the act were modified, but there still are requirements that eventually require a “zero emissions” electric system with the a net zero target.

I have been a fan of Roger Pielke Jr.’s book The Climate Fix: What Scientists and Politicians Won’t Tell You About Global Warming since it was published in 2010.  He described the “Kaya Identity” that was formulated in the 1980s by Yoichi Kaya in the book.   Pielke notes that the Kaya Identity was “originally developed to facilitate climate scenarios and projections, but it also turns out to be a very powerful tool for climate policy evaluation.”  It ““operationalizes the IPAT formulation, which holds that environmental impacts (I) are a result of the interactions of population (P), affluence (A), and technology (T) — hence, I = PAT.” 

While researching this article I discovered my Kaya Identity analysis of New York through 2008.  I updated this analysis for years but stopped doing so before I started this blog.  Pielke’s article prompted me to update my analysis so I could compare New York to the rest of the world.  Pielke provides a methods appendix and spreadsheet with documentation and data that I updated for this work.

New York Data

Pielke’s input data was from the 2026 Energy Institute Statistical Review of World Energy.  For equivalent New York energy data I used the New York State Energy Research & Development Authority Patterns and Trends most recent report covering data from 2009 -2023 and the edition covering 2007-2021.  The earlier edition provided data in a usable format.  For example, all the data tables listed 15 years of data but included a link to the complete data set.  The two reports since that report was released do not include as much information and are designed to support the political narrative more than to simply provide data.  I will follow up with a post about those changes someday.  In the meantime, the data used are available upon request.

Generation Trends

Pielke introduced his analysis by describing the carbon-free share of global energy consumption (Figure 1).  The 2026 Energy Review uses a longer and more recent data set.  Figure 2 overlays New York’s share of carbon-free generation from 1990 to 2023 to global emissions.  Note that New York’s share started at 16% and has increased to 25%.  This reflects New York’s geographical advantage for hydroelectric power generation and investments in nuclear.  Using these data there is no indication that the Climate Act has accelerated the carbon-free share of energy consumption.

Figure 1: Carbon-Free Share of Global Energy Consumption, 1965-2025

Source: Roger Pielke, Jr. Energy Transition: Yes, No, Maybe

Figure 2: Carbon-free Share of Global and New York State Energy Consumption 1990 – 2023

Pielke notes that “Total energy demand continues to increase, and fossil fuels have continued to meet the majority of that growth”.  Figure 3 lists his graph that shows that global fossil fuel consumption is still growing and includes New York’s contribution.  Not surprisingly, New York is such a small component that the data do not show a trend so I included another graph with just New York.  NY fossil fuel consumption has gone down but that trend started before the 2019 implementation of the Climate Act.

Figure 3: Global and New York State Fossil Fuel Consumption 1990 – 2023

Source for Global Data: Roger Pielke, Jr. Energy Transition: Yes, No, Maybe

Net-Zero Transition Projection

Pielke generated a graph showing what reductions are necessary to get the fossil fuel consumption to zero by 2050 (Figure 4).  Pielke notes:

Reaching zero by 2050 requires retiring ~21 exajoules of fossil energy every year, starting now. That annual reduction exceeds the total energy consumption of most countries on Earth. And every year the line fails to bend down, the required rate in the remaining years grows larger, just as a matter of math.

Figure 4:  Global Net-Zero By 2050 Requirement

Source: Roger Pielke, Jr. Energy Transition: Yes, No, Maybe

Figure 5 displays the New York requirement to reach the Climate Act 85% net-zero target using the same units and a different starting year.  The New York required decline is 0.5 Exajoules per year.  It appears to me that the existing reduction trend is flatter than what is required.

Figure 5: New York State Net-Zero By 2050 Requirement.  Required decline is 0.5 EJ /year.

Pielke described what is needed to meet the global requirement to replace fossil energy to reach net-zero:

Replacing 21 EJ of fossil energy per year, and retiring an equal amount of fossil supply alongside it, means building the equivalent of about one 1.75-gigawatt nuclear plant every day from now until 2050 — roughly 420 plants a year. Measured in wind turbines instead, at 3 megawatts and a 0.30 capacity factor, that comes to about 2,000 turbines a day, every day, for 25 years.

