Category: NYS Energy Plan

The last several weeks I have written multiple articles about the State Energy Plan and the Energy Planning Board.  This post describes a letter I sent to the members of the Energy Planning Board that said that it was premature to approve the Plan at this time.  I wrote this post to document the fact that Board was told that there were issues before they voted to approve the Energy Plan because someday it will be obvious that approving the plan was a mistake.

In short, implementing New York’s net-zero dreams are unaffordable.  The State Energy Plan analysis of total monthly household energy costs estimates that the capital costs  to install replacement appliances and vehicles that can meet the Climate Act zero-emissions mandate is nearly $600 a month more than replacement with conventional household appliances and vehicles even when the savings of more efficient equipment are considered.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 600 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Energy Plan

The New York State Energy Plan is billed as a “comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers”. I have provided background information and a list of relevant articles including summaries of recent meetings on my Energy Plan page. My latest article discussed presentations of findings from analyses completed since last summer (presentation and recording) at the December 1 meeting. 

NYSERDA presentations and documentation are carefully curated to amplify the political messaging of the Hochul Administration, so it is necessary to read between the lines and carefully check all the statements that are made.  The most important finding in the presentation on December 1 is what I think is a clear admission of expected unaffordable costs necessary for New York households to achieve the Climate Act mandates for zero emissions.  I have explained how I derived the $600 a monthcost estimates in multiple posts and in a summary description of the Equipment Cost Sensitivity slide in the NYSERDA energy affordability presentation.

This information is not explicitly mentioned in the Energy Affordability Fact Sheet (Fact Sheet).  I recognize that this is an extraordinary claim, so I prepared two articles focusing just on the calculation of that estimate.  The Energy Affordability Initial Thoughts at SEP Board Meeting on 12/1/2025 article was my first attempt to document this finding. My latest article specifically addressed the claims in the Fact Sheet but also documented the location of every value in the Energy Affordability Data Annex spreadsheet published on 4 December 2025 after my first article on this topic. 

State Energy Plan Process

This description of the process is based on the Summary for Policy Makers Public Input, Section 1.2, . On September 9, 2024 the Hochul Administration initiated the development of the State Energy Plan announcing the release of a draft scope of the plan.  The Board solicited written public comment on the Draft Scope from September 9, 2024 to December 16, 2024.  Comments were reviewed and incorporated into the final Scope, which was adopted by the Board in March 2025.  In July 2025, the Board approved the release of the Draft Plan for public comment.  The public comment period ran from July 23, 2025 to October 6, 2025.   Nearly 15,000 written comments on the Draft Plan were submitted, with over 250 from organizations and the balance from individuals (80% of which were through 13 comment campaigns).  A “thematic summary of public comments” was discussed at the November 2025 meeting of the Energy Planning Board.  On December 16, 2025, the final act in the process will occur when the Board summarily approves the State Energy Plan.

The process is playacting.  The outcome was never in doubt.  Despite claims about the value of public engagement and input to inform the development of the State Energy Plan there is no record that all the input was considered.  On October 7^th the Energy Plan comment website promised that “All comments will be posted on the State Energy Plan website as soon as practicable” but they still are not posted.  During the State Energy Planning Board meeting presentation on November 13 Karl Maas stated: “This presentation and its appendix, which includes comments on each plan chapter, will be posted after this meeting.”  I used Perplexity AI to search for the appendix and confirmed that my search of the Energy Plan website had not missed that this was posted.  Perplexity concluded: “The State Energy Planning Board appears to have failed to follow through on its commitment to publicly release the detailed comments appendix, despite the explicit promise made during the meeting. This lack of transparency undermines the credibility of the public comment process for the Draft State Energy Plan.”

The bottom line is that the Energy Planning Board was never told anything that negatively reflected on the Administration’s narrative that the Energy Plan implementation meeting the Climate Act mandates would Be a comprehensive roadmap to “build a clean, resilient, and affordable energy system for all New Yorkers”.

My Letter

My final effort to reach the Energy Planning Board to reconsider rubber stamping the Administration’s overly optimistic Energy Plan was to send the following letter to the Board.

I am writing to the members of the State Energy Planning Board  to argue that it is premature to consider and act upon a resolution to adopt the State Energy Plan at the Board meeting scheduled for December 16, 2025.  The Energy Plan is supposed to be a “comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers”. The draft documents labeled “pending board decision” show that there are untenable upfront costs that New Yorkers would face if the State follows the existing State Energy Plan roadmap to achieve the Legislature’s aspirational 2030 deadlines.

