Category: Climate Act

Recommended Resource: Kris Martin’s Solar Divide Blog

Since November 2023 Kris Martin has been producing great articles at the Solar Divide blog documenting issues associated with the buildout of solar in New York associated with the Climate Leadership & Community Protection Act (Climate Act).  I highly recommend her website archive as a resource about issues associated with the irresponsible buildout of solar in New York and signing up alerts for her articles by subscribing to her Substack.

Background

Kris Martin is a retired software engineer in Western NY who writes about solar and wind buildout in rural communities.  At first glance her background does not appear to be applicable to renewable topics but it is my experience that 90% of the effort writing about renewable deployment in New York is tracking down state documentation.  As a software engineer, she has temperament to sift through reams of clutter to find the nuggets of relevant information necessary to show what is happening with complicated topics. 

Overview

Martin’s archive includes 28 articles (Table 1).  Most of the articles were published in the past year.  If you have a particular question about solar issues, I think just scanning through this list or the website archive itself will enable you to find information about most of the solar issues confronting New York.  Also note that many of her articles also provide a link to a pdf copy for download.

Table 1: Archive List of Solar Divide Articles

In the following sections I recommend specific articles covering several topics.

Costs

Kris Martin has done several articles about the costs of solar. 

One of my favorite articles explained solar subsidies because I wanted to know how this works but understood that unpacking how it works would be a long and frustrating effort.  I am indebted to her for figuring it out and then writing a clear and concise description.  She used a table to describe the entities playing the games in New York.

The article went on to describe the acronyms and why they matter, where developers can get loans from the state, how the Federal tax credits work, and  forms of tax relief.  Then summed up some of the major public funding sources for solar developers and who ultimately pays for each one on the following table.

She concludes:

Is NYS building out wind and solar on the backs of those who can least afford it? This question should concern those seeking to protect vulnerable populations from predatory corporate behaviors. After all, solar developers aren’t trying to save us from climate change—they’re profiting from it.

The post What it costs was another laudable cost-related effort that dug through many documents to uncover numbers that gubernatorial candidate Hochul does not want you to know.  This post looked at three issues:

  1. How much more renewable capacity we’ll need in 2040
  2. What it all costs: now and in the future
  3. What happens if we fail to meet the requirements of the Climate Act

One of the best characteristics of her articles is her use of graphics to explain issues.  The following figure shows how much renewable capacity is needed by 2040 based on one estimate from the New York Independent System Operator (NYISO).

Her next graphic shows where we stand today relative to the expected need.

This post has another example of analysis she did that I was planning to do but never got around to doing.  She described the expected costs in the DPS informational report and why they came up with suspiciously low numbers. 

Her analysis found that these estimates for future costs don’t include all the Renewable Energy Credits (REC) and OREC (offshore wind REC) costs that would be required to reach Climate Act targets—or even what they might realistically expect to complete. 

In another post discussing solar costs she discussed the possibility that the developers are fudging the numbers that project whether a solar project will ever generate enough energy to earn its keep.  While she tries to minimize using numbers for her articles this is one instance where the capacity factor number must be considered.  She defined capacity factor as “the percentage of the time it generated electricity at full capacity, compared with how much it could produce if it operated at full capacity 24 hours a day, 365 days a year.” That is not exactly correct.  It is the actual electricity produced at any capacity compared to the full capacity, but it shouldn’t make a difference because she relied on published capacity factors and did not calculate them herself.

She found that the expected energy output in the bids and the observed output were significantly less.  This has significant ramifications.  NYSERDA estimates of the renewable capacity needed are too low because they assumed unrealistic capacity factors.  The developer projections of expected energy projection determine if the project will be viable.  If those estimates are wrong, I am positive that they will go back to NYSERDA and ask for more money.  NYSERDA cannot afford for them to stop operating so they will pay up and consumers will end up footing the bill.

Land Use

One of my issues associated with solar deployment is the fact that New York State does not have a requirement for solar developers to minimize the use of prime farmland.  I highly recommend Martin’s look at the land requirements for solar buildout in upstate NY between now and 2050 as described in this post.  The original analysis was described in a white paper called Enough Land that was documented in her first post.  In August 2025 she updated the white paper.

Her analysis documents the fact that NYS experienced a 5.3% loss in farmland and 5% loss in cropland between 2017 and 2022.  She points out that this loss is before much utility scale solar was deployed.  She estimates how much solar capacity will need to be deployed to meet Climate Act goals and concludes:

More than a quarter of the state’s present farmland and a third of its cropland may be at risk from combined solar and non-solar development by 2050. These numbers mean we must look hard at all proposals that remove farmland from production.

As a born and raised Upstate New Yorker I have always resented the restrictions on land use imposed by the New York City Department of Environmental Protection (NYC DEP)  through its Watershed Rules and Regulations.  Martin describes the conflict between Upstate NY and the downstate region over the renewable energy buildout.  She explains that folks like me have noted that the upstate/downstate relationship reflects a pattern of neocolonialism in which NYC has dictated upstate land use. Historically, when NYC needed upstate land resources, upstate residents have had no say in the decisions.  She notes:

The goal of procuring clean energy for NYC has become a state priority, which has created an alliance between the city, state government, and renewable energy corporations. Consequently, today NYC is effectively establishing what amounts to an energy plantation on upstate land with the full support of state government. Individual property owners may choose whether to lease or sell their land for conversion to grid-scale renewable energy facilities, but communities and adjacent landowners have no decision-making role in siting them.

Two other articles also address land use problems.  Solar vs. trees addresses the issues associated with solar development in forests.  The article Seeing all the Sites discusses the alternatives to building out solar on farmland.  This is a good example of her in-depth analysis because she evaluates the arguments of responsible solar siting advocates and concludes that there simply is not enough “responsible” solar siting area to meet the solar capacity projections.

Retirements

Martin addressed the fate of the solar panels when they stop operating because of old age, damage, or owner insolvency.  She notes that the good news is that most facilities have decommissioning plans but that means the bad news s there are facilities that do not.  In another post she explained the other alternative that when a facility is past its prime that it will be re-powered.  She also prepared a two page summary addressing recycling of solar panels.

These posts define another example of what I have found regarding every Climate Act issue.  The reality is that every problem is more complicated, resolution more uncertain, and the costs are higher than the state has planned for or admitted.  These articles are great examples illustrating the problems with what will happen when these facilities stop operating. She concluded:

NYS urgently needs a statewide requirement that all solar installations—both residential and utility-scale—must have decommissioning plans. Decommissioning funds must be provided for utility-scale projects of all sizes. ORES should respect the host community’s efforts to protect itself and not waive local laws that are more protective than the state requires. Given that communities are often selected in part because they are economically disadvantaged, they deserve all the protection the state can give them.

Overviews

Finally, because she has a knack for explaining complicated topics simply, I want to recommend the following overview articles that describe the Climate Act itself and two components in the implementation plans. 

Martin’s description of community solar is very good.  She describes these facilities as follows:

Most community solar in NYS consists of 1-5 MWac utility-scale solar projects with multiple subscribers: residential, commercial, and other electricity consumers. Most sign up to get discounts of up to 10% on their electric bills. Unlike with residential solar installations, customers typically don’t own or lease the solar panels directly. Usually, these small plants are owned by solar developers, who receive various incentives and assistance to build and operate those facilities. One of the state’s goals is to sign up customers who can’t install residential solar because they can’t manage the up-front cost, don’t have an appropriate site, or don’t own their homes. A certain percentage of a project’s subscribers must be residential users, but commercial users may also take advantage of the discounts offered.

The article describes the characteristics, locations, battles between developers and local jurisdictions about these facilities, costs, and project performance.  She explains that “By providing generous assistance and favorable, predictable conditions for developing and selling electricity from community solar, the state has made itself an appealing choice for companies wanting to build small solar projects.”  She concludes:

As seems typical with state energy transition goals, we’ve invested an awful lot of money without demanding much accountability. It’s possible that community solar is contributing to resilience and reducing bills, but we don’t actually know it.

NYS’s 2030 goal of 10,000 MWdc of distributed solar may be one of the few we will meet on time. The state deserves bragging rights over building a large amount of community solar in a short time. It has created a favorable environment for developers, in which they can earn steady revenue despite mediocre performance. But buildout has sometimes taken place at the expense of rural communities, who may lack the knowledge and resources to evaluate these projects effectively and ensure compliance during and after construction.

Martin recently published an overview of battery energy storage systems (BESS) in New York.  Again, it is a well-researched, readable, and comprehensive summary of one aspect of the Climate Act.  She concludes:

Advocates of BESS insist that “the latest” li-ion technology is safe, that incidents are extremely rare, and communities are being misled by activists who find inaccurate information on the Internet. Most of what I have presented here comes from industry, government, news, and academic sources. While we would all like to say that the chance of a BESS fire occurring is so remote that it can be dismissed; five fires in NYS in the last three years suggest otherwise.

While proponents assert that utility-scale BESS deployments are crucial for NYS’s energy goals, the economic, environmental, and safety risks remain profound. The high costs of facilities, questions about adequate emergency response, environmental threats, and real-world incidents highlight the need for a cautious, community-first approach to battery storage. Policymakers should address these challenges before endorsing a large-scale BESS rollout across NYS.

Conclusion

I have a solar isses page that discusses many of the same issues covered by Marting, but her work should be a primary resource for anyone concerned about New York solar siting issues.  Her website archive is a great resource about issues associated with the irresponsible buildout of solar in New York.  If you are interested in any of these topics then I suggest signing up for alerts her articles are published by subscribing to her Substack.

Stalling the New York Climate Act Pause Evaluation

On January 28, 2026, the New York State Public Service Commission issued a notice soliciting comments regarding a petition for a hearing to suspend or temporarily modify the Renewable Energy Program. While on one hand I should be celebrating official recognition of something I have long advocated, on the other hand, the timing is problematic.  The evidence of the need for a hearing is overwhelming and this request for comments simply postpones the inevitable hearing.

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

Background

There is a fundamental Climate Act implementation issue.  Clearly there are bounds on what New York State ratepayers can afford and there are limits related to reliability risks for a system reliant on weather-dependent resources.  The problem is that there are no criteria for acceptable affordability bounds.

Proponents of the Climate Act argue that the transition strategies in the law must be implemented to meet the net-zero mandates.  However, they do not acknowledge that Public Service Law (PSL) Section 66-P, Establishment of a Renewable Energy Program, is also a law. PSL 66-P requires the Commission to establish a program to ensure the State meets the 2030 and 2040 Climate Act obligations.  It includes provisions stating that the PSC is empowered to temporarily suspend or modify these obligations if, after conducting an appropriate hearing, it finds that PSL 66-P impedes the provision of safe, adequate, and affordable electric service.  Today’s announcement is the first PSC response to numerous calls to address this requirement.

Announcement

The following is the text of the announcement requesting comments:

The Public Service Commission (Commission) is considering a petition, filed on January 6, 2026 (the Petition), by the Coalition for Safe and Reliable Energy (Coalition) requesting that the Commission hold a hearing, pursuant to Section 66-p of the Public Service Law, 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 (Climate Act).

The Coalition, which describes itself as a group consisting generally of associations, chambers of commerce, and other groups representing various businesses, industries, manufacturers, and constituencies from across the state, as well as two members of the state’s Climate Action Council, affirmatively contends that the Renewable Energy Program and its associated renewable energy targets may impede the provision of safe and adequate electric service. In support of its request for such a review by the Commission, the Coalition points to information that it claims suggests that the State will not achieve the Climate Act targets that, by 2030, 70% of statewide electricity generation be from renewable energy systems, and that, by 2040, the electric grid be zero emissions. The Coalition also suggests the existence of decreasing reliability margins and aging fossil-fueled generation resources, referencing statements by the New York Independent System Operator, Inc.

PLEASE TAKE NOTICE that interested stakeholders are invited to submit comments by March 30, 2026, on the Petition filed by the Coalition.

Comments provided in response to this Notice should reference “Case 15-E-0302.” Comments should be submitted electronically by going to http://www.dps.ny.gov, clicking on “File Search” (located under the heading “Commission Files”), entering “15-E-0302” in the “Search by Case Number” field, and then clicking on the “Post Comments” box located at the top of the page. Those unable to file electronically may mail their comments to the Hon. Michelle L. Phillips, Secretary, New York State Public Service Commission, Three Empire Plaza, Albany, New York 12223-1350; however, electronic filing of comments is strongly encouraged.

Basis for the Hearing Summary

New York Public Service Law § 66-p Section (4). “Establishment of a renewable energy program” includes safety valve conditions for affordability and reliability.   Section 66-p (4) states:

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. 

