Category: Climate Act

My last post described  comments submitted by the New York Independent System Operator (NYISO) on the New York Draft State Energy Plan prepared by the New York State Energy Research & Development Authority (NYSERDA).  This post summarizes the NYISO recommendations.

Net-Zero Aspirations

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

According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.”  This is the first update of the Energy Plan since the Climate Act was passed in 2019, so it will incorporate the net-zero mandates.  I have provided more background information and a list of previous articles on the Energy Plan on a page dedicated to the process. 

NYISO Overview of System Trends

The NYISO comments point out that there are three “structural trends” that create significant uncertainty about the future electric system:

The New York grid is at an inflection point, driven by the convergence of three structural trends: the aging of the existing generation fleet, the rapid growth of large loads, and the increasing difficulty of developing new dispatchable resources. These trends are not isolated, they are compounding. Generators in New York are among the oldest in the country. Large energy-intensive economic development projects, such as semiconductor manufacturing plants and data centers, are driving up demand for electricity significantly after relatively flat demand trends over the last decade. Collectively, all these elements create uncertain conditions today, in the near term, and in the longer term, and each uncertainty has the real potential to cause major impacts on electric system reliability. All electric industry stakeholders, including the state agencies involved, must be aware of and factor these concerns into their planning and strategy.

The NYISO comments describe the electric grid inflection point driven by several structural trends.  I believe their comments and recommendations also represent a Climate Act inflection point.  The NYISO comments and the Draft Energy Plan include statements that contradict the heretofore sacrosanct underlying assumptions of the authors of the law.  The majority of the Climate Action Council supported  Dr. Robert Howarth who believed that the transition away from fossil fuels would require no new technology, could be done quickly, could “be fueled completely by the power of the wind, the sun, and hydro”, that it would “be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs.”  I have argued that none of these beliefs are supportable but state organizations have not forcefully agreed with my comments.

It is encouraging that five NYISO concerns described in their comments contradict those fundamental presumptions:

1. Electric Grid Concerns Exist Today
2. Repowering Existing Generation and Introducing New Generation Will Prove Critical to Maintaining Electric System Reliability
3. Existing Nuclear Generation is Critical to Meeting the Demands of New Yorkers
4. Emerging Technologies and Other Resource Development
5. Key Risk Factors Shaping the Grid

Furthermore, there are six extensive quotations from the Draft Energy Plan that NYISO supports.  I have included those quotes in an addendum to this article.  They represent previously unacknowledged NYSERDA departures from the Climate Act ambition and schedule:

1. The State will need to be strategic about the pace of combustion unit retirements and/or replacement
2. Combustion generating units will remain essential parts of electric grid reliability and affordability. Retirement of these units will not be able to occur until resources that provide the same grid reliability attributes are put in place.
3. A primary challenge for New York’s energy system is its advancing age, which creates unique risks for reliability.
4. The State will need to be strategic in identifying and integrating clean firm technologies that have the attributes necessary to support the achievement of a zero emissions electric grid by 2040.
5. For the electricity system, continue to incorporate the impacts of climate change into future reliability planning scenarios.
6. Consider whether the current reliability-related metrics should be supplemented given the evolving nature of the grid and increased risks of high-impact reliability events

This article describes NYISO recommendations associated with their concerns and these quotes.  These admissions suggest that the NYSERDA Draft Energy Plan offers hope that reality is finally filtering through to New York energy policy. 

Recommendations

This section describes the recommendations from NYISO.  I believe they support my hope that we are at an inflection point regarding Climate Act implementation.

To this point the political belief that building as much renewable energy as possible as fast as possible would mean that fossil-fired generating units could quickly be retired.  NYISO recommends otherwise:

The final State Energy Plan must include a recommendation consistent with the Draft Plan observations that combustion generating units “remain essential parts of electric grid reliability and affordability, and retirement of these units will not be able to occur until resources that provide the same grid reliability attributes are put in to place.”

Soon after the passage of the Climate Act, the New York State Department of Environmental Conservation, undoubtedly at the direction of the Hochul Administration and cheered on by all the environmental organizations in the state, denied permits for new natural gas-fired power plants at Danskhammer and Astoria (including my thought) because they were inconsistent with the Climate Act.  The NYISO suggests that this was a fatal conceit because there were no plans to maintain reliability, just the presumption that the transition was only a matter of political will.  Frankly, it was disappointing that the NYISO did not comment during the permitting process and say it would be premature to reject the applications until all the ramifications were considered.  Now NYISO says:

The electric system needs all existing generation resources and needs new generation resources before the current fleet suffers a catastrophic failure that jeopardizes the health, safety, and welfare of New Yorkers. The final State Energy Plan must include a recommendation removing barriers to new resources to address the age of the generation resources that are critical to maintaining electric system reliability.

Better late than never but in my opinion, NYISO could have submitted the following comment as part of the permitting process for the proposed facilities that were rejected:

The age of the existing generation fleet and the lack of viable alternative technologies require steps to use the best technology currently available.  The final State Energy Plan must include a recommendation to facilitate development of natural gas-fired combustion generation to immediately support electric system reliability and be available until new, dispatchable, emission-free generating technologies are commercially available to support electric system reliability, e.g., hydrogen and advanced nuclear.

Anyone who understands the electric system understands that nuclear resources must be part of a lower carbon electric system.  Ideological zealots do not accept that and still demand no nuclear power in the future.  I agree with NYISO’s recommendation to keep existing nuclear facilities in operation:

The reliability attributes and overall energy production that nuclear resources provide to

the electric system unquestionably demonstrate the need for these resources to remain available in New York. The final State Energy Plan must include the recommendation from the Draft Plan to complete the ZEC program “evaluation prior to any federal relicensing application deadlines, to ensure the continued operation of the existing nuclear fleet to contribute to climate goals and help maintain fuel diversity and fuel security.

The NYISO made a pragmatic recommendation for emerging technologies and noted that continued investments in current technologies are needed:

Given the significant need for resources demonstrated by the Outlook and contemplated in the Draft Plan, the final State Energy Plan should explore all emerging technologies, while focusing on promising technologies that will be readily available sooner and continuing to invest in current technologies including repowering fossil-fuel-fired generation to support fuel diversity and overall electric system reliability

The Recommendations section in the NYISO comments makes suggestions for inclusion in the Final State Energy Plan:

The NYISO applauds the Draft Plan’s efforts to holistically consider the multiple goals and long-range planning objectives around New York’s energy systems. The NYISO maintains that a reliable electric system supported by competitive wholesale markets must serve as the cornerstone to meet New Yorkers’ daily needs and advance broader economic objectives. The final State Energy Plan must focus on energy system reliability and acknowledge that both the near- and long-term future of the electric system are subject to numerous uncertainties. These uncertainties must be continually reevaluated through impactful, independent analysis, and planning processes like the NYISO’s Reliability Planning Process.

Schedule Inconsistencies

Problems associated with the Hochul Administration’s blind adherence to the Climate Act law are occurring today.  The NYISO comments stated:

During the summer of 2025, the NYISO was forced to declare several energy emergencies due to tight supply conditions as heat waves affected much of the Eastern Interconnection and real-time demand approached the seasonal 90/10 forecasts.

Reliability studies have shown that current and future electric system reliability in New York is, in part, dependent on scheduled imports and emergency assistance from neighboring control areas. New York’s eroding statewide reliability margins assume that all firm scheduled imports from neighboring systems are available when needed.  However, these neighbors are experiencing tighter margins for many of the same reasons as New York and may not be able to deliver power to New York due to their own system needs.

The NYISO comments point out that the implementation schedule is falling behind and that it is unlikely to get better anytime soon.

Supply chain issues are currently driving long lead times for the delivery of equipment needed to construct energy infrastructure and delays in receiving necessary permits to build projects increase risk for planned projects to meet their proposed in-service dates. Projects facing these uncertainties could include key transmission projects like Champlain Hudson Power Express (“CHPE”) and Propel NY Alternate Solution, which are expected to be necessary to improve and maintain overall electric system reliability.

The NYISO’s Reliability Planning Process currently assumes that more than 4,400 MW of new resources will be in service by the end of 2028, a majority of which are comprised of solar resources and offshore wind resources. Recent actions taken by the federal government have drastically impacted the prospective development and construction of offshore wind and other renewable resources.

Potential delays for these types of projects have become more likely since the Draft Plan was prepared and issued. Any delay or cancellation of these resources coming into service will have adverse effects on system reliability.

Discussion

I think there are indications that the realistic approach recommended in the NYISO comments are being considered as illustrated by some NYSERDA statements in the Draft Energy Plan.  Unfortunately, the ideological environmental organizations who take credit for the passage of the Climate Act vociferously argue that the Climate Act law requires that the Act’s mandates must be met.  However, they do not acknowledge New York Public Service Law § 66-p (PSL 66-P) “Establishment of a renewable energy program” that includes safety valve conditions for affordability and reliability. 

In my opinion, the Hochul Administration has excuses that they can use to deflect the maniac response.  In early August I co-authored a filing to New York Public Service Commission (PSC) Case 22-M-0149 – Proceeding on Motion of the Commission Assessing implementation of and Compliance with the Requirements and Targets of the Climate Leadership and Community Protection.  The filing argued that there are sufficient circumstances to warrant the PSC commencing a hearing process to consider modification and extension of New York Renewable Energy Program timelines consistent with PSL 66-P.  If the PSC were to act on our filing, then they could pause implementation.