I estimated the resources needed in New York by simple proportions with Pielke’s analysis.  Replacing 0.5 EJ of fossil energy per year and retiring an equal amount of fossil supply alongside it, means building the equivalent of about nine 1.75-gigawatt nuclear plant every five years from now until 2050 for a total of 48 facilities. Measured in wind turbines instead, at 3 megawatts and a 0.30 capacity factor, that comes to over 3,000 turbines a year totaling over 83,000 turbines.  As Pielke notes net-zero by 2050 is infeasible by any practical standard for the globe and I believe that is also true for New York.

Pielke goes on to describe annual changes in global energy consumption.  I do not think that this is a meaningful statistic for just New York State so I did not reproduce his findings for comparison.

Decarbonization Trend

Figure 6 shows the carbon intensity of the global economy 1992-2025 — CO₂ per unit of Gross Domestic Product (GDP).  Pielke has explained that the carbon intensity of GDP equals the product of two factors: how much energy the economy uses per dollar (energy intensity), and how much CO₂ that energy emits (carbon intensity of energy).  Pielke explains:

The global economy has decarbonized steadily since well before climate policy existed — back to at least the 1960s.

Two things follow.

• First, global climate policy does not drive decarbonization as the decrease in carbon intensity of the global economy long pre-dates the climate movement (which started as coordinated global policy in 1992 with the Rio Earth Summit); economies growing wealthier and using more energy more productively have driven that trend.
• Second, and less comfortably: since the climate-policy era began in 1992 the background rate shows no acceleration. Hitting deep-decarbonization targets requires this straight line to bend down. It has not done so.

Some economies cut their carbon intensity by about two-thirds since 1990 — China, the United Kingdom, Germany. Others moved the wrong way and grew more carbon-intensive, led by Iran. These differences track different starting points, energy mixes, and stages of development — not the presence or absence of climate ambition.

Figure 6: Global Decarbonization 1992-2025

Source: Roger Pielke, Jr. Energy Transition: Yes, No, Maybe

Figure 7 compares the global carbon intensity per unit of GDP to the New York carbon intensity per unit of Gross State Product (GSP). In 2023 the normalized to 1992 global value was 58 and the New York value was 48.  New York is decarbonizing faster than the world by this metric but Pielke’s criticism’s of climate policy are appropriate for New York as well.

Figure 7: New York and Global Decarbonization 1992-2023.

Figure 8: lists the energy intensity of GDP (energy ÷ GDP), carbon intensity of energy (CO2 ÷ energy), and carbon intensity of GDP (their product).  These component factors show how each has contributed to global decarbonization.  Pielke notes that:

The green line — the economy becoming less energy intensive per dollar of output — accounts for almost the entire decline in CO₂ per unit of GDP. The tan line — the carbon intensity of the energy that is consumed — has barely moved in 35 years, despite the impressive growth in carbon-free energy.

Figure 8: Factors Affecting Decarbonization 1990-2025

Source: Roger Pielke, Jr. Energy Transition: Yes, No, Maybe

I plotted the same parameters in Figure 8.  Global data are plotted in blue: energy intensity of GDP is lightest blue, carbon intensity of energy is darkest blue, and carbon intensity of GDP is medium blue.  New York data are plotted as follows: energy intensity of GDP is yellow, carbon intensity of energy is red, and carbon intensity of GDP is orange.  Globally the economy becoming less energy intensive per dollar of output accounts for almost the entire decline in CO₂ per unit of GDP. The global carbon intensity of the energy that is consumed is relatively steady.  New York is different.  The New York economy is also becoming less energy intensive per dollar of output at a rate consistent with the global data.  However, there also is a reduction in carbon intensity of energy so the combination of the two results in a greater decarbonization rate.  I believe that reflects New York’s fuel switching conversion away from goal and oil to natural gas in the electric and industrial sectors.  I believe those conversions were the result of economics as natural gas became the cheapest fuel, not because of climate policy.

Figure 8: Factors Affecting New York and Global Decarbonization 1990-2023

Pielke compares the change in carbon intensity of GDP from 2015 to 2025 in Table 1 for G20 economies and the world, ranked by largest reduction in CO2/GDP since the Paris Accord in 2015  New York’s reduction from 2015 to 2025 was 31.9% placing the state second to the countries Pielke evaluated.

Table 1: Change in Carbon Intensity of GDP from 2015 to 2025

Source: Roger Pielke, Jr. Energy Transition: Yes, No, Maybe

Discussion

Using the Kaya Identity methodology documented by Pielke I show that New York compares favorably with the world and other countries in the decarbonization race to net-zero.  There are two caveats. 

