Category: Climate Act

How Neighboring Electric Systems  Handled the July 2026 Heat Wave

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

I am convinced that implementation of the Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone. I acknowledge the use of Perplexity AI to research and organize the material summarized in this article.

Overview

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

PJM: The Most Acute Stress in the Country

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

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

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

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

ISO New England: Tight, But Wind Actually Helped

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

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

MISO: High Load, Weak Wind, No Emergency

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

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

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

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

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

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

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

Comparing the Regions

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

Conclusion

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

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

Ellenbogen’s Data From the July 2026 Heat Wave

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

I am convinced that implementation of the Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone. I used Perplexity AI to process commentary and data that Rich Ellenbogen shared with me and prepare a draft article. 

Overview

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

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

Voltage and Frequency at the Ellenbogen Factory

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

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

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

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

Source: Data provided by Rich Ellenbogen

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

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

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

The July 2–4 Event at the Factory

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

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

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

Source: Data provided by Rich Ellenbogen

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

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

Source: Data provided by Rich Ellenbogen

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

Source: Data provided by Rich Ellenbogen

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

Con Edison System Voltage on July 3

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

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

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

Source: Data provided by Rich Ellenbogen

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

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

Source: Data provided by Rich Ellenbogen

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

Source: Data provided by Rich Ellenbogen

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

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

Home Solar Inverter Fault Log

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

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

Broader Consequences

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

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

Conclusion

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

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

My Affordability Presentation at Stop Energy Sprawl Connect Across the Lines Conference

Update: My presentation is available on Youtube

On August 8, 2026 I gave an affordability presentation at the Stop Energy Sprawl Conference “Connect Across the Lines”.  This post documents my presentation as promised to the attendees. Although it just provides bullet points with links others may find it useful as a summary of my Climate Leadership & Community Protection Act (Climate Act) affordability concerns.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability risks, unacceptable costs, and adverse environmental impacts.  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

Stop Energy Sprawl is a coalition of  community groups, municipalities, and elected officials from localities in New York State targeted by land-wasting, large-scale wind and solar projects located far from where that energy is needed. This year’s conference, aims to inform on the affordability, legality, feasibility, and community impacts of New York’s energy policies. 

The post reproduces the slides with references included.  I acknowledge the use of Perplexity AI to find and summarize my articles documenting this presentation.  I used Perplexity AI to prepare a list of links to my articles related to specific topics that I linked to my web site. Those links are labeled as (Perplexity AI Summary).

Introduction

Affordability Presentation Topics

  • Climate Leadership & Community Protection Act (CLCPA or Climate Act) energy transition
  • “Cheap” renewables myth
  • Affordability Messaging in State plans
  • Ratepayer Impacts per Kris Martin

Climate Act Premise

Source: Climate Act Scoping Plan

  •  Public Service Law § 66-p
    • Public Service Law 66-p (Perplexity AI Summary) Implications
    • Section 66-p (4) includes an affordability safety valve if “there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.
    • PSC may “temporarily suspend or modify the obligations” of the CLCPA after conducting a hearing
    • Two petitions requested that the PSC address this
    • On 1/28/2026 the PSC asked for comments
    • Comment deadline was the end of April
    • No action taken yet
  • There is No Clear CLCPA Affordability Limit –  No references needed
    • CLCPA does not define acceptable consumer cost impacts
    • Without a clear affordability boundary, there is no real cost constraint.
    • That makes affordability a political slogan instead of a measurable requirement.

Source: Adapted from figure by Charles Rotter at Watts Up With That

  • But What About Cheap Renewables? (Perplexity AI Summary)
    • Energy storage
    • Transmission Upgrades
    • Backup generation
    • Grid ancillary support
    • Dispatchable, firm generating resources

These issues are addressed in a subsequent presentation.

  • Cheap Renewables – Only Half the Story
    • The “cheap renewables claim usually refers to low project-level Levelized Cost of Energy (LCOE), not total system cost.
    • LCOE measures the cost of producing electricity when available, not the cost of running a reliable grid.
    • Consumers pay for a full electric system, not just low-cost megawatt-hours.
    • The grid must work on the worst day of the year – high load low, renewables
    • Cheap electricity is not the same as dependable electricity.

Source: NYISO 2025-2044 System and Resource Outlook Appendix J: Renewable Generation Pockets

  • Hidden Cost – Transmission (Perplexity AI Summary)
    • Large-scale renewable development requires major transmission upgrades to move power from Upstate to New York City and Long Island
    • Simple project-level cost claim do not include interconnection and grid reinforcement costs
    • Consumers ultimately pay for wires, substations, and congestion relief through rates.
  • Hidden Cost – Reliability Backup (Perplexity AI Summary)
    • A weather-dependent grid still needs firm resources for cold, snowy, dark, and low-wind periods.
    • Short-duration batteries can help with ramps and short peaks, but not long-duration system stress.
    • Long-duration periods require special resources that are not commercially available at this time so costs are unknown.  This is the Dispatchable Emissions Free Resource (DEFR) technology
  • Hidden Cost: Electrification (Perplexity AI Summary)
    • Affordability impacts extend beyond utility bills to building conversions, appliance replacement, and vehicle transition costs.
    • Households face upfront capital costs even before any promised fuel savings appear.
    • Low- and middle-income customers are least able to absorb these transition costs.
    • A true affordability review should count economy-wide household energy burdens, not just electric rates.

Another Way to Look at “Cheap” Myth

  • Weather-dependent electric grid needs four systems for reliable power per Scott Grout
    • Base wind and solar fleet
    • Battery system for diurnal and short-term backup
    • Additional wind and solar to power the battery systems
    • Dispatchable firm resources during the doldrums
  • Each system makes for a larger, more complex, and more expensive electric grid.

Source: Healthy Skeptic “Energy Subsidies”

If renewables are so cheap why do they need subsidies?

  • Kevin Roche argues that the total taxpayer subsidy per energy produced shows that renewable wind and solar require subsidies

Source of Graph: Scoping Plan Chapter 10: Benefits of the Plan

Scoping Plan Affordability

State Energy Plan Affordability

  • State Energy Plan Affordability (Perplexity AI Summary)
    • The energy affordability analysis in the Energy Plan shows that “the use of new, efficient equipment and electrification can cut energy spending by $100 to over $300 every month for many New York households, across energy costs for transportation and heating and utility bills.”

Source: NYS Energy Planning Board Meeting Presentation Slide 40

  • State Energy Plan Affordability Claim

I developed this figure to summarize the changes needed to electrify households

Source: NYS Energy Planning Board Meeting Presentation Slide 43

Source: NYS Energy Planning Board Meeting Presentation Slide 43

  • Bottom Line Climate Act Household Cost
    • Difference between Conventional and High Efficient is cost of CLCPA
    • $1,968 minus $1,374 or $594 per month (43%)

Feasibility Warnings

  • State Agencies Feasibility Warnings and Affordability (Perplexity AI Summary)
    • State reviews have acknowledged inflation, supply chain problems, permitting barriers, siting opposition, and interconnection delays.
    • The State Energy Plan indicates current deployment trajectories are not sufficient to meet statutory ambitions.
    • Feasibility problems increase affordability risk because delay almost always increases cost.

Direct Ratepayer Costs

Ratepayer Costs – What is Included

  • Renewable projects are supported through Renewable Energy Credits (RECs) and Offshore wind Renewable Energy Credits (ORECs) purchased by NYSERDA and passed through to utilities.
  • Zero Emission Credits (ZECs) support nuclear plants undermined by renewable subsidies
  • Utilities recover those costs from customers through electric bills.
  • Climate Act charges also include related items such as EV incentives and transmission upgrades that are buried in utility bills.
  • Commercial and industrial customers face even higher Climate Act bill percentages than residential customers.