Given that the entire process has always been about politics the more likely excuse is to blame the Trump Administration. Draft Energy Plan Section 1 of the Summary for Policymakers at p. 3 provides a draft rationale for this approach.  It states:

The federal administration’s energy and unpredictable tariff policies bring additional political and regulatory uncertainty, which threatens critical federal support for clean energy development and creates barriers to private investment. This includes the rollback of tax credits provided under the Inflation Reduction Act, planned denial of permits for wind generation, and attempts to remove state-based clean car and clean truck rules.

I believe that resolving these constraints is going to come to a head by the end of the year.  If the Final Energy Plan incorporates the NYISO recommendations, then it acknowledges that the Climate Act mandates cannot be achieved on schedule.  The meltdown of the proponent constituency will be enormous.

Conclusion

I cannot over emphasize how much I agree with the NYISO description of the importance of the electric system:

Progress towards the Climate Act goals, other public policies, and supplying the electricity that New Yorkers demand requires the State Energy Plan to support a well-functioning, reliable electric power sector. Reliable electric power is the foundation of the State’s plans to electrify other aspects of the economy and to reduce emissions. The NYISO urges the Board and NYSERDA to consider these comments and prioritize electric system reliability in the final State Energy Plan.

If the State continues the implementation approach embedded in the Scoping Plan I have no doubts that there will be a blackout.   The negative impacts will not be model predictions or value-laden possible societal costs.  Instead, there will be real deaths, enormous costs, and unnecessary time and effort fixing the problems identified by the NYISO. 

Given that New York cannot solve global warming on its own, it is time for politicians to modify the schedule of the Climate Act and define acceptability limits for affordability, reliability, and environmental impacts.   It is also time for the Hochul Administration to grow a spine and incorporate all the NYISO recommendations in the Final State Energy Plan despite the inevitable environmental community backlash.  Will the political calculus cater to a constituency that does not understand the electric system and will never be happy or will they move to keep the lights on?

Addendum: NYISO Draft Energy Plan Quotes

This addendum lists the NYISO comments that reference sections of the Draft Energy Plan that are consistent with their concerns.

In the discussion of eroding reliability margins NYISO quotes the Draft Plan saying it “accurately points out” that:

The State will need to be strategic about the pace of combustion unit retirements and/or replacements as it works towards its clean energy goals and to meet reliability needs as quickly and cost-effectively as possible. Combustion generating units will remain essential parts of electric grid reliability and affordability, and retirement of these units will not be able to occur until resources that provide the same grid reliability attributes are put in place. New York will seek to carefully manage the retirement of existing assets and evaluate whether there is a need for new generation that is compatible with long-term policy targets.

NYISO goes on to note that “This theme continues in the Electricity chapter of the Draft Plan.”

Combustion generating units will remain essential parts of electric grid reliability and affordability. Retirement of these units will not be able to occur until resources that provide the same grid reliability attributes are put in place. Additionally, there are specific considerations with respect to the small clean power plants, or “peaking units”, owned and operated by NYPA. By 2030, NYPA will cease production of electricity at its peaking units unless the closure of any specific facility would result in increased emissions in a DAC or the facility is needed for reliability. With these strategic and statutory considerations, New York will seek to carefully manage the retirement of existing assets and evaluate whether there is need for new generation that is compatible with long-term policy targets.

In the section describing the age of the generation fleet NYISO states that it “supports and emphasizes the Draft Plan’s observations around aging generation”:

A primary challenge for New York’s energy system is its advancing age, which creates unique risks for reliability. The NYISO has reported, for example, that by 2028 a quarter of the state’s combustion generators (by capacity) will reach an age at which most such facilities are retired. For several utilities serving the Hudson Valley and Upstate New York, 60 percent to over 95 percent of transmission structures are 70 years old or older. The oldest still operational natural gas pipeline in New York dates to the Centennial, turning 150 years old next year. This aging infrastructure is more prone to failure, requiring more costly repairs, and results in a greater environmental impact than newer technologies.

The discussion of emerging technologies states “The Draft Plan accurately recognizes that”:

The State will need to be strategic in identifying and integrating clean firm technologies that have the attributes necessary to support the achievement of a zero emissions electric grid by 2040. Results from the study described in Section 4.3 will be leveraged to identify and propose pathways for the deployment of those technologies that have the greatest potential to solve the reliability needs expected to arise with the energy transition. The State will also pursue continued support for innovation and demonstration projects, as appropriate. These efforts will be critical, as many of the technologies under consideration to meet system needs for firm, dispatchable capacity (e.g., combustion of alternative fuels, nuclear, long-duration energy storage, etc.) are not commercially available at scale today.

NYISO comments describe key risk factors shaping the grid.  Included in the discussion of weather risks is support for the following Draft Plan recommendation:

For the electricity system, continue to incorporate the impacts of climate change into future reliability planning scenarios. Further consider whether the current reliability-related metrics should be supplemented given the evolving nature of the grid and the increased risks of high-impact reliability events. Establishing criteria for metrics like effective unserved energy (EUE) may help supplement traditional criteria based on loss of load expectation (LOLE) by providing information about risks of long-duration outages

Later in the same section NYISO states “The final State Energy Plan should include the related recommendations discussed in the Electricity Chapter of the Draft Plan”:

Consider whether the current reliability-related metrics should be supplemented given the evolving nature of the grid and increased risks of high-impact reliability events. New York should consider whether the current reliability-related metrics (i.e. loss of load expectation) should be supplemented given the evolving nature of the grid and the increased risks of high-impact reliability events. Establishing criteria for metrics like expected unserved energy (EUE) may help supplement traditional LOLE-based criteria by providing information about risks of long-duration outages. As fuel availability will be incorporated into the NYISO’s capacity accreditation framework, additional consideration should be given to whether this adjustment to capacity accreditation provides sufficient incentives and compensation to resources for attributes needed to ensure energy adequacy and resilience to extreme weather events from both a planning and operational perspective (e.g. compensation for fuel storage capabilities).

The New York Draft State Energy Plan prepared by the New York State Energy Research & Development Authority (NYSERDA) comment period closed on October 6.    This post summarizes the comments submitted by the New York Independent System Operator (NYISO).  It turned out that there was so much information that I am going to do a follow up post describing their recommendations.

Net-Zero Aspirations

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

According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.”  This is the first update of the Energy Plan since the Climate Act was passed in 2019, so it is being revised to incorporate the net-zero mandates.  I have provided more background information and a list of previous articles on my Energy Plan page. 

NYISO Overview of System Trends

The NYISO comments point out that there are three “structural trends” that create significant uncertainty about the future electric system:

The New York grid is at an inflection point, driven by the convergence of three structural trends: the aging of the existing generation fleet, the rapid growth of large loads, and the increasing difficulty of developing new dispatchable resources. These trends are not isolated, they are compounding. Generators in New York are among the oldest in the country. Large energy-intensive economic development projects, such as semiconductor manufacturing plants and data centers, are driving up demand for electricity significantly after relatively flat demand trends over the last decade. Collectively, all these elements create uncertain conditions today, in the near term, and in the longer term, and each uncertainty has the real potential to cause major impacts on electric system reliability. All electric industry stakeholders, including the state agencies involved, must be aware of and factor these concerns into their planning and strategy.

The comments describe five concerns associated with these trends:

1. Electric Grid Concerns Exist Today
2. Repowering Existing Generation and Introducing New Generation Will Prove Critical to Maintaining Electric System Reliability
3. Existing Nuclear Generation is Critical to Meeting the Demands of New Yorkers
4. Emerging Technologies and Other Resource Development
5. Key Risk Factors Shaping the Grid

I will summarize each of these concerns

Today’s Electric Grid Concerns

The discussion of the current electric grid concerns addressed two of the structural concerns. The first discussion addressed the fact that reliability margins are eroding.  Simply put more generation resources are retiring than being brought online: “As of June 2025, 4,315 MW have left the system while only 2,274 MW have been added since the passage of the Climate Act.”. 

I submitted comments that explained that I believe that NYSERDA was only paying lip service to the stakeholder process.  In the absence of a commitment to provide written documentation responding to all comments submitted that I decided not to try to review the Draft Energy Plan in any detail.  Due to the press of other commitments, I only provided comments on the Health Benefits Analysis Chapter.  I did not even read the other chapters.  As a result, I was pleasantly surprised that the NYISO comments noted that the Electricity chapter of the Draft Plan “accurately points out” that:

Combustion generating units will remain essential parts of electric grid reliability and affordability. Retirement of these units will not be able to occur until resources that provide the same grid reliability attributes are put in place. Additionally, there are specific considerations with respect to the small clean power plants, or “peaking units”, owned and operated by NYPA. By 2030, NYPA will cease production of electricity at its peaking units unless the closure of any specific facility would result in increased emissions in a DAC or the facility is needed for reliability.