My recent post summarized multiple independent analyses, audits, litigation findings, and party filings in DPS proceedings that document that the Climate Act transition will exacerbate energy affordability issues such that this PSL 66-P hearing is appropriate.  I also used Perplexity AI to generate a chronology of the recommendations made to hold a hearing that provides an overview of the suggestions for the hearing.

The chronology described three independent pathways to trigger PSL66-p(4) anyone of which  can justify a hearing:

Pathway 1: Reliability – “Program Impedes Safe and Adequate Electric Service”

Evidence Standard: The Commission must find that the Renewable Energy Program “impedes” (not merely “risks” or “threatens”) the provision of safe and adequate service.

Evidence Presented:

  • NYISO 2024 RNA identifies actionable reliability need in NYC beginning 2033 (17-97 MW deficiency)
  • Statewide resource adequacy approaching limits with “no surplus power” remaining by 2034 without further development
  • Net capacity loss of 2,000 MW since Climate Act passage (retirements outpacing additions)
  • NYISO official statement that emission-free technologies to replace fossil generation “are not yet available on a commercial scale”
  • NERC highest-level alert documenting systemic deficiencies in modeling Inverter Based Resources and >15,000 MW of unexpected generation reductions in major events
  • Multiple NYISO high-risk scenarios showing NYC deficiency could begin as early as 2025 and grow to >1,000 MW by 2034

Assessment: The reliability evidence is substantial and comes from authoritative technical sources (NYISO, NERC). The case for a hearing under the reliability criterion is strong.

Pathway 2: Contractual – “Program Likely to Impair Existing Obligations”

Evidence Standard: The Commission must find the program is “likely” to impair existing obligations and agreements.

Evidence Presented:

  • Repowering disincentive: Current Climate Act targets effectively discourage repowering existing facilities because developers face 2040 forced retirement risk, “undermining investment recovery”
  • Offshore wind contract renegotiations: Multiple offshore wind developers have sought contract amendments due to changed economic conditions
  • Tier 1 REC contract attrition: Biennial Review acknowledged 30% attrition rate in renewable energy contracts

Assessment: The evidence on contractual impairment is moderate. This criterion appears to be less central to the petitioners’ arguments than reliability and affordability.

Pathway 3: Affordability – “Significant Increase in Arrears or Disconnections”

Evidence Standard: The Commission must find (1) a “significant” increase in arrears or service disconnections and (2) determine the increase is “related to the program.”

Evidence Presented:

  • Statistical significance established: Independent Intervenors demonstrated increases exceeding 2× standard deviation for statewide totals and 4 of 10 utilities
  • Magnitude: $1.8 billion in arrears affecting 1.2 million households
  • Trend: NMPC 17% increase (33,840 customers), Con Ed 59% increase (173,398 customers)

The Perplexity AI summary also lists two examples of evidence that does not support the claim that need to be explained.  For the “Causation not established”  description the AI program referenced an article written before the latest  DPS annual informational report came out that said it was impossible to determine if increases are “related to the program”.  A more recent report is now available, but DPS staff did not try to link the observed increases to this PSL 66-P requirement so it still is impossible to attribute significant changes to the Climate Act.  The other example gave an alternative explanation for the number of customers in arrears: “Post-pandemic economic impacts, inflation, and energy price increases due to factors beyond Climate Act (e.g., natural gas price volatility, supply chain disruptions)”

The Perplexity AI Assessment description stated:

The affordability evidence meets the first criterion (statistical significance) but cannot satisfy the second criterion (program causation) until DPS provides the mandated cost reporting. This represents a data gap, not necessarily a failure of the substantive argument. A hearing could establish causation through discovery and testimony.

The conclusion in this section notes that the reliability pathway has the strongest evidentiary weight:

Among the three pathways, the reliability criterion presents the most compelling case for a hearing:

  • Evidence comes from independent technical authorities (NYISO, NERC) with statutory responsibility for reliability
  • Deficiencies are quantified with specific MW shortfalls and timeframes
  • High-risk scenarios demonstrate sensitivity to plausible uncertainties
  • NYISO’s statement that required technologies “are not yet available on a commercial scale” directly supports finding that the program “impedes” safe and adequate service
  • Net capacity loss since Climate Act passage (2,000 MW) demonstrates actual, not theoretical, impact

The affordability criterion faces an evidentiary gap on program causation, though the statistical significance of arrears increases is well-established. Importantly, this gap exists because the PSC/DPS have failed to comply with their own reporting mandates—the very accountability failure the petitioners criticize. 

Discussion

In this discussion I liberally paraphrased the Perplexity AI response. Ultimately, the Legislature included Section 66-p(4) precisely to address the situation New York now faces: implementation challenges that threaten reliability and affordability emerging as the aggressive timelines and technology requirements of the Climate Act confront real-world supply chain, permitting, interconnection, and technological readiness constraints. 

In response to the petitions ACE-NY and WEACT filed a response that urged the PSC to reject the petition suggesting that all progress would stop if the heating was held.  However, the provision for a hearing does not require abandoning climate goals—it authorizes temporary suspension or modification to ensure safe, adequate, and affordable service while the transition continues. This represents pragmatic management, not capitulation.

I have long warned of the consequences if the current aspirational ambition and schedule of the Climate Act is not changed.  The PSC’s decision extends beyond energy policy:

  • If reliability suffers, the result could be rolling blackouts, industrial curtailments, and catastrophic economic disruption
  • If affordability spirals, the political backlash could undermine not just Climate Act but climate policy more broadly
  • If the safety valve remains unused, the precedent may discourage future legislatures from including adaptive management mechanisms in ambitious policy frameworks

Conclusion

Clearly it is no longer possible for the Hochul Administration to ignore the adverse impacts of Climate Act Implementation.  I have long argued that PSL 66-P was a logical excuse to reconsider the ramifications of the Climate Act so I should be happy that the potential of this requirement has been recognized at last.

However, this response is more evidence that the Climate Act has always been more about political catering to constituencies than about saving the planet. The evidence of the need for a hearing is overwhelming so I believe that the PSC should have moved to hold the hearing at this time.  That would infuriate the proponents of the Climate Act that Hochul needs for her re-election campaign.  This request for comments pushes the hearing and any decision related to the hearing beyond the election next November.  The question is whether New Yorkers will catch on that the Hochul Administration is risking reliability and affordability in an effort to appease Climate Act proponents.

Stay tuned because there I will undoubtedly be writing about this more before the comments are due,

New York Climate Act Affordability Status

In my opinion the biggest problem with the Climate Leadership & Community Protection Act (Climate Act or CLCPA) is that it will inevitably lead to extraordinary cost increases.  My last article described the recent rate case decisions that have markedly increased residential customer electric bills. These rate increases arrive amid an escalating affordability crisis, as of December 2024, over 1.3 million households are behind on their energy bills by sixty-days-or-more, collectively owing more than $1.8 billion.  This article documents unresolved affordability issues associated with the Climate Act.

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

Background

There is a fundamental Climate Act implementation issue.  Clearly there are bounds on what New York State ratepayers can afford and there are limits related to reliability risks for a system reliant on weather-dependent resources.  The problem is that there are no criteria for acceptable affordability bounds.

Proponents of the Climate Act argue that the transition strategies in the law must be implemented to meet the net-zero mandates.  However, they do not acknowledge that Public Service Law (PSL) Section 66-P, Establishment of a Renewable Energy Program, is also a law. PSL 66-P requires the Commission to establish a program to ensure the State meets the 2030 and 2040 Climate Act obligations.  It includes provisions stating that the PSC is empowered to temporarily suspend or modify these obligations if, after conducting an appropriate hearing, it finds that PSL 66-P impedes the provision of safe, adequate, and affordable electric service.  This requirement has been noted but, unfortunately, establishing a methodology to resolve the mandate has been ignored.

Petitions for a Hearing

The first unresolved affordability issue is the petitions by the Coalition for Safe and Reliable Energy and the Independent Intervenors submitted to PSC Proceeding Case 22-M-0149 that called for a hearing.  There has been no indication by the PSC that they will respond to those petitions.

The recent filings argued that the PSC should convene a hearing. On August 11, 2025 “Independent Intervenors” Roger Caiazza, Richard Ellenbogen, Constatine Kontogiannis, and Francis Menton petitioned  the  PSC arguing that safety valve provisions for customers in arrears trends in PSL  66-p(4) have been exceeded  which should trigger a hearing.  On January 6, 2026 the Coalition for Safe and Reliable Energy filed a petition with the Public Service Commission (PSC) requesting that the Commission act expeditiously to hold a hearing pursuant to Public Service Law § 66-p (4).  Both filings make similar arguments.  The Independent Intervenors argued that there was an explicit requirement for the hearing because the customers in arrears threshold has been exceeded.  The Coalition makes a persuasive argument that there are sufficient observed threats to reliability that a hearing is necessary to ensure safe and adequate service.

In addition, last summer two members of the Climate Action Council, Donna DeCarolis and Dennis Elsenbeck, sent a letter to Rory Christian, Chair & Chief Executive Officer of the New Yok State Public Service Commission (PSC) that made a similar argument that there are more than sufficient circumstances to warrant the PSC commencing a hearing process to “consider modification and extension of New York Renewable Energy Program timelines pursuant to Public Service Law § 66-p (4).

Agency Affordability Findings

There also have been New York Agency findings that argue that observed issues with schedule and costs suggest a pause to reconsider the mandates is appropriate.

The Draft Clean Energy Standard Biennial Review prepared by Department of Public Service (DPS) Staff and NYSERDA  “details the numerous factors, including inflation, transmission constraints, shifting federal energy and trade policies and interconnection and siting challenges that have adversely impacted renewable development and the state’s trajectory towards achieving the Program’s 2030 target.”  The Biennial Review “concludes that a delay in achieving the 70% goal may be unavoidable.”

The recently completed New York State Energy Plan (SEP) found that “current renewable deployment trajectories are insufficient to meet statutory targets, and that external constraints continue to impede progress.”  Volume 2 “Our Energy Systems” explains that “Considering resource build limitations and increased loads, the model aligns with the CES Biennial Review, projecting the procurement schedule of CES resources through 2035.”  In other words, the SEP acknowledges that the Climate Act schedule is impossible to meet.  The SEP found that Climate Act costs are expected to require $120 billion in annual energy system investments through 2040, equivalent to $1,282 per month per household. This baseline includes what the authors of the SEP characterizes as costs “no matter which future path we take” but I believe that framing is fundamentally deceptive because that scenario includes substantial greenhouse gas reduction programs implemented before 2019 that are necessary to meet the Climate Act goals.

The July 2024 New York State Comptroller Status report “Climate Act Goals – Planning, Procurements, and Progress Tracking” audited PSC and NYSERDA efforts to achieve the Climate Act mandates.  It found that “While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and CES, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs.”  The report recommended that the agencies begin the comprehensive review of the Climate Act, “continuously analyze” existing and emerging risks and known issues, conduct a detailed analysis of cost estimates, and “assess the extent to with ratepayers can reasonably assume the responsibility” of the implementation costs.  This is the information necessary for the PSL 66-P hearing.

My last article summarized recent residential electric utility customers rate case decisions approved between March 2025 and January 2026.  The New York Public Service Commission (PSC) “approved new multi-year rate plans for five major utilities—Con Edison, National Grid, Central Hudson, and Orange & Rockland—while two additional utilities (New York State Electric & Gas (NYSEG) and Rochester Gas & Electric (RG&E) have pending rate cases seeking significantly larger increases”.

Kris Martin from NY Solar Divide pointed out:

When we look at those modest Climate Act (CLCPA) percentages on “typical” electric bills, it’s important to understand that we have incurred only a small fraction of Climate Act expenses to date. The bulk of those expenses will really start to impact us in another 5-10 years as we start to seriously build out onshore and offshore wind and grid-scale solar, implement policy changes (e.g., school bus electrification), and deal with increases in demand.

Department of Public Service (DPS) staff is supposed to provide Climate Act information. On September 18, 2025 the PSC announced that they “received an update from DPS staff regarding progress toward the clean energy goals of the Climate Act”.  The Second Informational Report prepared by Department of Public Service (DPS) staff “focuses on Commission actions from January 2023 through August 2025, and includes the estimated costs and outcomes from 2023 through 2029 to provide the most up to date information.”  According to the Summary of Ratepayer Impact for Electric Utilities table, residential impacts of the Climate Act range from 4.6% to 10.3% of 2023 total monthly electric bills.  In my opinion, those estimates are conservative because there is immense pressure on agency staff to minimize the costs of the Climate Act.  In addition, the costs necessary to implement the Climate Act were ramping up in 2023.  As Martin notes these costs are just the tip of the iceberg.

