Category: Reasons to Pause Climate Act

Both New York Democrats and Republicans are embracing an all-of-the-above Climate Leadership & Community Protection Act (Climate Act) energy strategy that includes a role for wind and solar because it provides a “diversity of generation sources”.  I believe that wind is useless and solar should only be used on-site to reduce a structure’s energy use, so I have wanted to respond to this for a while.  However, providing an easily understood comprehensive explanation why dependency on wind and solar is flawed has given me pause.  Richard Lyon has written up exactly what I needed and this article describes his series of posts describing the core arguments of his forthcoming book The Energy Trap: Why the Renewable Energy Transition Can’t Work — And What Can.

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  The Climate Action Council (CAC) was responsible for preparing the 2022 Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” In 2025, the State Energy Planning Board approved the 2025 Energy Plan that “provides broad program and policy development direction to guide energy-related decision making “.  The documents did not provide a complete, transparent accounting of the total costs to achieve the Climate Act mandates or a feasibility analysis that demonstrated that the proposed dependency on renewable energy would provide safe and adequate electricity.

Wind and solar are intermittent, diffuse, and correlated. I believe that those physical realities preclude their use as the backbone of New York’s electric system.  Explaining why those characteristics and others make a renewable energy transition impossible is a challenge, however.  Richard Lyon has provided the necessary documentation by describing his forthcoming book at The State of Britain Substack.

He is a former senior oil and gas operations manager with 35 years of international experience, and academic qualifications in electrical engineering and power systems, petroleum engineering, and energy economics. 

His series of posts: “walks through the core arguments of my book The Energy Trap: Why the Renewable Energy Transition Can’t Work — And What Can. Each post is self-contained, but they build on one another”. He suggests starting at the top and once you’ve read them all, use this page is your reference.  In this article I quote each post with some comments.

Renewables Cannot Work – Physics

Every electrical engineer has told me straight up that renewables won’t work because “physics”  In Chapter 1 — The Physics of Energy Lyons provides an analogy that explains why they all say that:

There is far more heat energy in a swimming pool than in a pan of boiling water. You can boil an egg in the pan. You cannot boil an egg in the pool. And if you doubled the size of the pool, you’d double the energy available — and still have a cold, raw egg.

This is not a riddle. It is the single most important concept in the energy debate, and almost nobody making energy policy understands it.

The difference is not quantity but quality: the gradient between hot and cold that makes work possible. This chapter introduces the three physical measures — energy gradient, energy density, and areal power density — that determine whether an energy source can sustain industrial civilisation. Every successful transition in history moved up on all three. The proposal to replace gas and nuclear with wind and solar reverses the direction.

When I said that renewables won’t work because they are diffuse, energy density is an example of that problem.  Lyons goes on to explain two other physical constraints:  gradient or the difference in energy availability  and power density or the amount of energy that can be extracted from a given area.  The weather related impacts that wind and solar are intermittent and correlated compound these issues.

Renewables Cannot Work – Chemistry

I always want to ask people who want to ban fossil fuels if they want to ban the use of fossil fuels for energy generation and as feedstock to society  In Chapter 2 — The Industrial Metabolism Lyons shows why we are not ready to go completely off fossil fuels.

Steel, cement, ammonia, and plastics: four materials that hold up virtually everything. Each requires hydrocarbons not merely as a fuel but as a chemical feedstock — the carbon and hydrogen atoms become part of the product itself. Electricity is an energy carrier, not a fuel, and each conversion from one to the other loses energy. “Electrify everything” is a slogan that ignores the chemistry. The industrial core of civilisation will continue to require hydrocarbons for the foreseeable future.

Renewables Life Cycle

New York’s Climate Act accounting mandates the life cycle of fossil-fired infrastructure be considered but ignores the life cycle of renewables.  In Chapter 4 — The renewables paradox Lyons eviscerates that approach:

The number that matters is not how much energy a turbine produces, but how much is left over after the system has fed itself. Add storage, grid infrastructure, and fossil-fueled backup to the headline figures and the system Energy Return on Energy Invested (EROEI} drops into the danger zone of the energy cliff — where small errors in the ratio can be civilisation-ending. The IEA calculates that onshore wind requires nine times more critical minerals than a gas plant, offshore wind thirteen times more. Every link in the supply chain is a hydrocarbon operation. And because wind and solar wear out in 20–30 years while a nuclear plant runs for 60–80, the entire system must be rebuilt two or three times within the life of the conventional plant it replaces.

Magical Solutions

Looking back at the Climate Act Council deliberations during the development of the Scoping Plan there was great faith in the ideas that energy efficiency would provide significant benefits, that hydrogen could replace fossil fuels for hard to electrify applications among other things, and that reducing energy use would not affect the economy  Lyons addresses these ideas in Chapter 5 — The escape hatches.