I agree that these are accurate statements.  I provided a comment that pointed out that the Climate Act dismissal of natural gas attributes was irrational and that the arguments about problems with peaking units were wrong.  The continued operation of these facilities will have no discernable impact on local neighborhood air quality and shutting them down is solely political virtue-signaling

The NYISO comments also noted that New York’s generators are among the oldest generators in the nation.  I knew they were old but I was surprised that “New York’s statewide fleet of fossil-fuel-based generation includes more than 10,000 MW that has been in operation for more than 50 years.”  Also, NYISO “supports and emphasizes” the Draft Energy Plan’s comment on the transmission system: “For several utilities serving the Hudson Valley and Upstate New York, 60 percent to over 95 percent of transmission structures are 70 years old or older.”  In a rational world this problem would affect recommendations in the State Energy Plan.

The other structural concern address the fact that energy intensive development is driving up demand for electricity.  Now, development projects, “such as microchip fabrication, bitcoin mining, and data centers, are projected to be major drivers of load growth, in addition to the electrification of the building and transportation sectors”.  Their comments note that:

Large load projects can also be added to the system at a much faster pace than the new generation projects required to serve them. In the short term, this i) increases the pace required for constructing new renewable generation projects and ii) increases the reliance on existing fossil-fuel-fired generators, which thereby increases CO2 emissions. The coordination of new large load additions, new generation capacity, and retention of existing generators is very important to support economic development, maintain adequate generation capacity, and protect electric system reliability.

While I agree with most of the NYISO comments I am not optimistic about the potential that “Some large load projects also present opportunities to the electric grid with expected flexibility in the amount and timing of their demand for electricity from the grid.”  The only new load that applies to is bit coin mining.  I do not believe that semi-conductor manufacturing and data centers will cut back their operations for demand response programs.

The NYISO comments point out that “Access to renewable generation resources, sufficiency of overall generation available, and a robust transmission network should increasingly be an integral part of the consideration of where to locate large load projects.”  I do not disagree but wish they had recommended co-generation as an alternative approach for these new sources.

Repowering and New Generation

I support the pragmatic suggestions that “Repowering existing generation can offer a bridge between old and new, the past and the future” and “Integrating new efficient fossil-fuel-based generation (which may be capable of operating with lower- or zero-emissions fuels in the future) will immediately improve electric system reliability and reduce total emissions”.  The following sums up:

Using natural gas as the basis for combustion units for the foreseeable future necessitates improving and upgrading the aging generation fleet.  Upgrading the existing fleet not only can help with a stepped approach to emissions reductions by replacing older, higher emitting turbines with new, low-emissions cutting-edge technology, it also holds the potential for avoiding future generator failures and improves generating flexibility that allows for more renewable energy generation, therefore bolstering grid reliability and further reducing emissions.

The NYISO comments addressed the need for replacing existing fossil fuel resources.  While I wholeheartedly agree I also know that this is a line in the sand for many environmental organizations.  The suggestion to repower existing generation and build new generators will ignite a passionate demand to kibosh that plan despite the argument that “new generation will prove critical to maintaining electric system reliability”.   Thomas Sowell’s observation that “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong” is apropos but it will come at a political cost for the ideological constituency that thinks that anyone who disagrees is evil.

Nuclear Generation

Similarly, the NYISO recommendation that “existing nuclear generation is critical to meeting the demands of New Yorkers” is certain to upset a vocal minority.  They will still demand shutdowns even when the organization responsible for keeping the lights on says the existing nuclear facilities are needed because “Without the dynamic voltage support services of these key resources the electric system could not transmit power generated by emission-free resources in Western NY to serve load statewide.”  Stay tuned to see how the final State Energy Plan resolves this.

Emerging Technologies

The NYISO comments discussed the importance of emerging technologies and other resource development:

As noted in the Draft Plan, many of the technologies necessary to meet system needs for firm, dispatchable capacity are not yet commercially available at scale. The development of these technologies must start now as these technologies need to be proven and deployed to the electric grid before the resources that currently supply the energy that consumers demand and the reliability attributes needed to support the grid can be retired.

There are vocal organizations that believe this is not true and that it is only a matter of “political will”.  Again, we need to watch the resolution of this closely.  It is long past time that New York energy policy return to those who are responsible for keeping the lights on and not the loudest voices in the room.

Key Risk Factors

The final technical discussion of concerns addressed key risk factors shaping the grid.  NYISO stated that

Given the significant need for resources demonstrated by the Outlook and contemplated in the Draft Plan, the final State Energy Plan should explore all emerging technologies, while focusing on promising technologies that will be readily available sooner and continuing to invest in current technologies including repowering fossil-fuel-fired generation to support fuel diversity and overall electric system reliability.

This is a pragmatic approach.  I hope this makes it into the final State Energy Plan.

Discussion

The conclusion of the NYISO comments stated that:

Strategic coordination between market design, planning, and policy will be essential to address emerging risks and maintain a reliable electric system. A reliable electric system is the only way to protect our health, safety, and welfare, and to meet the demands of societal preferences and public policies driving greater electricity usage. Reliable, dispatchable, and dependable electric generation is critical to every aspect of New Yorkers’ daily lives and is vital to the state’s economy.

I think these should be prime considerations in the Draft Energy Plan.  The NYISO comments describe elements that “create uncertain conditions today, in the near term, and in the longer term, and each uncertainty has the real potential to cause major impacts on electric system reliability.”  As much as I admire NYISO staff and analytic capabilities I think the massive changes associated with relying on inverter-based resources to the most complex machine ever created will inevitably cause reliability issues unless the schedule is made contingent upon feasibility analyses and methodical testing.

It is also disappointing that the affordability component of the electrical system transition has never been addressed by NYISO.  The NYISO resource modeling analysis includes cost information necessary to develop future projections of resource distributions.  I suspect that their cost projections are significantly higher than the NYSERDA work so release of that information would be politically embarrassing.  While I sympathize with the need to get along with politicians, I believe it is not in the best interests of the citizens of New York who have never been provided with transparent cost estimates.

Conclusion

The description of the uncertainties associated with three structural trends in the New York grid should be a wakeup call to New York politicians because they explicitly say the plan cannot work on the current schedule.  The final State Energy Plan will ultimately be consistent with some political narrative and not necessarily what the experts are saying.   Milton Friedman noted: “One of the great mistakes is to judge policies and programs by their intentions rather than their results”.  The NYISO comments clearly state the results are inconsistent with the aspirational intentions of the Climate Act.  It is time for the politicians to concede that we need to pause implementation and reassess what is possible with current technology.

The New York Draft State Energy Plan prepared by the New York State Energy Research & Development Authority (NYSERDA) is currently out for comments.  I have been describing my comments in a series of articles.  This post describes comments submitted by Richard Ellenbogen and David Dibbell.

Ellenbogen Comments

Richard Ellenbogen provided the following biography for his comments.

I am a Former Bell Labs Engineer that has done work on the utility system with NYSERDA and Con Ed. Starting in 1999 I decarbonized my factory and set up monitoring system to track power use.  Those measurements resulted in the Public Service Commissions Case 08-E-0751 to reduce power line losses. I was an invited speaker to a PSC Utility Conference in 2008 for that line loss reduction case initiated by Steven Keller based upon my work at the factory.  I authored a paper written at the request of Con Ed after a factory visit. I was the Keynote Speaker at the 2023 Business Council of NY Renewable Energy Conference and an invited speaker at the Dutchess County Chamber of Commerce meeting on Energy. I was an early adopter of renewable technologies going back to the 1990’s and decarbonized both my home and my business two decades ago. Between 2006 and mid-2023, the business recycled or repurposed 100% of its waste and sent nothing to a landfill. Over the past 20 years, the factory has generated between 60% and 85% of its electrical energy onsite with a carbon footprint approximately 30% lower than the Con Ed System, even prior to the closing of Indian Point.

Here are the comments submitted by Ellenbogen:

I have been making arguments to Albany for years that touch tangentially on Climate Change but are more centered around what is economically possible based upon the structure of the grid and societal issues.  This makes my work directly applicable to the Draft Energy Plan and the Climate Leadership & Community Protection Act (CLCPA). As both an engineer and a business owner, I am very cognizant of the technical issues, but I also have to pay attention to economics if I expect to stay in business.  Both issues have been lost in the Energy Plan discussion.  In addition, the technical issues are not understood by most policy makers that I have spoken with over the past seven years and costs don’t seem to matter.  However, even if New York were to eliminate 100% of statewide GHG emissions, global temperatures would drop by 0.0004 degrees-Celsius but New York State’s expenditures will be into the trillions of dollars. Based on the 35-year experience of Germany the New York attempt to eliminate GHG emissions will fail magnificently.  We do not have the solar resource climate of California, the Iberian Peninsula, or Australia.

I have written several papers for the Public Service Commission (PSC) that explain why the current plan will not work.  In a 2023 response to 14 questions posed by the PSC I described five issues and offered a viable alternative. In and additionally, the final document explains a plan that will work with presently existing technology.  In early 2024 I filed comments I raised additional issues and argued that installing Combined Cycle Natural Gas Generation now and phasing to nuclear over time is a far more cost effective and secure way to power the state than what the CLCPA is mandating. Earlier this year I submitted a viable plan for the decarbonization of the downstate system, starting with Long Island along with justifications for the technologies and relative prices compared to other solutions planned for, tried, or implemented by the state. It will result in a 50% reduction in natural gas usage, a 90% reduction in emissions at the location of every generating plant, and a 76% reduction in emissions across the power sector of NY State.  Further, it is not weather dependent and can provide very low carbon dispatchable generation that will support the system.  The price tag for Long Island would be in the range of $20 billion, however that is a drop in the bucket compared to the trillions of dollars that the CLCPA will cost.  

