Category: Climate Act Feasibility

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.

New York State Sen. Peter Harckham argues that New York’s Climate Leadership & Community Protection Act (Climate Act).  will reduce high utility rates “if we let it.” He blames today’s affordability crisis entirely on fossil fuel volatility, dismisses nuclear as a “fantasy,” and claims that if we just double down on renewables and distributed solar, families will see “real, predictable savings.”  He is wrong on all three counts.

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. I acknowledge the use of Perplexity AI to generate an outline and draft for this post.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.

In a recent post I described several initiatives that have led Governor Hochul to suggest that the timeline for the Climate Act electric sector goals needs to be revised.  Apparently, the proposed changes are part of the budget negotiations and there is very little information describing exactly what the Governor has proposed.  The most disappointing thing to me is that Climate Act proponents like Harkham refuse to acknowledge that there are any issues that cannot be resolved by doubling down on current policies.

The opinion piece by Harkham is mal-information.  Media Defence defines mal-information as information that is based on reality, but it is used to inflict harm on a person, organization or jurisdiction like New York.  Given the status of the Climate Act, it is necessary to refute the opinion piece because what he claims bears little resemblance to what the New York State Energy Research & Development Authority (NYSERDA), the Public Service Commission (PSC), the New York Independent System Operator (NYISO), and even the State Energy Plan are now saying.

Affordability Crisis: Not Just Fossil Volatility

Senator Harckham correctly notes that in 2025 more than 1.3 million New York customers were over 60 days behind on their bills, with arrears approaching $1.8 billion. Where we part company is the explanation.

Harckham says these customers are struggling only because of the “fossil fuel status quo” and “future green energy targets” are not to blame. I addressed this in my “New York Climate Act Affordability Status” article. But the arrears crisis is occurring while Climate Act implementation is driving up both utility and economy‑wide energy costs.  In recent rate cases approved between March 2025 and January 2026, residential electric bills at the major utilities increased markedly, and that was before most Climate Act capital spending shows up in rates. The PSC’s own staff “Second Informational Report” on Climate Act costs found that CLCPA‑related program impacts already account for 4.6% to 10.3% of 2023 residential electric bills—numbers I consider conservative given the political pressure to minimize cost estimates.

And we are still at the front end of the cost curve. As Kris Martin from NY Solar Divide pointed out, only a small fraction of Climate Act expenses has hit bills so far; the bulk will land in the next 5–10 years as offshore wind, large‑scale solar, school‑bus electrification, and other mandates scale up.  So no, this is not just a “fossil fuel” affordability problem. It is also a policy‑driven cost‑loading problem, and the state’s own documents say so.

What NYSERDA and the State Energy Plan Actually Show

If the Climate Act were really a path to lower bills, NYSERDA and the State Energy Plan (SEP) would show that clearly. They don’t.

The 2025 State Energy Plan admits that “current renewable deployment trajectories are insufficient” and that external constraints “continue to impede progress,” concluding that the Climate Act schedule is effectively impossible to meet. It also estimates that achieving the Climate Act goals will require about $120 billion per year in energy system investment through 2040—roughly $1,282 per month per household when you levelize those costs.

NYSERDA’s Energy Affordability analysis underlying the plan is even more revealing. The public‑facing fact sheets emphasize that electrification might lower operating energy expenses for some households. But when you examine the data tables and include the levelized capital cost of mandated equipment, the picture changes dramatically.  For a representative upstate moderate‑income gas‑heated household, NYSERDA’s own numbers show that replacing fossil systems and vehicles with the required “zero‑emission” alternatives adds about $594 per month in 2031 compared to a conventional replacement path—a 43% increase in total energy‑related costs. That is roughly $7,000 per year in additional costs that the glossy brochures don’t emphasize.

In other words, once you include what it actually costs to buy the heat pumps, envelope upgrades, and EVs that the mandates require, the Climate Act is not a bill‑cutting program. It is a massive, regressive cost shift onto households that Albany has never honestly explained.

Reliability: The Cost of Ignoring NYISO

Harckham frames the debate as a simple choice between “low‑cost” renewables and “volatile” fossil fuels. He never mentions grid reliability, even though NYISO has been warning for years that Climate Act timelines and technology assumptions are pushing the system toward unacceptable risk.  NYISO’s 2024 Reliability Needs Assessment shows statewide resource margins declining so quickly that by 2034 there is no surplus left without additional development. A 2025 Short‑Term Assessment of Reliability identified a Zone J (New York City) reliability need as early as summer 2027, requiring peaker units scheduled for retirement to be retained.  There has already been a net loss of dispatchable capacity—NYISO’s 2025 Power Trends notes that since the Climate Act passed, 4,315 MW of capacity have retired while only 2,274 MW of mostly intermittent resources have been added, a net loss of about 2,041 MW.  

These reports also point out that Climate Act planning assumes timely completion of critical transmission projects like Champlain Hudson Power Express (CHPE) if this slips, New York City’s reliability margins become “deficient.” And their studies show that high penetrations of wind and solar require more operating reserves, new reserve products, and far more total installed capacity, including firm, zero‑emission resources that do not yet exist at required scale.

None of that shows up in Harckham’s breezy claim that renewables are “the cheapest new power source.” A system that must rely increasingly on emergency procedures, backstop contracts, and delayed environmental rules to keep the lights on is not a low‑cost system.

The “Cheapest Renewables” Talking Point

Harckham leans heavily on Energy Information Administration data and asserts that a kWh of solar is “consistently” cheaper than electricity from gas or nuclear.  I have addressed this “cheap renewables myth” at length. Project‑level levelized cost of energy (LCOE) comparisons ignore the system‑wide costs that NYISO must actually manage:

• Backup and firming capacity to cover multi‑hour ramps and multi‑day renewable droughts.
• New transmission to move remote resources to load centers.
• Storage sized to reliability needs, not just to smooth daily solar output.
• Curtailment and overbuild required as penetration rises.

