The New York Draft State Energy Plan prepared by the New York State Energy Research & Development Authority (NYSERDA) is currently out for comments. I have been describing my comments in a series of articles. This post describes comments submitted by Richard Ellenbogen and David Dibbell.
Ellenbogen Comments
Richard Ellenbogen provided the following biography for his comments.
I am a Former Bell Labs Engineer that has done work on the utility system with NYSERDA and Con Ed. Starting in 1999 I decarbonized my factory and set up monitoring system to track power use. Those measurements resulted in the Public Service Commissions Case 08-E-0751 to reduce power line losses. I was an invited speaker to a PSC Utility Conference in 2008 for that line loss reduction case initiated by Steven Keller based upon my work at the factory. I authored a paper written at the request of Con Ed after a factory visit. I was the Keynote Speaker at the 2023 Business Council of NY Renewable Energy Conference and an invited speaker at the Dutchess County Chamber of Commerce meeting on Energy. I was an early adopter of renewable technologies going back to the 1990’s and decarbonized both my home and my business two decades ago. Between 2006 and mid-2023, the business recycled or repurposed 100% of its waste and sent nothing to a landfill. Over the past 20 years, the factory has generated between 60% and 85% of its electrical energy onsite with a carbon footprint approximately 30% lower than the Con Ed System, even prior to the closing of Indian Point.
Here are the comments submitted by Ellenbogen:
I have been making arguments to Albany for years that touch tangentially on Climate Change but are more centered around what is economically possible based upon the structure of the grid and societal issues. This makes my work directly applicable to the Draft Energy Plan and the Climate Leadership & Community Protection Act (CLCPA). As both an engineer and a business owner, I am very cognizant of the technical issues, but I also have to pay attention to economics if I expect to stay in business. Both issues have been lost in the Energy Plan discussion. In addition, the technical issues are not understood by most policy makers that I have spoken with over the past seven years and costs don’t seem to matter. However, even if New York were to eliminate 100% of statewide GHG emissions, global temperatures would drop by 0.0004 degrees-Celsius but New York State’s expenditures will be into the trillions of dollars. Based on the 35-year experience of Germany the New York attempt to eliminate GHG emissions will fail magnificently. We do not have the solar resource climate of California, the Iberian Peninsula, or Australia.
I have written several papers for the Public Service Commission (PSC) that explain why the current plan will not work. In a 2023 response to 14 questions posed by the PSC I described five issues and offered a viable alternative. In and additionally, the final document explains a plan that will work with presently existing technology. In early 2024 I filed comments I raised additional issues and argued that installing Combined Cycle Natural Gas Generation now and phasing to nuclear over time is a far more cost effective and secure way to power the state than what the CLCPA is mandating. Earlier this year I submitted a viable plan for the decarbonization of the downstate system, starting with Long Island along with justifications for the technologies and relative prices compared to other solutions planned for, tried, or implemented by the state. It will result in a 50% reduction in natural gas usage, a 90% reduction in emissions at the location of every generating plant, and a 76% reduction in emissions across the power sector of NY State. Further, it is not weather dependent and can provide very low carbon dispatchable generation that will support the system. The price tag for Long Island would be in the range of $20 billion, however that is a drop in the bucket compared to the trillions of dollars that the CLCPA will cost.
One of my primary concerns is the premature conversion of all homes to electric heat. Many of the issues mentioned in the following paragraphs would be rectified by the $20 billion plan I previously mentioned but it is way too early to start converting locations to electric heat until cleaner fossil-fired units are in place that will ensure a reduction in GHG emissions.
To provide a pictorial view of the issues, below is a graph that I generated for a discussion with NYSERDA (NY State Energy Research and Development Authority) in 2019 that shows the relative costs of various types of heating solutions in the downstate region. NYSERDA confirmed that the numbers matched their analysis. I updated it in 2023 for another presentation. Gas heat was at $1.94 per therm (100,000 BTU) including efficiency losses. An air source heat pump costs $3.79 per therm because of the high cost of downstate electricity relative to gas. One of the reasons that our electricity costs so much is that 90% of the fossil fuel plants in the downstate region are from the 1960’s and 1970’s and are very inefficient. As a result, even if a heat pump has a 300% efficiency but it gets its electricity from a power plant that is 30% efficient, that is only 90% efficient in the best-case scenario. In cold weather, the heat pump efficiencies can drop below 200% and even as low as 100%, so the system wide efficiency can drop to 66% efficient or 33% efficient while a new gas furnace can operate with efficiencies of 90% – 95%. That is why I said that heat pumps can reduce holistic efficiency. Local Law 97 using false metrics to support the plan is dangerous and will likely end up with NY City subject to a class action lawsuit for all the penalty revenue that they collect under the Law.
The solutions that the state is taking to make heat pumps affordable is to provide early adopters with a special utility rate, but that money has to come from somewhere and it is in other ratepayers higher bills. So, if we are talking about affordability, it not only will raise the actual costs for the adopters, but it will raise the bills for the other ratepayers, as well. The utility costs are the tip of the iceberg.
Beyond those are the costs of the conversions. An article in The City about a Brooklyn Co-op that converted to heat pumps illustrates those costs. Tenants had been previously using oil for heat so their operating costs went down, however if they had been using gas, their operating costs would have doubled. Heat pumps for locations with oil make sense but not for locations with gas. The conversion cost mentioned in the article was $50,000 per unit, $40,000 after rebate, but the state will run out of money for rebates in a large program and again, those rebate costs are shouldered by the ratepayers and taxpayers as a fee on their bills, the System Benefits Charge or SBC. At a 6% interest rate over 30 years, that will add $300 per month to the carrying cost of every unit. In a city where 25% – 33% of the residents already pay 50% of their annual income for rent, how is that sustainable? I have been asking that question and no one will answer me. There is also an exhibit in a filing that I co-filed that shows how the number of Con Ed customers in arrears is up 59% since 2019 when the CLCPA was passed. That is going to get far worse as this process proceeds because the state is only at the beginning of its journey and the obstacles here are far larger than they were in Germany.
Despite claims that affordability has been considered in the Draft Energy Plan there are no defined triggers for acceptable cost limits. In the Ontario “Green Transition” lip service to costs caused problems because public support can turn in an instant when they can no longer afford food and rent. The article should be a warning to every politician that is supporting this process. As difficult as that may be to believe, NY State will turn Purple at a minimum and more likely will turn Pink when everyone realizes that they have astronomical utility bills, no environmental benefits to show for it with multiple blackouts and battery fires proliferating in their neighborhoods.
As I tried to explain to the NY State Energy and Telecommunications committee when I addressed them in March, you can’t legislate physics and math and they are trying to do that. It is an unmovable object and trying to move it in any direction will not go well raising costs exponentially. This is supported by the NYISO’s Power Trends 2025 report. Page 9 has the downstate generation pie chart and pages 22 – 25 show the reliability issues. Everything below the black line at “0” is a blackout and they will be extremely likely within a few years. Keep in mind that generating plants take years to build and intermittent renewables will not support the system, especially with the local pushback on siting and moratoriums against them.
The fundamental problem is that the CLCPA is based upon “bad” science that has been disproven. The CLCPA was passed based upon the writings of Bob Howarth who sat on the CLCPA and said that the rise in atmospheric methane emissions was caused by fossil fuel extraction and leaking pipelines. Some experimental scientists scooped methane out of the atmosphere and found that the atmospheric methane is coming primarily from organic decomposition and that the fossil fuel industry is not the primary culprit. The atmospheric carbon has the wrong carbon isotope. They contradict Howarth’s work by name on page 11 of the document.
I agree with Roger Caiazza that even though the Draft Energy Plan messaging claims that stakeholder input will be considered there is no evidence supporting that claim. As a result, even though I could elaborate in far more detail, I am only going to submit this summary of the issues.
Dibbell Comments
David Dibbell is an engineer and project manager, now retired, with a background in facilities engineering, capital projects, energy management, and technical compliance systems in the pharmaceutical and food industries. I am active on the X platform and on WattsUpWithThat.com to communicate science-based material from which one can see that the claims of the climate movement are fundamentally unsound.
The following lists the comments made by Dibbell. I added the figure referenced.
I refer to Figure 48 in Volume II, 16. Pathways Analysis.
This figure depicts the year 2040 outcome of benefits vs. costs for the four scenarios, Current Policies; Additional Action; Net Zero Scenario A; Net Zero Scenario B.
The Costs (blue column) must be incurred for each of these scenarios as expenditures for hard-money assets require. But the speculative Health Benefits and Avoided GHG Benefits (composite column) do not produce a hard money stream of receipts to justify the expenditures for assets to be created to begin with. This is fundamentally imprudent, especially in a multi-faceted energy system on which the State relies for its social and economic well-being.
For the projected Health Benefits, largely relying on PM2.5 reductions, I simply note that the regional trends are such that there will be no conceivable way to confirm a cause-and-effect relationship for whatever health outcomes emerge in the State. There could be improvement unrelated to NY energy systems evolution, or there could be degradation for reasons unrelated to energy systems even if one of the scenarios occurs physically as projected. No one will know. This problem of confounding factors is apparent from the graphs at this EPA website, as air quality data varies within a generally improving trend since 2010.