Affordability Metrics

PSL law Section 66-p (4) states that the hearing could “temporarily suspend or modify the obligations” of the Renewable Energy Program if the PSC makes a finding that “there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.   This refers to affordability limits, but they are not specific enough.  I believe the PSC must establish specific affordability limits.

This issue was also raised to the DPS last year.  On March 26, 2025, Jessica Waldorf, Chief of Staff and Director of Policy Implementation for the Department of Public Service (DPS) posted a letter responding to a letter from Michael B. Mager Counsel to Multiple Intervenors that had been submitted earlier in March to Chair of the Public Service Commission Rory Christian regarding the affordability standard.       I agreed with the comments submitted by Multiple Intevenors and was disappointed with the DPS response so I submitted a letter to Christian.

As described in my article My Comments on the NYS Affordability Standard: I believe that as part of the Scoping Plan the Climate Action Council should have developed criteria for the PSC to consider affordability and reliability.  That did not happen.  Based on issues observed with the transition it is incumbent upon the Commission to define “safe and adequate electric service” and “significant increase in arrears or service disconnections” as part of this Proceeding.  My letter stated that this is necessary so that there is a clearly defined standard for the temporarily suspending or modifying the provisions of Section 66-p (4).

The Public Service Commission has an existing target energy burden set at or below 6 percent of household income for all low-income households in New York State.  Reviewing it raises questions about its suitability for defining energy affordability acceptability.

The six percent target was included as part of Public Service Commission (PSC) Case Number: 14-M-0565, the Proceeding on Motion of the Commission to Examine Programs to Address Energy Affordability for Low Income Utility Customers.  According to the PSC: “The primary purposes of the proceeding are to standardize utility low-income programs to reflect best practices where appropriate, streamline the regulatory process, and ensure consistency with the Commission’s statutory and policy objectives.”  On May 20, 2016 the Order Adopting Low Income Program Modifications and Directing Utility Findings adopted “a policy that an energy burden at or below 6% of household income shall be the target level for all 2.3 million low income households in New York.” 

The order notes that:

There is no universal measure of energy affordability; however, a widely accepted principle is that total shelter costs should not exceed 30% of income. For example, this percentage is often used by lenders to determine affordability of mortgage payments. It is further reasonable to expect that utility costs should not exceed 20% of shelter costs, leading to the conclusion that an affordable energy burden should be at or below 6% of household income (20% x 30% = 6%). A 6% energy burden is the target energy burden used for affordability programs in several states (e.g., New Jersey and Ohio), and thus appears to be reasonable. It also corresponds to what U.S. Energy Information Administration data reflects is the upper end of middle- and upper-income customer household energy burdens (generally in the range of 1 to 5%). The Commission therefore adopts a policy that an energy burden at or below 6% of household income shall be the target level for all low-income customers.  The policy applies to customers who heat with electricity or natural gas. 

The utility companies submit quarterly reports documenting the number of low-income customers receiving discounts and the amount of money distributed.  However, I have been unable to find any documentation describing how many customers meet the 6% energy burden criteria, much less any information on how those numbers are changing.  The biggest problem with this energy burden program is that it only applies to electric and gas utility customers.  Citizens who heat with fuel oil, propane, or wood are not covered.  Moreover, it only considers utility costs but the economy-wide provisions of the CLCPA include transportation energy burdens.

Clearly, if this parameter is to be used for a CLCPA affordability standard, then defining what is acceptable and what is not acceptable is necessary.  Whatever affordability standard is chosen a clear reporting metric must be provided and frequent updates of the status of the implementation relative to the affordability standard provided.

It is also notable that Assistant Attorney General Meredith G. Lee-Clark submitted correspondence related to the litigation associated with Climate Act implementation.  The State’s submittal  to the petition addressed “two categories of new developments: (1) the publication of the 2025 Draft New York State Energy Plan by the New York State Energy Planning Board on July 23, 2025 and (2) additional actions by the federal government that impede New York’s efforts to achieve the Climate Leadership and Community Protection Act’s (the Climate Act) goals in a timely manner.” 

The submittal means that the State of New York argued that it was inappropriate to implement regulations that would ensure compliance with the 2030 40% reduction in GHG emissions Climate Act mandate because meeting the target is “currently infeasible”.  The following paragraph concedes that there are significant upfront cost issues that out-weigh other benefits.

Ordering achievement of the 2030 target would equate to even higher costs than the net zero scenarios and would affect consumers even sooner. Undoubtedly, greenhouse-gas reducing policies can lead to longer-term benefits such as health improvements. This does not, however, offset the insurmountable upfront costs that New Yorkers would face if DEC were forced to try to achieve the Legislature’s aspirational emissions reductions by the 2030 deadline rather than proceeding at an ambitious but sustainable pace.

The letter concluded that the Climate Act is unaffordable:

Petitioners have not shown a plausible scenario where the 2030 greenhouse gas reduction goal can be achieved without inflicting unanticipated and undue harm on New York consumers, and the concrete analysis in the 2025 Draft Energy Plan dispels any uncertainty on the topic: New Yorkers will face alarming financial consequences if speed is given preference over sustainability.

Conclusion

It is impossible to ignore that multiple independent analyses, audits, litigation findings, and party filings in DPS proceedings document that the Climate Act transition will exacerbate energy affordability issues at a time when more than a million New York households are already in arrears on their energy bill.  Unfortunately, the Hochul Administration and Legislature have not adopted clear affordability metrics, a transparent tracking system, or mandatory corrective actions when affordability thresholds are exceeded.  Of course, these are bright line accountability metrics, and no political supporter of the Climate Act wants to admit their role in the New York affordability crisis.

New York Recent Rate Case Impacts on Residential Customers

In my opinion the biggest problem with the Climate Leadership & Community Protection Act (Climate Act) is that it will inevitably lead to extraordinary cost increases.  This post summarizes recent residential electric utility customers rate case decisions approved between March 2025 and January 2026. I do not discuss gas rate cases.  The New York Public Service Commission (PSC) “approved new multi-year rate plans for five major utilities—Con Edison, National Grid, Central Hudson, and Orange & Rockland—while two additional utilities (New York State Electric & Gas (NYSEG) and Rochester Gas & Electric (RG&E) have pending rate cases seeking significantly larger increases”. These rate increases arrive amid an escalating affordability crisis, as of December 2024, over 1.3 million households are behind on their energy bills by sixty-days-or-more, collectively owing more than $1.8 billion.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) 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. 

Background

There is a fundamental Climate Act implementation issue.  Clearly there are bounds on what New York State ratepayers can afford and there are limits related to reliability risks for a system reliant on weather-dependent resources.  The problem is that there are no criteria for acceptable affordability bounds.

Trying to decipher rate case decisions is a difficult task because of the volume of materials associated with each rate case. The PSC maintains a database that compiles all the filed documents and public comments for each rate case.  The Matter Master file for the current NYSEG rate case lists 913 filed documents and 1967 public comments.  To compile this summary, I acknowledge the use of Perplexity AI to generate summaries and references included in this document.  Assume all the results shown are referenced to the original Perplexity response.

Rate Case Results

Figure 1 summarizes the recent rates cases for Con Edison, National Grid, Central Hudson, and Orange & Rockland that have been completed since 2025.  NYSEG and RG&E have pending rate cases, so their results shown are not directly comparable.

Figure 1: New York Utility Rate Cases Impact on Residential Customer (2025-2026) – Perplexity

The NYSEG and RG&E cases are pending and the results shown represent their initial offer.  All the results shown for the other utilities had much higher initial rates. For example, Con Edison initially requested annual revenue increases of $1.612 billion for electric service (18.0 percent increase in base delivery revenues) and $440 million for gas service (18.8 percent increase in base delivery revenues). Following intense public opposition, intervention by Governor Kathy Hochul, and even comments by President Trump, and extensive settlement negotiations, the PSC approved a dramatically reduced three-year rate plan on January 22, 2026.   The approved joint proposal represents an 87 percent reduction from Con Edison’s initial request.

Utility Summaries

Con Edison’s service territory covers New York City and Westchester County with 3.6 million residential customers.  For typical NYC residential customers using 280 kilowatt-hours monthly, electric bills will increase by approximately $4 per month (3.9 percent) in 2026, $3.55 per month in 2027, and $4.22 per month in 2028, resulting in a cumulative 10.4 percent increase over three years. Westchester County residential customers using 425 kWh monthly face increases of $5.25 (2.6 percent) in year one, $4.84 (2.3 percent) in year two, and $4.95 (2.2 percent) in year three, totaling 10.1 percent over the period

National Grid’s rate case was approved on August 13, 2025.  The service territory covers 1.7 million electric customers across 25,000 square miles in Upstate New York. For residential electric customers using an average of 625 kilowatt-hours per month National Grid’s three-year upstate rate plan includes a $14.32 per month increase in year 1, a $6.44 per month increase in year 2, and a $4.34 per month increase in year 3 with an expected total increase over three years of 31%.

Central Hudson 315,000 residential customers in its Hudson Valley and Mid-Hudson region service territory.  Central Hudson’s rate case followed a unique trajectory, proceeding through litigation rather than settlement, ultimately resulting in a one-year rate plan approved on July 18, 2024, followed by a subsequent multi-year joint proposal filed on May 13, 2025, and approved on August 14, 2025.  Typical residential electric customers will experience total bill increases of approximately 7.85 percent, equating to approximately $12.65 per month.

Orange & Rockland serves 233,000 residential electric customers in Rockland, Orange, and Sullivan counties.  On March 19, 2025, the PSC adopted a three-year rate plan for Orange & Rockland that substantially reduced the utility’s initial request, keeping electric revenue flat for the first year while authorizing incremental increases in subsequent years. For residential electric customers using 600 kilowatt-hours per month the 2025 total bill increase will be 4.6 percent, in 2026 the total bill increase will be 3.3 percent and in 2027 the total bill increase will be 3.5 percent total bill increase.

New York State Electric & Gas (NYSEG) and Rochester Gas & Electric (RG&E) filed rate case proposals on

June 30, 2025.  The case is currently under review.  I am an active party in the rate cases and am unsure what I can say about the status.  I don’t think it is inappropriate to note that an evidential hearing is scheduled for early February.  The service territories of the two utilities are all over the state but is primarily located in Central and Western New York.  NYSEG serves 921,000 customers and RG&E serves 392,00 customers. The initial NYSEG electric request asked for an amount that works out for a typical residential customers (600 kWh electric usage) to a $33.12 per month increase (23.7 percent increase to total bill).  The initial RG&E electric request asked for an amount that works to a $33.01 per month increase (26.0 percent increase to total bill).

 Climate Act Impacts

It is unfortunate that the utilities fail to provide a breakdown of how much implementation of the Climate Act adds to these rate case costs.  I used a Perplexity AI search of the National Grid rate case to provide Climate Act cost estimates.   It found that the approved rate plans do not contain explicit breakdowns of specific dollar amounts or percentages of the rate increases allocated specifically to the Climate Act projectsand state mandated programs. The query response included the following:

CLCPA-Related Investments Identified

While specific cost breakdowns are not provided, the orders identify several CLCPA-related investment categories within the approved rate plans:

Electric System CLCPA Investments

Transmission Infrastructure:

  • CLCPA Phase 2 Transmission Projects
  • Smart Path Connect
  • Grid Modernization

Distribution System Enhancements:

  • Enhanced grid capabilities for solar, wind, and energy storage interconnection
  • Smart grid technologies to manage intermittent renewable resources
  • Electric vehicle infrastructure support programs

Historical CLCPA Investment Context

Previous utility filings and planning documents provide context for CLCPA-related costs across New York utilities:

Statewide CLCPA Transmission Investments:

  • Phase 1 Projects: Approximately $4.16 billion in transmission investments and $2.64 billion in distribution investments across all New York utilities
  • Phase 2 Conceptual Estimates: $7.62 billion in transmission and $2.16-$2.85 billion in distribution investments (conceptual estimates)

National Grid’s Historical CLCPA Share:

  • Phase 2 Transmission: $1.37 billion estimated for National Grid transmission projects
  • Phase 2 Distribution: $510 million to $1.2 billion estimated for National Grid distribution projects

Department of Public Service (DPS) staff is supposed to provide Climate Act information. On September 18, 2025 the PSC announced that they “received an update from DPS staff regarding progress toward the clean energy goals of the Climate Act”.  The Second Informational Report prepared by Department of Public Service (DPS) staff “focuses on Commission actions from January 2023 through August 2025, and includes the estimated costs and outcomes from 2023 through 2029 to provide the most up to date information.”  According to the Summary of Ratepayer Impact for Electric Utilities table, residential impacts of the Climate Act range from 4.6% to 10.3% of 2023 total monthly electric bills.  In my opinion, those estimates are conservative because there is immense pressure on agency staff to minimize the costs of the Climate Act.  In addition, the costs necessary to implement the Climate Act were ramping up in 2023.  I expect that these costs will continue to climb.