One of my primary concerns is the premature conversion of all homes to electric heat.  Many of the issues mentioned in the following paragraphs would be rectified by the $20 billion plan I previously mentioned but it is way too early to start converting locations to electric heat until cleaner fossil-fired units are in place that will ensure a reduction in GHG emissions.

To provide a pictorial view of the issues, below is a graph that I generated for a discussion with NYSERDA (NY State Energy Research and Development Authority) in 2019 that shows the relative costs of various types of heating solutions in the downstate region. NYSERDA confirmed that the numbers matched their analysis.   I updated it in 2023 for another presentation.  Gas heat was at $1.94 per therm (100,000 BTU) including efficiency losses.  An air source heat pump costs $3.79 per therm because of the high cost of downstate electricity relative to gas.  One of the reasons that our electricity costs so much is that 90% of the fossil fuel plants in the downstate region are from the 1960’s and 1970’s and are very inefficient. As a result, even if a heat pump has a 300% efficiency but it gets its electricity from a power plant that is 30% efficient, that is only 90% efficient in the best-case scenario.  In cold weather, the heat pump efficiencies can drop below 200% and even as low as 100%, so the system wide efficiency can drop to 66% efficient or 33% efficient while a new gas furnace can operate with efficiencies of 90% – 95%.  That is why I said that heat pumps can reduce holistic efficiency.  Local Law 97 using false metrics to support the plan is dangerous and will likely end up with NY City subject to a class action lawsuit for all the penalty revenue that they collect under the Law. 

The solutions that the state is taking to make heat pumps affordable is to provide early adopters with a special utility rate, but that money has to come from somewhere and it is in other ratepayers higher bills.  So, if we are talking about affordability, it not only will raise the actual costs for the adopters, but it will raise the bills for the other ratepayers, as well.   The utility costs are the tip of the iceberg. 

Beyond those are the costs of the conversions.  An article in The City about a Brooklyn Co-op that converted to heat pumps illustrates those costs.  Tenants had been previously using oil for heat so their operating costs went down, however if they had been using gas, their operating costs would have doubled.  Heat pumps for locations with oil make sense but not for locations with gas.  The conversion cost mentioned in the article was $50,000 per unit, $40,000 after rebate, but the state will run out of money for rebates in a large program and again, those rebate costs are shouldered by the ratepayers and taxpayers as a fee on their bills, the System Benefits Charge or SBC.  At a 6% interest rate over 30 years, that will add $300 per month to the carrying cost of every unit.  In a city where 25% – 33% of the residents already pay 50% of their annual income for rent, how is that sustainable?  I have been asking that question and no one will answer me.  There is also an exhibit in a filing that I co-filed that shows how the number of Con Ed customers in arrears is up 59% since 2019 when the CLCPA was passed.  That is going to get far worse as this process proceeds because the state is only at the beginning of its journey and the obstacles here are far larger than they were in Germany.

Despite claims that affordability has been considered in the Draft Energy Plan there are no defined triggers for acceptable cost limits.   In the Ontario “Green Transition”  lip service to costs caused problems because public support can turn in an instant when they can no longer afford food and rent.  The article should be a warning to every politician that is supporting this process.  As difficult as that may be to believe, NY State will turn Purple at a minimum and more likely will turn Pink when everyone realizes that they have astronomical utility bills, no environmental benefits to show for it with multiple blackouts and battery fires proliferating in their neighborhoods.

As I tried to explain to the NY State Energy and Telecommunications committee when I addressed them in March, you can’t legislate physics and math and they are trying to do that.  It is an unmovable object and trying to move it in any direction will not go well raising costs exponentially.  This is supported by the NYISO’s Power Trends 2025 report.  Page 9 has the downstate generation pie chart and pages 22 – 25 show the reliability issues.  Everything below the black line at “0” is a blackout and they will be extremely likely within a few years.  Keep in mind that generating plants take years to build and intermittent renewables will not support the system, especially with the local pushback on siting and moratoriums against them.

The fundamental problem is that the CLCPA is based upon “bad” science that has been disproven.  The CLCPA was passed based upon the writings of Bob Howarth who sat on the CLCPA and said that the rise in atmospheric methane emissions was caused by fossil fuel extraction and leaking pipelines.  Some experimental scientists scooped methane out of the atmosphere and found that the atmospheric methane is coming primarily from organic decomposition and that the fossil fuel industry is not the primary culprit.  The atmospheric carbon has the wrong carbon isotope.  They contradict Howarth’s work by name on page 11 of the document. 

I agree with Roger Caiazza that even though the Draft Energy Plan messaging claims that stakeholder input will be considered there is no evidence supporting that claim.  As a result, even though I could elaborate in far more detail, I am only going to submit this summary of the issues.

Dibbell Comments

David Dibbell is an engineer and project manager, now retired, with a background in facilities engineering, capital projects, energy management, and technical compliance systems in the pharmaceutical and food industries.  I am active on the X platform and on WattsUpWithThat.com to communicate science-based material from which one can see that the claims of the climate movement are fundamentally unsound.  

The following lists the comments made by Dibbell.  I added the figure referenced.

I refer to Figure 48 in Volume II, 16. Pathways Analysis.

This figure depicts the year 2040 outcome of benefits vs. costs for the four scenarios, Current Policies; Additional Action; Net Zero Scenario A; Net Zero Scenario B.

The Costs (blue column) must be incurred for each of these scenarios as expenditures for hard-money assets require.  But the speculative Health Benefits and Avoided GHG Benefits (composite column) do not produce a hard money stream of receipts to justify the expenditures for assets to be created to begin with.  This is fundamentally imprudent, especially in a multi-faceted energy system on which the State relies for its social and economic well-being.

For the projected Health Benefits, largely relying on PM2.5 reductions, I simply note that the regional trends are such that there will be no conceivable way to confirm a cause-and-effect relationship for whatever health outcomes emerge in the State.  There could be improvement unrelated to NY energy systems evolution, or there could be degradation for reasons unrelated to energy systems even if one of the scenarios occurs physically as projected.  No one will know.  This problem of confounding factors is apparent from the graphs at this EPA website, as air quality data varies within a generally improving trend since 2010.

https://www.epa.gov/air-trends/particulate-matter-pm25-trends

For the projected Avoided GHG Benefits, a more definite case is made here that there is no perceptible risk from GHG emissions at all, and no attributable harm in the form of storms, floods, extreme conditions, and the like.  This implies that the Social Costs per metric ton of CO2 and other GHGs assumed in the analysis are highly exaggerated.  See the Social Cost of GHG Mitigation tab in the Pathways Analysis Technical Supplement: Inputs and Assumptions spreadsheet (Annex 1). Any value higher than zero is based on the speculation that climate trends and impacts are driven by these emissions.  The analysis in this Draft Plan relies on these Social Cost values as though they were real.  This is a fatal error in any serious planning exercise which purports to show costs and benefits with a net benefit to justify the costs.  

The scientific material from which it is concluded that there is no risk from GHG emissions is given here in a recent formal comment submitted to the EPA concerning the 2009 Endangerment Finding.  Within this comment is a link to a Google Drive folder containing plots, histograms, and a Readme document.

https://www.regulations.gov/comment/EPA-HQ-OAR-2025-0194-0305

In short, it is demonstrated from the ERA5 reanalysis that the minor increment in the atmosphere’s radiative absorbing power is massively overwhelmed by energy conversion within the general circulation.

Please take this seriously within the NYSERDA, NYPA, and DPS organizations.  You have experienced resources on staff that surely know better than to continue on the current path which promotes non-emitting but intermittent wind and solar sources with massive battery support.  The NY State administration and legislature should repeal the CLCPA and rescind or avoid any related mandates for vehicles.  Start over.  Drop the unwarranted concern over “climate” trends and GHGs.  Prioritize affordability, reliability, and an ample supply of electricity and fuels for industrial development, transportation, and for the general well-being and safety of the citizens of our State.

Thank you for inviting comments on the Draft 2025 Energy Plan.

Conclusion

I like both sets of comments.  Although it is the last minute I encourage readers to submit your own. 

Dennis Higgins notes that you can use WePlanet’s  interface here Support a Nuclear New York | WePlanet https://act.weplanet.org/nuclear-new-york or email comments to nysenergyplan@nyserda.ny.gov

Comments are due Oct 6.  

This post is a revised version of an article posted at Watts Up With That.  It combines information from earlier posts here.  The New York Draft State Energy Plan prepared by the New York State Energy Research & Development Authority (NYSERDA) is currently out for comments.  There is absolutely no indication the New York State is treating the stakeholder comment period as anything but an obligation so I had no plans to invest time and effort developing technical comments that would be ignored.  Then I read the Health Impacts Analysis chapter.  It is so bad that I had to document this embarrassing scientific travesty for the record.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 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. 

Net-Zero Aspirations

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

According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.”  This is the first update of the Energy Plan since the Climate Act was passed in 2019, so it is being revised to incorporate the net-zero mandates.  I have provided more background information and a list of previous articles on my Energy Plan page. 