For the projected Avoided GHG Benefits, a more definite case is made here that there is no perceptible risk from GHG emissions at all, and no attributable harm in the form of storms, floods, extreme conditions, and the like. This implies that the Social Costs per metric ton of CO2 and other GHGs assumed in the analysis are highly exaggerated. See the Social Cost of GHG Mitigation tab in the Pathways Analysis Technical Supplement: Inputs and Assumptions spreadsheet (Annex 1). Any value higher than zero is based on the speculation that climate trends and impacts are driven by these emissions. The analysis in this Draft Plan relies on these Social Cost values as though they were real. This is a fatal error in any serious planning exercise which purports to show costs and benefits with a net benefit to justify the costs.
The scientific material from which it is concluded that there is no risk from GHG emissions is given here in a recent formal comment submitted to the EPA concerning the 2009 Endangerment Finding. Within this comment is a link to a Google Drive folder containing plots, histograms, and a Readme document.
In short, it is demonstrated from the ERA5 reanalysis that the minor increment in the atmosphere’s radiative absorbing power is massively overwhelmed by energy conversion within the general circulation.
Please take this seriously within the NYSERDA, NYPA, and DPS organizations. You have experienced resources on staff that surely know better than to continue on the current path which promotes non-emitting but intermittent wind and solar sources with massive battery support. The NY State administration and legislature should repeal the CLCPA and rescind or avoid any related mandates for vehicles. Start over. Drop the unwarranted concern over “climate” trends and GHGs. Prioritize affordability, reliability, and an ample supply of electricity and fuels for industrial development, transportation, and for the general well-being and safety of the citizens of our State.
Thank you for inviting comments on the Draft 2025 Energy Plan.
Conclusion
I like both sets of comments. Although it is the last minute I encourage readers to submit your own.
This post is a revised version of an article posted at Watts Up With That. It combines information from earlier posts here. The New York Draft State Energy Plan prepared by the New York State Energy Research & Development Authority (NYSERDA) is currently out for comments. There is absolutely no indication the New York State is treating the stakeholder comment period as anything but an obligation so I had no plans to invest time and effort developing technical comments that would be ignored. Then I read the Health Impacts Analysis chapter. It is so bad that I had to document this embarrassing scientific travesty for the record.
I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Net-Zero Aspirations
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.
According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.” This is the first update of the Energy Plan since the Climate Act was passed in 2019, so it is being revised to incorporate the net-zero mandates. I have provided more background information and a list of previous articles on my Energy Plan page.
Alberto Brandolini has stated that: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.” To fully document the problems in the Health Impacts Analysis would require an overly large post so this will previous articles addressing the different components. Nonetheless I show that the NYSERDA analysis chose its health impact goals and then contrived an analysis to support those claims.
Health Benefits Claims
In a recent article Doreen M. Harris who serves as President and CEO of the New York State Energy Research and Development Authority and Chair of the New York State Energy Planning Board summarized the health benefit message in the Draft Energy Plan. She said: “Additional analysis shows that continued implementation of the State’s energy policies would provide substantial public health benefits throughout the State in all communities, with the greatest benefits realized in disadvantaged community areas.” She made some specific claims: “This includes reduced emissions and cleaner air resulting in avoided hospitalizations, work loss days and emergency room visits due to asthma.”
The relationship between inhalable particulate matter and emergency room visits due to asthma is frequently cited as proof of air quality impacts. In my analysis I only looked at those parameters because of the frequent references and because I found historical data for both parameters.
Before continuing I should note that asthma health impact claims related to air quality is a shaky proposition from the get-go. I used Perplexity AI to generate a summary of the confounding factors affecting asthma related emergency room visits. There are environmental, socio-economic, healthcare access, clinical, comorbidity, behavioral, clinical management and psychosocial confounder factors affecting asthma. Claiming that any one of the factors affecting emergency room visits is agenda-driven science.
Health Impact Relationship
Correlation does not indicate causation. Claiming causation when then is no correlation is tone-deaf agenda driven science. I posted an article that documents there is no relationship.
I compared data from two sources. The New York State Department of Health has developed the New York State Asthma Dashboard that includes asthma emergency department visits data. The New York State Department of Environmental Conservation (DEC) operates an ambient air quality monitoring system across the state and prepares annual reports. The Methodology Appendix in the Health Impact Analysis chapter of the Draft Energy Plan compares the observed inhalable particulate matter (PM2.5) with their model predictions to validate their approach as shown in Table A-3 below. That analysis used data from 19 monitoring sites. I used the same sites except for the near-road monitor because they are not intended to capture average ambient concentrations.
In my article on this relationship, I provided plots of the observed data for county-level pollution and emergency room visits. I did not think there would be an obvious relationship, but I was surprised that it was so bad. Only two of the sixteen comparisons suggested that there was a relationship that indicated that inhalable particulate concentrations influenced asthma emergency department visits.
Air Quality Analysis
I have a long and wide-ranging background in air quality modeling. When I read that the health analysis estimated benefits from reduced exposure to inhalable particulate matter concentrations at the community scale, I was taken aback because of the level of effort required. Estimating the impacts of all the sources of air pollution down to the level of 4,911 census tracts in New York State is challenging simply due to numbers. The second challenge is that they considered five pollutants and the Appendix notes that both primary and secondary pollutants were considered. Inhalable particulates (PM2.5) can be emitted directly but most of the observed particles are secondary pollutants formed in chemical reactions from NOx, SO2, VOCs, and NH3. The chemical reactions that create secondary pollutants vary by season, meteorological conditions, and distance/time from the emitting source. When modeling local impacts, it is sufficient to only consider straight line impacts determined by hourly wind directions. However, secondary upwind pollutant reactions occur over multiple hours necessitating more sophisticated transport patterns to track pollution transport.
The solution to this policy impact challenge is to use a simplified average impact analysis. EPA’s CO–Benefits Risk Assessment (COBRA) screening model fits the bill. COBRA uses the well-established and proven Climatological Regional Dispersion Model (CRDM) that categorizes parameters affecting pollutant dispersion and transport. This approach is best suited for local impacts of primary pollutants. When used for secondary pollutants it is less appropriate because there are more factors involved.
The Draft Energy Plan needed an analysis that addressed disadvantaged communities at a finer resolution than COBRA provides. This analysis was conducted using a newly developed air quality and health impacts modeling framework—the NY Community-Scale Health and Air Pollution Policy Analysis (NY-CHAPPA) model. My problem with the NY-CHAPPA model is that it over-simplifies the air quality analysis. The most important air pollution impact parameter is wind direction, because impacts only occur if the wind is blowing from the source to the receptor of concern. CRDM uses 16 wind categories, but NY-CHAPPA only uses four. Given all the sources in the analysis I think using only four wind directions is unacceptable. This gives results that are just too crude to be representative of the actual relationship between sources and receptors.
Given that this is a new modeling approach, I believe it is incumbent upon NYSERDA to verify that their new model is valid. The Appendix to the Health Impact Analysis chapter purports to validate the model for this reason. An air quality model verification analysis uses historical meteorology and emissions input to predict air quality concentrations and compares those results with observed concentrations over the same time period. The process is not complicated. It is necessary to compare model results against observed concentrations. Obviously, the observations need to be for the same time period as the predictions. The NYSERDA analysis does not do that. On page A-13 the draft states: “Because model projections were only available starting with year 2025, these results were compared against multiple years of observational data”.
When I first read that statement, I did a double take and read it again. I could not believe it. It is inconceivable that anyone could claim to evaluate model performance by comparing observed historical concentrations against future predicted concentrations. It is just plain wrong. The verification statistics presented are worthless. The biggest problem describing this situation is finding the right terms to describe the enormity of the error without using profanity.
Context
There is no question that reducing air pollutant emissions will provide health benefits, but the relationship is complex, and in my opinion usually exaggerated. NYSERDA’s claimed public health effects are listed in Table 2 of the Health Impacts Analysis chapter. I addressed whether the avoided emergency room visits due to asthma benefits which range from 1,100 to 3,600 fewer cases per year are meaningful relative to historical rates.
I compared the emergency room visits due to asthma health effect relative to observed data from the .New York State Asthma Dashboard. Table 1 lists the annual asthma emergency room visits for different age groups. All my analyses used the total asthma emergency department visits. Of particular interest note that the Covid Pandemic changed the identification of asthma. In my opinion, limiting the comparison data from 2009 to 2019 would be more representative of an actual relationship.
Table 1: NYSDOH New York State Asthma Dashboard Asthma Emergency Department Visits
Emergency room asthma reporting changed in 2020 due to Covid. Because this changed the reporting metric, I ran the statistics for the data available from 2009 to 2019. Table 2 lists simple statistics describing the data for that period. The range of emergency room visits over all 10 years of data before Covid is 47,636. The maximum number of avoided emergency room visits is 24% of the standard deviation and 7.6% of the range of observed emergency room visits. The predicted improvement is a small fraction of the observed emergency room visit variation.