Discussion

The Perplexity summary of the rate cases raised some overarching issues.  New York residential utility bills consist of two primary components, each subject to different pricing mechanisms and contributing to overall cost increases through distinct channels.

Delivery Charges account for approximately two-thirds of bills. These charges represent what customers pay utilities to build, maintain, and operate the physical infrastructure that transmits electricity and natural gas to homes and businesses. Delivery charges remained relatively stable historically but have increased substantially in recent years to fund:

  • Infrastructure Modernization and Replacement: Utilities must replace aging equipment that has reached the end of its useful life, including transformers, substations, transmission lines, and distribution networks.
  • Grid Hardening and Storm Resiliency: Utilities must enhance system resiliency to manage severe weather events. This includes vegetation management, reinforced poles and wires, and backup systems.
  • Clean Energy Integration Infrastructure: The Climate Act mandates necessitate substantial transmission and distribution system upgrades to connect renewable energy resources, accommodate distributed generation, manage bi-directional power flows, and handle increased electrification of transportation and heating.
  • Property Taxes: Utility companies pay significant property taxes on their infrastructure, which are passed through to customers. Note that the clean energy infrastructure increases the property tax burden.
  • Return on Equity (Profit Margin): Regulated utilities earn a PSC-approved rate of return on their capital investments. Approved returns on equity in recent cases range from 9.4 percent (Con Edison) to 9.5 percent (National Grid).

Supply Charges  account for approximately one-third of bills.  They represent the actual cost of purchasing electricity or natural gas in wholesale markets. These charges fluctuate based on market conditions and are typically adjusted monthly. These have increased for the following reasons:

  • Explosive Demand Growth: New York and the broader Northeast region are experiencing unprecedented electricity demand growth driven by several factors that are fundamentally reshaping the supply-demand balance. The New York Independent System Operator (NYISO) reports that the pace of new energy sources coming online is insufficient to keep pace with demand growth.
  • Wholesale electricity prices have responded predictably to this supply-demand imbalance. The average monthly wholesale electricity price in New York soared by 67 percent over the past year according to NYISO data.
  • Thermal Generation Fuel Costs: Natural gas remains the marginal fuel setting electricity prices in New York’s wholesale markets during most hours. Natural gas commodity prices have increased due to growing domestic demand (particularly for heating during cold winters), export demand for liquefied natural gas, and supply constraints.
  • Weather-Driven Consumption: The 2025-26 winter has proven particularly severe, with temperatures 15-20 percent colder than the prior year. Colder weather increases heating demand, driving up both consumption (measured usage) and market prices due to heightened competition for available supply.

Conclusion

These rate case results are unsustainable.  For all the noise made by politicians about affordability, the fact remains that the New York State Legislature or Administration has not defined affordable energy.  The Public Service Commission has an existing target energy burden set at or below 6 percent of household income for all low-income households in New York State.  I have been unable to find any documentation describing how many customers meet the 6% energy burden criteria, much less any information on how those numbers are changing.  The biggest problem with this energy burden program is that it only applies to electric and gas utility customers.  Citizens who heat with fuel oil, propane, or wood are not covered.  There is a clear need for an affordability metric that can be tracked.

Investments for New York’s Future

According to a new report from Environmental Defense Fund (EDF) and Greenline Insights, New Yorkers will “realize significant economic benefits, including household savings and new job creation, with the Clean Air Initiative.”  This article explains why this report is bogus on multiple levels.

I have extensive experience with market-based pollution control programs.  I have been involved in the Regional Greenhouse Gas Initiative (RGGI) program process since its inception and have no such restrictions when writing about the details of the RGGI program.  I have worked on every cap-and-trade program affecting electric generating facilities in New York including RGGI, the Acid Rain Program, and several Nitrogen Oxide programs. I have also been following the New York Cap-and-Invest (NYCI) program and other similar programs in New York   The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated

Clean Air Initiative

My first thought when I read this was what is the Clean Air Initiative?   The report states: “state agencies have developed proposals for an economy-wide cap-and-invest program – known as the Clean Air Initiative (CAI).”  I have been following the economy-wide cap-and-invest program and I was unaware of any agency calling the economy-wide program anything other than the New York Cap-and-Invest (NYCI) program.  So, I used Perplexity AI to ask if any New York agencies used CAI instead of NYCI.    The response stated:

No New York State agency officially refers to the cap-and-invest program as the “Clean Air Initiative.” Throughout all Department of Environmental Conservation (DEC) and New York State Energy Research and Development Authority (NYSERDA) official documentation, press releases, regulatory proposals, and public communications from 2023 through early 2026, the program is consistently designated as:

  • New York Cap-and-Invest (NYCI) – the primary official name
  • Cap-and-Invest Program – the standard reference

I believe the answer to why these organizations use this nomenclature is directly related to the mission of the organizations. Greenline Insights “provides non-partisan research to drive smart decision-making. We specialize in modeling, analysis, and policy design to maximize positive outcomes for local workforces, businesses, and communities.” Their description of services provided states: “We work with clients to develop compelling research questions and build the right mix of tools to answer them.”  Reading between that line I think it means that if a client wants a particular answer, they will get that result.

EDF claims “Guided by science and economics, and committed to climate justice, we work in the places, on the projects and with the people that can make the biggest difference.”  According to another Perplexity AI query EDF has “strongly supported the economy-wide cap and invest program proposal included in the Climate Leadership and Community Protection Act (CLCPA) Scoping Plan” finalized in 2022 and since then “has engaged in extensive and sustained lobbying and advocacy efforts to advance New York’s economy-wide cap-and-invest program since early 2023.”  EDF has a vested interest in the success of an economy-wide program.

The Perplexity AI “Deep Research” response to my query about the use of CAI the AI program concluded “The Environmental Defense Fund and allied advocacy organizations strategically adopted “Clean Air Initiative” as alternative branding to frame the program around air quality and public health benefits in their campaigns to pressure Governor Hochul to finalize and implement the regulations.”

In other words, the Clean Air Initiative terminology  is all about the messaging.

Clean Air Initiative Claims

The January 8, 2026 CAI  report announcement states:

NEW YORK — New Yorkers will realize significant economic benefits, including household savings and new job creation, with the Clean Air Initiative, a new report from Environmental Defense Fund and Greenline Insights finds.  

The report comes as New Yorkers continue to await the launch of the Clean Air Initiative: an economywide cap-and-invest program that works by simultaneously putting a limit on the tons of pollution companies can emit — “cap” — while requiring them pay for each ton of emissions, funding clean energy projects that create health and cost-saving benefits for communities — “invest.” At the same time, energy affordability remains an issue that’s top of mind for New York voters.  

“Our analysis shows that the vast majority of New Yorkers are missing out on savings and economic opportunities across the state due to delays in implementing the Clean Air Initiative,” said Kate Courtin, Senior Manager for State Climate Policy & Strategy. “The sooner this program is implemented, the sooner communities will see billions in investments that will expand access to cleaner, cheaper energy, cut pollution and create healthier, more resilient communities.” 

The report finds that, over its first decade, the Clean Air Initiative would deliver: 

$6.9 billion in net savings, or an average of $1,060 per household earning $200k per year or less — about 85% of households in the state.  

Over 300,000 new jobs, with job growth strongest in fields like construction and transit as a result of investments in clean transportation services, decarbonization of buildings, and the build-out of clean energy infrastructure.

$48 billion in economic growth supported by program investments across the state. 

“The data is clear that the Clean Air Initiative is a potent job creator and economic development tool.” said Jonah Kurman-Faber, Founder and Principal at Greenline Insights. “The program’s investments play to the state’s economic strengths and provide meaningful financial benefits to an overwhelming majority of the population.” 

Pollution Control

EDF claims without any evidence that setting a cap ensures compliance with the arbitrary limits of the Climate Leadership & Community Protection Act (Climate Act).  The report claims that the “economywide cap-and-invest program works by simultaneously putting a limit on the tons of pollution companies can emit — “cap” — while requiring them pay for each ton of emissions, funding clean energy projects that create health and cost-saving benefits for communities — “invest.”  That is the theory.

I recently published several articles about RGGI, the existing New York cap-and-invest program for electric utility generating units that shows reality is different.  I showed that the reason NY utility emissions have dropped is because NY power plants switched from using coal and oil to using natural gas.  Natural gas emits less CO2 and was cheaper, so the observed reductions are mostly because of economic fuel switching not RGGI.  I compared the observed reductions and RGGI investment emission savings and found that the total cumulative annual emission savings represents a reduction of only 4.2% from the pre-RGGI baseline.  That comparison also found that the observed cost per ton of emissions removed is $583.  None of these results suggest that the CAI will work as claimed.

GHG emissions are directly related to energy generation.  When a GHG pollution control program caps emissions it caps energy use so capping emissions essentially rations energy use.   Combined with the RGGI results, that means that compliance with the cap can only occur if energy use is rationed

Economic Benefits

According to the announcement, Kate Courtin, Senior Manager for State Climate Policy & Strategy said that “The sooner this program is implemented, the sooner communities will see billions in investments that will expand access to cleaner, cheaper energy, cut pollution and create healthier, more resilient communities.”   I am not an economist so I submitted another Perplexity AI query asking about opportunity costs and the Greenline Insights analysis.  The summary notes:

The “Investments for New York’s Future” report by Environmental Defense Fund (EDF) and Greenline Insights, released in January 2026, projects that New York’s Clean Air Initiative (cap-and-invest program) would generate $6.9 billion in household savings, create over 300,000 jobs, and support $48 billion in economic growth over the program’s first decade (2026-2035). While the specific methodological details of this report remain inaccessible through the provided URL, extensive research into Greenline Insights’ comparable analyses, standard input-output (I-O) modeling practices, and economic impact assessment literature reveals fundamental concerns about the treatment—or more precisely, the omission—of opportunity costs in such economic analyses.

Even a non-economist like me understands that if an analysis does not consider how the money raised by NYCI might have been used elsewhere is not considered, then that is a problem: 

Opportunity cost represents “the value of the alternative foregone by choosing a particular activity”—the benefits that could have been realized if the same resources were deployed differently. In climate policy analysis, this concept is essential because government spending and regulatory mandates redirect capital, labor, and productive resources from alternative uses. A comprehensive economic evaluation must compare not just the projected benefits of a policy against its direct costs, but also assess what economic activity would have occurred absent the intervention—the counterfactual baseline.

The response to my query raised the following issues with the Greenline Insights methodology:

1. The “Missing Peter” Problem

As economists from the Beacon Hill Institute articulated in critiquing renewable energy economic impact studies: “They are robbing Peter [existing economic activities] to pay Paul [the supported sector], and claiming the program increased total spending because now Paul spends more, but they ignore accounting for Peter”.

​

Every dollar collected through allowance auctions or allocated to climate investments is a dollar unavailable for alternative economic uses—whether private consumption, business investment in other sectors, or different government priorities. Standard I-O models “cannot compute possible reductions in output and jobs elsewhere in the economy, due to the reallocation of resources towards the supported project”.

2. Assumption of Idle Resources

The typical economic impact study assumes “that the dollar that flows through the industries identified by model’s I-O tables, and the resources that they are commanding, would not otherwise be used”. This assumption may be defensible during severe recessions with high unemployment and underutilized productive capacity, but becomes increasingly problematic as economies approach full employment.

New York State added over 1 million private sector jobs since April 2020 and reached record employment levels as of September 2024. In this context, labor and capital redirected to clean energy investments necessarily displace activity in other sectors. One analysis noted explicitly: “IMPLAN cannot be used to model nonresidential sector opportunity costs, so those were not included”—a tacit acknowledgment of the methodology’s inherent limitation.

3. No Counterfactual Baseline

Rigorous policy evaluation requires comparing outcomes under the policy scenario against a well-specified counterfactual: what would have happened in the policy’s absence. This counterfactual must account for:

  • Alternative deployment of capital: If the $61-126 billion in projected cap-and-invest revenues were instead left with households and businesses, what consumption and investment would occur?
  • Baseline economic trajectories: What job growth, wage increases, and economic output would materialize under business-as-usual conditions?
  • Displaced economic activity: Which sectors contract as resources shift toward clean energy, and what are the productivity implications?

Standard I-O models do not construct this counterfactual. They measure gross economic activity associated with program spending but do not subtract the economic activity that would have occurred with alternative resource allocation.