Pielke’s bottom line for the world is also appropriate for New York:

The 2026 update is fully consistent with the pattern I have documented here year after year. Carbon-free energy is growing. Decarbonization continues its long, slow, pre-policy downward trend. Global fossil fuel consumption continues to increase. The carbon intensity of energy has barely budged, drifting downward ever so slowly. The gap between the required rate of change to hit aggressive decarbonization targets and the observed rate in the real world widens every year.

If we are to achieve deep decarbonization this century, the lesson to take is that we should start thinking about some different options for how to get there. What we have been doing isn’t working.

The second caveat is that while New York’s carbon intensity was more of a factor in the state’s decarbonization,  I believe it was affected by fuel switching to natural gas and there are not many more opportunities for that to occur in the future. 

Conclusion

Pielke claims that the aspiration of net-zero is not impossible.  Based on these results I believe that even if New York’s net zero aspiration is not impossible, it is impractical. 

Worldwide support for the net-zero energy transition is falling apart as the existential threat justification falls apart and the reality of the harms to affordability, reliability, and the environment become apparent.  The question now is not if but when New York’s Climate Leadership & Community Protection Act (Climate Act) will be paused to account for reality.

As a retired air‑pollution meteorologist who has spent a career worrying about both the air people breathe and whether the lights stay on, I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 650 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone. 

Impetus

I was prompted to write this article by Judith Curry’s announcement that her blog Climate Etc. is being euthanized.   She described the reasons that she will no longer support her blog:

• Major progress has been made in the climate debate and the political climate has changed
• My interests have evolved in other directions
• The logistics and cost of keeping the blog running are substantial.

Her summary of the state of the climate debate prompted me to write about the situation in New York.  First, I want to acknowledge the impact her blog had on this one. I have great respect for Dr. Curry, and her writings influenced me greatly.  I also strongly admire her courage because she took the politically inconvenient position that the existential threat of climate change argument was not supportable and paid for it personally and professionally.   In addition, she published some of my guest posts and put my blog on the map so to speak when she added it to her blog roll.  For many years most of my visitors came from that list.  It also led to some collaboration related to the New York State Reliability Council’s Extreme Weather Working Group.  I am in her debt.

State of the Climate Debate

Kevin Killough wrote a good summary of Dr. Curry’s decision.  She waswas a member of the “Climate Working Group” with John Christy, Steve Koonin, Ross McKitrick, and Roy Spencer that prepared a draft report for U.S. Energy Secretary Chris Wright on the topic of climate change impacts on the United States.   The draft “Critical Review” remains publicly available and on DOE’s books, but the Climate Working Group that wrote it has been dissolved and a federal court has ruled that DOE violated the Federal Advisory Committee Act (FACA) in the way it set up and used the group.  Earlier this year McKitrick cleared up some misconceptions about the report.

In my opinion, critics of the report ignore the fact that this process was more transparent and open than the process used by the Intergovernmental Panel on Climate Change (IPCC) to produce its reports that are considered the “proof” that action on climate change is needed.  Therefore, I believe that the criticisms of the process are overblown and the Executive Summary arguments are valid:

• CO₂ has substantial fertilization and “global greening” benefits and that these are underplayed in IPCC assessments.
• CMIP-class climate models overstate historical and projected warming, especially in the troposphere, and therefore exaggerate risks.
• Long‑term trends in most U.S. extreme weather metrics (hurricanes, tornadoes, floods, droughts, wildfires) are weak or absent in the historical record, and U.S. sea‑level rise shows little acceleration once local subsidence is accounted for.
• Economically, plausible climate sensitivities imply relatively modest damages, uncertain and potentially low social cost of carbon, and U.S. mitigation policies with “undetectably small” direct effects on global climate.

Dr. Curry noted that the DOE report has influenced the climate debate by changing the arguments for the need to transition away from fossil fuels.  Another key argument in the debate is the widespread acknowledgement that the emissions scenario used to produce the most extreme impacts is an implausible emissions scenario. Over the past few years, climate scientists and assessment bodies have moved away from treating RCP8.5 as a realistic baseline or “business‑as‑usual” trajectory and now generally regard it as an implausible, low‑likelihood pathway whose coal‑heavy emissions profile no longer matches observed and projected energy trends. In updated scenario sets and popular explanations, RCP8.5 (and its successor SSP5‑8.5) is explicitly excluded from the range of plausible futures, yet retained as a worst‑case or “high‑end risk” scenario because its strong forcing signal is valuable for probing upper‑bound climate responses, local impacts, and model behavior.