Alberto Brandolini has stated that: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.”  To fully document the problems in the Health Impacts Analysis would require an overly large post so this will previous articles addressing the different components.  Nonetheless I show that the NYSERDA analysis chose its health impact goals and then contrived an analysis to support those claims.

Health Benefits Claims

In a recent article Doreen M. Harris who serves as President and CEO of the New York State Energy Research and Development Authority and Chair of the New York State Energy Planning Board summarized the health benefit message in the Draft Energy Plan.  She said: “Additional analysis shows that continued implementation of the State’s energy policies would provide substantial public health benefits throughout the State in all communities, with the greatest benefits realized in disadvantaged community areas.”   She made some specific claims: “This includes reduced emissions and cleaner air resulting in avoided hospitalizations, work loss days and emergency room visits due to asthma.” 

The relationship between inhalable particulate matter and emergency room visits due to asthma is frequently cited as proof of air quality impacts.  In my analysis I only looked at those parameters because of the frequent references and because I found historical data for both parameters.

Before continuing I should note that asthma health impact claims related to air quality is a shaky proposition from the get-go.  I used Perplexity AI to generate a summary of the confounding factors affecting asthma related emergency room visits.  There are environmental, socio-economic, healthcare access, clinical, comorbidity, behavioral, clinical management and psychosocial confounder factors affecting asthma.  Claiming that any one of the factors affecting emergency room visits is agenda-driven science.

Health Impact Relationship

Correlation does not indicate causation. Claiming causation when then is no correlation is tone-deaf agenda driven science.  I posted an article that documents there is no relationship. 

I compared data from two sources.  The New York State Department of Health has developed the New York State Asthma Dashboard that  includes asthma emergency department visits data.  The New York State Department of Environmental Conservation (DEC) operates an ambient air quality monitoring system across the state and prepares annual reports.  The Methodology Appendix in the Health Impact Analysis chapter of the Draft Energy Plan compares the observed inhalable particulate matter (PM_2.5) with their model predictions to validate their approach as shown in Table A-3 below.  That analysis used data from 19 monitoring sites.  I used the same sites except for the near-road monitor because they are not intended to capture average ambient concentrations.

Source: Draft Energy Plan Health Impacts Analysis

In my article on this relationship, I provided plots of the observed data for county-level pollution and emergency room visits.  I did not think there would be an obvious relationship, but I was surprised that it was so bad.  Only two of the sixteen comparisons suggested that there was a relationship that indicated that inhalable particulate concentrations influenced asthma emergency department visits.

Air Quality Analysis

I have a long and wide-ranging background in air quality modeling.  When I read that the health analysis estimated benefits from reduced exposure to inhalable particulate matter concentrations at the community scale, I was taken aback because of the level of effort required.  Estimating the impacts of all the sources of air pollution down to the level of 4,911 census tracts in New York State is challenging simply due to numbers.  The second challenge is that they considered five pollutants and the Appendix notes that both primary and secondary pollutants were considered.  Inhalable particulates (PM_2.5) can be emitted directly but most of the observed particles are secondary pollutants formed in chemical reactions from NOx, SO2, VOCs, and NH3.  The chemical reactions that create secondary pollutants vary by season, meteorological conditions, and distance/time from the emitting source.  When modeling local impacts, it is sufficient to only consider straight line impacts determined by hourly wind directions. However, secondary upwind pollutant reactions occur over multiple hours necessitating more sophisticated transport patterns to track pollution transport.

The solution to this policy impact challenge is to use a simplified average impact analysis.  EPA’s CO–Benefits Risk Assessment (COBRA) screening model fits the bill.  COBRA uses the well-established and proven Climatological Regional Dispersion Model (CRDM) that categorizes parameters affecting pollutant dispersion and transport.  This approach is best suited for local impacts of primary pollutants.  When used for secondary pollutants it is less appropriate because there are more factors involved.

The Draft Energy Plan needed an analysis that addressed disadvantaged communities at a finer resolution than COBRA provides. This analysis was conducted using a newly developed air quality and health impacts modeling framework—the NY Community-Scale Health and Air Pollution Policy Analysis (NY-CHAPPA) model. My problem with the NY-CHAPPA model is that it over-simplifies the air quality analysis.  The most important air pollution impact parameter is wind direction, because impacts only occur if the wind is blowing from the source to the receptor of concern.  CRDM uses 16 wind categories, but NY-CHAPPA only uses four.  Given all the sources in the analysis I think using only four wind directions is unacceptable.  This gives results that are just too crude to be representative of the actual relationship between sources and receptors.

Given that this is a new modeling approach, I believe it is incumbent upon NYSERDA to verify that their new model is valid.  The Appendix to the Health Impact Analysis chapter purports to validate the model for this reason.  An air quality model verification analysis uses historical meteorology and emissions input to predict air quality concentrations and compares those results with observed concentrations over the same time period.  The process is not complicated.  It is necessary to compare model results against observed concentrations.  Obviously, the observations need to be for the same time period as the predictions.  The NYSERDA analysis does not do that.  On page A-13 the draft states: “Because model projections were only available starting with year 2025, these results were compared against multiple years of observational data”. 

When I first read that statement, I did a double take and read it again. I could not believe it.  It is inconceivable that anyone could claim to evaluate model performance by comparing observed historical concentrations against future predicted concentrations.  It is just plain wrong.  The verification statistics presented are worthless.  The biggest problem describing this situation is finding the right terms to describe the enormity of the error without using profanity. 

Context

There is no question that reducing air pollutant emissions will provide health benefits, but the relationship is complex, and in my opinion usually exaggerated.  NYSERDA’s claimed public health effects are listed in Table 2 of the Health Impacts Analysis chapter.  I addressed whether the avoided emergency room visits due to asthma benefits which range from 1,100 to 3,600 fewer cases per year are meaningful relative to historical rates.

Source: Draft Energy Plan Health Effects Chapter

I compared the emergency room visits due to asthma health effect relative to observed data from the .New York State Asthma Dashboard.  Table 1 lists the annual asthma emergency room visits for different age groups.  All my analyses used the total asthma emergency department visits.  Of particular interest note that the Covid Pandemic changed the identification of asthma.  In my opinion, limiting the comparison data from 2009 to 2019 would be more representative of an actual relationship.

Table 1: NYSDOH New York State Asthma Dashboard Asthma Emergency Department Visits

Emergency room asthma reporting changed in 2020 due to Covid.  Because this changed the reporting metric, I ran the statistics for the data available from 2009 to 2019. Table 2 lists simple statistics describing the data for that period.  The range of emergency room visits over all 10 years of data before Covid is 47,636.  The maximum number of avoided emergency room visits is 24% of the standard deviation and 7.6% of the range of observed emergency room visits.  The predicted improvement is a small fraction of the observed emergency room visit variation.

Table 2: NYSDOH Asthma Dashboard Asthma Emergency Department Visits Statistics 2009-2019

In my analysis of the context of the predictions I also looked at the inhalable particulate variations.  The average predicted concentration reduction for all three modeling scenarios is less than the range of observed annual concentrations.  This means that the predicted reductions are within the range of inter-annual variation and that, contrary to the messaging, this suggests that the results will not be observable.

Discussion

My recent posts address shortcomings of the NYSERDA analysis of health benefits of the net-zero transition analyzed in the Draft State Energy Plan.  I believe that the air quality analysis used to predict health impacts was overly simplified.  NYSERDA used a new procedure to estimate health impacts that needs to be validated but the alleged verification process was fatally flawed.  One of the key health concerns is the effect of inhalable particulates on asthma related emergency room visits but there is no observed relationship between annual average PM_2.5 and emergency room visits related to asthma for the New York State monitoring stations used in the NYSERDA analysis.  I also showed that the predicted impacts on emergency room visits, and inhalable particulate air quality reductions are within the range of observed variations. 

Conclusion

My submitted comments should precipitate, at a minimum, a revision to NY-CHAPPA to include 16 wind directions and a valid verification analysis of the modeling. I don’t expect NYSERDA to respond.  Instead, I expect that my comments will be ignored like all my previous submittals.  It is clear to me that NYSERDA established the public relation slogans for the goals of the program and then perverted the science to get answers to support those claims.  When I described this to one of my friends, he remarked that this is proof that science and NYSERDA cannot be used in the same sentence. 

Articles published at Watts Up with That include illustrations.  While this admittedly appeals to my juvenile sense of humor I do think that my revision to the picture aptly illustrates the clown directing the New York Energy Plan that will work when pigs fly.

My last post documented the oral comments I submitted at the Draft State Energy Plan virtual public hearing on September 30, 2025.  The New York State Energy Research & Development Authority (NYSERDA) only allocated two minutes per person, and I had more arguments that I wanted to make so this article documents them.  My comments address plans to eliminate natural gas in the Draft Energy Plan.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 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. 

Net-Zero Aspirations

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

According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.”  The New York State Energy Planning Board is a “multi-agency entity established under Article 6 of the Energy Law, playing a core role in the State Energy Plan process”. Among its responsibilities is adopting the State Energy Plan: The Board has the authority to adopt the comprehensive statewide energy plan, and the stakeholder process should be an important component of that responsibility.