4. The Economist’s Critique

The academic economics community has long criticized the misapplication of I-O analysis for policy advocacy. As one prominent critique states: “There’s a joke among economists who look at economic impact studies, and we say ‘Define all costs as benefits, and double them'”. This captures the tendency of such analyses to:

  • Present gross job creation without netting out job displacement
  • Calculate multiplier effects on program spending without comparable analysis of opportunity cost multipliers
  • Report total economic output without addressing whether this represents additional output or reallocated output

The response to my query concludes:

For policymakers and stakeholders evaluating the economic case for New York’s Clean Air Initiative, this means:

  • The reported economic benefits are overstated to the extent they represent reallocation of economic activity rather than net additions
  • The true net economic impact depends on the relative productivity of clean energy investments versus displaced alternatives—a comparison the analysis does not make
  • The strongest case for the policy rests on climate and health benefits, not the economic multiplier effects emphasized in the report’s communications
  • More rigorous analysis following a similar Resources for the Future approach or comprehensive cost-benefit frameworks would provide better-informed decision-making

Conclusion

This report is simply a lobbying presentation that was commissioned by EDF to support their arguments that NYCI is a good idea.  One common aspect of all these analyses is that the benefits are overstated, the costs are minimized if not ignored, and the methodology is sketchy.  I do not think that any of the job estimates and economic projections are credible.

New York Nuclear Renaissance

Governor Hochul plans to pursue “the most ambitious development of nuclear power in America, setting a new goal to build five gigawatts of new nuclear capacity”.  I believe that nuclear power is the best option to reduce electric system GHG emissions but there are issues.  This post includes Richard Ellenbogen’s description of practical deployment issues and my observations relative to the Climate Leadership & Community Protection Act (Climate Act).

Richard Ellenbogen has been speaking to NY State policy makers and regulators since 2019 regarding the deficiencies inherent in NY State Energy policy.  He has a proven record implementing carbon reduction programs at his own manufacturing business in Westchester County where it has reduced its electric utility load by 80% while reducing its carbon footprint by 30% – 40% below that of the downstate system.  I have previously published other articles by Ellenbogen including a summary description of his issues with the Climate Act.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources. 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.

Hochul Proposal

Hochul’s State of the State Book describes the nuclear proposal in the following two sections:

Establishing a Nuclear Reliability Backbone for a Zero-Emission Grid

As New York transitions to a zero-emission electric grid, the State must ensure reliable and cost effective baseload power to keep homes, businesses, and critical infrastructure running at all hours.  Governor Hochul will ensure that New York State leads in the race to harness safe and reliable advanced nuclear energy to power homes and businesses with zero-emission electricity for generations to come.

To catalyze progress towards those goals, the Governor will advance a new initiative, the Nuclear Reliability Backbone, directing state agencies to establish a clear pathway for additional advanced nuclear generation to support grid reliability. The Nuclear Reliability Backbone will be developed by a new Department of Public Service (DPS) process to consider, review, and facilitate a cost-effective pathway to four gigawatts of new nuclear energy that will combine with existing nuclear generation and the New York Power Authority’s (NYPA) previously announced one gigawatt project, to create an 8.4 gigawatt “backbone” of reliable energy for New Yorkers.

This effort will provide firm, clean power that complements renewable energy resources and reduces reliance on fossil fuel generation. By creating a stable foundation of always-on energy, the Backbone will allow renewable resources to operate more efficiently and flexibly. Together, these actions will support a resilient, flexible, and zero-emission grid that meets New York’s growing energy needs.

Ensuring New York’s Nuclear Power Future is Built By and For New Yorkers

As New York expands advanced nuclear energy, the State must ensure that New Yorkers benefit from these jobs and investments, including making sure New Yorkers are prepared to build, operate, and sustain this emerging industry. Governor Hochul will launch NextGen Nuclear New York to develop a skilled, in-state nuclear workforce through coordinated education and training pathways.

The initiative will expand partnerships across K–12 schools, higher education institutions, labor organizations, and training programs to align curricula, credentials, and career pathways with industry needs. It will also support workforce transitions for existing energy workers and increase public awareness of nuclear career opportunities. By investing in people and skills, New York will ensure its nuclear future is powered by New Yorkers, for New Yorkers.

Practical Deployment Issues – Ellenbogen

Ellenbogen recently sent an email that described his concerns about the proposal to add 5 Gigawatts (GW) of nuclear to NY State’s generation fleet that forms the basis for this article.  Because we are closely aligned on our thoughts I am not going to try to differentiate between his material and my supplemental information.  However, I take responsibility for the contents of this article and accept that I may have misquoted or misrepresented Ellenbogen’s beliefs.

For background consider New York’s nuclear power plants (Table 1).  Five gigawatts of nuclear is basically equivalent to building five new traditional reactors like Nine Mile 2, the last completed plant in New York. Note that Shoreham was completed, tested, and then shut down before it operated in the mid 1980’s.

Table 1: New York Nuclear Generating Plants

We agree on one thing completely: It’s a step in the right direction but it is too little, too late.  Building this amount of capacity will take a long time.  Nine Mile 2 construction took 13 years, and the most recent reactors built in the US at Vogtle, Georgia took 15 years from the start of initial site work.

According to a Perplexity AI query, The new Vogtle units are Westinghouse AP1000 designs with passive safety systems; The capacity of each unit is on the order of 1.1 GW.  Construction went over schedule and budget “as the first new U.S. nuclear build in decades, became a protracted megaproject with schedule slips and cost growth to roughly the mid‑$30‑billion range, widely characterized as one of the most expensive infrastructure projects in U.S. history”. These issues were caused by a “combination of incomplete design and planning, contractor and supply‑chain problems, first‑of‑a‑kind AP1000 implementation issues, weak project management and oversight, and the 2017 Westinghouse bankruptcy, which disrupted construction and financing”. 

Most of these underlying factors will be problems for New York State.  If new technology is used the design and planning will have to evolve as the plants are built.  There are contractor and supply-chain problems with existing infrastructure construction so this will be more of a problem for the new technology.  If the deployment goes so far as to mandate that the facilities are “built by and for New Yorkers”, then there will be delays because there are insufficient skilled trade workers available today.

Climate Act Schedule and Reliability Issues – Ellenbogen

The Climate Act has a requirement for zero emissions electric generation by 2040.  There is no possibility that all the nuclear capacity proposed by Hochul could be built by 2040 and there is a low probability that any new nuclear could be built by then.  Last June Hochul ordered the New York Power Authority (NYPA) to develop at least on gigawatt of nuclear capacity.  NYPA has not even announced where they might consider siting new nuclear capacity.  In my experience with power plant permitting, it takes at least three years to secure permits for existing design equipment.  There have been indications that New York would favor new designs which would slow down permitting substantially.  Finally, “Nuclear” has been a four-letter word in New York State for about 45 years so we expect opponents to try to delay permitting in every way possible.

Last November the New York Independent System Operator (NYISO) released its 2025-2034 Comprehensive Reliability Plan (CRP).  The report found that “the electric grid is at an inflection point driven by the convergence of three major trends: the rapid growth of large loads, (e.g.: microchip manufacturing and AI-related data centers); the aging generation fleet; and a lack of new dispatchable generation resources being added to the system.”   The description of the CRP went on to say:

The CRP highlights that the future reliability of the grid depends on the development of flexible generation capable of performing during extended periods of high consumer demand and extreme weather. The report examines lessons-learned from the June 2025 heatwave and the need for a planning framework that better reflects present challenges of operating the grid while anticipating plausible future risks.

“The system requires additional dispatchable generation to serve forecasted increases in consumer demand,” said Zach Smith, Senior Vice President, System and Resource Planning. “We also need to refine and evolve our planning processes to better reflect this period of great change on the grid and a broader range of plausible future outcomes.”

The CRP demonstrates that due to emerging reliability challenges, traditional planning methods built around a single forecast are no longer sufficient. To maintain system reliability and protect public safety, the economy and quality of life, the CRP recommends actions that will strengthen planning processes across a broad spectrum of system conditions and advance needed investment before reliability margins disappear.

Our biggest concern is the reliability margin crisis described in the CRP.  The NYISO plausible range of reliability margins illustrates the problem (Figure 1).  The CRP doesn’t explain what is going to keep the lights on after 2033, and possibly as early as 2027 if replacement capacity does not keep up with retirements.  My Perplexity AI search found that there are no new fossil-fired capacity proposed.  While adding new nuclear capacity is appropriate, replacement of existing capacity must also be considered.  The youngest of the 3.4 GW of existing nuclear in NY State will be reaching 60 years of age by 2040.

Figure 1: Plausible Range of Statewide System Margins NYISO 2025-2034 Comprehensive Reliability Plan     

Reason to Pause – Caiazza

Over the last year I have written many articles describing various reasons to pause implementation and reconsider the schedule and scope of the Climate Act.  The State Energy Plan and the CRP both include multiple future energy projections that include estimates of capacity and grid infrastructure additions.  The CRP “recommends actions that will strengthen planning processes across a broad spectrum of system conditions and advance needed investment”. The State Energy Plan advocates massive deployment of as much wind, solar, and energy storage capacity as possible as fast as possible hoping that it will work out.

Wind and solar energy resources are diffuse, intermittent, and correlated.  Because they are diffuse, utilizing wind and solar means that transmission and distribution systems must be upgraded.  Because they are intermittent, that means that energy storage is needed on daily to seasonal scales.  Because wind and solar are correlated, new dispatchable emissions-free resources (DEFR) are needed to make the electric energy system viable during extended periods of low wind and solar resource availability.  I believe the only likely viable DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready, can be expanded as needed, and does not suffer from limitations of the Second Law of Thermodynamics.

Every day that the resolving the DEFR requirement is delayed the costs associated with what may be a false solution increase.  If the only viable DEFR solution is nuclear, then the wind, solar, and energy storage approach cannot be implemented without nuclear power.  Nuclear power works best as a baseload resource so using it solely as DEFR backup is inappropriate.  Developing baseload nuclear eliminates the need for a huge DEFR backup resource and means that the “build as much as we can as fast as we can” wind and solar buildout currently in progress is unnecessary.  Climate Act implementation should be paused until the most appropriate path forward is determined.

Discussion

Both Ellenbogen and I have been harping about reliability for years.  Unfortunately, no one at the state level seems to be ready to confront the problem.  It is absolutely necessary to come to grips with it.  The state government keeps trying to defy physical law by pushing technologies that can’t keep the lights on.  They need to get out of their bubble because the time frame required to fix what has become a massive problem is getting increasingly small.  The rapidly decreasing margins and negative capacity margins appear likely before new generation of any type can be built.

One of the biggest takeaways from this latest political energy proposal is the danger of political interference in energy policy.  New York politicians now claim that we need 5 GW of nuclear generating capacity.  New York politicians shut down 3.1 GW of nuclear capacity since 1984.  Hochul’s announcement is encouraging but until it must be accompanied by a pause in Climate Act implementation to be credible.  If timely decarbonization using nuclear power is appropriate, then a restart at Indian Point should be considered because it is the cheapest and quickest option.  However, that would be politically toxic so I cannot imagine that ever being proposed by the Hochul Administration. 

Conclusion

In my opinion, nuclear power should be part of New York’s electric system future.  However, Hochul’s proposal is too little, too late as part of the Climate Act implementation without revising the schedule.  It is necessary first to pause implementation and reassess the schedule and ambition of the Act so that it can play a meaningful role.

Coalition for Safe and Reliable Energy Petition

On January 6, 2026 the Coalition for Safe and Reliable Energy filed a petition with the Public Service Commission (PSC) requesting that “the Commission act expeditiously to hold a hearing pursuant to Public Service Law § 66-p (4) to evaluate whether to temporarily suspend or modify the obligations under the Renewable Energy Program established as part of the Climate Leadership and Community Protection Act.”  Last August I described a filing and supporting documentation that I prepared with Richard Ellenbogen, Constatine Kontogiannis, and Francis Menton (Independent Intervenors) submitted to the same PSC Proceeding (Case 22-M-0149).  Our filing made a similar argument.  This article compares the filings.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) 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. 

Background

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

There is a fundamental Climate Act implementation issue.  Clearly there are bounds on what New York State ratepayers can afford and there are limits related to reliability risks for a system reliant on weather-dependent resources.  The problem is that there are no criteria for acceptable bounds and New York energy policy has not openly reassessed where we stand relative to acceptable affordability and reliability risk.