In my analysis of the context of the predictions I also looked at the inhalable particulate variations. The average predicted concentration reduction for all three modeling scenarios is less than the range of observed annual concentrations. This means that the predicted reductions are within the range of inter-annual variation and that, contrary to the messaging, this suggests that the results will not be observable.
Discussion
My recent posts address shortcomings of the NYSERDA analysis of health benefits of the net-zero transition analyzed in the Draft State Energy Plan. I believe that the air quality analysis used to predict health impacts was overly simplified. NYSERDA used a new procedure to estimate health impacts that needs to be validated but the alleged verification process was fatally flawed. One of the key health concerns is the effect of inhalable particulates on asthma related emergency room visits but there is no observed relationship between annual average PM2.5 and emergency room visits related to asthma for the New York State monitoring stations used in the NYSERDA analysis. I also showed that the predicted impacts on emergency room visits, and inhalable particulate air quality reductions are within the range of observed variations.
Conclusion
My submitted comments should precipitate, at a minimum, a revision to NY-CHAPPA to include 16 wind directions and a valid verification analysis of the modeling. I don’t expect NYSERDA to respond. Instead, I expect that my comments will be ignored like all my previous submittals. It is clear to me that NYSERDA established the public relation slogans for the goals of the program and then perverted the science to get answers to support those claims. When I described this to one of my friends, he remarked that this is proof that science and NYSERDA cannot be used in the same sentence.
Articles published at Watts Up with That include illustrations. While this admittedly appeals to my juvenile sense of humor I do think that my revision to the picture aptly illustrates the clown directing the New York Energy Plan that will work when pigs fly.
My last post documented the oral comments I submitted at the Draft State Energy Plan virtual public hearing on September 30, 2025. The New York State Energy Research & Development Authority (NYSERDA) only allocated two minutes per person, and I had more arguments that I wanted to make so this article documents them. My comments address plans to eliminate natural gas in the Draft Energy Plan.
I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Net-Zero Aspirations
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.
According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.” The New York State Energy Planning Board is a “multi-agency entity established under Article 6 of the Energy Law, playing a core role in the State Energy Plan process”. Among its responsibilities is adopting the State Energy Plan: The Board has the authority to adopt the comprehensive statewide energy plan, and the stakeholder process should be an important component of that responsibility.
The driving factor for the updated Energy Plan is net-zero ambitions of the Climate Act. This is the first update of the Energy Plan since the Climate Act was passed in 2019. I have provided more background information, links to summaries of previous oral comments, and a list of previous articles on my Energy Plan page. Because of the importance of this process on the future energy system of New York I am following it closely and will be submitting oral and written comments.
Oral Comments
My last post documented the oral comments I made arguing that New York’s irrational vilification of natural gas risks an unreliable, unsafe, and unaffordable energy system. I explained that laboratory measurements showing greater impacts of methane emissions than carbon dioxide (CO2) ignore the fact that in the atmosphere changes in methane concentrations have negligible climate impacts compared to CO2. I noted my personal experience with the benefits of natural gas when I lived through electric blackouts. Finally, I pointed out that hoping that a presently unavailable dispatchable, emissions-free resource can be deployed by 2040 is too risky so natural gas generation must be maintained. The rest of this document describes some of my other concerns about eliminating natural gas.
Transportation
Many argue that air pollution from diesel trucks is an environmental issue. The Transportation chapter of the Draft Energy Plan states:
Medium and Heavy Duty Vehicles (MHDVs) and non-road vehicles are major energy users within the transportation sector and substantial contributors to the sector’s GHG and local criteria pollutant emissions. Both industry segments have opportunities to electrify and move to ZEVs but are still in the early stages. MHDVs are a priority for New York State to electrify, with particular attention on electrifying school buses.
The chapter goes on to optimistically claim that markets for zero emissions options are “nearing maturity” but the reality is that there are significant issues. I acknowledge the use of Perplexity AI to generate a summary of substantial barriers to the success of electrification efforts for school buses and MHDVs That summary listed the following items: financial and economic barriers, technical reliability and performance issues, cold weather performance limitations, infrastructure and grid capacity challenges, manufacturing and industry instability, and workforce issues. I would add that New York is a single jurisdiction and mandates for long-haul heavy-duty vehicles would require buy-in from many other jurisdictions.
I believe that natural gas use for transportation, particularly heavy-duty trucks and buses, would improve inhalable particulate impacts decades before zero-emission alternatives could be deployed because the technologies involved mature proven technologies. Another Perplexity AI query described the benefits of adopting CNG trucks. CNG trucks have up to 90% lower nitrogen oxide emissions and similar reductions of inhalable particulate matter mass emissions. There are fuel cost savings, a strong return on investment, and reduced maintenance costs while at the same time providing comparable power and performance and enhanced vehicle longevity. Also note that diesel trucks can be converted to run on CNG which is a claim that electric trucks will never make.
Natural Gas Electric System Advantages
The Draft Energy Plan does not acknowledge benefits of natural gas generation for New York’s electric system.
To address intermittency of wind and solar resources it is cost-effective to over-build capacity. For example, if we were to rely entirely on solar, then we would have to build enough solar generation to provide the necessary power for the winters shorter days. In the summer the days are longer, and less capacity would be needed. It is simply not possible to build a system with sufficient energy storage capacity to avoid over-building. This results in curtailment which “involves deliberately reducing renewable energy output below maximum potential, resulting in significant economic losses and underutilization of clean energy resources”. Because natural gas units can be dispatched as needed curtailment is not an issue.
As noted in my previous post a new Dispatchable Emissions-Free Resource (DEFR) is needed for an electric generating system that relies on wind and solar. I believe that the most likely DEFR technology is nuclear generation because it is the only candidate resource that is technologically ready, can be expanded as needed and does not suffer from limitations of the Second Law of Thermodynamics. If the only viable DEFR solution is nuclear, then renewables cannot be implemented without it. But nuclear can replace renewables, eliminating the need for a massive DEFR backup resource. Nuclear works best as a baseload resource while natural gas generators can provide load-following and peaking services. It is common sense to replace aging natural gas-fired generating units that are nearing the end of their expected lifetime now rather than investing enormous money in renewables because they could be a false solution.
Arbitrary Permitting Decisions
I believe that environmental policy decisions should balance risks and benefits and that the rationale for permitting decisions should not be based on politics. The Draft Energy Plan should recognize that historical New York permitting decisions for natural gas pipelines are inconsistent with the on-going plans for renewable energy inspired transmission lines are inconsistent.
In one instance permits for the Constitution pipeline were rejected because of an inadequate water resource analysis for stream crossings. The Department of Environmental Conservation (DEC) was particularly worried about stream crossings. Rather than including permit conditions that require directional drilling to minimize impacts, DEC rejected the permit application outright. The permit denial came on Earth Day April 22, 2016, removing any thought that this was a political decision rather than a technical decision
The Northeast Supply Enhancement (NESE) Gas Pipeline was also rejected by DEC because of water quality concerns. The project would have caused 17.4 miles of underwater sediment disturbance in New York waters as part of a 23.5-mile total route from New Jersey coast to Rockaway, Queens. The
26-inch diameter natural gas pipeline required 4-6 feet burial depth. DEC’s denial of the Water Quality Certification in May 2020 was based on the project’s inability to demonstrate compliance with applicable water quality standards, particularly for mercury and copper contamination.
On the other hand, transmission line projects for renewable energy have managed to get permits. The Champlain Hudson Power Express (CHPE) successfully obtained permits because they “incorporated comprehensive monitoring and mitigation measures”. Testing demonstrated that sediment disturbance was brief and temporary, with values remaining below established threshold levels. However,NESE pipeline installation would also have had brief and temporary impact.
A portion of the CHPE transmission line and lines for two offshore wind facilities will be routed through New York Harbor and presumably would also have mercury and copper contamination issues. On one hand the burial process for the transmission lines is less intrusive but on the other hand the disturbance lengths are longer. CHPE travels approximately 27.8 miles in New York Harbor. The Queensboro Renewable Express (Rise Light & Power) transmission line will have 18.5 miles of underwater sediment disturbance in New York waters with two HVDC cables within a 200-300 foot wide corridor. Equinor’s Beacon Wind project had planned a much longer 115+ nautical mile transmission system from the offshore lease area OCS-A 0520 to the Astoria power complex. However, the company withdrew its transmission application in February 2025, citing project economics and regulatory challenges
These permitting decisions were clearly decided because of politics. New York’s Energy Plan should demand fuel-neutral permitting decisions.