Three reasons for believing the transition can still work — efficiency, hydrogen, and decoupling — and why none of them survive the evidence. Efficiency triggers the Jevons Paradox: cheaper energy use produces more use, not less, and economy-wide rebound effects typically exceed 50%. Hydrogen is an energy carrier with a round-trip efficiency of 30–40%, requiring infrastructure that would need to be largely rebuilt from materials resistant to hydrogen embrittlement. And decoupling — the claim that GDP can grow while energy use shrinks — has never been achieved by any country except through recession or near-stagnation. The escape hatches are closed.

Economics

Richard Ellenbogen constantly points out to me that renewable energy proponents do not understand the economics of infrastructure development.  In Chapter 6 — Energy and your money Lyons points out that there is a more fundamental economic problem.

Money is a claim on future energy conversion. When the money supply grows while the energy supply contracts, each unit of money claims less — and what follows is not a policy choice but an arithmetic certainty. McKinsey estimates the transition at $275 trillion, or 7.5% of global GDP, likely an underestimate. No government can raise that from taxation, so the unspoken plan is to print it. But you cannot print energy. Since 2008 the global economy has added roughly $200 trillion in debt against a contracting energy supply. Every pension, every bond, every mortgage is a promise that the energy to honour it will be there. The physics says it will not.

Oil Depletion

I am not as pessimistic about oil depletion as Lyons.  In Chapter 3 — The depleting oil inheritance he argues:

Not all oil is equal. A barrel of Saudi crude costs $10 to extract and returns over 30:1 on energy invested. The Canadian oil sands yield bitumen so heavy it must be mined or melted with steam. Conventional crude peaked around 2006; the shale boom that appeared to disprove peak oil was financed by $28 trillion in central-bank balance-sheet expansion and was cash-flow negative for over a decade. Discovery peaked in the 1960s at roughly 50 billion barrels a year; in 2024 the world discovered under 2 billion while consuming 30 billion. Oil is the bridge fuel that builds the new energy system while keeping us alive: we can’t squander a single barrel on replacements that can’t work. It’s running out.

I am optimistic because when there were similar historical constraints solutions were found and I expect that to continue.  For example, if we simply exploit resources we know exist, like New York’s shale gas, that are off limits now for irrational reasons, then there will be additional resources.  Despite my optimism the fact is that transforming to a new energy system is an enormous challenge that will take decades.  I agree that we should not be squandering oil.

The Solution

Energy system realists have argued for a long time that society needs a rational discussion of the future energy system and that always includes a nuclear power component.  Lyons addresses this in Chapter 7 — Forging a new realism.

The energy trap: the renewable transition is consuming the very hydrocarbon surplus needed to build whatever comes next. The only proven way up the quality ladder is nuclear — two million times the energy density of coal, power density matching gas, sixty to eighty years of operation from a one-time construction investment. Even so, a gap of decades is unavoidable while the new system is built. A seven-point blueprint — start with the physics, protect the inheritance, fast-track nuclear, eliminate demand, redirect subsidies, anchor money to energy, trust the public with the truth — offers a framework for navigating a managed descent rather than an unmanaged collapse.

Discussion

Taken together, Lyons’ work makes it clear that an “all of the above” energy policy is not prudent policy  but a way to avoid addressing hard physical and economic limits. His articles show that modern society depends on high‑quality, high‑density energy sources that deliver large surplus energy after the system feeds itself.  He shows that utility‑scale wind and solar move us away from that path and toward the energy cliff once storage, backup, and grid costs are honestly counted. At the same time, fossil fuels remain indispensable chemical feedstocks for steel, cement, ammonia, plastics, and broader societal needs.  They cannot simply be swapped out by electricity or slogans like “electrify everything.” In that light, “all of the above” becomes a dangerously vague invitation to waste our finite fossil fuels on low‑return projects, under build nuclear, and pretend that efficiency, hydrogen, and using less energy while still growing the  GDP will magically close the gap.  New York must commit to physically credible options with nuclear at the center and stop making believe that wind and solar should be included.

Conclusion

As an outsider with no concerns about appeasing the special interests foisting wind and solar energy upon New York, I can stop pretending that an “all of the above” energy policy is appropriate.  In the series of posts that Richard Lyon uses to describe his forthcoming book The Energy Trap: Why the Renewable Energy Transition Can’t Work — And What Can he clearly explains why utility-scale and wind and solar are a distraction for a rational energy policy.  Besides the intractable problems described here, there are enormous costs and scandalous environmental impacts related to wind and solar energy resource development.  It is time to just say no.

I recently published an article about cold weather operations in New York during the most extreme cold weather episode that described other articles I wrote that addressed the impacts of the cold weather.  This article describes the New York Independent System Operator (NYISO) summary of the renewable energy covering all of 2025 for the New York Control Area (NYCA)

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Among its interim 2030 targets is a 70% renewable energy electricity mandate and 100% zero emissions electric generation in 2040.  These mandates presume reliance on wind and solar.  I believe that the poor wind and solar resource availability described in this post make it impossible to achieve the aspirational renewable mandates and continue to provide safe and adequate electricity.