I have long been a critic of this practice in New York regulatory proceedings, especially as it relates to Part 490 Sea-Level Rise. It remains to be seen whether New York will modify its analyses to exclude this emission scenario. 

State of the Transition Debate

Despite the massive investments the wind, solar, and energy storage approach advocated in the Climate Act is failing globally.  “A sea-change is occurring in energy policy as realism overtakes magical thinking” but Robert Bradley notes that folks who rely on social media for their information still rely on magical thinking for energy policy.  The reality is that no amount of clean energy media messaging can avoid the fact that wind and solar require so much backup support that they will never be affordable.

This has been acknowledged in at least one state.  In April 2026, North Carolina regulators ordered Duke Energy to pause its next round of solar projects while finalizing a broader energy plan.  North Carolina’s carbon‑plan results show that even with strong climate goals, a real‑world grid ends up needing more firm capacity—gas and nuclear—alongside renewables and storage to keep the lights on and bills tolerable. Because New York faces harsher winters, more aggressive statutory mandates, and similar emerging reliability concerns in NYISO and State Energy Plan modeling, it is very hard to see how New York avoids eventually making the same kind of course correction.

In North Carolina, once planners incorporated actual load growth, winter risk, project lead times, and customer‑bill impacts, the Commission’s “carbon plan” backed away from a renewables‑only path and embraced new gas builds and extended nuclear as the least‑cost, reliability‑constrained solution, while loosening the 2030 interim emissions requirement. New York’s own studies already tell a parallel story: NYISO’s winter assessments flag growing fuel‑security risk and winter adequacy concerns; the State Energy Plan acknowledge a need for roughly 20–25 GW of “clean‑firm” capacity by 2040, equivalent to most of today’s fossil fleet.  I have shown that wind and solar can be almost absent during peak winter demand, making dispatchable emission-free resources (DEFRs) non‑negotiable.

On the Other Hand

Unfortunately, there is so much invested in the clean energy transition that stamping out the nonsense is a big problem.  Climate‑ and environment‑focused nonprofits now constitute a large professionalized industry, and climate change activism sits at the center of that funding stream. In the United States alone, environmental organizations collectively report more than 30 billion dollars in annual revenue and tens of billions more in assets, with climate advocacy a dominant theme in their campaigns, communications, and grant proposals. A relatively small number of large national and international NGOs capture a disproportionate share of this money, reporting annual revenues in the hundreds of millions and in some cases over a billion dollars, much of it from major foundations and high‑net‑worth donors explicitly interested in climate policy and energy transition. By contrast, the thousands of small grassroots climate groups that are often highlighted in media coverage operate on comparatively modest budgets, together accounting for only a small fraction of the sector’s total income even though they make up the vast majority of organizations by number.  John Robson’s weekly Climate Discussion Nexus newsletter regularly documents the “Green Money Machine”.  He describes the revenues of the smaller non-governmental organizations dedicated to the proposition that they can save the planet if only people would donate more for their work.   

In addition, there are many people who’s careers depend on climate change being an issue.  Consider all the universities that have climate change related programs.  Anthony Watts describes former EPA regulatory staff who want to the climate movement to continue.  “According to a June 23 New York Times report, “Former NOAA Employees Revive Climate Site Shut by Trump Administration,” a small group of former NOAA employees has recreated much of the former Climate.gov website under a new domain, Climate.us, after the original site was effectively retired during the Trump administration. The project reportedly involved former NOAA staff, approximately $280,000 in crowdsourced funding, and the painstaking recataloging of more than a thousand reports, datasets, articles, and educational resources.”

I have no doubts that the same actors will advocate that New York continue the Climate Act as long as possible.

Conclusion

The rationale to transform the energy system because there is an existential threat due to climate change caused by GHG emissions is no longer justifiable.  Once policymakers can no longer ignore the electric system constraints—especially as retirements and electrification continue—New York will face the same fundamental choice North Carolina just confronted: either relax or reinterpret interim targets and incorporate substantial firm capacity (through gas, nuclear, or other DEFRs), or accept growing reliability risk and politically unsustainable rate and outage impacts. The only question that remains is when this reckoning will occur.     