Natural Gas for Peaking Power Plants
The Draft Energy Plan must acknowledge that natural gas peaking power plants provide necessary reliability support. Environmental justice advocates like the Peak Coalition, have convinced state politicians that New York City peaking power plants are “perhaps the most egregious energy-related example of what environmental injustice means today.” The enacting law for the New York Power Authority (NYPA) Draft Renewables Strategic Plan specifically directed NYPA to publish a plan by May 3, 2025, to end generating electricity with fossil fuel at its 11 small natural gas power plant (SNGPP) units located at 7 sites in New York City and on Long Island by the end of 2030 if reliability and environmental requirements are met. I have documented that the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. In brief, the continued operation of these facilities will have no discernable impact on local neighborhood air quality and shutting them down is solely political virtue-signaling. On the other hand, these facilities serve specific reliability needs that are not easily replaced.
Discussion
One of the themes in the Draft Energy Plan is that the Climate Act law mandates compliance deadlines. However, it does not adequately acknowledge that Public Service Law (PSL) Section 66-P, Establishment of a renewable energy program, is also a law. PSL 66-P requires the PSC to establish a program to ensure the State meets the 2030 and 2040 Climate Act obligations. It includes provisions stating that the PSC is empowered to temporarily suspend or modify these obligations if, after conducting an appropriate hearing, it finds that PSL 66-P impedes the provision of safe and adequate electric service. The Draft Energy Plan should recommend that criteria for safe, adequate, and affordable electric service be established so that New Yorkers are assured that current reliability standards are maintained.
Conclusion
The policies incorporated into the Climate Act that drive the Draft Energy Plan are not based on facts or research but ideology. Viewed through a pragmatic lens, the New York obsession with eliminating natural gas is irrational. Increased use of natural gas has been responsible for most electric generation emission reductions observed in the state. Natural gas provides efficient, resilient, and safe energy to homes and businesses. Not so long ago the idea that natural gas could also be used a bridge fuel until the aspirational “green” generating resources and energy storage technologies could be tested at the scale needed, perform like a natural gas fired generating unit, and provide power at a similar cost, was generally accepted as a rational approach. The Draft Energy Plan must ensure that ideological demands to eliminate natural gas do not result in harm to society.
This post documents the oral comments I presented at the Draft State Energy Plan virtual public hearing on September 30, 2025. The New York State Energy Research & Development Authority (NYSERDA) only allocated two minutes per person, so this article documents the statements that I made. My comments addressed the irrational vilification of natural gas in the Draft Energy Plan.
I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Net-Zero Aspirations
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.
According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.” The New York State Energy Planning Board is a “multi-agency entity established under Article 6 of the Energy Law, playing a core role in the State Energy Plan process”. Among its responsibilities is adopting the State Energy Plan: The Board has the authority to adopt the comprehensive statewide energy plan, and the stakeholder process should be an important component of that responsibility.
The driving factor for the updated Energy Plan is net-zero ambitions of the Climate Act. This is the first update of the Energy Plan since the Climate Act was passed in 2019. I have provided more background information, links to summaries of previous oral comments, and a list of previous articles on my Energy Plan page. Because of the importance of this process on the future energy system of New York I am following it closely and will be submitting oral and written comments.
Comments
This section documents the comments I made on September 30, 2025. I used bullets to differentiate my comments from the explanations.
My name is Roger Caiazza. Documentation for these comments has been posted on my Pragmatic Environmentalist of NY blog.
As noted in the introduction I am convinced that implementation of the New York Climate Act will do more harm than good.
The Draft energy plan must reflect the reality of natural gas attributes and not the dreams of politicians.
The same ideologues that convinced the politicians that achieving Climate Act mandates would require no new technologies hate natural gas.
New York’s obsession with eliminating natural gas is irrational. Concerns about the higher observed global warming potential of methane molecules compared to carbon dioxide drive the rationale to control natural gas. However, laboratory measurements ignore the fact that in the atmosphere changes in methane concentrations have negligible climate impacts compared to CO2.
New York’s war on natural gas or methane is not based on pragmatic balancing of issues of cost, efficiency, and benefits, but only on an ideology built on the hatred of the natural gas industry. Worst of all the foundational argument that controlling methane is necessary because of enhanced impacts on global warming is not correct.
The relative impact of methane and carbon dioxide emissions on longwave radiation that causes the greenhouse gas effect is described in the following references.
Steve Gorham explains that “Because of greenhouse gas saturation in the atmosphere, methane regulations across the world will have no measurable effect on global temperatures.” This is a good overview of the irrelevance of methane.
Wijngaarden and Happer also did a paper on methane itself. They argued that the effect of the observed rate of CO2 molecules is so much bigger than the increase in methane atmospheric concentrations so the methane forcing is one tenth that of CO2. The paper is attempts to explain complex relationships for the general public but is still dense. Fortunately Vijay Jararaj summarized their work and conclusions.
Clyde Spencer explained that changes to radiation effects occur on a molecule-by-molecule basis in the atmosphere in an article titled The Misguided Crusade to Reduce Anthropogenic Methane Emissions. The Climate Act tracks emissions by weight. In the atmosphere CO2 is more than two orders of magnitude more abundant than CH4 on a molecular basis. The Climate Act uses the global warming potential that estimates the mid-range, long-term warming potential of CH4 is 32 times that of CO2. However, that equivalence is for equal weights of the two gases! Using a molecular basis (parts per million-volume mole-fraction) to account for the lighter CH4 molecule reveals that the annual contribution to warming is a fraction of that claimed for CO2. Methane emissions on a molecular basis are increasing at a rate of 0.58% of CO2 increases. Therefore, changes in methane emissions have insignificant effects.
Methane molecules affect the outgoing radiation in the same spectral band as water vapor. The lab measurements are based on a standard dry atmosphere. In the atmosphere, methane’s two main infrared absorption bands) are completely overlapped by two of the several broader and much stronger water vapor absorption bands. In a world averaging about 2% specific humidity, any methane effect is literally swamped by water vapor effect. In particular, water vapor reduces the potency of methane by about 82 percent at 80% relative humidity and at 46% relative humidity (from the US Standard Atmosphere) the reduction is 75%.
Ralph B. Alexander describes another molecular consideration ignored in the Climate Act. Each greenhouse gas affects outgoing radiation differently across the bell-shaped radiation spectrum One of the reasons that CO2 is considered the most important greenhouse gas is that its effect coincides with the peak of the bell shape. On the other hand, the effect of CH4 is down in the tail of the bell shape. As a result, the potential effect of CH4 is on the order of only 20% of the effect of CO2.
Andy May’s excellent summarization of Wijngaarden and Happer’s important paper “Dependence of Earth’s Thermal Radiation on Five Most Abundant Greenhouse Gases” explains that the greenhouse effect of methane is not only related to the effect on longwave radiation itself but also the concentration in the atmosphere. Because the atmospheric concentration of methane is so small doubling concentrations change the “outgoing forcing by less than one percent”. In other words, doubling emissions or cutting emissions in half of methane will have no measurable effect on global warming itself.
The residence time of the two gases is different. Methane only has a lifetime of about 10-12 years in the atmosphere. The “consensus” science claim is that 80% of the anthropogenic CO2 emissions are removed within 300 years. (Note however that there are other estimates of much shorter residence times.) This means that CO2 is accumulating in the atmosphere. CH4 is converted to CO2 and is then counted in the monthly CO2 measurements as part of the CO2 flux. Because methane does not accumulate the same way as CO2 it should be handled differently. However, the Climate Act doubles down on using the same approach. Climate Act authors claimed it was necessary to use 20-year global warming potential (GWP) values because methane is estimated to be 28 to 36 greater than carbon dioxide for a 100-year time horizon but 84-87 greater GWP over a 20-year period.
Dr. Mathew Wielicki gives a good, illustrated description that puts methane in perspective. Note that some of the article is behind a paywall.
Politicians must recognize the residential reliability benefits of natural gas. I have lived in my home for over 40 years. I have never had an outage of natural gas service. There have been many minor electric outages and two multi-day blackouts. We survived the long blackout because we had natural gas for heating and cooking. Surviving and recovering the grid in an all-electric energy system will be extraordinarily challenging.
I do not think that the Energy Plan has adequately recognized the resiliency value of natural gas and its benefits during electric outages. My described personal experience is shared by many and ignored in the Draft Energy Plan. I think it must acknowledge that recovery of an all-electric energy system will be extraordinarily challenging and that natural gas provides the fuel diversity necessary for a resilient energy system.
NYSERDA’s recently released GE Grid Performance Gaps Study states that New York needs approximately 25 gigawatts (GW) of capacity contribution by 2040 to replace the fossil fuel fleet. Politicians must acknowledge that dispatchable emissions-free resources simply will not be available by 2040.
One of the themes in the Draft Energy Plan is that the Climate Act law mandates compliance deadlines. However, it does not adequately acknowledge that Public Service Law (PSL) Section 66-P, Establishment of a renewable energy program, is also a law. PSL 66-P requires the Public Service Commission (PSC) to establish a program to ensure the State meets the 2030 and 2040 Climate Act obligations. It includes provisions stating that the PSC is empowered to temporarily suspend or modify these obligations if, after conducting an appropriate hearing, it finds that PSL 66-P impedes the provision of safe and adequate electric service.