Source: NYS DPS Second CLCPA Informational Report on Overall Implementation of the CLCPA

  • Current Bill Impacts Look Smaller Than They Really Are
    • The PSC says Climate Act costs are still a small portion of the typical residential bill.
    • That is true only because the forecasts include contracted Tier 1 projects awarded through 2024, not the much larger future buildout needed to meet the law’s targets.
    • In other words, today’s bill impacts reflect only part of the program cost.
    • The larger REC and OREC obligations are still ahead.
  • Charges Reflect an Incomplete Buildout
    • Kris Martin notes that the 2029 forecast includes existing and already-contracted capacity, but not the additional capacity still needed for the 2030 renewable mandate.
    • Those omitted resources represent considerable added cost.
    • If Climate Act costs remain “modest,” that is evidence that buildout is falling short, not that the transition is cheap.
    • Ratepayers will eventually be asked to fund the missing capacity if the mandates stay in place
  • REC Costs Could Rise Sharply
    • At roughly similar REC pricing, wind and solar generation growth from about 6.5 million MWh in 2024 to more than 63 million MWh in 2030 would raise REC costs from about $220.9 million to above $2.1 billion.
  • Affordability Key Findings
    • Climate Act “affordability” is a political slogan
    • “Cheap” renewables is a myth
    • Affordability messaging in state plans is misleading at best
    • Ratepayer impacts are significant and will get worse
  • Affordability Recommendations
    • Define affordable
    • Do not mandate technology
    • Do not mandate a schedule
    • Do not try to go to zero – lower is good enough
    • NYS GHG emissions are less than one half of one percent of global emissions
    • Global emissions have been increasing more than one half of one per cent per year for decades

Conclusion

New York should replace inflexible Climate Act mandates with an affordability-first, technology-neutral strategy that delivers practical emissions reductions without imposing costs on ratepayers that are disproportionate to the State’s limited influence on global emissions

NYISO’s New Resource Outlook – Affordability Implications

The New York Independent System Operator (NYISO) released its 2025-2044 System & Resource Outlook (Outlook on July 22, 2026.  The report is framed as a reliability and resource planning document — not an affordability study — but the cost implications buried in its findings are hard to miss. NYISO never uses the word “affordability” as a headline, but the numbers do the talking. Here’s what jumped out at me, and why I think it validates concerns I’ve been raising for years about the Climate Act’s implementation trajectory and associated costs.

I am convinced that implementation of the Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability risks, unacceptable costs, and adverse environmental impacts.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 650 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.  I acknowledge the use of Perplexity AI to generate an initial draft of this article. 

Background

The NYISO is responsible for electric resource planning for New York State.  The Comprehensive System Planning Process (CSPP) consists of four components: the Local Transmission Planning Process (LTPP), the Reliability Planning Process (RPP), the Economic Planning Process, and the Public Policy Transmission Planning Process. I discussed this process in my earlier article about the Outlook.  On August 3, 2026 the NYISO hosted a public information briefing on the document and the slide presentation gives a good overview.

Capacity Needed for Full Zero-Emissions

The Outlook evaluates 20 scenarios (up from just five in the prior 2023-2042 Outlook), varying demand growth, resource availability, and policy stringency. I think the most striking finding is that futures requiring a 100% zero-emissions grid by 2044 require roughly 105 GW of new resources under higher demand conditions, compared to just 30-60 GW for “policy-relaxed” futures that allow continued operation of repowered and new dispatchable fossil generation. Scenarios with no clean energy targets at all land at just 10-35 GW.

For context, New York has added less than 15 GW of new resources to the entire system in the last 25 years. NYISO is telling us, in its own understated way, that the full Climate Act pathway demands a buildout of a scale this state has never attempted — and that relaxing the emissions target by even a modest amount cuts the required build by two to three times.

That is not a subtle distinction. Every gigawatt of new capacity must be paid for by somebody, and in New York that somebody is ratepayers. When NYISO says policy design “significantly impacts scale of new resource development,” what they’re really saying is policy design significantly impacts your electric bill.

Hydrogen: The Expensive Bet NYISO Wants to Avoid

Here’s a detail that deserves more attention than it’s getting. The place holder Dispatchable Emissions Free Resource (DEFR) necessary to keep the lights on during extended periods of low renewable resource availability in the Scoping Plan was hydrogen-fueled generation.  In the fully zero-emissions scenarios, NYISO’s modeling leans on up to 30 GW of hydrogen-fueled generation to provide firm capacity during peak periods — capacity that renewables can’t reliably deliver on their own. The catch: hydrogen-based generation “is not currently available at commercial scale and would require significant investment in infrastructure for fuel production, storage, and transportation, which does not exist today.” It’s the only technology in the entire study that isn’t commercially available now.

Dark doldrums are a significant challenge for a wind and solar dependent electric system but are rare.  NYISO’s report notes hydrogen would be expected to run infrequently, at low utilization, because of high operating costs. So we’re talking about building tens of gigawatts of a generation type that’s unproven, expensive to fuel, and would sit mostly idle waiting for the infrequent periods when it is actually needed. Policy-relaxed pathways eliminate this requirement entirely by letting existing and repowered fossil units continue providing that same firm capacity function. This is about as clean an illustration as you’ll find of the tradeoff between chasing a zero-emissions label and containing costs.

Downstate Ratepayers Are Already Feeling the Squeeze

Figure 8 in the report — “Tightened Supply Conditions Drive Higher Downstate Load Payments” — is the closest thing in this document to a real affordability chart, even though NYISO doesn’t call it that. Under the Contract Case (which assumes only currently-committed resources come online, with no additional buildout), modeled load payments in New York City and Long Island climb sharply between 2030 and 2044, dramatically outpacing every other zone in the state. The report’s own explanation: as generator retirements outpace new firm capacity, downstate load centers become increasingly reliant on imports and “higher-cost resources,” and NYISO explicitly ties this to “increased energy prices.”

Outlook Figure 8: Tightened Supply Conditions Drive Higher Downstate Load Payments

Source: 2025-2044 System & Resource Outlook

This isn’t a hypothetical far-future problem, either. The report states system conditions could become “increasingly susceptible to constrained conditions as early as the mid-2030s” — well within a decade. Note that the costs increase in every region, but if you’re a downstate ratepayer, the Outlook is telling you that the bill for current state energy policy starts arriving in less than ten years. 

Even Current Commitments Aren’t Enough

Maybe the most sobering line in the whole report: “Current resource commitments alone, even assuming all resources that have been awarded Renewable Energy Credit (REC) contracts come into service, are insufficient to meet future system needs over the Outlook horizon.” Read that again. Even in the best case where every renewable energy credit contract signed to date actually gets built on time — which, given New York’s track record of delayed offshore wind and slowed renewable development that this same report acknowledges, is itself optimistic — the system still falls short of what’s needed. That’s before you even get to the question of whether ratepayers can absorb the cost of closing that gap.

The report also quietly concedes that under Higher Demand conditions, the Climate Act-aligned scenario does not achieve the 9 GW offshore wind target by 2035 or the 70% renewable-by-2033 requirement, citing real-world constraints reflected in NYSERDA’s own Large-Scale Renewables Supply Curve. I’ve written about this gap between statutory targets and physical/economic reality before — it’s good to see NYISO’s modeling now says so explicitly.

Transmission Fixes: The Cheap Insurance Policy

To its credit, NYISO does flag some lower-cost opportunities that any policymaker serious about affordability should prioritize. Chief among them: targeted dynamic voltage support upgrades at the Central East interface, which constrains the flow of power from upstate generation to downstate load. NYISO frames this as a way to “increase transfer capability and better utilize existing infrastructure” — bureaucratic language for “get more out of the wires we already have instead of building new ones.” Similarly, bulk transmission upgrades in Northern New York are recommended to prevent curtailment of low-cost renewable output that would otherwise get stranded behind transmission constraints — power that ratepayers already paid to develop but can’t use.

These are the kind of targeted, relatively low-capital investments that should be the easy, no-regrets wins in any planning conversation. Compare that to the cost of building 30 GW of hydrogen infrastructure from scratch, and the contrast couldn’t be sharper.

Discussion

Strip away NYISO’s carefully neutral “objective, fact-based planning insights” framing, and here’s what the 2025-2044 Outlook is actually telling New York’s policymakers:

  • The stringency of the zero-emissions mandate is the single biggest cost lever available. Relaxing it, even partially, cuts required new capacity by two to three times.
  • Betting on hydrogen to fill the capacity gap is a bet on an unproven, expensive technology — and one that policy-relaxed pathways don’t need to make at all.
  • Downstate ratepayers are on track for materially higher costs starting as soon as the mid-2030s, driven by tightening supply and increased reliance on higher-cost generation.
  • Even full delivery on today’s contracted renewable projects won’t be enough, meaning more spending is coming no matter what.
  • The cheapest wins are transmission fixes, not new generation — squeezing more capacity out of existing infrastructure at Central East and unlocking stranded renewable output in Northern New York.

Conclusion

I have long wished that the “independent” NYISO would be more explicit in its analyses about the dangers of political interference in the electric system. They are not in the business of telling Albany politicians what New York climate policy should be, but when their numbers show that the most ambitious version of the Climate Act costs two to three times more in new infrastructure, relies on a technology that doesn’t commercially exist, and hits all New Yorkers with rising bills especially Downstate with its already high prices within the decade — that’s a set of facts policymakers ignore at their own, and ratepayers’, peril.