In late February the Hochul Administration “leaked” a New York Energy Research & Development Authority (NYSERDA) memo that said that “full compliance with New York’s 2019 Climate Leadership and Community Protection Act could cost upstate households more than $4,000 a year – on top of what they are already paying today and gas prices could jump over $2 a gallon.”  I believe they recognized that the Climate Leadership & Community Protection Act (Climate Act) is so expensive that it would be a re-election campaign liability.  Sunce then there have been many hints during budget negotiations but nothing specific in the opaque New York budget process.  I got a copy of the relevant part of the budget bill and this is a summary of what is included.   

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

Overview

There are substantive issues that can no longer be ignored. Most targets are behind schedule, and the obvious increased costs of the Climate Act will exacerbate the existing energy affordability crisis.  New York State Department of Environmental Conservation needs to respond to the New York Cap-and-Invest (NYCI) economy wide emission reduction initiative requirements and will have to eventually respond to the litigation saying that the State must implement the regulations or amend the law.  

Budget Bill CLCPA Revisions

The Climate Act revisions are in Part VV of the TED bill. 

The revisions specify specific amendments to Section 1. Subdivisions 2, 8 and 13 of section 75-0101 of the environmental conservation law, as added by chapter 106 of the laws of 2019. 

• Subdivision 2 changes GHG accounting from 20GWP to 100GWP, making us comparable to everyone else.  This enables us to interact with other jurisdictions seamlessly and reduces impacts of the irrational methane obsession in the 2019 Climate Act.
• Subdivision 8 changes exclude biogenic (e.g., organic matter like wood, although they don’t add a definition) emissions from our GHG limit (again matching other jurisdictions)
• Subdivision 13 eliminates out of state extraction and transportation of fossil fuels from our state GHG limit emissions accounting.  It does not revise out of state emissions from generation of electric power imported to NYS as part of our inventory.

The Climate Action Council planning process is revised to modify the charge to the Climate Action Council to developing a plan “toward” rather than “for” achieving  the state’s GHG limits, requires an undated Climate Action Plan in 2008, then updates every six years, rather than an update every five years (under current law, the Plan would have been updated in 2026)

There is a technical correction that requires separate reporting for biogenic emissions “consistent with” treatment by the IPCC.

One of the big changes requires DEC, by 12/31/28 to adopt regulations that “to the maximum extent feasible and cost effective” to achieve a 60% reduction in GHG by 2040, from a 1990 baseline.   The current law requires a 40% reduction by 2030. 

Revisions also require DEC to consider the feasibility of a cap and invest program that could be linked to other jurisdictions, including its affordability for residents, business and other entities, its impact on economic development and energy costs, and other factors. 

There also is a revision that requires evaluation of the reduction measures.  DEC is required to issue a report on recommended GHG reduction measures four years after the adoption of these regulations.

There are changes to the environmental justice mandates. The revisions require that climate-related state funds be spent with a goal of 40% in or for the benefit of disadvantaged communities, with a goal of 45% (up from 30% and 35%, respectively.)

Impression

The budget bill makes several important technical changes to the CLCPA that intersect directly with concerns I have raised over the last few years. First, it finally abandons the outlier 20‑year global warming potential metric and redefines “carbon dioxide equivalent” using a 100‑year time frame, bringing New York’s accounting back in line with IPCC practice and most other jurisdictions.  The bill also narrows the definition of “statewide greenhouse gas emissions” by removing upstream emissions from the extraction and transmission of fossil fuels imported into the state, while continuing to count emissions associated with imported electricity.  Both changes move the law modestly toward a more conventional and transparent accounting framework, which I have argued is a necessary precondition for honest discussion of New York’s role in global emissions.

The revisions also adjust several process and timing provisions without changing the underlying statutory end‑points. The deadline for DEC’s implementing regulations is pushed back to December 31, 2028, and updates to the Climate Action Council plan are now scheduled for 2028 and every six years thereafter, rather than “at least once every five years.”  This effectively concedes that the original schedule was unrealistic but does not revisit the 2040 and 2050 outcome targets or introduce any formal safety valve tied to costs or reliability.  In that sense, the law’s ambition is unchanged; only the official calendar has been stretched.