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

NYCA Renewables 2025

Cameron McPherson, NYISO Senior Operations Analysis & Services Analyst, presented the following document at the NYISO Installed Capacity Working Group (ICAPWG}and Market Issues Working Group MIWG meeting on April 8, 2026.  There are five sections in the presentation:

• Wind Performance
• Behind the Meter (BTM) and Front of the Meter (FTM) Solar Performance
• Real-Time Market Curtailments
• Coincident Wind and Solar
• Load Ramps

Slide 3 in the presentation (Figure 1) documents the metrics used.  Offshore wind data is not reported because there is only one active facility and NYISO does not report individual unit information.  Past presentations and datasets are also available, Annual Renewable Presentations and hourly data sets from prior years can be found at the this primary link ant the locations below.

• BTM Solar Information is available under ‘Links’
• Annual Wind and Solar Information is available under ‘Reports’

Figure 1: Slide 3 from NYCA Renewables 2025

Source: NYCA Renewables 2025

I am not going to describe all the material in the presentation.  I will limit this to the overviews of solar and wind, and the annual and monthly capacity factors for the renewable energy resources.  There is much more interesting information in the presentation, so I encourage you to read the document.

NYCA Wind Performance

Figure 2 summarizes the wind nameplate capacity since 2005.  It is notable that there really hasn’t been an appreciable uptick in wind development since the passage of the Climate act in 2019.  That is going to change because the State and renewable energy developers have so rigged the permitting system now that any local objections are over-ruled and environmental protections are ignored.

Figure 2: Slide 6 from NYCA Renewables 2025

Source: NYCA Renewables 2025

Wind and solar generating resources are intermittent. The standard metric for measuring generating availability is the  capacity factor.  It is defined as the percentage of the electricity a power plant actually generates over a period of time compared to what it could have generated if it ran at full power the entire time.  Figure 3 describes NYCA monthly and annual wind capacity factors over the last four years.  There is interannual variation – some years are windier.  Note, however, that the last year may be affected by the addition of an offshore wind facility that we would expect to have higher capacity.  On a monthly basis there is a lot of variation.  In 2025, the windiest month, March had a capacity factor of 44% while September was only 12%.  The good news is that wind is available more in the winter when we expect solar to be less because the days are shorter and the sun is lower in the sky.

Figure 3: Slide 9 from NYCA Renewables 2025

Source: NYCA Renewables 2025

Figure 4 lists the frequency of hourly capacity factors in 2025.  There were less than 1,000 hours when the capacity factor of all the wind generators in the state were between 0% and 5%.  I added the annual percentages on the right for the hourly frequency labels on the left.  The less than 1,000 hours when the capacity factor of all the wind generators in the state were between 0% and 5% is somewhere between 9% and 11% of the annual hours.  I included this to show that the wind capacity factor across New York State was less than 10% for nearly a quarter of the hours.  At the other end, there are less than 20% of the hours when the statewide capacity factor exceeds 50%.  New York does not have an impressive wind resource capacity.

Figure 4: Slide 12 from NYCA Renewables 2025

Source: NYCA Renewables 2025

NYCA Solar Performance

Figure 5 describes the Behind-the-Meter (BTM) solar methodology.  These solar resources are the rooftop solar panels that are not directly monitored by NYISO.  To provide the data, NYISO depends on a vendor who has instrumented a representative sample of sites across the state.  Those measurements are combined with the estimated solar capacity to estimate solar production.  This slide describes the process.

Figure 5: Slide 14 from NYCA Renewables 2025

Source: NYCA Renewables 2025

Figure 6 summarizes the solar nameplate capacity since 2018.  The Climate Act set a goal of 6 GW of distributed photovoltaic solar generation by 2025 and met the target in 2024.

Figure 6: Slide 15 from NYCA Renewables 2025

Source: NYCA Renewables 2025

One of the more naïve presumptions by the authors of the Climate Act was the idea that success in other jurisdictions would lead to similar results in New York.  The available solar resources in California and Texas are the not the same as New York.  Figure 7 describes NYCA monthly and annual BTM solar capacity factors over the last four years.  There should be no surprise that at New York’s latitude January and December capacity factors are very low and that brings down the annual capacity factors.   In the best year rooftop solar was only 13% of the total possible. 

Figure 7: Slide 18 from NYCA Renewables 2025

Source: NYCA Renewables 2025

Figure 8 describes NYCA monthly and annual FTM or utility solar capacity factors over the last four years.  Utility-scale developments are sited to maximize the availability of solar resources and there is an improvement of annual capacity from 13% to 19%.  Of course, nothing can improve the length of the day so solar drops significantly in the winter.