With Richard Ellenbogen, Constatine Kontogiannis, and Francis Menton I submitted a filing in a PSC generic proceeding. As described here, our submittal includes the primary filing, two exhibits documenting the customers in arrears safety valve trigger, and five supporting exhibits. Responsible New York agencies all agree that new Dispatchable Emissions-Free Resource (DEFR) technologies are needed to make a solar and wind-reliant electric energy system viable during extended periods of low wind and solar resource availability. Two of the supporting exhibits document the implications of this necessity. Exhibit 4 – Resource Gap Characterization analyzes gaps between Climate Act mandates and available resources, and Exhibit 5 – Dispatchable Emissions-Free Resources explains that the need for a resource that is not currently commercially available risks investments in false solutions. I maintain that safe and adequate electric service can only be guaranteed if the necessary DEFR technology has been proven feasible.
In my opinion, the most promising DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready, can be expanded as needed and does not suffer from limitations of the Second Law of Thermodynamics. If the only viable DEFR solution is nuclear, then renewables cannot be implemented without it. But nuclear can replace renewables, eliminating the need for a massive DEFR backup resource. It is common sense to replace aging natural gas-fired generating units now rather than hope that the necessary replacement technologies will appear as needed in the future.
New York State has not developed a plan to ensure DEFR will be available as needed and that means that a natural gas generation must be available. NYSERDA’s coordinated study to assess future grid reliability and stability under high-renewable scenarios in the GE Grid Performance Gaps Study states that New York needs approximately 25 gigawatts (GW) of capacity contribution by 2040 to replace the retiring fossil fuel fleet. Politicians must acknowledge that zero-emission resources that provide all the grid reliability services provided by natural gas generation simply will not be available by 2040. We must use natural gas as a bridge fuel until proven dispatchable emissions-free resources are available.
I am going to follow up with another post on natural gas and the Draft Energy Plan. The oral comment time constraints prevented me from covering other topics. I will explain that natural gas has a place in the transportation sector, there are unacknowledged natural gas advantages, and the State used arbitrary permitting decisions to deny permit applications for needed infrastructure improvements.
Conclusion
My oral comments concluded using similar terminology to this. The policies incorporated into the Climate Act that drive the Draft Energy Plan are not based on facts or research but ideology. They are, in a word, irrational. Not so long ago the idea that natural gas could be used a bridge fuel until the aspirational “clean” generating resources and energy storage technologies could be tested at the scale needed, perform like a natural gas fired generating unit, and provide power at a similar cost, was generally accepted as a pragmatic approach. The only rational approach to maintain reliability and lower costs is to go back to that concept.
The New York Draft State Energy Plan prepared by the New York State Energy Research & Development Authority (NYSERDA) is currently out for comments. This is one in a series of posts describing my concerns about the Health Benefits chapter that I am planning to consolidate and submit as a written comment. This post describes issues with the air quality modeling analysis used to predict health benefits.
I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. The primary emphasis of my career was air pollution meteorology and air quality analysis which is the focus of my planned comments. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 575 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Net-Zero Aspirations
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.
According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.” This is the first update of the Energy Plan since the Climate Act was passed in 2019, so it is being revised to incorporate the net-zero mandates. I have provided more background information and a list of previous articles on my Energy Plan page.
Health Benefit Chapter Comments
My first post/ draft written comment described my oral comment at the virtual Draft State Energy Plan Public Hearing on September 13, 2025. I noted that NYSERDA is using a new modeling approach to project the air quality impacts associated with Climate Act implementation that are used to determine health benefits. Although they claimed that they had verified the approach, the methodology used was invalid, thus undermining the credibility of all the health benefits claims.
The crux of the NYSERDA health benefit claim is that various health effects are exacerbated by air pollution. If that is true, then observed inhalable particulate matter (PM2.5) should correlate with observed health outcomes. In my second post I compared observations of the same metrics cited in the Health Benefits chapter. I found no observed relationship between annual average PM2.5 and emergency room visits related to asthma for the New York State monitoring stations used.
The third post compared the air quality projections and the health benefit claims in context with observed variability. I showed that the predicted impacts on emergency room visits, and inhalable particulate air quality reductions are within the range of observed variations. Contrary to the messaging, this suggests that the results will not be observable.
Air Quality Modeling Challenges
I have a long and wide-ranging background in air quality modeling. When I read that the health analysis estimated benefits from reduced exposure to fine particulate matter (PM2.5) concentrations at the community scale I was taken aback because of the level of effort required. The Appendix to the Health Benefits Chapter states the analysis modeled “dispersion of primary PM2.5 and secondary PM2.5 precursor pollutants nitrogen oxides (NOx), sulfur dioxide (SO2), volatile organic compounds (VOCs), and ammonia (NH3)”. All this is needed to determine state-wide impacts on the resolution required to predict impacts to disadvantaged communities.
The first challenge is the large number of sources and receptors. All significant point sources of air pollution have Title V permits and there are 160 permitted facilities. The Appendix states: “On-road emissions from major and secondary road categories (interstates, arterials, and major collectors) were modeled as line sources.” It also notes that the modeling include “the residential, commercial, and non-road sectors, as well as non-point industrial sources.” All those sources were modeled to estimate impacts on 4,911 census tracts in New York State.
The second challenge is that there are five pollutants and the Appendix notes that both primary and secondary pollutants were considered. Inhalable particulates (PM2.5) can be emitted directly but most of the observed particles are secondary pollutants formed in chemical reactions from NOx, SO2, VOCs, and NH3. The chemical reactions that create secondary pollutants vary by season, meteorological conditions, and distance/time from the emitting source. In many areas of the state, the observed PM2.5 is mostly secondary from upwind sources. When modeling local impacts, it is sufficient to only consider straight line impacts determined by hourly wind directions, however, secondary upwind pollutant reactions occur over multiple hours necessitating more sophisticated transport patterns to track where the pollution transport.
Finally, it is not simple to characterize emissions for all of society as they claimed to do. It is hard enough to characterize existing emissions from power plants, factories, homes, businesses, and vehicles over time and space. In this analysis they also had to project how emissions would change during the transition away from fossil fuels for projections out to 2040.
Health Benefits Modeling Approach
My first hope was that they would try to do the air quality modeling right. I believe that would require a massive analysis simulating all the processes that affect the air quality concentrations. The analysis is even more complicated because the air quality analysis was only the first step. The goal was to predict health impacts and that required additional analysis The Introduction to the Appendix in the Health Benefits chapter explains that there are two more components in the analysis:
The basic framework of the analysis is:
Estimate changes in air pollutant emission reductions based on changes in fuel consumption as modeled in the Pathways Analysis (see Pathways Analysis chapter).
Analyze changes in air quality resulting from reductions in air pollutant emissions.
Analyze changes in health effects resulting from changes in air quality.
Calculate the monetized value of the change in health effects using standard economic values.
This analysis supports claims of Draft Energy Plan “substantial” health benefits for the transition across New York down to disadvantaged community levels. The first two components in the framework cover the air quality analysis portion that I have personally done in the past. The other two components listed represent policy support issues that are outside of my experience. It is apparent that the methodologies were dictated by the desire to prove substantial health benefits.
A key difference from the approach used for the Scoping Plan is that this analysis was conducted using a newly developed air quality and health impacts modeling framework—the NY Community-Scale Health and Air Pollution Policy Analysis (NY-CHAPPA) model —rather than using the Environmental Protection Agency’s (EPA’s) CO-Benefits Risk Assessment Health Impacts Screening and Mapping Tool (COBRA) to analyze health outcomes from changes in fine particulate matter (PM2.5) concentrations. In addition,
The need for impact resolution down to the census tracts required the new NY-CHAPPA model.
COBRA was used to evaluate the impact from changes in ozone concentrations at a county level (this is a new capability now available from COBRA but is limited to the county scale). The NY-CHAPPA modeling framework estimates benefits at a sub-county scale, which enables evaluation of potential health benefits by community type, allowing evaluation of health effects within geographic disadvantaged communities (DACs) as defined under the Climate Act.
EPA’s COBRA model was used to provide information not available from NY-CHAPPA.
Issues
As noted, a comprehensive air quality modeling analysis would require an enormous effort. NY-CHAPPA is a screening model like EPA’s COBRA model. Both include many simplifications to improve computational efficiency. Rather than analyze hour by hour data, COBRA’s core air quality modeling relies on the Phase II Source-Receptor (S-R) Matrix, which establishes fixed transfer coefficients representing the relationship between emission sources and air quality impacts at receptor locations. In my opinion, if the transfer coefficients are based on five years or more of historical meteorological data, then the results are generally acceptable for screening analyses like this health benefits analysis.