On the regulatory design side, the bill adds more explicit direction around issues I have frequently highlighted—affordability, leakage, economic competitiveness, and the potential role of a cap‑and‑invest program. DEC is instructed to design rules that minimize costs and maximize benefits, ensure reductions are “real, permanent, quantifiable, verifiable, and enforceable,” incorporate measures to minimize leakage, and consider options such as an economy‑wide, market‑based cap‑and‑invest system that may include linkages and cost‑containment features.  However, all of this remains in the language of “considerations” and broad objectives; there are no hard affordability limits, no explicit reliability criteria, and no defined thresholds at which the state must slow down or change course if costs, leakage, or reliability impacts become unacceptable.

Finally, the bill strengthens the statutory commitment to disadvantaged communities by raising both the goal and minimum share of “overall benefits” that must accrue to those communities, from 40 to 45 percent (goal) and from 35 to 40 percent (floor) of spending on clean energy and energy efficiency programs.  As with the original CLCPA, these percentages are defined in terms of “benefits,” not costs, and the bill does not resolve the practical questions of how those benefits are measured or how these distributional targets interact with least‑cost system planning. 

Reliability Problem

I am particularly concerned that the revisions do not address the reliability issues associated with the Renewable Energy Program.  There is nothing included that addresses what happens to the emissions free generation sector by 2040. This might be a portent that this issue will be addressed by the safety valve hearing in New York Public Service Law (PSL) § 66-p.  That would certainly be a political maneuver whereby they could get the necessary result but not take the blame for having to do it.

Unfortunately, this approach does not provide real solutions to the unfolding crisis.  The necessary technology to transition off fossil fuel generating resources is not available to address the extreme market events experienced during last winter’s cold snap.  At the same time,  the existing fossil resources that ensured the lights did not go out are aging and need to be replaced.  The business case for a developers to build new facilities and recover their costs with the existing timeline for zero emissions electric generation is very weak. The Governor needs to enact an interim solution that builds natural gas plants across the state until the ultimate future energy system is in place. 

Conclusion

Overall, the budget bill addresses some of the most egregious technical and accounting problems I have criticized, but it leaves my central concerns about feasibility, affordability, and reliability largely untouched.  Not surprisingly, the primary changes extend the deadlines for accountability beyond the election and avoids the hard decisions about the future of New York’s energy system untouched.

I have been privileged to join Stop Energy Sprawl monthly meetings for some time.  I always learn something and have been impressed with the dedication of its members. This post describes a recent distribution to its members titled “Tell New York State ‘It’s Time to Pause the CLCPA!’ and save our communities”.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written nearly 650 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

Stop Energy Sprawl is a “coalition of community groups, municipalities, and elected officials from localities in New York State targeted by land-wasting large-scale wind & solar projects located far from where that energy is needed.”  They have warned that Climate Act‑driven reliance on large‑scale wind and solar could require hundreds of thousands acres of New York farmland and forest for generation, storage, and associated transmission infrastructure.

Stop Energy Sprawl (has provided comments supporting the Coalition for Safe and Reliable Energy’s petition requesting a hearing on suspending or modifying the CLCPA targets.  This post describes a recent distribution to their members where they recommend submitting comments supporting the petition and announced a survey they set up to document how renewable development has harmed their communities.

Petition Recommendation

New York Public Service Law (PSL) § 66-p establishes a renewable energy program for the Climate Act.  It  provides that the Commission “may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.  In a rare example of commonsense this safety valve was included because even the lawmakers realized that it may not be possible to transition the electric system to “zero-emissions” by relying on renewable energy.  New York State never followed up with a feasibility study proving that it could be done, never pointed to another jurisdiction that implemented such a system successfully, and has not provided clear and comprehensive cost estimates.  Conducting a hearing is a commonsense reality check and I encourage you to submit comments.

Comments were originally due on March 30 but have been delayed to May 1.  Stop Energy Sprawl recommended submitting comments on the petition.

The CLCPA targets for 2030 are based on a technology goal — not an environmental goal (and they’re making the electric grid less reliable and more expensive) !

These targets put our communities at risk by mandating poorly-performing large-scale wind and solar facilities that will overrun hundreds of thousands of acres of high-quality farmland and forest, imperil fisheries and shorelines, destroy agriculturally-based, maritime, and tourism-based economies, and severely damage community character, historic sites, and the quiet enjoyment of our homes and communities, as well as the value of those residences and communities.  