Figure 8: Slide 20 from NYCA Renewables 2025

Source: NYCA Renewables 2025

Curtailments

Figure 9 “Background on Curtailment Metrics” explains the criteria for curtailments.  The NYISO’s real-time market economically evaluates bids submitted by wind and FTM solar resources and when forecasted generation is uneconomic, wind and FTM solar resources are instructed to limit their output to economic levels.  This section finds that real-time market curtailments associated with transmission constraints are the primary current driver of curtailments.  Those can be outages for maintenance, repair or upgrades or something that requires upgrades to the system.  All those who claim that the Climate Act does not affect utility rates must ignore that the costs for these transmission improvements are buried in the rate cases.  Someday the over build necessary to supply peak loads with as much renewable as possible will shift the reason for curtailments to generation-to-load balancing constraints.

Figure 9:  Slide 26 from NYCA Renewables 2025

Source: NYCA Renewables 2025

Coincident Wind and Solar

The sections describing wind and solar monthly capacity factors showed that wind was generally higher when solar was generally lower and vice versa.  This suggests that together they might be dependable.  However, both parameters must be considered at the same time.  Figure 10 describes monthly performance in 2025 and supports the idea that the combined wind and solar support each other.

Figure 10: Slide 36 from NYCA Renewables 2025

Source: NYCA Renewables 2025

NYISO grid operators match generating resources to load variations.  If that process worked on a monthly time scales it would be easy and this observation would be relevant, but operators must match load constantly at minute intervals.  Even the wind and solar daily performance shows the challenge of constantly meeting load.  In Figure 11 the total daily renewable energy production started at 36 GWh, rose to 58 GWh but plunged to 12 GWh later in the first week. To support the “free” renewable resources, other resources must be maintained so that they can be turned on during dark doldrums when the weather does not cooperate.

Figure 11: Slide 37 from NYCA Renewables 2025

Source: NYCA Renewables 2025

On an hourly basis the challenges are greater.  Figure 12 describes wind and solar performance during summer peak loads.  Obviously, NYISO must deal with diurnal solar availability.  Also note that wind and mostly solar appreciably reduce the generation needed from other resources for this example peak.  Based on this slide I don’t think NYISO has serious “duck curve” concerns yet.

Figure 12: Slide 38 from NYCA Renewables 2025

Source: NYCA Renewables 2025

Figure 13 describes wind and solar performance during a winter peak load example.   Note that they used this year’s winter peak as an example.  It appears that wind and solar make up a smaller proportion of the total load provided so can be relied on less in the winter.

Figure 13: Slide 39 from NYCA Renewables 2025

Source: NYCA Renewables 2025

NYCA Renewables 2025 includes a section describing “Load Ramps” that addresses the NYISO system load concerns related to short-term changes to the operating loads.  I am not going to describe any slides from this part of the presentation because I do not understand it well enough to explain it to others.  For most of my readers it is sufficient to know that there is a concern that wind and solar resources could change so quickly that operators would not be able to adjust other generating units to compensate.  The results indicate that the NYISO has this under control.

Discussion

A few observations based on the data.

On March 20, 2026 Governor Hochul stated in an exclusive opinion piece in New York Empire Report that “Since I have been Governor, more than $88.7 billion has been invested in clean energy through programs that have made us an example for the rest of the nation.”  I noted that the BTM 2025 target was achieved a year early.  However, other goals are in trouble.

I cannot break out the renewable capacity additions since she has been Governor but the nameplate capacities in Figures 1 and 5 enable us to calculate the capacity additions since the start of the Climate Act.  Table 1 shows that wind capacity has increased 876 MW, BTM solar has increased 5,114 MW and FTM solar has increased 540 MW.  This suggests that something has to change but the question is whether it can be done responsibly.

Table 1: Renewable Capacity Additions (MW) since Climate Act

Figure 14 describes emissions free resources in 2025.  The Climate Act has a 2030 “70% renewable” target as defined in Public Service Law §66‑p as “a minimum of 70 percent of the state wide electric generation secured by jurisdictional load serving entities…in 2030 be generated by renewable energy systems” (wind, solar, hydro, certain biomass, etc.)  The law requires that “by the year 2040…the statewide electrical demand system will be zero emissions.” This is framed as a characteristic of the entire system, not just a percentage of MWh from specific technologies.

Figure 14: Slide 40 from NYCA Renewables 2025

Source: NYCA Renewables 2025

Table 2 compares the observed emissions free data to the 2030 and 2040 targets.  In 2025 the sum of solar, wind and hydro contribution to gross load was only 21%, far short of 70%.  Adding nuclear to the total, zero emissions are only 38% of the total gross load.  Trying to achieve 100% in 15 years is not likely in my opinion.

Table 2: Percentage Contribution to Gross Load

Conclusion

Proponents of renewable energy in New York frequently point to other states and claim that New York should emulate their performance.  The fact is that the location and climate of New York are not conducive to wind and solar generating resources.  The NYISO summary of 2025 NYCA renewables documents this deficiency well.

Last month I took an initial look at the impact of the January 23-27 winter storm on wind and solar energy production.  I showed that  dispatchable  emissions free  resources (DEFR) are necessary to achieve net-zero in New York.  This post extends my analysis through the end of the cold snap ending on February 9, 2026.

