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.