Coalition for Safe and Reliable Energy

According to their petition the Coalition for Safe and Reliable Energy (Coalition) is “a diverse coalition consisting generally of associations, chambers of commerce and other groups representing various businesses, industries, manufacturers and constituencies from across the state, as well as two members of the state’s Climate Action Council”. Clearly, they have a vested interest in affordability because it affects their competitiveness.  Coalition members include:

  • Buffalo Niagara Builders Association
  • Buffalo Niagara Manufacturing Alliance
  • Buffalo Niagara Partnership
  • Builders Exchange of the Southern Tier
  • Business Council of Westchester
  • Capitol Region Chamber of Commerce
  • Center for Economic Growth
  • Commercial Real Estate Development Association – Upstate Chapter
  • Construction Exchange of Buffalo and Western New York
  • Engineers Labor Employer Cooperative 825
  • Greater Binghamton Chamber of Commerce
  • Greater Rochester Association of REALTORS
  • Greater Rochester Chamber of Commerce
  • Manufacturers Alliance of New York
  • Manufacturers Association of Central New York
  • Manufacturers Association of the Southern Tier
  • Multiple Intervenors – An unincorporated association of approximately 55 large industrial, commercial, and institutional energy consumers with manufacturing and other facilities located throughout New York State
  • National Federation of Independent Businesses
  • New York State Association of Plumbing, Heating and Cooling Contractors
  • New York State Builders Association
  • New York State Economic Development Council
  • Niagara USA Chamber of Commerce
  • North Country Chamber of Commerce
  • Northeastern Retail Lumber Association
  • Northeast Hearth, Patio and Barbecue Association
  • Power for Economic Prosperity – An active coalition of manufacturing companies that depend on low-cost hydropower from the New York Power Authority in order to maintain their operations in the Buffalo/Niagara Region.
  • Rochester Technology and Manufacturing Association
  • The Business Council of New York State – The leading business organization in New York State, representing the interests of large and small firms throughout the state. Its membership is made up of approximately 3,500 member companies, local chambers of commerce and professional and trade associations.
  • The Council of Industry, Manufacturers Association of the Hudson Valley
  • The Manufacturers Alliance of New York
  • Western New York Association of Plumbing and Mechanical Contractors
  • Also included in the Coalition are Donna L. DeCarolis and Dennis W. Elsenbeck, both members of the state’s Climate Action Council established by the CLCPA. 

The Coalition petition provides a description of each of its members

Independent Intervenor Filing

For comparison purposes I will describe the Independent Intervenor filing submitted on August 12, 2025, first.  My first post described our main argument and the second post described the supporting exhibits.  In brief, Public Service Law (PSL) § 66-p (4) states: “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”.  We argued the hearing was necessary because of the significant increase in arrears threshold has been exceeded.

Independent Intervenors – Affordability 

Exhibit 3 – Affordability-Focused Recommendations documents references to affordability and reliability recommendations in the New York Department of Public Service (DPS) Document and Matter Management (DMM) System.  Rather than wading through the system I acknowledge the use of Perplexity (https://www.perplexity.ai/) to generate summaries and references included in the document.

The Perplexity summary provided the following key takeaway:

Since 2022, at least six concrete safeguards have been proposed in the New York Department of Public Service (DPS) record to keep the Climate Leadership & Community Protection Act affordable for households and businesses. They call for (1) rigorous public cost reporting, (2) objective “safety-valve” triggers under Public Service Law §66-p(4), (3) systematic pursuit of alternative funding, (4) expansion of low-income bill-protection programs, (5) transparent data dashboards, and (6) stricter benefit-cost and rate-design standards.

In my opinion, these safeguards haven’t been implemented well enough to ensure affordability.  There has been no DPS staff response to any of the calls to develop affordability triggers.

Independent Intervenors – Reliability

The biggest unresolved reliability risk associated with Climate Act implementation is addressed in Case 15-E-0302 – Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and Clean Energy Standard.  Responsible New York agencies all agree that new Dispatchable Emissions-Free Resource (DEFR) technologies are needed to make a solar and wind-reliant electric energy system viable during extended periods of low wind and solar resource availability. 

Two exhibits addressed these reliability concerns.  To adequately address the amount of DEFR required it is necessary to determine how much is needed. Exhibit 4 – Resource Gap Characterization describes the challenges of defining the frequency, duration, and intensity of low wind and solar resource availability (known as dark doldrums) events.  One fundamental flaw in the Climate Act is the mistaken belief by the authors of the law that existing wind, solar, and energy storage resources would be sufficient and that no new technology would be required.  Exhibit 5 – Dispatchable Emissions-Free Resources explains that this presumption is not correct. There is a need for a resource that is not currently commercially available.  This reliance on unknown solutions risks investments in false solutions and poses significant reliability risks. 

Coalition Filing

The Coalition petition states:

The Coalition for Safe and Reliable Energy, a diverse coalition consisting generally of associations, chambers of commerce and other groups representing various businesses, industries, manufacturers and constituencies from across the state, as well as two members of the state’s Climate Action Council (hereinafter referred to as the “Coalition”), hereby petitions the New York State Public Service Commission to hold a hearing pursuant to Public Service Law § 66-p (4) to evaluate whether to temporarily suspend or modify the obligations under the Renewable Energy Program established as part of the Climate Leadership and Community Protection Act.

The preceding statement includes a footnote referencing the Independent Intervenor filing and another regulatory action that argued a heating was appropriate.  The Coalition lays out the basic argument:

 This Petition seeks Commission action authorized by the CLCPA. Recent evidence suggests that the Renewable Energy Program, and its associated renewable energy targets, may impede the provision of safe and adequate electric service and upset the necessary balance of reliable, economic and sustainable energy in New York State. This evidence justifies commencement of the hearing process in PSL § 66-p (4), which will allow the Commission to determine whether the temporary suspension or modification of the Renewable Energy Program obligations is necessary to ensure the continued provision of safe and adequate electric service. Further, the Coalition believes that any hearing held pursuant to PSL § 66-p (4) should examine the relationship between Renewable Energy Program costs and customer arrears.

The Executive Summary provides an excellent overview of the status of Climate Act implementation.

The CLCPA set extraordinarily ambitious targets for renewable energy generation in New York State, requiring that by 2030, 70% of statewide electricity generation be from renewable energy systems and that by 2040, the electric grid be zero emissions. Recent data from the Commission demonstrates that New York will not achieve – or even come close to achieving – the 70% target by 2030. In addition, recent developments at the federal level impacting clean energy are likely to have a negative impact on renewable energy in the near term. With respect to the target of zero emissions by 2040, the necessary emission-free generation resources are not currently available at commercial scale. The inability of New York to develop the amount of renewable energy generation necessary to meet the 70% target by 2030, the increasing retirement of aging fossil-fuel generators due to the CLCPA, and the uncertainty surrounding the development of resources necessary to meet the zero emissions target by 2040, presents a reliability concern.

This concern is exacerbated by the fact that it may take more than two times the amount of certain forms of renewable generation to make up for the loss of one megawatt of fossil-fuel generation, and by expected increases in electric demand driven by the combination of new large loads and electrification.

Pursuant to the PSL, the Commission is required to ensure the provision of “safe and adequate” electric service. Renewable energy development has not kept pace with generator retirements, which has resulted in declining reliability margins across New York, jeopardizing electric reliability and safe and adequate service. In recognition that the Renewable Energy Program might negatively impact electric reliability, the CLCPA includes a safeguard that allows the Commission to temporarily suspend or modify the obligations of the program, after a hearing, if it makes a finding that the program impedes the provision of safe and adequate electric service. Given recent evidence regarding delayed renewable energy generation and risks to reliability, the Commission should hold a hearing pursuant to PSL § 66-p (4) to determine whether safe and adequate electric service in New York is impeded by the Renewable Energy Program and, if so, to appropriately modify or suspend the program’s obligations.

Discussion

Both filings argue that the PSC should convene a hearing to determine whether it is appropriate to temporarily suspend or modify the obligations of the Climate Act.  The Independent Intervenors argued that there was an explicit requirement for the hearing because the customers in arrears threshold has been exceeded.  The Coalition makes a persuasive argument that there are sufficient observed threats to reliability that a hearing is necessary to ensure safe and adequate service.

The other difference is that the Independent Intervenors represent the views of four individuals whose credibility lies in our technical expertise. The Coalition consists primarily of associations, chambers of commerce and other groups representing various businesses, industries, manufacturers and constituencies from across the state whose credibility is based on its political and economic clout. 

Hopefully, the Coalition filing for a hearing will engender a response from the PSC.  There has been no hint of a response to the Independent Intervenor filing.  Perhaps the Coalition represents too big a constituency to ignore.

Some may say that the Coalition position is economically self-interested and therefore should be discounted.  They could also argue that the Independent Intervenors are not qualified to speak.  I think I can speak for both parties when I say we believe our concerns have never been openly discussed and addressed by the Hochul Administration.  All we want is the chance to make our case for the need to define affordability and reliability metrics that ensure safe, affordable, and adequate service.

Conclusion

I am encouraged that there is another group making similar arguments that the time has come to convene a hearing.  All my attempts have failed but maybe the Coalition will succeed in getting the PSC to convene a hearing.

Shortcomings of RGGI Caps and GHG Emissions Reporting in the Electric Sector

The Regional Greenhouse Gas Initiative (RGGI) is a market-based program to reduce CO2 emissions from electric generating units.  On July 3, 2025, RGGI announced that results of the Third Program Review.  On December 10, 2025 the New York State Department of Environmental Conservation (DEC) announced amendments to their CO2 Budget Trading Program that would change the rules to be consistent with the RGGI Third Program Review.  This post describes two shortcomings of New York’s GHG emission reduction regulations for the electric sector. 

Dealing with the RGGI regulatory and political landscapes is challenging enough that affected entities seldom see value in speaking out about fundamental issues associated with the program.  I have been involved in the RGGI program process since its inception and have no such restrictions when writing about the details of the RGGI program.  I have worked on every cap-and-trade program affecting electric generating facilities in New York including RGGI, the Acid Rain Program, and several Nitrogen Oxide programs, since the inception of those programs. I also participated in RGGI Auction 41 successfully winning allowances and holding them for several years.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

6 NYCRR Part 242 – CO2 Budget Trading Program

The DEC Recently Proposed Regulations web page included the following description (accessed on 1/1/26) of the rulemaking:

The proposed amendments to 6 NYCRR Part 242 CO2 Budget Trading Program would reduce the annual budget of CO2 allowances through 2037, add a second tier of Cost Containment allowances, remove the emissions containment reserve, remove offset projects, remove eligible biomass provisions, increase the minimum reserve price, reduce the number of allowances set-aside for long term contracts and voluntary renewable energy purchases while still maintaining enough allowances to accommodate anticipated demand, and make other improvements and clarifications to the program. The Department is also proposing complementary amendments to listings of related reference material in 6 NYCRR Part 200 General Provisions. Additionally, New York State Energy Research and Development Authority is proposing to amend 21 NYCRR Part 507 CO2 Allowance Auction Program to align with the proposed amendments to 6 NYCRR Part 242. Comments on these proposed revisions must be received by February 17, 2026.

This web page also includes the following links to elements of the regulatory package:

I am only going to address emissions contradictions and the proposed reduction in the annual budget of CO2 allowances through 2037 in this post.  Eventually I will describe my comments on the proposed amendments.

NYS Electric Utility Emissions

In a recent post I described the emission reduction performance of RGGI.  In that post I compared New York’s electric generating unit emissions during RGGI to historical information using data from the Clean Air Markets Program Data (CAMPD) database.  For consistency across the entire period, I used the CO2 emissions from all programs in CAMPD.  Table 1 shows that there is an inconsequential difference between that total and emissions from just units affected by RGGI.  RGGI does not include some units that are report for NOx Budget programs and RGGI has a size limitation that excluded small units over much of the program.

Table 1: Comparison of New York State EPA CAMPD CO2 Emissions (Short Tons) for All Programs and RGGI Program

Climate Act Emissions

One point that I want to make in this post is that the Climate Leadership & Community Protection Act (Climate Act or CLCPA) emissions accounting methodology complicates assessment of the RGGI emission cap and appears to be biased.  A recent post described the latest New York State (NYS) GHG emission inventory report based on Climate Act methodology.  The Climate Act authors mandated that emissions must use a Global Warming Potential (GWP) accounting over 20 years instead of the 100 year accounting used in RGGI.

Emission Inventory Table ES.2 in the Summary Report presents emissions for different sectors and different greenhouse gases.  There are four Intergovernmental Panel on Climate Change (IPCC) sectors and there are four  sectoral reports for energy, industrial processes and product use, agriculture, forestry and land use, and waste.  The table also includes United Nations Framework Convention on Climate Change (UNFCCC) totals that use the “conventional accounting used by other governments, applies a 100-year GWP, omits biogenic CO2, and does not include emissions outside of New York State.” 