Implications of the NYISO 2025-2044 System & Resource Outlook

The New York Independent System Operator (NYISO) has released its 2025-2044 System & Resource Outlook (Outlook).  It’s a long-term planning assessment that finds New York will need “substantial new investment in reliable generation and transmission infrastructure to serve growing electricity demand and state policy targets.”  The report supports my contention that the rapid electric system transition to a zero‑emissions grid mandated by New York politicians is technically and institutionally constrained, and that reliability can be put at risk if policy timelines outrun feasible infrastructure and resource development.

I am convinced that implementation of the Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability risks, unacceptable costs, and adverse environmental impacts.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 650 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.  I acknowledge the use of Perplexity AI to generate summaries and references included in this document. 

Background

The NYISO is responsible for electric resource planning for New York State.  The Comprehensive System Planning Process (CSPP) consists of four components: the Local Transmission Planning Process (LTPP), the Reliability Planning Process (RPP), the Economic Planning Process, and the Public Policy Transmission Planning Process. My particular interest is the RPP.

Last December a NYISO update on the CSPP described the Reliability Planning Process.  It is a two‑year process that starts in even years and has two components. The Reliability Needs Assessment (RNA) “evaluates the adequacy and security of the Bulk Power Transmission Facilities (BPTF)

over a seven-year Study Period (years four through ten of the next ten years) and identifies Reliability Needs defined as violations of Reliability Criteria” established by regulatory authorities.  The second component is the System & Resource Outlook that is developed in the years between RNA.s  It includes the following:

  • 20-year study of system and congestion
  • Identifies, ranks, and groups congested elements
  • Assesses the potential benefits of addressing the identified congestion
  • Provides information to developers and marketplace regarding future challenges in the New York power system

The current analysis covers 2025 to 2044, so it must consider the transition requirements of the Climate Act.  NYISO’s long‑term scenarios show that reaching very high levels of zero‑emissions generation is a serious challenge.  This post is an overview of the Outlook emphasizing key insights and recommendations.

NYISO Summary and Key Findings

The press release provides a good overview of the Outlook.

The Outlook is a scenario-based planning study intended to help policymakers, regulators, market participants, and developers understand how different policy choices can shape New York’s future resource mix, transmission needs, system costs, and reliability risks over the next 20 years.

Key findings from the Outlook include:

  • New York’s electricity demand is expected to grow over the next two decades, driven by electrification and emerging large loads that increase total energy needs and reshape when and where demand occurs.
  • All scenarios require significant new generation, and policy-driven scenarios require far more installed capacity than exists today to reliably meet demand.
  • Transmission capability is increasingly central to system performance, public policy achievement, congestion reduction, and the ability of new resources to serve consumers.
  • The Outlook also shows that the final increments of emissions reductions carry the greatest infrastructure challenges. Scenarios that move from 95 percent to 100 percent emissions-free electricity require substantially more investment in replacement resources and anticipate technologies not yet available at commercial scale. By comparison, other scenarios that also lower emissions significantly do so with much lesser investment in generation and transmission.

These analyses compare alternate projections of policy mandates against a business as usual or base case.  NYISO describes the modeling scenarios:

The Outlook is structured around three groups of scenarios that represent the various futures evaluated in the Outlook. The Base Case is a reference future that aligns with the NYISO’s Reliability Planning Process assumptions1 to define the load, generation, and transmission assumptions. The Contract Case builds on the Base Case by adding generation projects with financial commitments (e.g., NYSERDA and offshore wind REC contracts) and approved transmission projects, as well as incorporating projected fossil retirements, to evaluate near-term system conditions as renewables come online and aging thermal units exit. The Policy Case, which includes eighteen scenarios, reflects relevant state policy targets by modeling pathways to meet (existing or delayed) targets like 70% renewables and 100% zero-emissions electricity and evaluates alternative resource mixes—including potential new nuclear and/or fossil—to assess progress toward policy achievement and resulting system conditions.

The Outlook selects two core policy scenarios for detailed production‑cost analysis: one “Higher” pathway that reaches a fully zero‑emissions grid by 2044 and one “Baseline/Policy‑limited” pathway that only achieves roughly mid‑90s percent zero‑emissions by 2044.

Resource Planning

My primary Climate Act implementation concern is the disconnect between the naïve presumption of Climate Act authors that the zero emissions electric system transition was only a matter of political will because the technical, logistical, and economic challenges were small and the reality that those challenges are enormous.  I do concede that at the time the Climate Act was written there was no expectation of significant load growth but that is only one aspect of the problem  The Outlook outlines the real challenges and the approach:

Meeting New York’s future electricity needs will require a significant transformation of the generation fleet, driven by rising demand, evolving policy requirements, and the retirement of existing fossil generation. As conditions evolve, ensuring that sufficient energy and capacity resources are available to serve load becomes increasingly complex. In particular, tradeoffs emerge between the pace, scale, and timing of new resource development, the types of resources available, and the ability of those resources to meet both energy needs and firm capacity requirements across the system.

To explore these dynamics, the Outlook evaluates a range of potential resource pathways that reflect differing assumptions about policy achievement, development pace, and system conditions. These scenarios are not intended to predict a single outcome but rather to illustrate how different combinations of demand, policy, and resource availability can produce materially different system outcomes—and to highlight the implications of those differences for future grid planning.

NYISO explicitly uses alternative futures (including “Higher Demand” and scenarios with advanced nuclear) to highlight that different combinations of resources can hit similar CO₂ outcomes but with very different reliability and feasibility profiles. That is an important distinction.  The statute and agency rhetoric treat “100% zero emissions” as a single, deterministic path in their plans.  In practice resource mix and infrastructure choices matter enormously.

Resource adequacy and reliability risk

The Outlook focuses heavily on resource adequacy through 2044 and shows that preserving reliability under Climate Act‑consistent trajectories depends on how quickly firm capacity is replaced as fossil units retire. NYISO’s analysis indicates that without sufficient dispatchable zero‑emissions resources and/or substantial new nuclear or long‑duration storage, the system faces tighter margins and greater risk, especially under higher load or stressed conditions.

NYISO also examines scenarios where demand is higher and weather or electrification trends deviate from planning baselines, and under those cases the resource and infrastructure requirements to keep reliability within criteria become much more challenging. A long‑standing theme of this blog is that “electrify everything” plus aggressive fossil retirements is a reliability problem, not merely an emissions accounting problem.  Electric systems must be built around reliability during peak demand.  One of my primary concerns with the Climate Act renewable energy mandates is weather variability because the conditions that characterize the highest loads also have the weakest expected wind resource availability.  The Hochul Administration’s planning has emphasized central forecasts and has yet to grapple with the specific challenges associated with extreme cases.

Limits of “100% zero emissions” portfolios

The document notes that alternate scenarios can achieve CO₂ reductions comparable to “100% zero emissions” portfolios while using different mixes of nuclear, storage, and renewables. NYISO explicitly discusses an “Alternate” path and advanced nuclear build‑out with up to 5 GW, limited to Zones A, B, C, and E (Figure 1) as ways to provide firm, clean capacity that ease system stress compared to strictly constrained portfolios.

Figure 1: NYISO New York Control Area Load Zones

Source: NYISO 2025-2044 System & Resource Outlook

Those scenario results essentially validate my arguments that insisting on specific technologies (or excluding others) is a policy choice layered on top of the emissions objective, and that some technology‑constrained paths are significantly more brittle from a reliability and cost perspective. The Outlook’s willingness to model advanced nuclear as a serious resource option contrasts with the Climate Act mandate and lends technical credibility to my arguments about the need for firm zero‑emissions capacity beyond intermittent renewables.

The Outlook finds that “policy design significantly impacts the scale of new resource development”.  For example. “Outlook scenarios without clean energy targets require approximately ~10–35 GW, scenarios with relaxed or partial zero-emissions scenarios require ~30–60 GW, and scenarios targeting a fully zero-emissions system require substantially higher additions— approaching ~105 GW of new resources by 2044 under higher demand conditions.  The difference in costs for all the new resources necessary for zero emissions versus costs for the relaxed emission scenarios relative to the differences in emissions should be an energy policy discussion point.  Furthermore, relaxed emission scenarios eliminate the need for developing hydrogen-fueled generation capacity and infrastructure development that the Outlook estimates at upwards of 30 GW.