The State Energy Plan will have no energy affordability credibility if the Energy Planning Board adopts a plan that its analyses show is unaffordable.  The 2025 Energy Plan Data Annex spreadsheet titled Energy Affordability Outputs and Input Data contains unacceptable affordability information.  In the Equipment Cost Sensitivity slide there are monthly total energy costs including levelized equipment costs for a single household profile.  As documented here, the projections for a moderate-income household in Upstate New York that uses natural gas found the difference between replacement of conventional existing equipment and the highly efficient electrification equipment necessary for Climate Leadership & Community Protection Act (CLCPA) compliance increases monthly average energy expenditures $594 when capital costs are considered.  Only the wealthy could consider that affordable.

The Attorney General’s Office agrees that there are the “insurmountable upfront costs” if the Energy Plan is consistent with the CLCPA as it stands.  Earlier this year there was a court case considering whether the Department of Environmental Conservation had to issue final regulations establishing economy-wide greenhouse gas emission (GHG) limits.   During the case, the Attorney General  submitted a letter that addressed “two categories of new developments: (1) the publication of the 2025 Draft New York State Energy Plan by the New York State Energy Planning Board on July 23, 2025 and (2) additional actions by the federal government that impede New York’s efforts to achieve the CLCPA.”  The letter argued that it was inappropriate to implement regulations that would ensure compliance with the 2030 40% reduction in GHG emissions CLCPA mandate because meeting the target is “currently infeasible”. 

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

There is no obvious record of what insurmountable State Energy Plan upfront costs led to that statement in the Attorney General letter, but the statement is consistent with the Equipment Cost Sensitivity analysis.  I find it troubling that this finding received so little attention in the NYSERDA presentations to the Board.  This information is not explicitly mentioned in the Energy Affordability Fact Sheet, in the Volume I: Summary for Policymakers or in the Energy Affordability Impacts Analysis chapter.  The findings were mentioned in a 41 second segment of the December 1 Energy Affordability presentation (Page 8 in the annotated transcript):  “What we can take away is that the net costs for efficient electrification journeys could be thirty five to forty percent higher than conventional replacement when accounting for equipment, reinforcing the importance of action to address upfront equipment costs so that households are able to access the benefits of these systems.” 

In addition, the Pathways Analysis shows that meeting the 2030 CLCPA 40% GHG emission reduction target and electric system 70% renewable energy mandates are impossible.  Those results are consistent with other State agency findings.  I believe that these conclusions and the affordability results clearly show that it is time to amend the CLCPA  consistent with the Ulster County New York Supreme Court decision ordering the Department of Environmental Conservation to issue final regulations establishing economy-wide greenhouse gas emission (GHG) limits on or before Feb. 6, 2026 or go to the Legislature and get the Climate Act 2030 GHG reduction mandate schedule changed.   The Hochul Administration and DEC appealed the decision on November 25, 2025 claiming that “it is impossible for the Department to simultaneously comply with both the Court’s order and its substantive statutory obligations.” 

The State Energy Plan for approval on December 16, 2025, does not recognize these findings.  Ignoring them to meet an arbitrary schedule means the Plan will be immediately obsolete.  The Plan must explicitly state that the CLCPA mandates cannot be achieved and are unaffordable so must be amended for a State Energy Plan that ensures a clean, resilient, and affordable energy system for all New Yorkers.  Failure to do so would be a serious disservice to New Yorkers.

Discussion

I do not expect that there will ever be any acknowledgment of the letter.  This post documents that the State Energy Planning Board was told that total monthly household energy costs estimates for the capital costs  to install replacement appliances and vehicles that can meet the Climate Act zero-emissions mandate are nearly $600 a month more than replacement with conventional household appliances and vehicles even when the savings of more efficient equipment are considered.  Only the wealthy could consider that affordable.  The Energy Plan is supposed to consider affordability so ignoring this finding destroys the credibility of the document.

Conclusion

My hobby of fighting the Climate Act mandates certainly keeps me busy but certainly does not have any effect on New York energy policy.  I hope that someday I will be able to say I told you so.

Yesterday I published a post that described my thoughts about today’s State Energy Planning Board meeting that discussed public comments on the Draft State Energy Plan document.  This post describes my  initial thoughts about the meeting and compares my predictions for the outcome. 

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 nearly 600 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Energy Plan Overview

According to the New York State Energy Plan website (Accessed 3/16/25):

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

I have provided background information and a list of previous articles on my Energy Plan page. 

Meeting Overview

There were three items on the agenda: approval of last meeting minutes, discuss public comments on the Draft Energy Plan, and consider any new business. As has been the case for previous meetings Chair Doreen Harris added an Update on the status of the net-zero transition.