For this analysis, Table 2 extracts relevant information for the IPCC Electric Energy Sector from Table ES.2.  The table compares the CLCPA emissions that use GWP-20, includes other GHG gases, and adds non-RGGI stack emissions as well as three additional sources: imported electricity, transmission & distribution, and upstream fuel extraction.  There are two columns added that compare UNFCCC and CLCPA emission.  In 2023, the UNFCC emissions were 26.1 million metric tons (MMT) and the CLCPA emissions were 49.02 MMT.  The table clearly shows that increased emissions were the result of adding CH4 and N2O (0.18 MMT), Electricity T&D (0.12 MMT) and Imported Electricity (9.54 MMT).  The table does not explicitly address upstream fuel extraction emissions, but I estimated that they were 13.09 MMT.  That is approximately half the direct emissions total.

Table 2: ES.2: 2023 New York State GHG Energy Sector Emissions (mmtCO2e GWP20), by IPCC Sector with Comparison of CLCPA and UNFCCC Electric Power Emissions

In my opinion, the claim that fuel extraction emissions are around 50% of the direct stack emissions is extraordinary.  Table ES.2 does not explicitly list the fuel extraction component of electric power emissions.  I assumed that it would be equal to the percentage of electric power emissions to the total fuel combustion emissions.   That seems like a reasonable assumption, but the result is unrealistic. 

Projected Emissions and the RGGI Proposed Cap

The New York State Energy Plan provides the “official” emissions projections for the electric sector.  I have provided background information on my Energy Plan page.  For our purposes the thing to remember is that the Plan projects emissions for five different scenarios.  Table 3 lists projections starting in 2027 that range from 49.3 to 40.3 MMT.  The 2023 observed emissions from RGGI sources was 28.7 MMT.  Table 3 lists the proposed RGGI cap or limit on tons of CO2 permitted.  There is a big difference between the Pathways Analysis projection and the RGGI numbers.  I believe that those differences are explained by the factors affecting emissions in Table 2.

Table 3: Comparison of RGGI Proposed Part 242 Cap and State Energy Plan Pathways Analysis Electric Power Scenario Projections

In my review of the RGGI Third Program Review I explained that the RGGI states determined the proposed cap levels based on state laws like the Climate Act that mandate zero emissions by 2040.  The observed reduction trajectory simply is an extrapolation to zero.  On the other hand, the State Energy Plan modeling represents a fundamental change in official New York projection methodology.  Previously, projections assumed that emissions would get to zero no matter what.  The State Energy Plan is consistent with the estimates of the New York independent System Operator (NYISO) that do not assume zero emissions by 2040.  These estimates clearly show that the RGGI emission caps are unrealistic.

Discussion

This post describes two shortcomings of this component of New York’s GHG emission reduction regulations for the electric sector.  The emissions estimates using the Climate Act accounting fails a common-sense plausibility check.  There is simply no way that New York electric generating units affected by RGGI will be able to achieve the proposed revisions to Part 242.

I do not think that the emissions estimates for the electric sector are credible. These are indirect estimates of emissions using emission factors that project emissions based on fuel use and activity factors.  Emission factor estimates are fundamentally mass balance calculations.  I do not think it is reasonable to assume that extracting natural gas and oil would produce emissions equal to half the direct emissions.  Note that CH4 is the largest component pollutant and, given New York’s irrational obsession with it, that makes me suspect the emission factors used for methane are biased high. 

The 2025 GHG Energy Sectoral Report notes that “DEC has conducted a recalculation of upstream, out-of-state emissions from natural gas imports using a recently released updated methodology” which suggests that they recognize that there is an issue.  The report also states that “DEC continues to welcome feedback on this and any part of the current analysis.”   Given that they blew off my comments about the methane methodology that I submitted in October 2020, I believe that it this is only a gesture and while comments are welcomed making changes based on comments is not on the table.

The second issue discussed is the gap between the RGGI allowance cap trajectory and the State Energy Plan.  It is just not reasonable to think that electric generating unit emissions will be able to achieve those caps in that timeframe.  The RGGI cap on emissions essentially rations energy use because if there are insufficient permits to emit (aka allowances) affected generating units have no other options to reduce emissions so they can only shutdown to comply with the law.  If replacement zero emissions generating resources are unavailable, then the electric grid would be placed in an artificial energy shortage that would lead to blackouts.  This point will be emphasized  when I comment on the DEC Part 242 amendments.

Conclusion

This is my first post of 2026.  Sadly, there is nothing new here.  New York State agencies generate analyses and propose regulations that comply with the Climate Act narrative without considering the real world.  Reality bats last.  Is 2026 the last inning?

RGGI Cap-and-Invest Emission Reduction Performance in New York

The Regional Greenhouse Gas Initiative (RGGI) is a market-based program to reduce emissions from electric generating units.  On December 18, 2025, New York State Energy Research & Development Authority (NYSERDA) hosted a meeting (agenda, recording) to present proposed changes to the RGGI Operating Plan Amendment (“Amendment”) for 2026.  This post describes the trend of New York’s RGGI emissions that I will use as part of my comments on the draft Amendment.

I have been involved in the RGGI program process since it was first proposed prior to 2008.  I blog about the details of the RGGI program because very few provide any criticisms of the program.   There is no upside for companies affected by RGGI to disparage the program because it has become a sacred cow initiative that is treated as beyond criticism by agencies and activists. I have extensive experience with market-based programs because I have worked on analysis, implementation, and evaluation of every  program affecting electric generating facilities in New York including RGGI and several Nitrogen Oxide programs.  The opinions expressed in these comments 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.

Background

RGGI is a market-based program to reduce greenhouse gas emissions (GHG) (Factsheet). It has been a cooperative effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont to cap and reduce CO2 emissions from the power sector since 2008.  New Jersey was in at the beginning, dropped out for years, and re-joined in 2020. Virginia joined in 2021 but has since withdrawn and Pennsylvania recently withdrew completely.

According to a RGGI website:

The RGGI states issue CO2 allowances that are distributed almost entirely through regional auctions, resulting in proceeds for reinvestment in strategic energy and consumer programs.

Proceeds were invested in programs including energy efficiency, clean and renewable energy, beneficial electrification, greenhouse gas abatement and climate change adaptation, and direct bill assistance. Energy efficiency continued to receive the largest share of investments.

Proponents of RGGI claim the program has “successfully lowered CO2 emissions intensity and absolute emissions”.  This post will show that this conclusion is not reflected in the New York emissions trends.  In a subsequent post I will explain that ignoring the lessons of the observed reductions is leading to investment strategy decisions in the NY RGGI Operating Plan that will eventually cause serious problems.  Proposed investment descriptions include beneficial electrification, climate change adaptation, and direct bill assistance that do not reduce electric sector emissions.

New York RGGI Emissions

This analysis of annual New York CO2 emissions from electric generating units uses data from the EPA Clean Air Markets Program Data (CAMPD) database.  I downloaded unit-level data for all pollution control programs so that I can compare emissions from the start of RGGI in 2009 to a baseline before the program started.  The data include a record describing the primary fuel type These records are not standardized and include more categories than I need so I consolidated the labels as shown in Table 1.

Table 1: Consolidated Primary Fuel Type Labels

Table 2 lists the annual emissions since 2000 through 2024.  Claims that the program has “successfully lowered CO2 emissions intensity and absolute emissions” are debunked in the following table and figure.   This table lists mass CO2 emissions by fuel type along with the emission rate or intensity.  Both absolute and emissions intensity do go down.

Table 2: New York Clean Air Markets Program Data Emissions Data for All Regulatory Programs

Figure 1 clearly shows the role of fuel switching away from coal and oil and the increasing use of natural gas.  I believe that the fuel price differential for natural gas use was much greater than the added cost of RGGI allowances and thus the main driver of the observed reductions is economic fuel switching.   This figure labels the 2006 to 2008 period that I use as the baseline for “before RGGI”, the start of RGGI, and when the possibility of additional fuel switching became impossible.  If RGGI were the primary driver of emission reductions, then emission reductions would have continued to decrease after the lowest emissions in 2019, and they certainly would not have been increasing since then.  The other big takeaway from this is that 2019 was the year that the inane premature retirement of the Indian Point nuclear station began.  New York has not managed to replace generation from this zero emissions resource as emissions continue to rise.

Figure 1: New York Clean Air Markets Program Data Emissions Trend by Fuel Type

Table 3 lists the emissions reductions since the start of the RGGI program.  I included this because it shows that in 2024 CO2 emissions since the start of RGGI are 33% lower.  Also note that in 2019 emissions were 47% lower.  I included the gross load to show that gross load also decreased.  In theory this could represent displacement of fossil fired units because of RGGI investments. In my next post I will update last year’s analysis of the effect of RGGI investments that shows that is not the reason.  NYSERDA program funding status reports estimate the emission savings from their program investments.  Last year I showed that the total cumulative annual emission savings due to NYSERDA program investments through the end of 2023 that directly or indirectly affect electric generating source emissions  is 1,405,513 tons.  That means that emissions from RGGI sources in New York would have been only 3% higher if the NYSERDA program investments did not occur.  I do not expect that this will change using the 2024 data.

Table 3: New York RGGI Emissions and Gross Load Reductions Since Start of RGGI

Discussion

I have two overarching concerns about the implications of RGGI emission reduction performance.  Firstly, the RGGI cap on emissions essentially rations energy use because if there are insufficient permits to emit (aka allowances) affected generating units have no other options to reduce emissions so they can only shutdown to comply with the law.  If replacement zero emissions generating resources are unavailable, then the electric grid would be placed in an artificial energy shortage that would lead to blackouts.  Therefore, in my comments on the NYSERDA operating plan I will argue that programs that lead to emission reductions should be prioritized to prevent energy rationing.

My second concern is that idolatry of the RGGI as a program that should be replicated because of its success was a primary driver of the Climate Leadership & Community Protection Act’s Scoping Plan recommendation for an economy wide cap-and-invest program.  In my last update on the New York Cap-and-Invest (NYCI) program I explained that there is potential for a judge to order that NYCI be implemented.  These data show that this magical solution will not work as advertised.

Finally, I want to put the historical and projected generating load in perspective relative to RGGI and NYCI.  The New York Independent System Operator(NYISO) annual load and capacity data report universally known as the “Gold Book” provides input for a couple of relevant graphs in NYISO 2025 Gold Book Forecast Graphs.

Figure 2 lists historical and weather normalized annual loads from 2015 to 2024.  These observed loads closely track the RGGI electric generating unit loads.  The scary issue is that NYISO is projecting significant increases in load going forward without the addition of large load facilities.  The load increases are associated with electrification strategies associated with the Climate Act.

Figure 2: NYISO Historical New York Control Area (NYCA) Annual Energy and 10-Year Forecasts (GWh)

Figure 3 also lists historical and weather normalized annual loads from 2015 to 2024 but includes “additional load growth from large loads”.  This increases the 2035 baseline around 17,000 GWh or another 10%.  This would make it all the more difficult to provide sufficient zero-emission generating resources to comply with the Climate Act mandate to have a 100% zero-emission electric grid by 2040.

Figure 3: NYISO Historical New York Control Area (NYCA) Annual Energy and 10-Year Forecasts (GWh)

Conclusion

This analysis clearly shows that the primary driver of observed emission reductions from RGGI electric generating units was fuel switching.  These results are consistent with similar analyses that I have prepared regarding RGGI emission reductions.  I will incorporate these findings in my comments on the 2026 RGGI Operating Plan Amendment stating that this observations should be reflected in the Operating Plan just like I have for the last several years.  I fully expect that NYSERDA will ignore my comments again and will continue to make investments to appease political constituencies.  Political interference in energy policy will eventually fail, it is only a matter of time.

Climate Change Perceptions

I have been meaning to write this post for a long time because I think there is an important distinction about climate change that could potentially be affected by reducing GHG emissions that is not generally recognized.  I have postponed this article because I did not want to try to explain the driving factor for my concern – ocean and atmospheric oscillations.  Andy May is a petrophysicist who has a climate blog that recently published 14 articles about atmospheric oscillations that I have used in this post.

I am convinced that implementation of the New York 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.  Moreover, I take the heretical position that our understanding of the causes of climate change are not understood well enough to support the idea that reducing GHG emissions represents sound policy.  I have been a practicing meteorologist for nearly 50 years, was a Certified Consulting Meteorologist, and have B.S. and M.S. degrees in meteorology.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Background

Weather and climate are often confused.  According to the National Oceanic and Atmospheric Administration’s National Ocean Service “Weather reflects short-term conditions of the atmosphere while climate is the average daily weather for an extended period of time at a certain location.”  They go on to say: “Climate is what you expect, weather is what you get.” 

The standard climatological average is 30 years.  It is important to understand that programs like the Climate Act’s GHG emission reduction targets are intended to reduce global warming over longer time scales than 30 years.  Statements suggesting that even if aggressive mitigation reduces greenhouse gases  that temperature will still increase for 20-30 years due to inertia in the climate system are based on the premise that CO2 is the control knob for the climate.