My problem with the NY-CHAPPA model is that it over-simplifies the air quality analysis. COBRA uses the well-established and proven Climatological Regional Dispersion Model (CRDM) that categorizes atmospheric stability, wind direction and wind speed like NY-CHAPPA.. Both models use the same number of stability and wind speed categories. The most important air pollution impact parameter is wind direction, because impacts only occur if the wind is blowing from the source to the receptor of concern. CRDM uses 16 wind categories, but NY-CHAPPA only uses four. Given all the sources in the analysis I think using only four wind directions is unacceptable. This gives results that are just too crude to be representative of the actual relationship between sources and receptors.
My other problem is that the health impact emphasis on inhalable particulate matter and ozone amplifies the importance of secondary pollutants. The source receptor matrix approach is not well suited for this application. This simplification means the results have much uncertainty. Using them to drive the health benefits and monetized value of change components of the analysis prioritizes getting an answer over getting a defensible answer. One of my problems with the Draft Energy Plan process is that there is no provision for technical meetings to address specific topics where stakeholders could ask questions. One of the problems with a climatological approach like the one used here is interannual variation of the meteorological parameters. The Annex explains that the analysis reviewed five years of data from 29 meteorological monitoring stations:
The data from each year was analyzed to determine the interannual variability in the meteorological data, as discussed in the following section, “Meteorological Sensitivities.” Based on the results of this analysis, a single year of meteorological data (2017) was selected for use in NY-CHAPPA.
Discussion
This is the last of my topical health benefit articles. I will use these posts to prepare a written comment on the Draft Energy Plan. I have been critical of the stakeholder process because it appears that NYSERDA is treating the process as an obligation and not as an opportunity to improve the Energy Plan. This example is no different.
In a recent article Doreen M. Harris who serves as President and CEO of the New York State Energy Research and Development Authority and Chair of the New York State Energy Planning Board summarized the health benefit message. She said:
Additional analysis shows that continued implementation of the State’s energy policies would provide substantial public health benefits throughout the State in all communities, with the greatest benefits realized in disadvantaged community areas. This includes reduced emissions and cleaner air resulting in avoided hospitalizations, work loss days and emergency room visits due to asthma.
My written comment will show that the claim of “substantial public health benefits” is the result of an analysis that was designed to get that answer. I compared observed inhalable particulate matter emergency room visits related to asthma and found no relationship. When I compared the air quality projections and the health benefit claims relative to observed variability, I showed that the projections are within the range of observed variations suggesting no observable impact should be expected. This post describes issues with the modeling approach that can only be ignored if a validation analysis indicates that the simplifications do not affect the observed predictions. In my first post I showed that the purported verification study did not compare projections using historical inputs to observed air quality. This makes the methodology invalid, thus undermining the credibility of all the health benefits claims.
Conclusion
All the analyses in NYSERDA used in health benefits chapter of the Draft Energy Plan get a failing grade. They were designed to get a particular answer without regard to common sense science. It is incumbent upon NYSERDA to prove that their new methodology is credible. My comments should precipitate, at a minimum, a revision to NY-CHAPPA to include 16 wind directions and a valid verification analysis of the modeling. I don’t expect NYSERDA to respond. Instead, I expect that my comments will be ignored like all my previous submittals.
The New York Draft State Energy Plan prepared by the New York State Energy Research & Development Authority (NYSERDA) is currently out for comments. This is one in a series of posts describing my concerns about the Health Benefits chapter that I am planning to consolidate and submit as a written comment. This post puts the benefit claims in context with the observations.
I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. The primary emphasis of my career was air pollution meteorology and air quality analysis which is the focus of my planned comments. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 575 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Net-Zero Aspirations
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.
According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.” This is the first update of the Energy Plan since the Climate Act was passed in 2019, so it is being revised to incorporate the net-zero mandates. I have provided more background information and a list of previous articles on my Energy Plan page.
Health Benefit Chapter Comments
I am drafting the components of my planned written comments in a series of posts. The first post described my oral comment at the virtual Draft State Energy Plan Public Hearing on September 13, 2025. I noted that NYSERDA is using a new modeling approach to project the air quality impacts associated with Climate Act implementation that are used to determine health benefits. Although they claimed that they had validated the approach, the methodology used was invalid, thus undermining the credibility of all the health benefits claims.
The crux of the NYSERDA health benefit claim is that various health effects are exacerbated by air pollution. If that is true, then observed inhalable particulate matter (PM2.5) should correlate with observed health outcomes. In my second post I compared observations of the same metrics cited in the Health Benefits chapter. I found no observed relationship between annual average PM2.5 and emergency room visits related to asthma for the New York State monitoring stations used.
Air Quality and Health Impact Context
One of the key findings in the Health Benefits chapter states:
All communities in New York State would experience public health benefits as a result of implementing State energy policies that would substantially reduce air pollutant emissions relative to the No Action scenario and therefore lower pollutant concentrations. As a result of policies in the Draft Plan’s core planning scenario, Additional Action, population-level health risks associated with exposure to air pollutants would be lower, including cumulatively from 2025–2040 reducing premature mortality by approximately 9,700 cases, along with an estimated 4,100 fewer nonfatal heart attacks and nearly 12,500 fewer emergency room visits for asthma, and further improvements in other metrics. Under all planning scenarios, health benefits are expected to increase over time from 2025 to 2040 and continue beyond 2040.
There is no question that reducing air pollutant emissions will provide health benefits but the relationship is complex, and in my opinion usually exaggerated. My comments address whether the claimed asthma emergency room visit health benefits from the inhalable particulate air pollution improvements related to Climate Act implementation are credible. Claimed public health effects are listed in Table 2 of the Draft Energy Plan Health Effects chapter. I address the avoided emergency room visits due to asthma benefits which range from 1,100 to 3,600 fewer cases per year.
This analysis compares the emergency room visits due to asthma health effect relative to observed data. As documented in my previous post the New York State Department of Health (NYSDOH) New York State Asthma Dashboard provides these data. The Asthma Dashboard provides state-level data for 11 indicators in the “asthma emergency department visits” component. There is an export function tab on the Main State Dashboard that I used to download a file with state-level data in the Asthma dashboard to the “Asthma Data Dashboard – State” tab in my AD-State Trend Data RC spreadsheet. I extracted the asthma emergency department data in the “Data” tab. Note that no data were reported for 2015. The “Summary” tab describes the data. Table 1 lists the annual asthma emergency room visits for different age groups. All my analyses used the total asthma emergency department visits. Of particular interest note that the Covid Pandemic changed the identification of asthma. In my opinion, limiting the comparison data from 2009 to 2019 would be more representative of an actual relationship.
Table 1: NYSDOH New York State Asthma Dashboard Asthma Emergency Department Visits
Table 2 lists some simple statistics describing these data for the entire data record. NYSERDA modeling claims that avoided emergency room visits due to asthma improve from 1,100 to 3,600 cases per year. The range between maximum and minimum annual emergency room visits over all 13 years of available data is 107,713. Importantly, the improvement of 3,600 avoided emergency room visits is 10% of the standard deviation and 3.3% of the range of observed emergency room visits. I believe the predicted improvement is a negligible fraction of the observed emergency room visit variation.
Emergency room asthma reporting changed in 2020 due to Covid. Because this changed the reporting metric, I re-ran the statistics for the data available from 2009 to 2019. Table 3 lists the same statistics describing these data for that period. The range of emergency room visits over all 10 years of data before Covid is reduced to 47,636. The maximum number of avoided emergency room visits is 24% of the standard deviation and 7.6% of the range of observed emergency room visits. Even with this data set, the predicted improvement is a small fraction of the observed emergency room visit variation.
The Draft Energy Plan health benefits chapter includes a section on societal value. The introductory paragraph notes: “The public health benefits from reductions in air pollutant concentrations described above are also evaluated as a monetized societal value that can be combined into a single metric to evaluate and compare total public health benefits.” The final key finding states: “The combined societal value of the public health benefits from reductions in PM2.5 and ozone concentrations from 2025 to 2040 is estimated to be nearly $65 billion for Additional Action (net present value 2024$)”. This section puts the societal values in context.
First, I want to make a general point about NYSERDA documentation. Jim Shultz described the Scoping Plan as “a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it.” That extends to the spreadsheet documentation. In my opinion, spreadsheet documentation should be provided for every graph in the document. That is not the case. My tables in this section include numbers derived by interpolating numbers off graphs. In my jaded opinion, NYSERDA is hiding important but inconvenient numbers by not providing the numbers directly.
Figure 11 shows the estimated public health benefits for 2025–2040 (net present value 2024$) from reduced PM2.5 concentrations under each scenario relative to the No Action scenario. Table 4 lists the PM2.5 net present values for the different scenarios shown on the Health Benefits chapter figure. To compare the Health Benefits chapter benefits to the air pollution reductions I calculated the average annual benefit by dividing the total by the number of years in the range 2025-2040. The NYSERDA annual societal benefits range from $1,3 billion for the Current Policies scenario low end estimate to $7.9 billion for the Net Zero A scenario high end estimate. The aforementioned $65 billion total benefit claim is over 16 years for the Additional Action scenario.