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Among its interim 2030 targets is a 70% renewable energy electricity mandate and 100% zero emissions electric generation in 2040.

In a recent article I noted instances where Governor Hochul and Public Service Commission Chair Rory Christian have raised the possibility for limited changes to the Climate Act interim targets.  A recent article by Emily Pontecorvo summarizes the Green Energy Blob take on decarbonization but does not mention reliability risks of renewable energy.  Those folks do not understand that electric systems must be built around reliability during peak demand.  One of my primary concerns with the Climate Act weather-reliant renewable energy mandates is correlated variability because the conditions that characterize the highest loads also have the weakest expected wind and wintertime solar resource availability.  That makes electric resource planning for reliability during the peak period especially challenging. 

From January 23 to January 27, 2026, a very large and expansive winter storm caused deadly and catastrophic ice, snow, and cold impacts from Northern Mexico across the Southern and Eastern United States and into Canada.  In New York total snow/sleet accumulation ranged from 8-13” near the coast and 12-17” across the interior.  As the precipitation ended a glaze of freezing rain occurred.  Following the storm there was a period of prolonged sub-freezing weather.

I summarized the weather and load impacts of the January 23 – February 9 extreme weather episode in a recent post that was based on two New York Independent System Operator (NYISO) documents: a presentation titled Winter 2025-2026 Cold Weather Operations (“Winter Operations”) by Aaron Markham, NYISO Vice President Operations and the February 2026 Operations Performance Metrics Monthly Report.  This post relies on two additional NYISO sources of data:    New York fuel-mix load data are available at the NYISO Real-Time Dashboard and the January  Operations Performance Metrics Monthly Report.

NYISO Daily Energy Production

Figure 1 combines the net wind and solar performance data figures from the Operations Performance Metrics reports for the 2026 Winter episode.  It shows that solar energy production was near zero during and immediately after the snowstorm.  I interpolated data off this figure for the analysis described below.

Figure 1: Net Wind and Solar Performance Total Daily Production and Capacity Factors

Source: NYISO January and FebruaryOperations Performance Metrics Monthly Reports

©Copyright NYISO 2026. All rights reserved.

Table 1 combines data from the dashboard and the Operations Performance Metric reports.  I have previously described my use of the dashboard real-time fuel mix data to calculate daily energy use (MWh).  The generator types include real-time fuel mix data base “Hydro” that includes pumped storage hydro; “Other Fossil Fuels” is oil; “Nuclear”; “Natural Gas”; and “Dual Fuel” which are units that burn both natural gas and oil. Two renewables are shown. “Wind”, mostly land-based wind but does include 136 MW of offshore wind from the NYISO real-time fuel mix data base.  That source is also used for “Other Renewables” that covers solar energy (394 MW of “front-of-the-meter solar”), energy storage resources (63 MW), methane, refuse, or wood.  The performance metric reports break out the wind, utility-scale solar, also known as Front of the Meter (FTM) solar, and the rooftop top solar, also known as Behind the Meter (BTM) solar total daily production and capacity factors.  In this table, I subtracted the FTM solar data from the Performance Metric Report data. 

Table 1: Daily NYISO Energy Production (MWh) January 23 to February 9, 2026

Table 2 includes two data sets.  The top table lists resource capacity (MW) from the Operations Performance Metrics Monthly Report for solar and wind resources.  The main body of the table lists the calculated renewable daily energy (MWh) for each parameter and the renewable percentage of the total system energy based on my analysis of the real-time fuel mix data.  Note that wind and solar produced less than 10% of the total energy production for 17 consecutive days during an extremely cold period with high loads and seven of those days had renewable production under 5% of the total generation.

Table 2: Resource Capacity (MW) from Operations Performance Metrics Monthly Report, Calculated Renewable Daily Energy (MWh), and Realtime Total System Energy (MWh)

Table 3 combines a table from Markham’s Winter Operations presentation that summarizes the load and weather from January 23 through February 9 and the daily capacity factors calculated using Table 2 data.  Markham pointed out that:

• Highest peak load (24,317 MW) occurred on Saturday, 2/7, aligning with the lowest HB18 temperature (6.1^oF) and highest wind speed (19.3 mph) during the period
• SCR/EDRP was called, which reduced the measured peak load by an estimated 400 MW

NYISO documents are heavy on jargon.  HB18 temperatures means the load‑weighted average New York Control Area temperature during hour beginning 18:00 (6–7 PM).  “SCR/EDRP” refers to two reliability-based demand response programs: Special Case Resources (SCR) and the Emergency Demand Response Program (EDRP).  Were it not for those programs the peak loads would have been around 400MW higher.