The highlight of the update discussion was not what was mentioned but what was not mentioned.  I did not make a copy of the first slide that included impacts of Federal rollbacks on New York’s clean energy industry where it was mentioned that “reporting has estimated that more than 6,200 jobs and $2.5B in investments have been lost or delayed in 2025 due to the Trump administration’s energy policies.”  Harris put in a plug for Governor Hochul’s $1 billion Sustainable Future Program. The following slide shows where the money is allocated.

Harris described the renewable directive and energy solicitation.

Harris also mentioned that the New York State Department of Environmental Conservation (DEC) approved required permits for the proposed Northeast Supply Enhancement (NESE) pipeline project, that the Constitution pipeline application was withdrawn, and that the air permit for the Greenidge crypto mining facility had been approved.  There also were a couple of slides for statewide updates. 

That covers what was mentioned in the Update.  Conspicuous by its absence, there was no mention of the Supreme Court decision described in yesterday’s post.  On Oct. 24, 2025,  New York Albany Supreme Court issued a decision in a case brought by environmental organizations that sued the New York State Department of Environmental Conservation (DEC).  The judge ordered DEC to issue final regulations establishing economy-wide greenhouse gas emission (GHG) limits on or before Feb. 6, 2026 or go to the Legislature and get the Climate Act 2030 GHG reduction mandate changed.  Importantly, the Attorney General Office supplemental letter submitted during the trial stated that the Climate Act target would cause “undue harm”:

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

In my opinion, the fact that the Attorney General said this is unaffordable and the Judge said they need to consider changing the law is important information relative to the Energy Plan so it was inappropriate to exclude this as part of the update. 

Public Comment Discussions

My previous article highlighted four issues that I thought should be addressed in the discussion of the public comments.  Unfortunately, the presentations gave no indication whatsoever that individual comments would be addressed.  I will follow up with another post that describes the presentation specifics.  For this post I will only describe my initial impression relative to issues raised yesterday.

In my first oral comments I stated that unless the process includes stakeholder meetings that give the public to ask clarifying questions and there is a commitment to document the response to all comments submitted, the stakeholder process will have no credibility.  The fact that people asked for more meetings was mentioned during the meeting but no reason that they did not hold them was given.  My suggestions for changes to make the comment process credible were ignored.

The New York Independent System Operator (NYISO) comments included recommendations that are sure to infuriate proponents of the Climate Act. They say that we are not ready to retire existing fossil-fired generating plants, the necessary resources to replace them will not be ready any time soon so we need to build new fossil-fired units, and maintaining existing nuclear facilities is necessary.  I was very disappointed that the discussion of comments was just an overview and that the impression given was that the greater number of comments supporting a particular position the greater the value of the comment.  NYISO had some unique opinions and there was no acknowledgement of their positions relative to others on things like the need to keep fossil fired infrastructure in place.

I submitted comments that described significant problems with the Health Benefits Analysis chapter including over-simplification of the air quality analysis used to predict health impacts, failure to correctly verify the new model used,  claiming health benefits when there is no observed relationship between annual average PM_2.5 and emergency room visits related to asthma, and suggesting significant benefits when the effects are much less than the observed inter-annual variation. Another characteristic of the NYSERDA description of comments was that there was no indication that any of the numbers in the Draft Plan or Pathways Analysis were incorrect anywhere.  The Energy Planning Board can only assume that the NYSERDA work is infallible and above reproach.

I also submitted comments that described why New York is not ready to eliminate the use of natural gas.  I addressed natural gas use for transportation, unacknowledged advantages for natural gas used for electric generation, arbitrary permitting decisions that have blocked necessary infrastructure projects, and the use at peaking power plants that provide critical reliability support.  As I will show in a subsequent post, this topic was popular.  The following slide exemplifies the briefing approach as it only shows themes of the comments.  There is nothing explicit in this to suggest a link to my concerns. I want to make the point that I never heard the word feasibility in any of the presentations.  NYISO says you need natural gas but “others urge leaning further into renewables, energy storage, electrification, and/or the efficient use of energy to reduce reliance on fossil fuels.  How will this contradiction get resolved?

Discussion

When the meeting materials are released, I will follow up with more observations on the comments.  However, it is probably a waste of time because this process is not credible.  While there are some indications that reality is dawning on the Hochul Administration, these presentations show that NYSERDA, undoubtedly at the behest of the Administration, is using the Energy Plan process to fulfill an obligation and further their energy agenda.  Unfortunately for the Governor there is a loud faction of her party that demand doubling down on renewable energy resources at the same time reality is showing that simply will not work.  This tradeoff colors everything related to energy policy.  It appears that the Administration is going to try to placate both sides by not taking public positions on controversial issues.

All signs are that NYSERDA did not use the Energy Plan as an opportunity to consider the implications of the observed transition and improve the transition going forward.  There is no indication that there will be any attempt to meaningfully engage with stakeholders and address feasibility.