The State uses the RAPID Act to implement these wind & solar goals. New York State routinely places out-of-state and foreign developers ahead of its own citizens and stomps on communities’ Home Rule and self-determination by overriding nearly every local law the developers ask them to.

Help us fight back for your community and all our communities by submitting a comment:

1. There are two cases.  Either go to this link at the Department of Public Service website:  https://documents.dps.ny.gov/public/Comments/PublicComments.aspx?MatterCaseNo=15-E-0302  or this link https://documents.dps.ny.gov/public/Comments/PublicComments.aspx?MatterCaseNo=22-M-0149   E-0302 is a huge proceeding so going to M-0149 will be faster.
2. Enter your name, address, and email address.
3. Copy and paste the message at the end of the post into the comments field (feel free to modify or add information about projects in your town)
4. Click the “I understand…” box and the “I’m not a robot” Captcha box
5. Wait until the Captcha completes and Click  Post Comment 
6. That’s it. You’re done!

Stop Energy Sprawl also told readers to  share thismessage with others in your organization, friends, neighbors, and town and county officials.  The voices looking to defile our communities with these facilities are already loudly opposing this hearing — we need to make our voices known!

Harmful Impact Survey

In addition, the distribution asked readers to compile their stories from communities targeted by land-wasting and coast-endangering large-scale wind and solar projects located far from where that energy is needed.  They have prepared a survey that seeks to collect information about the impacts experienced by communities throughout New York State targeted be wind, solar and energy storage development.  The goal is to bring awareness to these issues and to fight back against ill-considered laws that enable these destructive policies.

New York readers who have experience with these projects are encouraged to respond to the survey “How Did Wind or Solar Harm Your Community?”  Whether it was fire, farmland desecration, habitat loss, or setting residents against one another, we want to hear about it.  Respond at https://forms.gle/DYxEpmTBFkAAp11M8

For more information, contact them at stopenergysprawl@gmail.com or check out our website, stopenergysprawl.org

Conclusion

I think we are at an inflection point relative to the Climate Act.  It appears that the Hochul Administration has caught on that the net-zero transition is unsustainable.  Unfortunately there are still many that fail to acknowledge that physics, engineering, and economics all indicate that the renewable-based electric system is impossible.  The PSL 66-P hearing will provide a venue for public debate on the capability for renewable energy to provide safe and adequate electricity.

I also think that careful documentation of the harmful impacts of renewables developments will prove that the Rapid Act is an environmental disaster scandal.  The failure of the state to establish siting standards has led to unacceptable impacts that very few people know about.  I look forward to the survey results and encourage everyone with first-hand knowledge to tell their story.

Comment Recommendation

The following are the suggested comments supporting the Coalition for Safe and Reliable Energy’s petition requesting a hearing on suspending or modifying the CLCPA targets

It’s time for a hearing.  I support the Coalition for Safe and Reliable Energy’s petition requesting that the Commission hold a hearing pursuant to Public Service Law (PSL) Section 66-p(4) to evaluate whether to temporarily suspend or modify the targets or provisions under the Renewable Energy Program established as part of the Climate Leadership and Community Protection Act (CLCPA).

PSL 66-p(4) provides that the Commission “may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.  A PSL 66-p(4) hearing is essential to evaluate whether the Renewable Energy Program, as currently implemented, is compatible with safe, adequate, and affordable electric service.

Safe and adequate service is imperiled by declining reliability margins documented by the New York Independent System Operator.  Acceptable reliability risks associated with the Renewable Energy Program have not been defined so the public has no assurance that the declining margins are safe.

Transmission deficiencies threaten reliable delivery.  New transmission is needed to get the renewable energy collected to where it is needed.  If this transmission is not available, then the energy supply will not be adequate.

The affordability crisis demands a hearing because safe and adequate is only possible if it is affordable.  The PSL 66-p(4) hearing must define acceptable affordability metrics that can be tracked.

Multiple independent sources confirm the need for a hearing.  State agencies, the Attorney General Office, the NYISO and others have identified schedule and ambition issues associated with the Climate Act implementation that affect the Renewable Energy Program.

The Legislature included Section 66-p(4) precisely to address the situation New York now faces: implementation challenges that threaten reliability and affordability as the aggressive timelines and technology requirements of the Climate Act confront real-world constraints. The Commission has both the authority and the obligation to act.  The Commission must convene a hearing as soon as possible.