Infrastructure, siting, and transmission constraints

NYISO’s long‑range analysis implicitly underscores how much new transmission and bulk infrastructure is required to move large quantities of upstate renewable and nuclear output to downstate loads, and to integrate storage at scale. The scenarios with substantial new nuclear and renewables in upstate zones make clear that geography, siting limits, and zonal restrictions are binding constraints, not footnotes.

By identifying zonal limits NYISO is effectively quantifying some of the siting and societal impacts that disproportionately impact Upstate New York. The Outlook notes:

Downstate capacity requirements continue to shape where firm resources are needed. Because the highest and most constrained load centers remain in downstate New York, locational capacity requirements continue to drive firm and dispatchable resources near those areas. Even in futures with substantial upstate renewable development, additional firm capacity is often needed closer to load centers to satisfy capacity requirements that cannot be met through statewide totals alone.

Resource availability assumptions create a persistent tension between where clean energy is most developable and where it is most needed. Land-based wind and utility-scale solar are more available in upstate zones, while demand remains concentrated downstate. This creates a recurring planning challenge. The system may have strong opportunities to add clean energy where development potential is greatest, but it still requires transmission capability and additional downstate resources to ensure that energy and capacity can serve load.

This supports my concerns that Climate Act implementation treats land use, transmission corridors, and community opposition as solvable details, whereas the system modeling shows they materially shape feasible resource portfolios.

Recommendations

NYISO finds that growing demand and planned fossil retirements mean the system needs “substantial new investment in reliable generation and transmission infrastructure” across all futures. They recommend prioritizing timely development of new resources, especially in policy driven scenarios that require much more installed capacity than exists today.

A central recommendation is to “establish a viable path for the development of resources capable of providing firm capacity and operational flexibility as the generation mix evolves,” explicitly recognizing the need for dispatchable, firm resources even in highly decarbonized futures. NYISO also calls for coordinating the timing of resource additions, repowering, and retirements to reduce transition risk and avoid tightening system conditions during the Climate Act transition.

On the transmission side, the Outlook urges targeted enhancements to increase transfer capability across the Central East interface (e.g., dynamic voltage support) and bulk transmission upgrades to support zero emissions generation development in Northern New York. These are framed as necessary to reduce congestion, improve deliverability, and allow new renewables and firm resources to actually serve downstate load.

Conclusion

The NYISO recommendations address my concerns that: (1) reliability requires firm capacity (DEFRs or equivalent), not just wind/solar/storage; (2) the timing of retirements versus new builds is critical; and (3) transmission constraints are central to Climate Act implementation feasibility, and (4) it is long past time that a feasibility analysis be completed to define New York’s energy future. NYISO’s call for “a viable path” for firm resources and its acknowledgment that policy driven zero emissions futures demand far more capacity than today are similar to my warnings about the DEFR gap and the risk of retiring peakers without firm backup.  Until Climate Act implementation policy aligns with the NYISO Outlook the risks of reliability problems is a serious concern.  The difference in costs for all the new resources necessary for zero emissions versus costs for the relaxed emission scenarios relative to the differences in emissions for the two approaches should be an energy policy discussion point.

Alle-Catt: A Climate Act Project Doing More Harm Than Good

During my career as an air pollution meteorologist, I have done many air quality assessments for new or existing permits.  That process is rigidly quantitative.  The agencies and the applicants must follow specific assessment protocols to determine whether the facility meets specific numerical limits.  If the facility cannot meet those limits the permit to construct or continue to operate cannot be granted.  Period.  This post documents the situation for the Alle-Catt Wind Energy Center where the state permitting process has managed to let the applicant construct wind turbines that cannot lawfully operate because it cannot meet its own noise protection conditions. 

I am convinced that implementation of the Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability, affordability risks, and unacceptable environmental impacts.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 650 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.  I acknowledge the use of Perplexity AI to generate summaries and references included in this document. 

Background

Invenergy’s Alle-Catt Wind Energy Center is a 340-megawatt wind power generation facility in Allegany, Cattaraugus, and Wyoming Counties, New York.  The permitting case is 17-F-0282 – Alle-Catt Wind Energy LLC.  Cattaraugus County Legislator Brenda S. Hanson filed a letter on June 30, 2026 requesting information regarding the current permitting situation:

I write as a duly elected Cattaraugus County Legislator representing constituents who reside in close proximity to the Alle-Catt Wind Farm project in the Towns of Farmersville and Freedom. My constituents and I welcome the Siting Board’s June 23, 2026 denial of Alle-Catt Wind Energy LLC’s petition to amend its Certificate of Environmental Compatibility and Public Need to remove Certificate Condition 68(d)(vi) — the requirement to demonstrate, through pre-construction noise modeling, conformance with the L(night) Design Goal of 40 dBA annual equivalent continuous average nighttime sound level outside any existing non-participating residence.

That denial raises three urgent and distinct questions that I respectfully ask the Board and DPS staff to answer in writing: (1) What is Alle-Catt now obligated to do? (2) Does that obligation extend to turbines already erected in Rushford and Farmersville? (3) What happens if Alle-Catt fails to comply, and who enforces it?

This is Exhibit A in my argument that the environmental permitting process for renewable energy in New York is broken. 

Noise Limit Issues

Alle‑Catt’s Article 10 certificate includes Condition 68(d)(vi), which requires the developer to file a Pre‑Construction Noise Impact Assessment (PNIA) at least 60 days before “Commencement of Full Construction.” That PNIA must demonstrate, through sound modeling, that the project as finally designed will meet a 40 dBA annual equivalent nighttime sound level (Lnight‑outside) at all existing non‑participating residences. In other words, the turbines are not supposed to be built, let alone operated, unless the design can be shown up front to protect neighbors from chronic nighttime noise above 40 dBA.

Cattaraugus County Legislator Brenda Hanson notes in her June 24, 2026 letter that Alle‑Catt’s own December 3, 2025 PNIA predicts that noise at “most receptors” will exceed the 40 dBA Lnight goal. The Coalition of Concerned Citizens’ attorney, Gary Abraham, points out that Alle‑Catt’s later, March 24, 2026 PNIA—filed in redacted form—also shows annual nighttime noise above 40 dBA at many non‑participating homes, even after the applicant’s modeling tricks.

Independent acoustician Robert Rand goes further. Using the methodology the Siting Board actually approved in prior wind cases (Bluestone and Deer River), he reconstructs Alle‑Catt’s long‑term nighttime source power and propagation and concludes that restoring the project’s 2 dB “discount” from an improper ground absorption factor shows the 40 dBA Lnight goal cannot be met at 19 non‑participating residences and 36 non‑participating properties. In addition, there are hundreds of acoustic paths from turbines to residents with concave topography, where the receptor is in a line of sight to the turbine and little or no ground absorption occurs to dampen the noise. Alle-Catt acknowledged this problem in earlier PNIAs but avoided analyzing it in its latest one. In short, under valid assumptions, Alle‑Catt is not designed to  meet the noise condition the developer accepted when it took the certificate.

Inexplicable Siting Board Decision

Despite that, Alle‑Catt has already moved ahead with heavy construction and has erected most of the wind turbines. Hanson’s letter recounts that the Commission’s April 29, 2025 order approved certain compliance filings under Condition 68—specifically 68(a), 68(c)(i), 68(d)(v), (vii), and (viii)—covering excavation, foundations, and erection of the turbines. That is how we arrive at today’s reality: turbines standing in the Towns of Centerville, Rushford and Farmersville, concrete poured and steel in the air.

But the same April 29, 2025 order states, in plain language, that “Alle‑Catt Wind Energy LLC cannot commission or operate any wind turbines” until additional compliance filings under Certificate Conditions 68(b), 68(c)(ii), 68(d)(i), (ii), (iii), and (vi) are approved. Condition 68(d)(vi)—the PNIA demonstrating conformance with the 40 dBA Lnight standard—is explicitly on that list. Hanson rightly asks the Board to confirm that no turbine anywhere in the project area may be commissioned or operated until a compliant PNIA is filed and approved, without exception for turbines already physically erected.  In addition, erection of those turbines violates the Certificate’s requirement to obtain approval of the PNIA at least 60 days prior to commencing full construction.

This is an important point for renewable energy permitting policy: the prohibition is self‑executing. DPS does not need to “decide” to block operation; it has already ordered that Alle‑Catt cannot operate unless and until it proves compliance with the 40 dBA condition. If DPS looks the other way and lets the turbines run without an approved, compliant PNIA, it will be ignoring its own order and its enforcement duty under PSL §168(5).  There is another problem: the Public Service Commission approved commencement of full construction on April 6, 2026, prior to approval of any PNIA for the night noise goal. See DMM No. 883. The June 23, 2026 Order of the Siting Board establishes that no such approval has been granted to date.