Conclusion

The Energy Plan should be based on energy and physical reality.  Unfortunately, there are clean energy ideologues who cannot accept that their presumptions are indefensible relative to those standards.  Sooner or later this conflict must be resolved, and it will cause political fallout for the Governor.  Holding the safety of the citizens of New York hostage for political gain will not end well.

On July 23, 2025, the Draft Energy Plan was released for comment and comments were due on October 6, 2025.  On November 13 the State Energy Planning Board will meet to discuss public comments on the Draft document.  I predict that the New York State Energy Research & Development Authority (NYSERDA) will avoid specifics and only describe the comments received in general terms.  I have no expectations that NYSERDA will provide a summary of comments received or document how comments submitted were treated.  The Draft Energy Plan also has addressed affordability, but it is not clear how that will be treated going forward.  I will publish a summary soon after the meeting to verify my prediction.

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 nearly 600 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Energy Plan Overview

According to the New York State Energy Plan website (Accessed 3/16/25):

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

I have provided background information and a list of previous articles on my Energy Plan page.  While there are some indications that reality is dawning on the Hochul Administration, the process has not given me a lot of confidence that those concerns will be addressed sufficiently. My biggest concerns are whether the Hochul Administration will use the Energy Plan process as an opportunity to consider the implications of the observed transition so far and if the advice of stakeholders in its stakeholder process will be treated as an opportunity to improve the transition or an obligation with no attempt to meaningfully engage with any comments inconsistent with the narrative.

Supreme Court Decision

There is another interesting angle to this meeting.  I recently described the Oct. 24, 2025,  New York Albany Supreme Court decision as a fork in the road.  Multiple environmental organizations sued the New York State Department of Environmental Conservation (DEC).  The judge ordered DEC to issue final regulations establishing economy-wide greenhouse gas emission (GHG) limits on or before Feb. 6, 2026 or go to the Legislature and get the Climate Act 2030 GHG reduction mandate changed.  There has been no indication yet how this will be addressed.

This is relevant to the resolution of the Draft Energy Plan because during the legal process the State submitted a letter  that addressed “two categories of new developments: (1) the publication of the 2025 Draft New York State Energy Plan by the New York State Energy Planning Board on July 23, 2025 and (2) additional actions by the federal government that impede New York’s efforts to achieve the Climate Act.  The letter argued that it was inappropriate to implement regulations that would ensure compliance with the 2030 40% reduction in GHG emissions Climate Act mandate because meeting the target is “currently infeasible”. 

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

The letter concluded that the Climate Act is unaffordable:

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

The biggest question for the State Energy Planning Board discuss of the resolution of the Draft Energy Plan is how this acknowledged affordability issue will be addressed.

Resolution of My Comments

My Energy Plan page lists 6 articles describing the Pathways Analysis that provided quantitative information for the Draft Energy Plan and 18 more articles about comments on the Plan.  Here are some highlights that I will be watching for

The New York Independent System Operator (NYISO) comments included recommendations that are sure to infuriate proponents of the Climate Act. They say that we are not ready to retire existing fossil-fired generating plants, the necessary resources to replace them will not be ready any time soon so we need to build new fossil-fired units, and maintaining existing nuclear facilities is necessary.  Will these reality-based comments be incorporated in the Final Energy Plan?

I submitted comments that described significant problems with the Health Benefits Analysis chapter including over-simplification of the air quality analysis used to predict health impacts, failure to correctly verify the new model used,  claiming health benefits when there is no observed relationship between annual average PM_2.5 and emergency room visits related to asthma, and suggesting significant benefits when the effects are much less than the observed inter-annual variation. This makes the Draft plan claims of benefits invalid.  Will the final energy plan acknowledge this?  

I also submitted comments that described why New York is not ready to eliminate the use of natural gas.  I addressed natural gas use for transportation, unacknowledged advantages for natural gas used for electric generation, arbitrary permitting decisions that have blocked necessary infrastructure projects, and the use at peaking power plants that provide critical reliability support.  Will NYSERDA support natural gas use?

In my first oral comments I stated that unless the process includes stakeholder meetings that give the public to ask clarifying questions and there is a commitment to document the response to all comments submitted, the stakeholder process will have no credibility.  NYSERDA never held a stakeholder meeting, and I doubt that the comment responses will be documented.

Discussion

This will be interesting.  Despite my pessimism that NYSERDA will meaningfully respond to all stakeholder input, the meeting’s discussion of affordability relative to the position of the Attorney General’s supplemental letter will be fascinating.  I also wonder if they will acknowledge that something must be done relative to the judge’s decision.  In the best case, they will describe a path forward.

Stay tuned.

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.