At low penetration, subsidized wind and solar can appear cheap on paper. At high penetration, the cost of keeping the system reliable at all hours rises sharply, and those costs are socialized through rates and surcharges.

Nuclear: New York Policy Disaster

Harckham dismisses nuclear as a “fantasy” for bill relief, citing the long and expensive Vogtle expansion in Georgia. That is a convenient example, but ignores New York’s misguided nuclear policy  Cheered on by Harckham, New York chose to close Indian Point, a major source of zero‑emission, dispatchable power located near the New York City load center, and then tried to cover both that loss and growing demand with a mix of imports, gas, and promised future renewables. Emissions went up in the short term, and reliability margins tightened.

The fastest way to raise both emissions and costs is to shut down existing nuclear plants and then pretend that nuclear is irrelevant to affordability. New York State has not provided clear and transparent cost estimates for the Climate Act transition using renewables or an alternative approach using nuclear as the base load source.  As a result, it is simply false to claim that nuclear has no role in cost containment, especially if the alternative is building a massive overbuilt, weather‑dependent system plus long‑duration storage that does not yet exist commercially at scale.

Distributed Solar and the “$1 Billion” Promise

Harckham touts a Synapse Energy Economics study for the Accelerate Solar for Affordable Power Act, claiming “an estimated $1 billion in annual savings for ratepayers” by raising distributed solar goals and reforming interconnections.  I don’t doubt that a modeling exercise can produce that figure under optimistic assumptions. But New York’s record with these programs is that system‑level “savings” often mask who pays and who benefits.

Net metering and Value of Distributed Energy Resource credits shift revenue shortfalls onto non‑participants. Interconnection and distribution upgrade costs are socialized. Program administration and incentives are funded via surcharges. Those costs show up in the bills of the very households already in arrears.  Unless a study rigorously accounts for these rate‑base effects and distributional impacts, a headline “$1 billion in savings” can easily mean $1 billion in shifted costs, not genuine relief for the typical customer. Furthermore, I recently showed that the distributed solar failed to provide any meaningful energy during last winter’s extreme weather.  I doubt that the long-term costs will be cheaper if all the expenses necessary to support the system when solar is unavailable are included.

What PSL §66‑p(4) Is There For – And Why It Matters Now

One thing Harckham does not mention is that the Legislature itself anticipated a situation where Climate Act implementation might threaten affordability and reliability. Public Service Law §66‑p(4) explicitly authorizes the PSC to temporarily suspend or modify Renewable Energy Program obligations if it finds that the program:

• Impedes the provision of safe and adequate electric service,
• Is likely to impair existing obligations, and/or
• Is associated with a significant increase in arrears or service disconnections.

Two recent petitions—one from Independent Intervenors (including me), and one from the Coalition for Safe and Reliable Energy—ask the PSC to hold a §66‑p(4) hearing based on precisely these concerns. On January 28, 2026, the PSC issued a notice soliciting comments on whether Renewable Energy Program targets should be suspended or adjusted. That is not routine housekeeping. It is a legal acknowledgment that the current trajectory may be incompatible with safe, adequate, and affordable service.  The fact is that New York has never done a feasibility study proving that transitioning the electric system to depend on renewables will work.

Conclusion: Stop Pretending, Start Reviewing

Harckham urges New Yorkers to “reject misinformation” and “double down” on the Climate Act to lower bills. But the state’s own data tell a different story:

• NYSERDA’s cap‑and‑invest modeling shows steep fuel price increases and thousands of dollars per year in added household costs.
• Energy affordability analysis shows a 40+% increase in energy‑related costs for a representative upstate family once capital is included.
• The State Energy Plan projects $120 billion per year in system investment, about $1,282 per month per household on a levelized basis.
• NYISO warns of declining reliability margins, dependence on a few critical transmission projects, and a technology gap for firm, zero‑emission resources.
• More than 1.3 million households already owe nearly $1.8 billion in arrears.

This is not what an affordable transition looks like.

Reconsidering the Climate Act’s timelines and mandates does not mean abandoning climate goals. It means using the tools the Legislature provided—especially PSL §66‑p(4)—to align ambition with reality, ensure that reliability is not sacrificed, and prevent climate policy from becoming an uncontrolled energy tax on working families.

New Yorkers were promised a “clean, resilient, and affordable” energy future. Now that NYSERDA, NYISO, the Comptroller, and the Attorney General’s office have all signaled serious cost and feasibility issues, the responsible course is not to “double down” on slogans, but to require a transparent §66‑p(4) hearing on whether the Renewable Energy Program is compatible with safe, adequate, and affordable service.

That is the conversation we should be having—not whether critics are guilty of “misinformation” for reading the state’s own numbers aloud.  It is frustrating that misinformation claims are grounded on information that is based on reality, but it is incorrect that it inflicts harm on the state.

Conclusion

Since the promulgation of the Climate Act we now know we must address what we have learned.  New York’s affordability crisis is being exacerbated by Climate Act‑driven costs, not just fossil volatility.  NYSERDA and the State Energy Plan show large household cost increases once capital is included, not bill reductions.  NYISO’s reliability warnings reveal that a high‑renewables system without firm backup is neither cheap nor risk‑free.  Claims that renewables are “the cheapest power” ignore system‑wide costs, rate‑base effects, and reliability needs. Finally, PSL §66‑p(4) exists as a safety valve and should be used now to review and, if necessary, modify Climate Act obligations.