The driving factor for the updated Energy Plan is net-zero ambitions of the Climate Act.  This is the first update of the Energy Plan since the Climate Act was passed in 2019.  I have provided more background information, links to summaries of previous oral comments, and a list of previous articles on my Energy Plan page.  Because of the importance of this process on the future energy system of New York I am following it closely and will be submitting oral and written comments. 

Oral Comments

My last post documented the oral comments I made arguing that New York’s irrational vilification of natural gas risks an unreliable, unsafe, and unaffordable energy system.  I explained that laboratory measurements showing greater impacts of methane emissions than carbon dioxide (CO2) ignore the fact that in the atmosphere changes in methane concentrations have negligible climate impacts compared to CO2.  I noted my personal experience with the benefits of natural gas when I lived through electric blackouts.  Finally, I pointed out that hoping that a presently unavailable dispatchable, emissions-free resource can be deployed by 2040 is too risky so natural gas generation must be maintained.  The rest of this document describes some of my other concerns about eliminating natural gas.

Transportation

Many argue that air pollution from diesel trucks is an environmental issue.  The Transportation chapter of the Draft Energy Plan states:

Medium and Heavy Duty Vehicles (MHDVs) and non-road vehicles are major energy users within the transportation sector and substantial contributors to the sector’s GHG and local criteria pollutant emissions. Both industry segments have opportunities to electrify and move to ZEVs but are still in the early stages. MHDVs are a priority for New York State to electrify, with particular attention on electrifying school buses.

The chapter goes on to optimistically claim that markets for zero emissions options are “nearing maturity” but the reality is that there are significant issues.  I acknowledge the use of Perplexity AI to generate a summary of substantial barriers to the success of electrification efforts for school buses and MHDVs  That summary listed the following items: financial and economic barriers, technical reliability and performance issues, cold weather performance limitations, infrastructure and grid capacity challenges, manufacturing and industry instability, and workforce issues.  I would add that New York is a single jurisdiction and mandates for long-haul heavy-duty vehicles would require buy-in from many other jurisdictions.

I believe that natural gas use for transportation, particularly heavy-duty trucks and buses, would improve inhalable particulate impacts decades before zero-emission alternatives could be deployed because the technologies involved mature proven technologies.   Another Perplexity AI query described the benefits of adopting CNG trucks.  CNG trucks have up to 90% lower nitrogen oxide emissions and similar reductions of inhalable particulate matter mass emissions.  There are fuel cost savings, a strong return on investment, and reduced maintenance costs while at the same time providing comparable power and performance and enhanced vehicle longevity.   Also note that diesel trucks can be converted to run on CNG which is a claim that electric trucks will never make.

Natural Gas Electric System Advantages

The Draft Energy Plan does not acknowledge benefits of natural gas generation for New York’s electric system.

To address intermittency of wind and solar resources it is cost-effective to over-build capacity.   For example, if we were to rely entirely on solar, then we would have to build enough solar generation to provide the necessary power for the winters shorter days.  In the summer the days are longer, and less capacity would be needed.  It is simply not possible to build a system with sufficient energy storage capacity to avoid over-building.  This results in  curtailment which “involves deliberately reducing renewable energy output below maximum potential, resulting in significant economic losses and underutilization of clean energy resources”.  Because natural gas units can be dispatched as needed curtailment is not an issue.

As noted in my previous post a new Dispatchable Emissions-Free Resource (DEFR) is needed for an electric generating system that relies on wind and solar.  I believe that the most likely DEFR 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. If the only viable DEFR solution is nuclear, then renewables cannot be implemented without it.  But nuclear can replace renewables, eliminating the need for a massive DEFR backup resource.  Nuclear works best as a baseload resource while natural gas generators can provide load-following and peaking services.  It is common sense to replace aging natural gas-fired generating units that are nearing the end of their expected lifetime now rather than investing enormous money in renewables because they could be a false solution.

Arbitrary Permitting Decisions

I believe that environmental policy decisions should balance risks and benefits and that the rationale for permitting decisions should not be based on politics.  The Draft Energy Plan should recognize that historical New York permitting decisions for natural gas pipelines are inconsistent with the on-going plans for renewable energy inspired transmission lines are inconsistent.

In one instance permits for the Constitution pipeline were rejected because of an inadequate water resource analysis for stream crossings.  The Department of Environmental Conservation (DEC) was particularly worried about stream crossings.  Rather than including permit conditions that require directional drilling to minimize impacts, DEC rejected the permit application outright.  The permit denial came on Earth Day April 22, 2016, removing any thought that this was a political decision rather than a technical decision

The Northeast Supply Enhancement (NESE) Gas Pipeline was also rejected by DEC because of water quality concerns.  The project would have caused 17.4 miles of underwater sediment disturbance in New York waters as part of a 23.5-mile total route from New Jersey coast to Rockaway, Queens.  The

26-inch diameter natural gas pipeline required 4-6 feet burial depth.  DEC’s denial of the Water Quality Certification in May 2020 was based on the project’s inability to demonstrate compliance with applicable water quality standards, particularly for mercury and copper contamination.

On the other hand, transmission line projects for renewable energy have managed to get permits.  The Champlain Hudson Power Express (CHPE) successfully obtained permits because they “incorporated comprehensive monitoring and mitigation measures”.  Testing demonstrated that sediment disturbance was brief and temporary, with values remaining below established threshold levels.  However,NESE pipeline installation would also have had brief and temporary impact.

A portion of the CHPE transmission line and lines for two offshore wind facilities will be routed through New York Harbor and presumably would also have mercury and copper contamination issues. On one hand the burial process for the transmission lines is less intrusive but on the other hand the disturbance lengths are longer.  CHPE travels approximately 27.8 miles in New York Harbor. The Queensboro Renewable Express (Rise Light & Power) transmission line will have 18.5 miles of underwater sediment disturbance in New York waters with two HVDC cables within a 200-300 foot wide corridor.  Equinor’s Beacon Wind project had planned a much longer 115+ nautical mile transmission system from the offshore lease area OCS-A 0520 to the Astoria power complex. However, the company withdrew its transmission application in February 2025, citing project economics and regulatory challenges

These permitting decisions were clearly decided because of politics.  New York’s Energy Plan should demand fuel-neutral permitting decisions.

Natural Gas for Peaking Power Plants

The Draft Energy Plan must acknowledge that natural gas peaking power plants provide necessary reliability support.  Environmental justice advocates like the Peak Coalition, have convinced state politicians that New York City peaking power plants are “perhaps the most egregious energy-related example of what environmental injustice means today.”  The enacting law for the New York Power Authority (NYPA) Draft Renewables Strategic Plan specifically directed NYPA to publish a plan by May 3, 2025, to end generating electricity with fossil fuel at its 11 small natural gas power plant (SNGPP) units located at 7 sites in New York City and on Long Island by the end of 2030 if reliability and environmental requirements are met.  I have documented that the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts,  and ignorance of air quality trends. In brief, the continued operation of these facilities will have no discernable impact on local neighborhood air quality and shutting them down is solely political virtue-signaling.  On the other hand, these facilities serve specific reliability needs that are not easily replaced. 

Discussion

One of the themes in the Draft Energy Plan is that the Climate Act law mandates compliance deadlines.  However, it does not adequately acknowledge that Public Service Law (PSL) Section 66-P, Establishment of a renewable energy program, is also a law. PSL 66-P requires the PSC to establish a program to ensure the State meets the 2030 and 2040 Climate Act obligations.  It includes provisions stating that the PSC is empowered to temporarily suspend or modify these obligations if, after conducting an appropriate hearing, it finds that PSL 66-P impedes the provision of safe and adequate electric service.  The Draft Energy Plan should recommend that criteria for safe, adequate, and affordable electric service be established so that New Yorkers are assured that current reliability standards are maintained.

Conclusion

The policies incorporated into the Climate Act that drive the Draft Energy Plan are not based on facts or research but ideology. Viewed through a pragmatic lens, the New York obsession with eliminating natural gas is irrational. Increased use of natural gas has been responsible for most electric generation emission reductions observed in the state.  Natural gas provides efficient, resilient, and safe energy to homes and businesses.  Not so long ago the idea that natural gas could also be used a bridge fuel until the aspirational “green” generating resources and energy storage technologies could be tested at the scale needed, perform like a natural gas fired generating unit, and provide power at a similar cost, was generally accepted as a rational approach.  The Draft Energy Plan must ensure that ideological demands to eliminate natural gas do not result in harm to society.

This post documents the oral comments I presented at the Draft State Energy Plan virtual public hearing on September 30, 2025.  The New York State Energy Research & Development Authority (NYSERDA) only allocated two minutes per person, so this article documents the statements that I made.  My comments addressed the irrational vilification of natural gas in the Draft Energy Plan.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 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. 

Net-Zero Aspirations

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

According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.”  The New York State Energy Planning Board is a “multi-agency entity established under Article 6 of the Energy Law, playing a core role in the State Energy Plan process”. Among its responsibilities is adopting the State Energy Plan: The Board has the authority to adopt the comprehensive statewide energy plan, and the stakeholder process should be an important component of that responsibility.