Table 4: PM2.5 Net Present Value (Billions 2024$) Derived from Figure 11
Health Benefits chapter Figure 4 presents the population-weighted average PM2.5 concentration reductions by scenario relative to the No Action Scenario, 2040 (μg/m3). Table 5 lists the interpolated concentration values I estimated from the graph.
Table 5: Population-Weighted Average PM2.5 Concentration (μg/m3)Reductions by Scenario
Table 6 lists the observed (2017-2022) inhalable (PM2.5) particulate matter concentration data included in the Appendix to the Health Benefits chapter. I calculated the average, standard deviation, and range for each monitor and for the regions used in the chapter.
Table 6: Observed (2017–2022) PM2.5 Concentrations (μg/m3) in New York State
The point of this exercise is to compare the predicted concentrations with the observed concentration variations (Table 7). The average predicted concentration reduction for all three scenarios is less than the range of observed annual concentrations. This means that the predicted reductions are within the range of inter-annual variation. I therefore conclude that is not a significant impact.
Table 7: Population-Weighted Average PM2.5 Concentration Reductions by Scenario Compared to Observed PM2.5 Concentrations
There is another point of emphasis. The Health Benefits chapter claims annual benefits of $7.9 billion for emission reductions of up to 1.8 μg/m3. Although the lack of detail precludes a refined valuation, note that the observed interannual variation exceeds the largest predicted concentration reduction. If the NYSERDA modeling is correct, then the societal benefits should be observable in the observed annual variation of societal costs. To prove this is an appropriate approach, NYSERDA should document the observed benefits and how they vary with observed pollution concentrations.
Discussion
The Public Health Impacts Overview states “The draft analysis shows that implementation of State energy policies would continue to provide substantial public health benefits throughout the State in all communities, with the greatest benefits realized in disadvantaged community areas.” I do not assert this analysis disproves NYSERDA’s claim of substantial public health benefits . However, I do conclude that NYSERDA justification of their claim for ”substantial public health benefits” has not been adequately justified.
The rationale to reduce fossil-fired emissions because of the relationship between inhalable particulates and asthma is touted in this analysis and is commonly used in other emission reduction proposals. This analysis shows that when the NYSERDA numbers are compared to observations, that observed interannual variations exceed the projected changes in PM2.5 concentrations and number of avoided emergency room visits related to asthma. If these claims are accurate and substantive, then the societal benefits claims should also be observed. In the absence of any data, I believe that the only value of these efforts is to feel good about an emission reduction. They are not substantive enough to claim that the net-zero transition is providing health benefits that justify the enormous costs of the proposed emission reductions.
Conclusion
My recent posts address three shortcomings of the NYSERDA analysis of health benefits of the net-zero transitions. NYSERDA used a new procedure to estimate health impacts that needs to be validated but the alleged verification process was fatally flawed. One of the key health concerns is the effect of inhalable particulates on asthma related emergency room visits but there is no observed relationship between annual average PM2.5 and emergency room visits related to asthma for the New York State monitoring stations used in the NYSERDA analysis. This post shows that the predicted impacts on emergency room visits, and inhalable particulate air quality reductions are within the range of observed variations. This means that the impacts do not justify the investments.
The New York Draft State Energy Plan is currently out for comments. While I have submitted oral comments at three hearings I have no intention of preparing detailed written comments on many topics because there is no indication that the New York State Energy Research & Development Authority (NYSERDA) will seriously consider stakeholder input. Because of my experience as an air pollution meteorologist and because of the fundamental flaw in the air quality analysis underpinning the Health Benefits chapter analysis I am preparing written comments on this topic. This post presents one component of that submittal – the premise that air quality is responsible for observed asthma health impacts.
I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 575 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Net-Zero Aspirations
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.
According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.” The driving factor for the updated Energy Plan is net-zero ambitions of the Climate Act. This is the first update of the Energy Plan since the Climate Act was passed in 2019. I have provided more background information and a list of previous articles on my Energy Plan page.
Air Quality and Health Impacts
I submitted an oral comment at the virtual Draft State Energy Plan Public Hearing on September 13, 2025, about the health benefits chapter. Because comments are limited to two minutes it was impossible to justify my submittal so I posted a documentation article here. The crux of the oral comment was that NYSERDA is using a new modeling approach to project the air quality impacts associated with Climate Act implementation that are used to determine health benefits. Although the Health Benefits chapter claimed that they had validated the approach, I showed that their analysis was wrong.
In my written comments I intend to explain why the analysis is wrong. This is important because one key rationale for the transition is health improvements so if their estimates of air quality improvements are wrong the health benefits are wrong too. The Public Health Impacts fact sheet claims the following health effect benefits.
All these calculations are based on air quality impacts estimated using a methodology that is based on the premise that air quality is the driver for these health effects. I have always been uncomfortable with claims like this but haven’t found data for health impacts that I could compare to air quality observations. This article simply compares asthma and air quality data to see if there is a clear relationship.
Asthma Data
The New York State Department of Health has developed the New York State Asthma Dashboard. There are five component New York State data sets available:
Asthma Emergency Department Visits
Asthma Hospital Discharge Data
Asthma Deaths and Death Rates
Asthma Prevalence
Asthma Data for the Medicaid Managed Care Population
Note that the health effect “Emergency room visits, asthma” parameter in the Draft Energy Plan health effects analysis and the “asthma emergency department visits” parameter in the first component measure the same thing. Documentation for the data sources notes that there are qualifications on these data. For example, people can have asthma and not go to the emergency department and asthma visits are not only related to exposure but also are related to access and quality of primary care.
The Asthma Dashboard provides county-level data for 11 indicators in the “asthma emergency department visits” component. There is an export function tab on the Main County Dashboard that I used to download a file with county-level data in the Asthma dashboard – county trend tab in AD-County Trend Data RC spreadsheet. The annual trend tab lists values for the discrete years 2017-2022. The County tab lists values for those counties that had ambient air quality monitoring stations listed in the Health Benefits Chapter Appendix Table A-3.
Ambient Air Quality Data
The New York State Department of Environmental Conservation (DEC) operates an ambient air quality monitoring system across the state and prepares annual reports. The methodology appendix in the Health Benefits chapter of the Draft Energy Plan compares the observed inhalable particulate matter (PM2.5) with their model predictions to validate their approach as shown in Table A-3 below. That analysis used data from 19 monitoring sites. This analysis will use the same sites except for the near-road monitor because they are not intended to capture average ambient concentrations.
The presumption in the Health Impacts analysis is that higher pollution levels will result in greater asthma health effects. The purpose of this article is to simply check the data for this relationship. The data used, graphs generated and statistics calculated are available. I used EXEL to calculate correlation coefficients using the CORREL function. This coefficient ranges from -1 (perfect negative) to +1 (perfect positive); values near zero indicate little/no linear relationship between the variables. If asthma rates are related to inhalable pollution, then the coefficient should be close to +1. I also plotted the asthma health impacts against the pollution levels to see if there is an obvious relationship. The relative changes of the parameters over time should indicate if the premise is likely. Note that I have scaled the inhalable particulate concentrations so that the plots both show differences with time.
The CORREL correlation coefficient for the Albany monitor and the Total asthma emergency department visit rate per 10,000 in Albany County was 0.07 and for Loudonville it was 0.40. Note that these were the only correlation coefficients that suggested there was a positive relationship between pollution and asthma. Inhalable particulate (PM2.5) concentrations are multiplied by 5 in the graph.
The CORREL correlation coefficient for the IS-52 monitor and the Total asthma emergency department visit rate per 10,000 in the Bronx was -0.46 and -0.80 for Pfizer Lab Site Botanical Garden. Inhalable particulate (PM2.5) concentrations are multiplied by 20.
The CORREL correlation coefficient for the Amherst monitor and the Total asthma emergency department visit rate per 10,000 in Erie County was -0.62 and -0.51 for Pfizer Lab Site Botanical gar. Inhalable particulate (PM2.5) concentrations are multiplied by 10.
The CORREL correlation coefficient for the Whiteface Base monitor and the Total asthma emergency department visit rate per 10,000 in Erie County was -0.02. Inhalable particulate (PM2.5) concentrations are multiplied by 10.
The CORREL correlation coefficient for the JHS 126 monitor and the Total asthma emergency department visit rate per 10,000 in Kings County was -0.58. Inhalable particulate (PM2.5) concentrations are multiplied by 10.
The CORREL correlation coefficient for the IS 45 monitor and the Total asthma emergency department visit rate per 10,000 in Manhattan was -0.63. Inhalable particulate (PM2.5) concentrations are multiplied by 10.
The CORREL correlation coefficient for the IS 45 monitor and the Total asthma emergency department visit rate per 10,000 in Monroe County was -0.75. This relationship was the worst observed. Inhalable particulate (PM2.5) concentrations are multiplied by 10.
The CORREL correlation coefficient for the Newburgh monitor and the Total asthma emergency department visit rate per 10,000 in Orange County was -0.45. Inhalable particulate (PM2.5) concentrations are multiplied by 10.