I often hear and have noticed myself that “winters aren’t what they used to be” and that leaves are turning color later than the past.  The goal of this article is to show that there are climatic oscillations with time periods greater than 30 years that are likely causing these perceived examples of climate change.  However, I will show there is no connection between those observations and the value of the Climate Act as a potential reason to reduce GHG emissions in hopes of changing those observations.

Climate Oscillation Analysis

Earlier this year Andy May published 14 articles about climate oscillations in the oceans and atmosphere. I think his analysis is notable because it is data driven.  The basis of his analysis is articles describing observed oceanic and atmospheric changes, not modeled simulations.  Given the complexity of the interactions between oceans and the atmosphere and the poor understanding of their relationships, assuming that modeled simulations are credible is not reasonable. 

His articles provide compelling evidence that each of the 14 oscillations is natural.  I believe his work provides sufficient evidence proving that “each oscillation is natural and has been around since the pre-industrial period, or even earlier, and thus is natural and not random variability.”  This is important relative to claims that reducing the GHG emissions will affect global temperatures. 

May’s work consists of a statistical regression analysis of observed features in the oceans and atmospheres that have occurred over many years.  He uses the HadCRUT5  global average temperature data set used by the Intergovernmental Panel on Climate Change (IPCC) to track global warming in his analyses.  May offers the following caveat about his work.

Finally, this is a regression analysis to predict HadCRUT5 with climate oscillations to try and detect the climate oscillations that best correlate to “global warming.” This is not a climate model, it is not an attempt to make a climate model, it is only a statistical exercise. Statistics and statistical analysis are not proof of anything, it isn’t even scientific analysis, they are just useful tools to sort through datasets. Just as AI is not intelligent, statistics is not science, both are useful tools.

Climate Oscillations

May’s work consisted of the following posts:

In Climate Oscillations 1: The Regression May provides the following table that lists the oceanic and atmospheric oscillations considered in his series of articles.  For each of these oscillations he did a statistical regression analysis.  The first seven of the oscillations correlated with the GMST measured using HadCRUT5.  May points out that “HadCRUT5 is not representative of global climate, it is just an average temperature”.  Nonetheless, it is the primary climate change parameter.  The rationale for the Climate Act uses climate change and global warming interchangeably.

May Table 1. A list of the climate oscillations discussed and analyzed in this series. The first eight oscillations are listed in order of importance in modeling HadCRUT5, the remaining six did not add to the model. The links in this table will not work, to see the list in a spreadsheet with working links, download it here.

I am not going to review each post in this article but will describe several of the oscillations. If you want to review the articles and are content with a summary using Perplexity AI I did get a review of his work.    It notes:

The series begins with a foundational regression analysis that ranks fourteen major climate oscillations by their statistical correlation with HadCRUT5 global surface temperature. May’s analysis reveals that the top three oscillations—the Atlantic Multidecadal Oscillation (AMO), Western Hemisphere Warm Pool (WHWP) area, and Southern Annular Mode (SAM)—together explain 77% of HadCRUT5 variability since 1950. This finding directly contradicts the IPCC’s characterization of these oscillations as unpredictable “internal variability” with minimal influence beyond a few years.

The Atlantic Multidecadal Oscillation (AMO) has the most significant relationship with global mean surface temperature (GMST).  There are several definitions based on different measurements.  For example, Gray, et al. use detrended raw tree-ring measurements to demonstrate “a strong and regular 60-100 year variability in basin-wide (0-70°N) North Atlantic sea surface temperatures (SSTs) that has been persistent for the past five centuries.”

The general approach used by May is simple.  Figure 4 plots GMST using the HadCRUT 5 data and the AMO parameter using the HadSST 4.1 data.  It is obvious that the two parameters track well.  May used regression analysis to show the strength of the relationship. Note the variation in global temperature since 1850 shown in this graph.  The first challenge for proponents of the idea that CO2 is the driver of climate change is that it is acknowledged that it is only since 1950 that CO2 has affected global warming.  So, what happened in the past to cause the observed variations?   I do not think it is reasonable to claim that all the natural drivers that caused variations before 1950 stopped and global warming became entirely dependent upon CO2 since, but that is the argument used by Climate Act proponents.

May Figure 4. HadSST and HadCRUT detrended temperature anomalies plotted together. Both anomalies are from 1961-1990 originally but are from their respective linear least squares trends. This is updated from figure 2 in (May & Crok, 2024).

May points out:

The reason for the AMO SST 60-70-year pattern is unknown, but according to Gray et al. it extends back to 1567AD, so it is a natural oscillation of some kind. Some have speculated that it is a result of the thermohaline circulation in the North Atlantic or a “combination of natural and anthropogenic forcing during the historical era.” (Mann, Steinman, & Miller, 2020). But while interesting these ideas are speculative. Further if the oscillation has existed since 1567, it seems unlikely that it is caused by human CO2 and aerosol emissions.

The AMO has the best correlation with GMST in all the statistical analyses.  Combined with two other oscillations –  Western Hemisphere Warm Pool (WHWP) area, and Southern Annular Mode (SAM) these three  explain 77% of HadCRUT5 variability since 1950.

The Western Hemisphere Warm Pool Area (WHWP) is an area of abnormally warm ocean that extends from the eastern North Pacific (west of Mexico, Central America, and Columbia) to the Gulf of Mexico, the Caribbean, and well into the Atlantic during the WHWP peak in August and September.  Because this area is important to hurricane formation, the strength and extent of the warm pool is important.  May points out that the WHWP  combined with the Antarctic Oscillation or Southern Annular Mode and the AMO predict GMST well.  He concludes that “This suggests that The North Atlantic and the Southern Hemisphere circulation patterns correlate very well with global climate trends, CO2 may fit in there somewhere, but it must share the spotlight with these natural oscillations.”

The Southern Annular Mode/Antarctic Oscillation (AAO) is defined as the difference between the zonal (meaning east-west or circumpolar) sea level air pressure between 40°S and 65°S.  This parameter has a powerful influence on global climate and can affect weather in the Northern Hemisphere (Lin, Yu, & Hall, 2025), in particular the Warm Arctic-Cold Eurasian weather pattern that causes a lot of extreme winter weather. The AAO also affects the Indian summer monsoon and other eastern Asia weather phenomena.

Synthesis

The final article in the series, Climate Oscillations 12: The Causes & Significance, addressed the claim by proponents of the Climate Act that “ocean and atmospheric oscillations are random internal variability, except for volcanic eruptions and human emissions, at climatic time scales.”  May explains:

This is a claim made by the IPCC when they renamed the Atlantic Multidecadal Oscillation (AMO) to the Atlantic Multidecadal Variability (AMV) and the PDO to PDV, and so on. AR6 (IPCC, 2021) explicitly states that the AMO (or AMV) and PDO (or PDV) are “unpredictable on time scales longer than a few years” (IPCC, 2021, p. 197). Their main reason for stating this and concluding that these oscillations are not influenced by external “forcings,” other than a small influence from humans and volcanic eruptions, is that they cannot model these oscillations, with the possible exceptions of the NAM and SAM (IPCC, 2021, pp. 113-115). This is, of course, a circular argument since the IPCC models have never been validated by predicting future climate accurately, and they also make some fundamental assumptions that simply aren’t true.

This is a good point to remind readers that little fluctuations in incoming radiation have big impacts on the climate.  The Milankovitch theory is the most widely accepted cause of glaciation.  It states  that variations in earth’s orbit and tilt cause changes in the amount of sunlight that cause climate fluctuations strong enough to trigger continental glaciers. 

May’s analysis finds relationships between similarly small external variations that correlate with global surface temperatures.  Note however that proponents of CO2 as the control knob disregard all climate drivers but the greenhouse effect.    May explains:

Finally, oscillations are inconsistent with anthropogenic greenhouse gas emissions as a dominant forcing of climate change. Greenhouse gas emissions do not oscillate; recently they have only increased with time. So, we will examine the relationship between solar and orbital cycles and the climate oscillations. As Scafetta and Bianchini (2022) have noted, there are some very interesting correlations between solar activity and planetary orbits, and climate changes on Earth.

May’s final article describes multiple observed oscillations including a period of about ~64 years, ±5 years (Wyatt, et al., 2012), Nathan Mantua and colleagues (Mantua, et al., 1997) identified 20th century “climate shifts” which results in a major multidecadal climate oscillation of 22 to 30 years and there are shorter 2-, 5-, 5-, and 9-year observed oscillations.  Note that there also are other cycles that are longer than these.

The ~64 year oscillation is of particular interest.  Marcia Wyatt’s “stadium wave” hypothesis shows that a suite of global and regional climate indicators vary over roughly the same 64-year period.  Wyatt explains:

“Stadium wave” is an allusive term for a hypothesis of multidecadal climate variability. Sequential propagation of an “audience wave” from one section of sports fans to another in a sports arena – i.e. a “stadium wave” – is analogous to the premise of the climate stadium-wave hypothesis. It, too, involves sequential propagation of a signal. In the case of the climate stadium wave, propagation proceeds sequentially through ocean, ice, and atmospheric systems. Key to signal propagation is network, or collective behavior – a feature ubiquitous throughout natural and man-made systems, a product of time and self-organization.

I think of climate as a product primarily of the climate stadium wave cycle plus contributions from other oscillations.  May explains:

If we define “global climate change” as the observed changes in HadCRUT5 or BEST global mean surface temperature (GMST) as the IPCC does, then the oscillations that correlate best are the AMO and the global mean sea surface temperature (SST) as shown in figure 2. None of the other oscillations correlate well with GMST.

In figure 2, the gray curve is a 64-year cosine function. It fits the 20th century data but departs significantly around 2005 and before 1878. The early departure could be due to poor data, the 19th century temperature data is very bad, see figure 11 in (Kennedy, et al., 2011b & 2011). Data quality problems still exist today, but are much less of a factor and the departure after 2005 is likely real and could be caused by any combination of the of the two following factors:

  1. Human-emitted greenhouse gases.
  2. The full AMO/world SST/GMST period is longer and/or more complex than we can see with only 170 years of data.

It is probably a combination of the two. As discussed by Scafetta and Stefani, climate, orbital, and solar cycles are known to exist that are longer than 170 years. The fact that I had to detrend all the records shown in figure 2 testifies to that. It is also noteworthy that the ENSO ONI trend since 2005 is trending down; as shown in the last post. So is the current PDO trend. All the notable oscillations are not synchronized, teleconnections or not, climate change is not simple. The trends in figure 2 result from complex combinations of gravitational forces and teleconnections (Scafetta, 2010), (Ghil, et al., 2002), and (Stefani, et al., 2021).

Discussion

May gives a concise summary of the potential human influence that has never been considered by the State of New York:

Whether global warming is a problem or not is in dispute, but it is a fact that the world is warming, and some are concerned about it. What is the cause of the warming? Is it natural warming after the cold winters of the Little Ice Age? Is it caused by human emissions of CO2? Most of the natural ocean and atmospheric circulation oscillations examined in this post are not modeled properly (some say not modeled at all) in current global climate models (Eade, et al., 2022). The IPCC AR6 report admits that the AMO (they call it the “AMV”) signal in the CMIP6 climate models is very weak, specifically on page 506:

“However, there is low confidence in the estimated magnitude of the human influence. The limited level of confidence is primarily explained by difficulties in accurately evaluating model performance in simulating AMV.” (IPCC, 2021, p. 504)

In other words, the models that predict gloom and doom that are used as the rationale that we must reduce New York GHG emissions don’t accurately predict the oscillation that correlates best with global temperatures.  If you cannot model this relationship, then the likelihood that future temperature projections are accurate is zero.

In addition, NYSERDA presentations at meetings consistently attribute the latest extreme weather events to climate change.  Maybe someday I will explain why I think that is completely divorced from reality and only serves to support the narrative that there is an existential threat.  In the meantime Roger Pielke, Jr. recently eviscerated this line of reasoning and those that continually use it.  He points out that this approach is “counter to the terminology, frameworks, and assessments of the IPCC and the broad base of research on which the work of the IPCC is based upon.”  I strongly recommend his article as definitive proof that the Hochul Administration picks and chooses the “science” to fit their narrative.

Conclusion

The intent of this article was to explain why anecdotal “evidence” of climate change is no more than recognition that there are weather pattern cycles that currently show warming.  It does not mean that there is conclusive evidence that continued GHG emissions will inevitably increase global temperatures.  There is overwhelming evidence that the current warming cycle will eventually reverse.  This does not mean that GHG emissions are not a factor but does mean they are a tweak not the primary driver.  This combined with the fact that New York GHG emissions are so small relative to global emissions that we cannot meaningfully affect global emissions means that GHG emission reductions for the sake of the climate is a useless endeavor.