The capacity factor results are particularly important for the Public Service Law 66-P renewable energy program component of the Climate Act.  This law mandates increased use of renewable energy.  For the days when the electric system was stressed enough that the NYISO requested demand response programs note that on the renewable capacity factor on the best day was 18%. That result is because of weather conditions and will not change appreciably however much new renewable capacity is added.  As a result, if, for example, the NYISO determines that they need another 1,000 MW of energy, then providing that using renewables will require at least 5,000 MW of capacity.  That is for the best case!  To cover the 24^th of January 10,000 MW of additional renewable energy capacity is needed.

Table 3: New York Control Area Weather and Peak Load Statistics and Renewable Capacity Factors for January 23 to February 9, 2026

Dark Doldrum

This episode is a great example of what the Germans call “Dunkelflaute” and I have called the dark doldrums.    This refers to episodes when solar resource availability is reduced due to the length of day or clouds and there are light winds.  Based on this episode we know that dark doldrums impacts can be exacerbated by the snow that covered solar panels with enough snow to eliminate production (Figure 1).  Note that most rooftop solar in New York City is essentially flat so snow cover is this is a significant issue there.  I am going to have to amend my worst weather label to “snowy dark doldrums”.

DEFR and Peaking Units

In an article last month I showed earlier that these conditions are the fundamental driver of the need for DEFR.  It is disappointing that clean energy advocates have continued to argue that the size of the DEFR gap has been overstated even after all the agencies responsible for electric system reliability argue otherwise.  These results should put those arguments to rest.  In this analysis, I take a slightly different approach to demonstrate both the need for DEFR and dispute arguments that things like Virtual Power Plants can replace the need for DEFR and existing electric system peaking power plants.

In New York State, peaking power plants have been vilified by environmental advocates because they emit more pollutants and are expensive to operate during peak demand periods. However, their essential role in providing power when the grid is most strained is often overlooked, as some proponents argue that their output can be replaced by expanded demand response programs, energy storage systems, and Virtual Power Plants (VPPs)

My analysis of the January data and VPP showed that the lack of renewable energy recharge means that the short-term energy storage systems will be completely exhausted early in a snowy, dark doldrum event and will not be recharged for days.  This raises the question why we would want to invest in something that may save some short tern money, but when it inevitably fails the costs will be greater than the savings and potentially threaten lives in the ensuing blackout.

One rationale for virtual power plants (VPPs) is that they could reduce or even eliminate the need for peaking power plants. Estimating how much electricity peaking units produce compared to other fossil-fired plants involves considerable interpretation. However, it is clear that oil-fired power plants operate as peaking units—the high cost of oil relative to natural gas ensures they are dispatched only when needed to meet peak demand.

Figure 2 from the Winter Operations presentation lists the Real-Time Dispatch schedule of alternative fueled units during the 2026 extreme winter weather episode.  In other words, this represents the shows the use of oil-fired units.  Two fuels stand out: Ultra Low Sulfur Oil (ULSO) and Oil #6.  ULSO is burned in New York City at several of the vilified peaking power plants.  There are a small number of oil-fired steam boilers that use residual oil (#6).  The Winter Operations report notes that an estimated 2 million MWh were produced from liquid fuels during this period.

Figure 2: Alternative Fuel Mix Plot for January 23 – February 9, 2026

Source: Winter 2025-2026 Cold Weather Operations Presentation to NYISO Operations Committee March 19, 2025 ©Copyright NYISO 2026. All rights reserved.

These observations allow us to estimate how much additional renewable capacity would be required to replace the 2 million MWh supplied by oil. The total renewable energy produced over this period was 469,308 MWh.   During peak load periods with limited renewable output, it is likely that all short-term energy storage would be depleted early, leaving insufficient renewable generation to both meet demand and recharge storage systems. The overall renewable capacity factor in this episode was only 10% so replacing the oil-fired generation would require expanding renewable capacity from the current 10,389 MW to approximately 100,000 MW. This level of expansion is clearly unrealistic, reinforcing the conclusion that DEFR is essential.

Discussion

Large wind and solar capacities do no good when the sun doesn’t shine and the wind doesn’t blow.  This period exemplifies a period where that situation is evident.  Addressing this problem is a major concern of the NYISO resource planners. 

I wish I could say that Governor Hochul understands the magnitude of this challenge.  Alas,  Governor Hochul recently claimed that “Since I have been Governor, more than $88.7 billion has been invested in clean energy through programs that have made us an example for the rest of the nation.”  I am not sure that investments that produced less than 10% of the total energy production for 17 days during an extremely cold period with high loads is an example anyone else would want to emulate.

My last concern is that DEFR is indispensable for a renewables heavy system, yet there is still no concrete plan to commercialize and deploy any DEFR technology at the scale required. Significant technical, economic, and regulatory uncertainties remain for all proposed DEFR options, so assuming that a viable solution will simply emerge in time amounts to taking an extraordinary reliability risk with the bulk power system.

If nuclear ultimately proves to be the only practical DEFR candidate, then a grid architecture centered on wind, solar, and short duration storage cannot be implemented reliably without large scale nuclear generation. However, nuclear power is best suited to continuous, high capacity factor operation, so holding it in reserve as an infrequently used DEFR “backup” misuses the technology and wastes its economic advantages.