On May 7, 2026 Coalition of Concerned Citizens’ attorney, Gary Abraham filed a letter documenting more details about the Siting Board response to the noise condition problem.  Coupled with the Rand filing, they explicitly describe the applicant’s approach and offer evidence that the siting process is broken.  I am not going to provide those details here,

Environmental Impacts

I have long held the position that the Hochul Administration has not properly accounted for cumulative environmental impacts.  In my comments presented on the draft Energy Plan I noted that the last update of the cumulative environmental impact assessment of the transition to net zero was completed in 2020.  Onshore wind projected capacity is 145% higher than previously analyzed, offshore wind is 62% higher, and solar is 241% higher than the maximum scenario expectation in the latest cumulative assessment.

Abraham’s May 7 comments explain that Alle‑Catt’s environmental impacts are not hypothetical.  He reviews the Hearing Examiners’ Recommended Decision and the Siting Board’s certificate order, which estimate 480–515 bird fatalities per year over the life of the project, including six state‑listed threatened or endangered bird species. The record anticipates that at least 41 bald eagle fledglings will be killed or nests will fail over 30 years, associated with one active nest inside the project area and six more close by; most turbines are sited in USFWS “High Mortality Risk to Eagles” zones.

For bats, the project is expected to kill between 26,000 and 39,500 individuals over 30 years, including two species listed as threatened or endangered. Alle‑Catt’s own Exhibit 22 acknowledges that local bat populations will not survive the mortality rate caused by the turbines. On the habitat side, the project removes roughly 1,550 acres of interior forest and fragments about 1,686 acres of unbroken forest out of about 5,900 acres of interior forest in the facility area, degrading movement, breeding, roosting, and nesting behavior for birds and bats.

Since certification, Alle‑Catt has reduced the number of turbines from 116 to 83 and shifted some locations to address landowner concerns, but it retained the original 340 MW capacity by moving to larger Vestas V150‑4.5 machines. Abraham notes that the wind‑swept area of the V150‑4.5 blades (about 17,671 m²) is roughly 20% larger than the GE 3.6‑137 machines modeled in the 2019 PNIA (~14,741 m²). Larger swept area means more blade surface moving through air and thus increased collision risk for birds, bats, and insects, plus an expanded noise footprint, offsetting the modest impact reductions that might have come from fewer towers.  Low frequency thumping sounds as blades cross the tower every second also increases.

The State Department of Health testified during the Article 10 process that the noise levels approved for Alle‑Catt would pose a public‑health risk to host communities, and that shadow flicker above 30 hours per year and 30 minutes per day would likewise be a health concern. The Siting Board rejected DOH’s recommended per‑day limit and noise limit, instead adopting the noise and flicker limits requested by the applicant. Alle-Catt was silent about the night noise requirement, included in all other Article 10 Certificates, but the Siting Board added that to the Certificate after Abraham pointed it out and Alle-Catt accepted it. That was in June 2020. Those decisions are now colliding with Alle‑Catt’s inability to demonstrate compliance even with applicant‑friendly assumptions.

The impacts of these 83 wind turbines are significant.  The State Energy Plan Net Zero scenario projects that 15,700 MW of onshore wind capacity will be needed to meet Climate Act goals.  That equates to 3,800 similar turbines and, if environmental impacts are proportional, statewide environmental impacts 46 times higher than these 83 wind turbines. 

Now What?

Hanson’s letter lays out a layered enforcement framework that now hangs over Alle‑Catt.

  1. PSC has already ordered that Alle‑Catt cannot commission or operate any turbines until a compliant PNIA under 68(d)(vi) is approved.
  2. Certificate Condition 10 gives DPS staff authority to issue stop‑work or stop‑operation orders wherever construction or maintenance violates the certificate or a DPS order.
  3. The certificate spells out a non‑compliance remediation timeline: within 60 days of a non‑compliance finding, Alle‑Catt must file operational and physical minimization options; within 90 days, it must implement operational mitigation; within 150 days, physical mitigation—and if those are not timely implemented, the non‑compliant turbines “must not be operated” until compliance is shown.
  4. Certificate Condition 17 allows the Board to seek penalties not only against the certificate holder but its contractors, and 16 NYCRR 1000.16(e) preserves the Board’s jurisdiction to suspend or revoke the certificate at any point before the final compliance filing is approved. Finally, Public Service Law §168(5) requires DPS to “monitor, enforce and administer” compliance with certificate terms. Hanson asks DPS to confirm in writing that it will use these tools if Alle‑Catt attempts to operate without meeting the 40 dBA Lnight condition.

From a Climate Act permitting perspective, that enforcement puzzle is telling. Either DPS enforces its own orders and certificates, which may leave Alle‑Catt as a stranded, non‑operating monument to bad siting and unrealistic transmission assumptions, or it loosens protections and quietly tolerates non‑compliance to keep the project on the books as “renewable capacity” helping to meet goals. Neither path is a triumph for the environment and non-compliance is not protective of health.

It gets worse.  Abraham’s letter also shows that claimed climate benefits—downstate emissions reductions—depend on transmission upgrades that do not exist and are not planned, in a grid region that is already largely carbon‑free. The project’s output will mostly displace other low‑carbon resources, not fossil generation, and it cannot shut down upstate fossil plants because they are needed to back up intermittent wind. New York is asking rural communities to absorb irreversible environmental and health impacts for a project whose net emissions benefits are “meager” at best.

UPDATE I have been told that today, On July 23, 2026, Cattaraugus County and Abraham’s Coalition of five environmental groups filed petitions requesting that the Siting Board declare what Alle-Catt’s obligations are in light of the Board’s refusal to remove the night noise goal, and Alle-Catt’s inability to demonstrate it can comply. The petitions note that permission to proceed with operations must still be obtained. We will have to wait and see how the Board resolves this mess.

Conclusion

Alle‑Catt shows what Climate Act renewable energy implementation looks like when you strip away the aspirational language and press releases. A rural region loses interior forest, critical bird and bat habitat, and landscape integrity to hundreds of megawatts of industrial turbines. Neighbors face excessive nighttime noise and shadow flicker that the State Department of Health has already flagged as public‑health risks, while the developer cannot even demonstrate compliance with a noise limit under valid modeling assumptions.

If the Climate Act is going to produce more benefit than harm, permitting for projects like Alle‑Catt need to be confronted honestly. That means re‑examining not only noise and wildlife conditions, but also the assumption that any renewable project located anywhere in the state automatically advances climate goals. On the record before us in Case 17‑F‑0282, Alle‑Catt does not. It is a stranded Climate Act project whose primary legacy, so far, is environmental degradation and regulatory contortions, not meaningful emissions reductions.

NYISO on the June-July Heat Wave

I recently analyzed how New York’s grid performed during the late-June/early-July 2026 heat wave.  This post updates that analysis with a  New York Independent System Operator (NYISO) presentation on the heatwave.

I am convinced that implementation of the Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.  I acknowledge the use of Perplexity AI to generate summaries and references included in this document.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Although the original interim 2030 target of a 70% renewable energy electricity mandate has been modified, there still are requirements that require much greater use of wind and solar energy generation.

Electric systems must be built around reliability during peak demand.  One of my primary concerns with the Climate Act renewable energy mandates is weather variability because the conditions that characterize the highest loads also have the weakest expected wind resource availability.  That makes electric resource planning for reliability during the peak period especially challenging.  . 

My post on the performance of New York’s grid performance during the late-June/early-July 2026 heat wave described strong, persistent upper-level ridge and associated surface high forming a classic summer pattern—now branded a “heat dome”—that trapped hot, humid air and stressed electric systems across most of the country. 

I found that the fuel-mix profile over the heat wave showed nuclear at 16% and fossil fuels at 64%, meaning 80% of energy came from non-renewables; renewables provided 20%, but hydro alone was 15%. Those actual operations numbers contrast poorly with statutory mandates—70% renewables by 2030 and 100% zero-emissions by 2040. The data make clear that under classic high-load, low-wind conditions, New York remains heavily dependent on thermal generation, and that building a reliable peak system replacing that with wind, solar, and energy storage alone would be extremely challenging.