The driving factor for the updated Energy Plan is net-zero ambitions of the Climate Act.  This is the first update of the Energy Plan since the Climate Act was passed in 2019.  I have provided more background information, links to summaries of previous oral comments, and a list of previous articles on my Energy Plan page.  Because of the importance of this process on the future energy system of New York I am following it closely and will be submitting oral and written comments. 

Comments

This section documents the comments I made on September 30, 2025.  I used bullets to differentiate my comments from the explanations. 

• My name is Roger Caiazza.  Documentation for these comments has been posted on my Pragmatic Environmentalist of NY blog.

As noted in the introduction I am convinced that implementation of the New York Climate Act will do more harm than good.

• The Draft energy plan must reflect the reality of natural gas attributes and not the dreams of politicians. 

The same ideologues that convinced the politicians that achieving Climate Act mandates would require no new technologies hate natural gas. 

• New York’s obsession with eliminating natural gas is irrational.  Concerns about the higher observed global warming potential of methane molecules compared to carbon dioxide drive the rationale to control natural gas.  However, laboratory measurements ignore the fact that in the atmosphere changes in methane concentrations have negligible climate impacts compared to CO2.

New York’s war on natural gas or methane is not based on pragmatic balancing of issues of cost, efficiency, and benefits, but only on an ideology built on the hatred of the natural gas industry. Worst of all the foundational argument that controlling methane is necessary because of enhanced impacts on global warming is not correct.

The relative impact of methane and carbon dioxide emissions on longwave radiation that causes the greenhouse gas effect is described in the following references.

Steve Gorham explains that “Because of greenhouse gas saturation in the atmosphere, methane regulations across the world will have no measurable effect on global temperatures.”  This is a good overview of the irrelevance of methane.

Wijngaarden and Happer also did a paper on methane itself.  They argued that the effect of the observed rate of CO2 molecules is so much bigger than the increase in methane atmospheric concentrations so the methane forcing is one tenth that of CO2. The paper is attempts to explain complex relationships for the general public but is still dense. Fortunately Vijay Jararaj summarized their work and conclusions.

Clyde Spencer explained that changes to radiation effects occur on a molecule-by-molecule basis in the atmosphere in an article titled The Misguided Crusade to Reduce Anthropogenic Methane Emissions.  The Climate Act tracks emissions by weight.  In the atmosphere CO2 is more than two orders of magnitude more abundant than CH4 on a molecular basis. The Climate Act uses the global warming potential that estimates the mid-range, long-term warming potential of CH4 is 32 times that of CO2.  However, that equivalence is for equal weights of the two gases!  Using a molecular basis (parts per million-volume mole-fraction) to account for the lighter CH4 molecule reveals that the annual contribution to warming is a fraction of that claimed for CO2.  Methane emissions on a molecular basis are increasing at a rate of 0.58% of CO2 increases.   Therefore, changes in methane emissions have insignificant effects.

Methane molecules affect the outgoing radiation in the same spectral band as water vapor.  The lab measurements are based on a standard dry atmosphere.  In the atmosphere, methane’s two main infrared absorption bands) are completely overlapped by two of the several broader and much stronger water vapor absorption bands. In a world averaging about 2% specific humidity, any methane effect is literally swamped by water vapor effect.  In particular, water vapor reduces the potency of methane by about 82 percent at 80% relative humidity and at 46% relative humidity (from the US Standard Atmosphere) the reduction is 75%.

Ralph B. Alexander describes another molecular consideration ignored in the Climate Act.  Each greenhouse gas affects outgoing radiation differently across the bell-shaped radiation spectrum   One of the reasons that CO2 is considered the most important greenhouse gas is that its effect coincides with the peak of the bell shape.  On the other hand, the effect of CH4 is down in the tail of the bell shape.  As a result, the potential effect of CH4 is on the order of only 20% of the effect of CO2.

Andy May’s excellent summarization of Wijngaarden and Happer’s important paper “Dependence of Earth’s Thermal Radiation on Five Most Abundant Greenhouse Gases” explains that the greenhouse effect of methane is not only related to the effect on longwave radiation itself but also the concentration in the atmosphere.  Because the atmospheric concentration of methane is so small doubling concentrations change the “outgoing forcing by less than one percent”.  In other words, doubling emissions or cutting emissions in half of methane will have no measurable effect on global warming itself. 

The residence time of the two gases is different.  Methane only has a lifetime of about 10-12 years in the atmosphere.  The “consensus” science claim is that 80% of the anthropogenic CO₂ emissions are removed within 300 years.  (Note however that there are other estimates of much shorter residence times.) This means that CO2 is accumulating in the atmosphere.  CH₄ is converted to CO₂ and is then counted in the monthly CO₂ measurements as part of the CO₂ flux.  Because methane does not accumulate the same way as CO2 it should be handled differently.  However, the Climate Act doubles down on using the same approach.  Climate Act authors claimed it was necessary to use 20-year global warming potential (GWP) values because methane is estimated to be 28 to 36 greater than carbon dioxide for a 100-year time horizon but 84-87 greater GWP over a 20-year period. 

Dr. Mathew Wielicki gives a good, illustrated description that puts methane in perspective. Note that some of the article is behind a paywall.

• Politicians must recognize the residential reliability benefits of natural gas.  I have lived in my home for over 40 years.  I have never had an outage of natural gas service. There have been many minor electric outages and two multi-day blackouts. We survived the long blackout because we had natural gas for heating and cooking.  Surviving and recovering the grid in an all-electric energy system will be extraordinarily challenging.

I do not think that the Energy Plan has adequately recognized the resiliency value of natural gas and its benefits during electric outages.  My described personal experience is shared by many and ignored in the Draft Energy Plan.  I think it must acknowledge that recovery of an all-electric energy system will be extraordinarily challenging and that natural gas provides the fuel diversity necessary for a resilient energy system.

• NYSERDA’s recently released GE Grid Performance Gaps Study states that New York needs approximately 25 gigawatts (GW) of capacity contribution by 2040 to replace the fossil fuel fleet.  Politicians must acknowledge that dispatchable emissions-free resources simply will not be available by 2040. 

One of the themes in the Draft Energy Plan is that the Climate Act law mandates compliance deadlines.  However, it does not adequately acknowledge that Public Service Law (PSL) Section 66-P, Establishment of a renewable energy program, is also a law. PSL 66-P requires the Public Service Commission (PSC) to establish a program to ensure the State meets the 2030 and 2040 Climate Act obligations.  It includes provisions stating that the PSC is empowered to temporarily suspend or modify these obligations if, after conducting an appropriate hearing, it finds that PSL 66-P impedes the provision of safe and adequate electric service. 

With Richard Ellenbogen, Constatine Kontogiannis, and Francis Menton I submitted a filing in a PSC generic proceeding.  As described here, our submittal includes the primary filing, two exhibits documenting the customers in arrears safety valve trigger, and five supporting exhibits.  Responsible New York agencies all agree that new Dispatchable Emissions-Free Resource (DEFR) technologies are needed to make a solar and wind-reliant electric energy system viable during extended periods of low wind and solar resource availability.  Two of the supporting exhibits document the implications of this necessity.  Exhibit 4 – Resource Gap Characterization analyzes gaps between Climate Act mandates and available resources, and Exhibit 5 – Dispatchable Emissions-Free Resources explains that the need for a resource that is not currently commercially available risks investments in false solutions.  I maintain that safe and adequate electric service can only be guaranteed if the necessary DEFR technology has been proven feasible.

In my opinion, the most promising 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. If the only viable DEFR solution is nuclear, then renewables cannot be implemented without it.  But nuclear can replace renewables, eliminating the need for a massive DEFR backup resource.  It is common sense to replace aging natural gas-fired generating units now rather than hope that the necessary replacement technologies will appear as needed in the future.

New York State has not developed a plan to ensure DEFR will be available as needed and that means that a natural gas generation must be available.  NYSERDA’s coordinated study to assess future grid reliability and stability under high-renewable scenarios in the GE Grid Performance Gaps Study states that New York needs approximately 25 gigawatts (GW) of capacity contribution by 2040 to replace the retiring fossil fuel fleet.  Politicians must acknowledge that zero-emission resources that provide all the grid reliability services provided by natural gas generation simply will not be available by 2040.  We must use natural gas as a bridge fuel until proven dispatchable emissions-free resources are available.

I am going to follow up with another post on natural gas and the Draft Energy Plan.  The oral comment time constraints prevented me from covering other topics.  I will explain that natural gas has a place in the transportation sector, there are unacknowledged natural gas advantages, and the State used arbitrary permitting decisions to deny permit applications for needed infrastructure improvements.

Conclusion

My oral comments concluded using similar terminology to this.  The policies incorporated into the Climate Act that drive the Draft Energy Plan are not based on facts or research but ideology. They are, in a word, irrational.  Not so long ago the idea that natural gas could be used a bridge fuel until the aspirational “clean” generating resources and energy storage technologies could be tested at the scale needed, perform like a natural gas fired generating unit, and provide power at a similar cost, was generally accepted as a pragmatic approach.  The only rational approach to maintain reliability and lower costs is to go back to that concept.