Nuclear generation instead should serve as the backbone of a decarbonized electric system, providing the bulk of firm capacity and energy, with wind, solar, and storage playing complementary roles. In that case, the only realistically workable path to deep decarbonization may be a nuclear centered system model, implying that large scale investment in a wind , solar , and storage only strategy would amount to pursuing a “false solution” that cannot stand on its own without nuclear support.

Conclusion

The extreme winter weather episode of January 23 – February 9, 2026, has major implications for New York Climate Act implementation.  The current debate about the possibility for limited changes to the Climate Act interim targets has focused on cost impacts.  However these unacknowledged  findings of reliability risks make an equally strong case for consideration of changes to the Climate Act.

Last month I wrote a couple of articles about the January 23-27 winter storm and its ramifications on a future electric system that depends upon wind and solar and how it demonstrated that Dispatchable Emissions-Free Resources (DEFR) will be needed.  This article describes New York Independent System Operator (NYISO) documents that extend the previous analysis through February 9.  The following documents were on the agenda for the NYISO Operating Committee March 19, 2026 meeting: a presentation titled Winter 2025-2026 Cold Weather Operations by Aaron Markham, NYISO Vice President Operations and the February 2026 Operations Performance Metrics Monthly Report.  This article is limited to the description of the weather and resulting loads.  I will follow up on the implications to the Climate Leadership & Community Protection Act (Climate Act) later.

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Among its interim 2030 targets is a 70% renewable energy electricity mandate and 100% zero emissions electric generation in 2040. 

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

January and February Winter Weather

From January 23 to January 27, 2026, a very large and expansive winter storm caused deadly and catastrophic ice, snow, and cold impacts from Northern Mexico across the Southern and Eastern United States and into Canada.  In New York total snow/sleet accumulation ranged from 8-13” near the coast and 12-17” across the interior.  As the precipitation ended a glaze of freezing rain occurred.  Following the storm there was a period of prolonged sub-freezing weather.

Markham’s presentation summarized the cold weather event from January 23 through February 9:

• Coldest stretch of the 2025/2026 winter season with a daily average temperature of 15.2^oF.
• Central Park was below freezing from 1/24 to 2/1 (9 days); longest consecutive day stretch since December 2017-January 2018 (14 days)
• Albany was below freezing from 1/23 to 2/10 (19 days); longest consecutive day stretch since January 2011 (21 days)
• Minimum temperature (-0.1^o F) occurred on Sunday, February 8th and was the lowest of the season
• Essentially equal to the Winter 90th percentile design condition (0^oF)
• Average season minimum: 3.8^o F (2004-2005 to 2024-2025)

Figure 1: Observed Hourly Temperature and Wind Speed 1/23/26 to 2/9/26

Source: Winter 2025-2026 Cold Weather Operations Presentation to NYISO Operations Committee March 19, 2025 ©Copyright NYISO 2026. All rights reserved.

NYISO Real-Time Fuel Mix

New York fuel-mix load data are available at the NYISO Real-Time Dashboard.  These data include links to current and historical five-minute generation (MW) for energy generated in New York State.  I processed that data to calculate hourly averages.  The generator types include “Hydro” that includes pumped storage hydro; “Wind”, mostly land-based wind but does include 136 MW of offshore wind; “Other Renewables” that covers solar energy (394 MW of “front-of-the-meter solar”), energy storage resources (63 MW), methane, refuse, or wood; “Other Fossil Fuels” is oil; “Nuclear”; “Natural Gas”; and “Dual Fuel” which are units that burn both natural gas and oil.  Note, my calculated values are not completely compatible with the final NYISO values. 

Figure 1 graphs all the fuel mix hourly data and Table 1 summarizes the data. The relative average fuel mix energy provided over these ten days was nuclear 19%, hydro 14%, and fossil fuels 62% totaling 94% of the total.   

Figure 1: Hourly NYISO Realtime Fuel Mix (MW) January 24 to February 9, 2026

Table 1: Summary of Daily NYISO Realtime Fuel Data Mix (MWh) January 24 to February 9, 2026

These data do not show the contribution of wind and solar well.  “Other Renewables” includes solar energy (394 MW of “front-of-the-meter solar”), energy storage resources (63 MW), methane, refuse, or wood. The methane, refuse and wood facilities show up as the relatively constant base in Figure 3.  Assuming that the 63 MW of energy storage is too small to show up, that means that the utility-scale “front-of-the-meter” solar shows up as the daily green peaks.  The snow arrived in New York on the night of 24 January and continued through the next day.  Note that utility solar was essentially zero on the 25^th and did not return to the level of the 24^th until February 2^nd.