The NYISO has been flagging narrow reliability margins, growing dependence on emergency actions, and sensitivity to gas supply and extreme weather for several years.  For example:

  • Summer 2026 Capacity Assessment (Operations Committee): NYISO shows a baseline summer capacity margin of just 417 MW, the lowest in recent history, and warns that under plausible extreme‑heat scenarios the margin turns sharply negative, requiring up to 3,166 MW of emergency operating actions to maintain reliability.
  • NYISO press release “New York Electric Grid Faces Narrow Reliability Margin Heading Into Summer” (April 23, 2026): The NYISO cautions that “extreme weather and aging generation pose significant risks to reliability” and that, under a three‑day heatwave with average daily temperature of 95–98 °F, capacity margins would be ‑1,679 MW to ‑3,370 MW, forcing operators to rely on emergency procedures.

This post describes a presentation that summarizes issues that showed up in the July 2026 heatwave that push these concerns from theory to high-risk reality.

NYISO July 2026 Heatwave

Aaron Markham from the NYISO presented a summary of the July 2026 heatwave to the Operating Committee. While there was some overlap with my post, he had access to other relevant information.  We both addressed  weather and loads and the real-time fuel mix. His presentation discussed unavailable capacity, transmission outages, interchange flows with neighboring areas, and demand response.  Figure 1 lists five key observations about the electric system during the heat wave.

Figure 1: NYISO Presentation Key Observations

Source: NYISO July 2026 Heatwave Presentation

Weather and Loads

The first key observation in Figure 1 described the weather during the event.  Most of this is self-explanatory but the “peak CTHI of 87.1 °F” reference and the “90/10 assumptions” is not.  CTHI is NYISO’s Cumulative Temperature Humidity Index, a three‑day weighted temperature‑humidity metric used to represent heat stress on the system more accurately than regular temperature alone.  The reference “exceeds 90/10 assumptions” means that the observed CTHI during the heat wave was higher than the extreme‑weather (90th‑percentile) conditions NYISO uses in its summer capacity and peak‑load planning studies.

The NYISO presentation included a couple of interesting graphs describing the weather and load.  The summary of the heat wave compares this episode with the NYISO all time high load day (Figure 2).  The observed peak load of 31,097 MW occurred on July 2 which is pretty close to the baseline peak load projection of 31,578 MW.          

Figure 2: June 30 – July 4, 2026 Heat Wave Summary

Source: NYISO July 2026 Heatwave Presentation

In my analysis I mentioned that the loads could have been much worse.  Figure 3 details factors affecting load during the heat wave.

Figure 3: Key Weather and Load Observations

Source: NYISO July 2026 Heatwave Presentation

One of the key observations was that forced generation and transmission outages exceeded planning assumptions in the downstate region and resulted in challenging operating conditions.  Each stacked bar in Figure 4 represents total unavailable capacity on a given day, with the blue portion labeled Prior to DAM (Day Ahead Market) and the orange portion labeled DAM to RT (Real Time). Prior to DAM means units or resources that were already unavailable before the day-ahead market ran, so NYISO could at least account for those outages in its day-ahead commitment and dispatch plan.


DAM to RT means additional capacity that was available or expected in the day-ahead case but then became unavailable during the day.  The horizontal lines show the assumed unavailable-capacity levels from NYISO’s 2026 Summer Capacity Assessment under two planning cases.  It is concerning that downstate New York entered the July heat wave with far more power plants already out of service than planners normally expect and then lost still more capacity as the days  went on, making grid operations much tougher than the official summer assumptions anticipated.

Figure 4: Unavailable Generating Capacity in New York City and on Long Island

Source: NYISO July 2026 Heatwave Presentation

Figure 5 lists the transmission outages during the heat wave.  CHPE is the nearly commissioned Champlain Hudson Power Express transmission line that is supposed to bring 1,250 MW of emissions-free electricity from Quebec directly into New York City precisely to address summer peak loads.  It only worked for 32 hours during the heat wave and has yet to return to service at this time. (20 July 2100)

Figure 5: NYISO Transmission Line Outages

Source: NYISO July 2026 Heatwave Presentation

Figure 6 describes the flow of energy during the heat wave between New York and surrounding electric systems. It shows that, during the peak‑load hours of the June 30–July 4 heat wave, New York was leaning heavily on imports from its neighbors to keep the lights on. The stacked bars break out scheduled flows from Hydro‑Québec even without CHPE, New England, Ontario, and PJM, and the overlay line shows net interchange—imports minus exports—on each day’s peak hour.  Net imports are  consistently above the level assumed in NYISO’s Summer 2026 Capacity Assessment. The chart says that New York needed substantial help from surrounding regions at the exact hours when its own system was most stressed, and that actual reliance on imports was greater than the “normal” planning assumptions, underscoring how tight New York capacity margins have become.

Figure 6: Interchange Flows with Neighboring Areas

Source: NYISO July 2026 Heatwave Presentation

Figure 7 lists the SCR/EDRP Events June 30 – July 4, 2026.  SCR stands for Special Case Resources, and EDRP stands for the Emergency Demand Response Program, both of which are NYISO demand‑response programs that pay large customers to cut their electricity use when the grid is under stress. Figure 6 shows that these emergency tools had to be activated across most of the state on three consecutive days (July 1–3) and again in downstate zones on July 4, which means the system could not meet demand with available generation and imports alone and had to lean on voluntary or obligated load curtailments just to maintain reliability. This pattern is a clear sign of a fragile grid: instead of having enough built‑in capacity margin to ride through a fairly typical multi‑day heat wave, NYISO had to call on “last‑line‑of‑defense” customer cutbacks four days in a row, indicating that routine weather now pushes the system up against its limits.

Figure 7: SCR/EDRP Events June 30 – July 4, 2026

Source: NYISO July 2026 Heatwave Presentation

One of the key observations stated: “The NYISO issued an Energy Watch on July 2 due to forecasted reserves dropping below 2,620 MW for longer than 60 minutes.”  NYISO defines an “Energy Watch” as the point where operating reserves are forecast to fall below 2,620 MW for more than an hour, even though there are still enough resources on paper to meet demand. In practical terms, it’s a first level warning that the cushion of standby generation and imports the system relies on to ride through contingencies is getting uncomfortably thin.  During these conditions operators start lining up extra units, lean harder on demand response, and ask customers to conserve in order to avoid escalating into an “Energy Warning” or full emergency. The fact that NYISO had to issue an Energy Watch on July 2 because reserves were expected to dip below this threshold tells you that a fairly ordinary summer heat wave was enough to erode the safety margin the grid is supposed to maintain.  This is a clear sign that the system is operating closer to the edge than in the past.

Another key observation stated that “Natural Gas Pipeline and Local Gas Distribution Company (LDC) Operational flow Orders were observed during high load periods”.  Operational Flow Orders (OFOs) are directives that gas pipelines and local gas distribution companies issue when the gas system is under strain and they need customers – especially large users like power plants – to keep their gas use tightly in line with what they’ve scheduled, or face penalties and possible curtailments. When NYISO notes that OFOs were in effect during the July heat wave, it means gas operators were already worried about maintaining safe pressures and overloaded pipelines at the same time the electric grid was depending heavily on gas‑fired units to meet peak air‑conditioning load.

That combination is a red flag for the public because it shows both the gas and electric systems were being pushed close to their limits at once. Tight gas conditions can force generators to reduce output just when demand is highest, shrinking the real reserve margin and making the grid more vulnerable to a single large contingency. In the winter natural gas heating raises the demand, and power plants are required to switch fuels to more expensive fuels.  If this kind of gas constraint becomes a recurring feature of hot days, New Yorkers should expect more frequent price spikes, calls to conserve, and a higher risk that even routine heat waves could trigger emergency actions or outages.  There is a second-order impact as well.  Many power plants have limits on the number of hours that they can burn alternate, higher polluting fuels.  If this situation happens frequently enough then this could limit operations from the facilities that provide critically needed energy.

Figure 8 lists generation and import percentages at peak load.  My analysis found that the fuel-mix profile over the heat wave showed nuclear at 16% and fossil fuels at 64%, meaning 80% of energy came from non-renewables; renewables provided 20%, but hydro alone was 15%.  On July 3 renewables produced 41% of the power but on the previous day renewables only produced 20%.  The significant fraction of wind was made possible because the edge of the heat dome was close to New York.  If we were closer to the center, then the wind support at peak load would have been much smaller.  The other observation is that imports accounted for 10% of the energy at peak loads.  Because other electric systems are facing similar problems this may not be possible in the future.