The New York Draft State Energy Plan prepared by the New York State Energy Research & Development Authority (NYSERDA) is currently out for comments.  This is one in a series of posts describing my concerns about the Health Benefits chapter that I am planning to consolidate and submit as a written comment.  This post describes issues with the air quality modeling analysis used to predict health benefits.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  The primary emphasis of my career was air pollution meteorology and air quality analysis which is the focus of my planned comments.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 575 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. 

Net-Zero Aspirations

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

According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.”  This is the first update of the Energy Plan since the Climate Act was passed in 2019, so it is being revised to incorporate the net-zero mandates.  I have provided more background information and a list of previous articles on my Energy Plan page. 

Health Benefit Chapter Comments

My first post/ draft written comment described my oral comment at the virtual Draft State Energy Plan Public Hearing on September 13, 2025.  I noted that NYSERDA is using a new modeling approach to project the air quality impacts associated with Climate Act implementation that are used to determine health benefits.  Although they claimed that they had verified the approach, the methodology used was invalid, thus undermining the credibility of all the health benefits claims.

The crux of the NYSERDA health benefit claim is that various health effects are exacerbated by air pollution.  If that is true, then observed inhalable particulate matter (PM_2.5) should correlate with observed health outcomes.  In my second post I compared observations of the same metrics cited in the Health Benefits chapter. I found no observed relationship between annual average PM_2.5 and emergency room visits related to asthma for the New York State monitoring stations used. 

The third post compared the air quality projections and the health benefit claims in context with observed variability.  I showed that the predicted impacts on emergency room visits, and inhalable particulate air quality reductions are within the range of observed variations.  Contrary to the messaging, this suggests that the results will not be observable.

Air Quality Modeling Challenges

I have a long and wide-ranging background in air quality modeling.  When I read that the health analysis estimated benefits from reduced exposure to fine particulate matter (PM_2.5) concentrations at the community scale I was taken aback because of the level of effort required.  The Appendix to the Health Benefits Chapter states the analysis modeled “dispersion of primary PM2.5 and secondary PM2.5 precursor pollutants nitrogen oxides (NOx), sulfur dioxide (SO2), volatile organic compounds (VOCs), and ammonia (NH3)”.  All this is needed to determine state-wide impacts on the resolution required to predict impacts to disadvantaged communities.

The first challenge is the large number of sources and receptors.  All significant point sources of air pollution have Title V permits and there are 160 permitted facilities.  The Appendix states: “On-road emissions from major and secondary road categories (interstates, arterials, and major collectors) were modeled as line sources.”  It also notes that the modeling include “the residential, commercial, and non-road sectors, as well as non-point industrial sources.”  All those sources were modeled to estimate impacts on 4,911 census tracts in New York State.

The second challenge is that there are five pollutants and the Appendix notes that both primary and secondary pollutants were considered.  Inhalable particulates (PM_2.5) can be emitted directly but most of the observed particles are secondary pollutants formed in chemical reactions from NOx, SO2, VOCs, and NH3.  The chemical reactions that create secondary pollutants vary by season, meteorological conditions, and distance/time from the emitting source.  In many areas of the state, the observed PM2.5 is mostly secondary from upwind sources.  When modeling local impacts, it is sufficient to only consider straight line impacts determined by hourly wind directions, however, secondary upwind pollutant reactions occur over multiple hours necessitating more sophisticated transport patterns to track where the pollution transport.

Finally, it is not simple to characterize emissions for all of society as they claimed to do.  It is hard enough to characterize existing emissions from power plants, factories, homes, businesses, and vehicles over time and space.  In this analysis they also had to project how emissions would change during the transition away from fossil fuels for projections out to 2040.

Health Benefits Modeling Approach

My first hope was that they would try to do the air quality modeling right.  I believe that would require a massive analysis simulating all the processes that affect the air quality concentrations.  The analysis is even more complicated because the air quality analysis was only the first step.  The goal was to predict health impacts and that required additional analysis  The Introduction to the Appendix in the Health Benefits chapter explains that there are two more components in the analysis:

The basic framework of the analysis is:

• Estimate changes in air pollutant emission reductions based on changes in fuel consumption as modeled in the Pathways Analysis (see Pathways Analysis chapter).
• Analyze changes in air quality resulting from reductions in air pollutant emissions.
• Analyze changes in health effects resulting from changes in air quality.
• Calculate the monetized value of the change in health effects using standard economic values.

This analysis supports claims of Draft Energy Plan “substantial” health benefits for the transition across New York down to disadvantaged community levels.  The first two components in the framework cover the air quality analysis portion that I have personally done in the past.  The other two components listed represent policy support issues that are outside of my experience.  It is apparent that the methodologies were dictated by the desire to prove substantial health benefits.

A key difference from the approach used for the Scoping Plan is that this analysis was conducted using a newly developed air quality and health impacts modeling framework—the NY Community-Scale Health and Air Pollution Policy Analysis (NY-CHAPPA) model —rather than using the Environmental Protection Agency’s (EPA’s) CO-Benefits Risk Assessment Health Impacts Screening and Mapping Tool (COBRA) to analyze health outcomes from changes in fine particulate matter (PM2.5) concentrations. In addition,

The need for impact resolution down to the census tracts required the new NY-CHAPPA model.

COBRA was used to evaluate the impact from changes in ozone concentrations at a county level (this is a new capability now available from COBRA but is limited to the county scale).  The NY-CHAPPA modeling framework estimates benefits at a sub-county scale, which enables evaluation of potential health benefits by community type, allowing evaluation of health effects within geographic disadvantaged communities (DACs) as defined under the Climate Act.

EPA’s COBRA model was used to provide information not available from NY-CHAPPA.

Issues

As noted, a comprehensive air quality modeling analysis would require an enormous effort.  NY-CHAPPA is a screening model like EPA’s COBRA model.  Both include many simplifications to improve computational efficiency. Rather than analyze hour by hour data, COBRA’s core air quality modeling relies on the Phase II Source-Receptor (S-R) Matrix, which establishes fixed transfer coefficients representing the relationship between emission sources and air quality impacts at receptor locations. In my opinion, if the transfer coefficients are based on five years or more of historical meteorological data, then the results are generally acceptable for screening analyses like this health benefits analysis. 

My problem with the NY-CHAPPA model is that it over-simplifies the air quality analysis.  COBRA uses the well-established and proven Climatological Regional Dispersion Model (CRDM) that categorizes atmospheric stability, wind direction and wind speed like NY-CHAPPA..  Both models use the same number of stability and wind speed categories.  The most important air pollution impact parameter is wind direction, because impacts only occur if the wind is blowing from the source to the receptor of concern.  CRDM uses 16 wind categories, but NY-CHAPPA only uses four.  Given all the sources in the analysis I think using only four wind directions is unacceptable.  This gives results that are just too crude to be representative of the actual relationship between sources and receptors.

My other problem is that the health impact emphasis on inhalable particulate matter and ozone amplifies the importance of secondary pollutants. The source receptor matrix approach is not well suited for this application.  This simplification means the results have much uncertainty.  Using them to drive the health benefits and monetized value of change components of the analysis prioritizes getting an answer over getting a defensible answer. One of my problems with the Draft Energy Plan process is that there is no provision for technical meetings to address specific topics where stakeholders could ask questions.  One of the problems with a climatological approach like the one used here is interannual variation of the meteorological parameters.  The Annex explains that the analysis reviewed five years of data from 29 meteorological monitoring stations:

The data from each year was analyzed to determine the interannual variability in the meteorological data, as discussed in the following section, “Meteorological Sensitivities.” Based on the results of this analysis, a single year of meteorological data (2017) was selected for use in NY-CHAPPA.

Discussion

This is the last of my topical health benefit articles.  I will use these posts to prepare a written comment on the Draft Energy Plan.  I have been critical of the stakeholder process because it appears that NYSERDA is treating the process as an obligation and not as an opportunity to improve the Energy Plan.  This example is no different.

In a recent article Doreen M. Harris who serves as President and CEO of the New York State Energy Research and Development Authority and Chair of the New York State Energy Planning Board summarized the health benefit message.  She said:

Additional analysis shows that continued implementation of the State’s energy policies would provide substantial public health benefits throughout the State in all communities, with the greatest benefits realized in disadvantaged community areas. This includes reduced emissions and cleaner air resulting in avoided hospitalizations, work loss days and emergency room visits due to asthma.

My written comment will show that the claim of “substantial public health benefits” is the result of an analysis that was designed to get that answer.  I compared observed inhalable particulate matter emergency room visits related to asthma and found no relationship.  When I compared the air quality projections and the health benefit claims relative to observed variability, I showed that the projections are within the range of observed variations suggesting no observable impact should be expected.  This post describes issues with the modeling approach that can only be ignored if a validation analysis indicates that the simplifications do not affect the observed predictions.  In my first post I showed that the purported verification study did not compare projections using historical inputs to observed air quality.  This makes the methodology invalid, thus undermining the credibility of all the health benefits claims.

Conclusion

All the analyses in NYSERDA used in health benefits chapter of the Draft Energy Plan get a failing grade.  They were designed to get a particular answer without regard to common sense science.  It is incumbent upon NYSERDA to prove that their new methodology is credible.  My comments should precipitate, at a minimum, a revision to NY-CHAPPA to include 16 wind directions and a valid verification analysis of the modeling. I don’t expect NYSERDA to respond.  Instead, I expect that my comments will be ignored like all my previous submittals.