Figure 3: Hourly NYISO Realtime Fuel Mix Other Renewables and Wind January 24 to February 9, 2026

Loads Markham’s presentation summarized the load from January 23 through February 9:

• Highest peak load (24,317 MW) occurred on Saturday, 2/7, aligning with the lowest HB18 temperature (6.1^oF) and highest wind speed (19.3 mph) during the period
• SCR/EDRP was called, which reduced the measured peak load by an estimated 400 MW

NYISO documents are heavy on jargon.  HB18 temperatures means the load‑weighted average New York Control Area temperature during hour beginning 18:00 (6–7 PM).  “SCR/EDRP” refers to two reliability-based demand response programs: Special Case Resources (SCR) and the Emergency Demand Response Program (EDRP).

Table 1: NYCA Weather and Peak Load Statistics For January 23 to February 9, 2026

Source: Winter 2025-2026 Cold Weather Operations Presentation to NYISO Operations Committee March 19, 2025 ©Copyright NYISO 2026. All rights reserved.

This article is not going to describe the SCR/EDRP resources and what these results mean but I will define what they mean.  Special Case Resources (SCR) are demand response or behind-the-meter generation resources enrolled in the ICAP market that commit to be available to reduce load when NYISO calls an emergency event.  Emergency Demand Response Program (EDRP) is an emergency-only demand response program that pays for voluntary load reductions during NYISO-declared emergencies but does not provide capacity payments.

These resources do impact observed load as shown in Figure 4.  The blue bars represent the observed load and the light green the estimated reduction in load due to the SCR/EDRP programs.  The dotted lines represent the projected daily peak load from the NYISO annual load and capacity data report universally known as the “Gold Book”.  The P50 load forecast is the “most likely” baseline forecast.  Tt represents the expected New York Control Area (NYCA) load under expected future weather conditions, with the load-modifying impacts already included. The P90 estimate is the weather-uncertainty “stressed weather” forecast case for a colder-than-expected winter peak episode.  Demand during three days during the cold snap were about equal to the baseline peak load forecast of 24,200 MW.  If the SCR/EDRP demand response programs were not available, then five days would have exceeded the baseline forecast topping out at 24,717 MW on 2/7/26. 

Figure 4: Daily Peak Load and Estimated SCR/EDRP Impact

Source: Winter 2025-2026 Cold Weather Operations Presentation to NYISO Operations Committee March 19, 2025 ©Copyright NYISO 2026. All rights reserved.

Figure 5 puts the peak loads in perspective. The cold weather this winter was the second lowest winter average since 2010-2011.  The winter 2025–2026 peak load (24,317 MW) occurred on February 7^th and was the highest winter peak since 2018-2019.  Note that the SCR/EDRP demand reduction programs reduced the peak by an estimated 400 MW and was activated eight days.  There were 33 daily peak loads in excess of 22,000 MW which is the most since winter 2014–2015

Figure 5: Winter 2025–2026 Daily Peak Loads In Perspective

Source: Winter 2025-2026 Cold Weather Operations Presentation to NYISO Operations Committee March 19, 2025 ©Copyright NYISO 2026. All rights reserved.

Renewables vs. Load

The NYISO Winter 2025-2026 Cold Weather Operations summarizes the NYCA renewables and load for the January and February portions of the cold snap in Figures 6 and 7.  Relative to the total load it is clear that wind and solar under performed during the event.  By 25 January solar output was essentially zero and did not provide much support until 4 February. 

Figure 6: NYCA Renewables vs. Load – January 23 – 31, 2026

Source: Winter 2025-2026 Cold Weather Operations Presentation to NYISO Operations Committee March 19, 2025 ©Copyright NYISO 2026. All rights reserved.

Figure 7: NYCA Renewables vs. Load – February 2 – 9, 2026

Source: Winter 2025-2026 Cold Weather Operations Presentation to NYISO Operations Committee March 19, 2025 ©Copyright NYISO 2026. All rights reserved.

The observed lack of solar is an important result.  It shows that when there was a large snowstorm, all the solar resources in New York produced virtually nothing to support the system when there were significant peak loads.  Wind performed better but still was only a small component of the total generation.  It is impossible to resolve this by building more solar and wind because all New York weather-reliant generating resources ares correlated.  One way to resolve this is to build energy storage but the amount of storage necessary is overwhelming.  All the responsible projections for future energy resources that rely on solar and wind resources agree that a new dispatchable emissions-free resource (DEFR) is needed for these situations.

Discussion

This article simply describes the observed renewable energy production and loads during the episode with the day with this winter’s coldest temperature and peak load.  Solar resources performed poorly during the episode and on the days when the wind gave out the need for DEFR is unquestionable.  I intend to follow up with another post describing the implications to future electric resource planning.  I expect that NYISO will incorporate their observations of this winter’s weather in their planning.  I would not be surprised if revisions result in substantive changes.

Conclusion

The results provided confirm my prior assertions that wind and solar fail to support the system when needed most. Proponents of the Climate Act fail to recognize that electric systems must be built around reliability during peak demand and that this winter’s weather shows how risky the dependence on wind and solar will be without DEFR.