Figure 8: Generation and Imports at Peak Load (%)

Source: NYISO July 2026 Heatwave Presentation

Conclusion Recent NYISO documents explicitly warned that the kinds of problems highlighted by the July 2026 heatwave—thin reserve margins, dependence on emergency actions, and fuel constraints—were coming.  These warnings are translating into observations.  The risks of a fragile electric system must be addressed, or contingencies or worse weather will occur that cause a blackout.  If the system becomes overly reliant on weather dependent resources that

New York Court Refuses to Block State’s Plan for a Renewables Program

For several months my “to do” list has included writing a post about an Article 78 proceeding Richard Ellenbogen and I had submitted with Mathew Hardin.  Article 78 is used to challenge an Agency action by New York State agencies.  I haven’t had a chance to do it but Francis Menton just published an excellent summary of our court case. 

In our case we went after the order approving the Tier Four implementation plan.  This particular component of the Climate Leadership & Community Protection Act (Climate Act) is supposed “to reduce New York City’s reliance on fossil-fuel fired generation”.  We argued that the proposed plan will do no such thing.  Spoiler alert this challenge failed.  With that background I reproduce Menton’s post below.

New York Court Refuses to Block State’s Plan for a Renewables Program

For a couple of years now, I have been collaborating with a small group of friends here in New York to see if we can introduce some rationality into the State’s completely insane energy plans. The other three members of our little cabal (Roger Caiazza, Richard Ellenbogen and Constantine Kontogiannis) are a scientist (Caiazza) and two engineers who are knowledgeable about how the electrical grid works. Our efforts have included things like submitting comments on various regulatory proposals, intervening in Public Service Commission proceedings, and even bringing court proceedings to try to block crazy and impossible schemes from taking effect. So far we have scored exactly zero public successes, although we do occasionally receive communications (always confidential and never in writing) from various bureaucrats who say things like “I know you’re right, but I can’t speak up or I will lose my job.”

On Monday (July 13) we achieved our latest defeat when a Justice of the Albany County Supreme Court (William Little) issued an Order dismissing a Petition we had filed seeking to overturn a May 2025 Order of the Public Service Commission on the subject of the State’s Renewable Program and Clean Energy Standard. The PSC’s Order was issued in one of its proceedings, numbered 15-E-0302. Here is a link to the PSC’s Docket of that proceeding, where the Order in question can be found as item number 1364.

Much of this stuff gets little coverage in the general press, and I thought that readers may be interested in some of the blow by blow.

The backstory is that New York adopted a Climate Act back in 2019, mandating conversion of the electrical grid to a zero emissions system by 2040, with interim deadlines; and under that statute various state agencies got tasked with figuring out how to do it. Note that there had not been in 2019, nor has there been as of today, any demonstration project or feasibility study on how to make a functional “zero emissions” electrical grid that can fulfill the demands of our economy. The State agencies that got the task, in this instance, were mainly the Public Service Commission (PSC) and the New York State Energy Research and Development Authority (NYSERDA).

So, how to move forward? Well, if you’re the PSC, your standard MO is to conduct some kind of massive quasi-litigation “proceeding,” where everybody and his brother gets invited to toss ideas into the hopper, and eventually the all-knowing bureaucrats somehow digest it all and ultimately apply their infinite expertise to issue a ruling to tell everyone what to do. Did that model make any sense in this instance? Well, central planning in general never makes any sense. And anyway, it doesn’t matter, because this is what the PSC does and it’s all they know how to do; and so, if they’re in charge, this is how it’s going to be done.

Here, by the time the Climate Act came down in 2019 the PSC already had one of these “proceedings” going, number 15-E-0302, with the title “Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard.” So they decided to use that proceeding as a vehicle for coming up with Orders to tell the peons what to do.

In 2023, Ellenbogen and Caiazza decided to get involved, and started throwing comments into the mix. This was before I began working with them, so I never personally became a party in this proceeding. On the PSC Docket at the link above, the following are comments submitted by those two prior to the PSC’s May 2025 Order: # 1094, 8/16/23, by Ellenbogen; # 1203, 2/20/24, by Ellenbogen; # 1255, 7/30/24, by Ellenbogen; and # 1348, 2/24/25, jointly by Caiazza and Ellenbogen. There may also be others that I have missed; plus, Ellenbogen continued to submit comments after the May 2025 Order came down.

The gist of the comments was that the State’s plans for the electrical grid, particularly for primarily wind and solar generation and battery backup, were essentially impossible and could never work. As just a couple of examples of points made in these extensive comments, this is from the initial Ellenbogen Comment of 8/16/23:

[T]he way that the [New York State Climate Act] policy is structured cannot possibly work and it is going to cost the state hundreds of billions of dollars, while not reducing atmospheric carbon, and worse yet, it precludes methods of reducing carbon emissions that actually will work much more rapidly based upon the physics of how utility systems actually operate. . . . The issues with the CLCPA Plan are as follows:

1 – There is a lack of available energy to support the Plan

2 – Costs to implement the Plan will far exceed other, better solutions. These costs accrue based upon shortages of materials and skilled labor, high energy storage costs, and a lack of financial adequacy

3 – Atmospheric Carbon Levels will rise far above what could be achieved using other alternatives

4 – Planned timing mandates are unachievable. . . .

All these points are then fully supported in the text of the comment.

In their joint comment in February 2025, Caiazza and Ellenbogen raised the absurd fact that New York State agencies had recognized that an emissions-free grid could not be achieved without something called “dispatchable emissions-free resources,” or DEFRs, but that these DEFRs did not exist. Excerpt:

Responsible New York agencies all agree that new [dispatchable emissions-free resources] DEFR technologies are needed to make a solar and wind-reliant electric energy system work reliably. No one knows what those technologies are. We 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. This situation is a fundamental reason why a pause [of Climate Act implementation] is necessary. If the only viable DEFR solution is nuclear, then the wind, solar, and energy storage approach cannot be implemented without nuclear power. Using nuclear solely as a backup is inappropriate because it works best as a baseload resource. Developing baseload nuclear eliminates the need for a huge DEFR backup resource and massive buildout of wind turbines and solar panels sprawling over the state’s lands and water. NYSERDA and DPS have a five-year plan presumably to determine what technology should be used going forward. It is obviously prudent to pause renewable development until some DEFR technology is proven feasible.

Needless to say, the PSC paid no attention whatsoever to these comments. On May 16, 2025 it went ahead and issued its Order. The gist of the Order is to approve something called the “Tier 4 Implementation Plan” put forward by NYSERDA. The final version of that Plan was then issued by NYSERDA in June 2025, and appears as item 1367 on the PSC Docket of the case. It is about as dense an example of bureaucratese as anything you will ever read. Go ahead and try to read it if you don’t mind losing a few million brain cells. It’s about some various trading schemes for some kinds of RECs (renewable energy credits), and systems for meeting the CES (clean energy standards). None of it has any chance of accomplishing any actual material reduction in greenhouse gas emissions (in case you think that might be significant), but by failing to pay attention to new reliable generation it puts grid reliability at serious risk.

So in August 2025, Ellenbogen and Caiazza filed what is called in New York an Article 78 proceeding, which is a court case challenging the action of a state agency as “arbitrary and capricious.” (I did not join as a party in this proceeding because I had not gotten involved early enough to submit my own comments in this particular case.). The Petition filed in court by Ellenbogen and Caiazza substantially tracked the comments that they had submitted in the PSC proceeding. Excerpt:

This case seeks judicial review of a May 16, 2025 decision of the New York Public Service Commission (“PSC”) in its Case No. 15-E-0302, which is attached hereto as Exhibit A. In that PSC case, the agency approved a petition by the New York State Energy Research and Development Authority (“NYSERDA”) proposing a Clean Energy Standard (“CES”) Tier 4 Implementation Plan. . . . The PSC does not appear to have considered or rationally evaluated the evidence presented to it, to the effect that the Tier 4 Implementation Plan is unfeasible and unreasonable. Mr. Caiazza and Mr. Ellenbogen each submitted comments to the PSC before it adopted the Tier 4 Implementation Plan. Mr. Ellenbogen specifically notified the PSC that:

• There is a lack of available energy to support the Plan.

• Costs to implement the Plan will far exceed other, better solutions.

• These costs accrue based upon shortages of materials and skilled labor, high energy storage costs, and a lack of financial adequacy.

• Atmospheric Carbon Levels will rise far above what could be achieved using other alternatives.

• Planned timing mandates are unachievable.

Basically, Ellenbogen and Caiazza are completely right on all of these points. So how did the court find a way to dismiss the case? Easy! It found that the case had not been timely filed under the relevant statute of limitations. In this case the relevant statute of limitations provides that the case must be filed within four months of the Order being challenged, and this case was in fact filed within that window. However, the court found that NYSERDA, and not just the PSC, was a “necessary party” to the case; and the original Petition, which was timely, had failed to name NYSERDA. When the PSC had complained that NYSERDA should have been added as a party, Ellenbogen and Caiazza promptly added that additional agency. But that occurred some days after the four month statute had expired. Too bad! And by the way, just in case this bullshit technicality may not stick, the court adds that Ellenbogen and Caiazza don’t have “standing” because they have not suffered a sufficiently “particularized” injury to complain.

Are you shocked by the result? I am not. Sure the PSC and NYSERDA are doing absurd things here that are the very definition of “arbitrary and capricious” actions that Article 78 proceedings are designed to address. However, I am not surprised that Justice Little was looking for an easy exit strategy. Implementation of the impossible Climate Act mandates is perhaps the biggest political hot potato in New York at the moment. Would one lonely trial court judge in Albany really stick his neck out to try to stop the vast climate juggernaut arrayed in our state against the boogeyman enemy of carbon emissions? Unlikely.

Concluding Remarks

My thanks to Menton for preparing this summary. He summarized my thoughts perfectly:

A victory would have been great. But piece by piece we are laying down markers that become increasingly difficult for the bureaucrats to ignore. We may be only four people, with thousands lined up against us. But we do have math and physics on our side. Eventually we will prevail.

Comparing the New York Energy Transition Against the World

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

I am convinced that implementation of the Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

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

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

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

New York Data

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

Generation Trends

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

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

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

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

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

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

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

Net-Zero Transition Projection

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

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

Figure 4:  Global Net-Zero By 2050 Requirement

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

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

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

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

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

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

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

Decarbonization Trend

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

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

Two things follow.

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

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

Figure 6: Global Decarbonization 1992-2025

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

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

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

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

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

Figure 8: Factors Affecting Decarbonization 1990-2025

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

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

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

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

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

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

Discussion

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

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

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

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

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

Conclusion

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

June 29 – July 4 2026 Heat Wave Weather Impacts to the New York Grid

Last week a strong, persistent upper‑level ridge and associated surface high formed a classic summer ridge (which the media now hypes as a heat dome)  over the central and eastern United States, acting as a subsident “lid” that trapped and reinforced hot, humid air over several days.  These conditions stressed electric systems across the country. This post offers examines the availability of New York renewable energy resources during classic high-load hot weather conditions. 

I am convinced that implementation of the Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Although the original interim 2030 target of a 70% renewable energy electricity mandate has been modified, there still are requirements that require much greater use of wind and solar energy generation.

Electric systems must be built around reliability during peak demand.  One of my primary concerns with the Climate Act renewable energy mandates is weather variability because the conditions that characterize the highest loads also have the weakest expected wind resource availability.  That makes electric resource planning for reliability during the peak period especially challenging.  . 

Earlier this year I wrote multiple articles about the January 23-27 winter storm and subsequent cold snap that lasted until February 9.  This is a good case study for a New York extreme event that must be addressed by electric system planners.  I described the New York Independent System Operator (NYISO) document Winter 2025-2026 Cold Weather Operations and the Climate Act transition implications.

For this assessment of the heat wave, I relied on the New York Independent System Operator (NYISO) fuel-mix load data are available at the NYISO Real-Time Dashboard.  For last winter’s analysis I used the Operations Performance Metrics Monthly Report prepared by the NYISO Operating Committee that data set is not available yet.  This article is limited to the description of the weather, generation mix, and resulting loads. 

NYISO Real-Time Fuel Mix

The dashboard real-time fuel mix data includes links to current and historical five-minute generation (MW) for energy generated in New York State.  I processed that data to calculate hourly averages.  The generator types include “Hydro” that includes pumped storage hydro; “Wind”, mostly land-based wind but does include 136 MW of offshore wind; “Other Renewables” that covers solar energy (394 MW of “front-of-the-meter solar”), energy storage resources (63 MW), methane, refuse, or wood; “Other Fossil Fuels” is oil; “Nuclear”; “Natural Gas”; and “Dual Fuel” which are units that burn both natural gas and oil.

Figure 1 graphs all the fuel mix hourly data and Table 1 summarizes the data. The relative average fuel mix energy provided over the heat wave was nuclear 16% and fossil fuels 64% for a total of 80%. Although renewables accounted for 20%, hydro made up 15% of that.  This year’s Budget Bill revised the Climate Act but the core power‑sector mandate—70 percent renewable electricity by 2030 and 100 percent zero‑emissions electricity by 2040—remains intact.  Clearly power generation during this heat wave is nowhere near these mandates.

Figure 1: Hourly NYISO Realtime Fuel Mix June 29 – July 4, 2026

Table 1: Summary of Hourly NYISO Realtime Fuel Data Mix June 29 to July 4, 2026

These data do not show the contribution of wind and solar well.  “Other Renewables” includes solar energy (394 MW of “front-of-the-meter solar” at the end of 2025), energy storage resources (63 MW), methane, refuse, or wood. The methane, refuse and wood facilities show up as the relatively constant base in Figure 3.  If the 63 MW of energy storage is too small to show up, that means that the utility-scale “front-of-the-meter” solar shows up as the daily peaks each day.  It appears that there some component of “Other Renewables” is base load because the nighttime values all are approximately 300 MW

Figure 3: Hourly NYISO Realtime Fuel Mix Other Renewables and Wind June 29 to July 4, 2026

Weather

New York wind resource availability dodged a bullet during this episode.  Northeastern United States heat waves are typically associated with high pressure systems, the media hyped “heat dome”, and the location of the center of the dome makes all the difference.  I combined daily NYISO realtime fuel data mix data and the June 29 daily weather map in Figure 4 and Table 2 to show how bad it could have been.  The Weather Prediction Center National Center Environmental Prediction National Oceanic & Atmospheric Administration provides daily weather mapsthat I used to describe the weather during this heat wave episode.

The daily weather map for June 29, 2026, shows that there was a high-pressure system centered over  New York.  The brown lines are isobars that show constant atmospheric pressure. Wind speed increases as the distance between isobars get smaller. Note that there are two closed 1020 isobar circles labeled with “H” in Quebec and western PA that are both labeled with pressures of 1021 millibars (mb).  I have added four orange arrows that highlight the location of the 1016 mb contour.  On an east to west basis the dome of air pressure greater than 1016 mb is over a 1000 miles with a peak at 1021.  North south the dome is even longer.  This weak pressure gradient led to extraordinarily weak wind production for New York’s land-based and offshore wind generators (Table 2). 

Figure 4: June 29, 2026 Weather Map at 7:00 AM EST

Table 2: Hourly Data for June 29, 2026

I maintain that New York dodged a bullet because the center of the high pressure system was mostly south of New York for the rest of the event as opposed to June 29.  Consider July 1 as shown in Figure 5.  The pressure gradient on this day between 1012 mb and 1016 mb is on the order of 300 miles as opposed to 500 miles on June 29. Table 3 lists the hourly data statistics for the two days. It is important to note that even though July 1 wind resources are better the average generation was only 1,000 MW which represents 35% of the total NYS wind capacity of 2,858 MW.  That is not terrible, but it surely is not good.

Figure 5: Jul 1, 2026 Weather Map at 7:00 AM EST

Table 3: Hourly Wind Statistics for June 29 and July 1

Figure 6 shows all the weather maps for the episode and I have prepared documentation with more details.  The location of the high pressure ridge or dome was far enough away from New York that wind speeds did not drop off like they did on the June 29.

Figure 6: June 29 – July 4, 2026 Weather Maps at 7:00 AM EST

Because Behind-the-Meter solar data are only provided in the NYISO Operations Performance Metrics Monthly Report I was not able to determine the solar resources available.  I would expect that they would be as good as they can get because the weather system had few clouds, the days were about as long as they can get and the solar angle maximized solar radiation to the panels.

Conclusion

There is no meteorological reason that the high-pressure system ridge or heat dome could not have been centered close enough to New York to replicate the poor wind resource availability or that these conditions could not have persisted longer.  The takeaway message from the 2026 extreme winter and summer weather observed is that in the winter solar can go to zero availability and wind availability can go to zero at any time.  This makes providing reliable electricity using an electric system that dependent upon wind and solar extremely challenging.  In my opinion the challenge is so large that it is more appropriate to rely on nuclear power as the backbone of the future electric system.