The CORREL correlation coefficient for the East Syracuse monitor and the Total asthma emergency department visit rate per 10,000 in Onondaga County was -0.45. Inhalable particulate (PM2.5) concentrations are multiplied by 10.
The CORREL correlation coefficient for the Queens College 2 monitor and the Total asthma emergency department visit rate per 10,000 in Queens County was -0.37. Inhalable particulate (PM2.5) concentrations are multiplied by 10.
The CORREL correlation coefficient for the Port Richmond monitor and the Total asthma emergency department visit rate per 10,000 in Richmond County was -0.00. This was the monitor with the least indication of a relationship. Inhalable particulate (PM2.5) concentrations are multiplied by 10.
The CORREL correlation coefficient for the Pinnacle State Park monitor and the Total asthma emergency department visit rate per 10,000 in Steuben County was -0.08. Inhalable particulate (PM2.5) concentrations are multiplied by 10.
The CORREL correlation coefficient for the Babylon monitor and the Total asthma emergency department visit rate per 10,000 in Suffolk County was -0.50. Inhalable particulate (PM2.5) concentrations are multiplied by 10.
Asthma, Ozone, and Inhalable Particulates
The Health Benefits chapter calculates benefits based on impacts from inhalable particulates and ozone. The following graphs include ozone. I did not calculate the correlation coeffients. Note that there are fewer ozone monitors.
Inhalable particulate (PM2.5) concentrations are multiplied by 5 and ozone concentrations are multiplied by 1,000.
Inhalable particulate (PM2.5) concentrations are multiplied by 20 and ozone concentrations are multiplied by 1,000.
Inhalable particulate (PM2.5) concentrations are multiplied by 10 and ozone concentrations are multiplied by 1,000.
Inhalable particulate (PM2.5) concentrations are multiplied by 10 and ozone concentrations are multiplied by 1,000.
Inhalable particulate (PM2.5) concentrations are multiplied by 10 and ozone concentrations are multiplied by 1,000.
Inhalable particulate (PM2.5) concentrations are multiplied by 10 and ozone concentrations are multiplied by 1,000.
Inhalable particulate (PM2.5) concentrations are multiplied by 10 and ozone concentrations are multiplied by 1,000.
Inhalable particulate (PM2.5) concentrations are multiplied by 10 and ozone concentrations are multiplied by 1,000.
Inhalable particulate (PM2.5) concentrations are multiplied by 10 and ozone concentrations are multiplied by 1,000.
Discussion
I believe that NYSERDA has the responsibility to show that their health effect methodology is accurate. The intent of this post was to simply generate the graphs and run a simple statistic to see if there was an obvious relationship between normalized county-wide total asthma emergency department visits and air quality monitoring station measured concentrations of inhalable particulates and ozone. I did not think there would be an obvious relationship, but I was surprised that it was so bad. Only two of the sixteen comparisons suggested that there was a relationship that indicated that inhalable particulate concentrations influenced asthma emergency department visits.
In the oral comments I made on September 13, I stated that to establish credibility the modeling must prove the methodology is accurate by comparing predictions and observations over the same time period. Incredibly, the Draft Energy Plan does not do that. On page A-13 the draft states: “Because model projections were only available starting with year 2025, these results were compared against multiple years of observational data”. That is just plain wrong.
The 2017-2022 data set used was listed in their Table A-3. This is a very limited data set for validating a model. I did not bother to try to calculate more sophisticated statistics for my evaluation because the level of effort was high and the data sets so small that any result would not be robust. Nonetheless, these results set a high bar for the Draft Energy Plan health effects analysis validation study. If there is no observed relationship between observed air quality and asthma effects, then I cannot imagine a scenario where model predictions compared to observations over the same time period could possibly show that the model is working satisfactorily.
Conclusion
I intend to use the information in this post as part of my written comments on the Draft Energy Plan. I have more concerns that will make the modeling results used in the health benefits analysis even less credible. As I said in my oral comments last week, I have seen no indication that NYSERDA is going to seriously consider stakeholder input so this will likely be the extent of my written comments. When I submit my comments, I will conclusively prove that the air quality relationships that are the fundamental driver of the health benefits are wrong. The question is whether NYSERDA and, by extension the Hochul Administration, will concede that there is a problem and revise their analysis. I do not think that they will even acknowledge that I submitted a contradictory comment.
This post documents the oral comments I submitted at the virtual Draft State Energy Plan Public Hearing on September 13, 2025. The New York State Energy Research & Development Authority (NYSERDA) only allocated two minutes per person, so this article documents the statements that I made.
I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 575 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Net-Zero Aspirations
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.
According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.” The New York State Energy Planning Board is a “multi-agency entity established under Article 6 of the Energy Law, playing a core role in the State Energy Plan process”. Among its responsibilities is adopting the State Energy Plan: The Board has the authority to adopt the comprehensive statewide energy plan, and the stakeholder process should be an important component of that responsibility.
The driving factor for the updated Energy Plan is net-zero ambitions of the Climate Act. This is the first update of the Energy Plan since the Climate Act was passed in 2019. I have provided more background information and a list of previous articles on my Energy Plan page. Because of the importance of this process on the future energy system of New York I am following it closely and will be submitting oral and written comments.
Comments
This section documents the comments I made on September 13, 2025. I used bullets to differentiate my comments from the explanations.
My name is Roger Caiazza. Documentation for my comments will be posted on my Pragmatic Environmentalist of NY blog
As noted in the introduction I am convinced that implementation of the New York Climate Act will do more harm than good.
I have not seen any indication that NYSERDA is going to seriously consider stakeholder input, so I have no plans to submit written comments on all the problems I have seen in the draft. Air quality modeling is a particular expertise of mine so I have looked at the Public Health Impact Chapter air quality modeling analysis.
I submitted comments at the first virtual meeting on August 19 that argued that there had to be assurances that the process will respond to stakeholder input if the process is to be credible. There hasn’t been any suggestion that the process will respond to stakeholder input. Moreover, despite assurances that recordings of the hearings would be posted, links to the first hearing were not posted until September 12.
I have been employed as an air pollution meteorologist since 1976. According to Perplexity AI that means I am a “specialized atmospheric scientist who applies meteorological principles and techniques to understand, predict, and mitigate air pollution impacts.” To predict air pollution impacts I have used several models that use source characteristics, emission rates, and meteorological conditions to estimate pollution concentrations.
The modeling methodology is new and, in my opinion, flawed because it over-simplifies inhalable particulate air quality source-receptor relationships. At the same time, it applies the model to an extraordinarily large emission inventory. I will submit written comments addressing those concerns.
I am still working on detailed comments about these flaws. In brief, they use a simplified approach that cuts down on computer time but I think they have oversimplified the source to receptor metrics. For example, one of the simplifications is to limit the meteorological inputs to four wind directions. Given that wind direction is enormously impactful on pollution impacts I think that is unacceptable. A minimum of 16 wind directions are necessary to represent impacts satisfactorily.
To establish credibility the modeling must prove the methodology is accurate. The appendix to the health impact chapter purports to validate the model for this reason. An air quality model verification analysis uses historical meteorology and emissions input to predict air quality concentrations and compares those results with observed concentrations over the same time period.
While working for a consulting firm I did extensive air quality model evaluation work. The process is not complicated. It is necessary to compare model results against observed concentrations. Obviously, the observations need to be for the same time period as the predictions.
The draft does not do that. On page A-13 the draft states: “Because model projections were only available starting with year 2025, these results were compared against multiple years of observational data”.
When I first read that statement, I did a double take and read it again. I could not believe it. It is inconceivable that a reputable analysis could claim to evaluate model performance by comparing observed historical concentrations against future predicted concentrations.
That is just plain wrong. The verification statistics presented are worthless. It means that the health benefit claims are unsupportable.
The biggest problem describing this situation is finding the right terms to describe the enormity of the error without using profanity.
Discussion
The Public Health Impacts fact sheet claims the following health effect benefits.
All these calculations are based on air quality impacts estimated using a new methodology that has not been validated. I have many other questions about this methodology that I need to research before I can comment. I am not denying that there will be benefits but the magnitude of the claims appears to be exaggerated. My first impression is that because the range of observed PM2.5 concentrations is greater than the projected emission reductions then these projections are suspect.
There are troubling implications associated with this finding that a critical component in the health impact analysis is incorrect. It does not speak well for the scientific integrity of the work products. I presumed that NYSERDA hired experts to review the draft before it was released but the enormity of this error indicates that the review process failed.
Also consider that in the Scoping Plan analysis NYSERDA estimates of the benefits were deliberately misleading. The Draft Energy Plan is similarly hiding the true costs needed to meet the Climate Act targets. In both cases the primary trick was to use an inappropriate future baseline scenario. I have no doubt that the primary charge given to NYSERDA was to make the costs and benefits look as good as possible. It appears those marching orders override scientific principles.
The Climate Act includes requirements to address disadvantaged community impacts. To respond to that requirement NYSERDA needed a new model so they developed the modeling approach used here. I think it is likely that the pressure to produce favorable benefits at the resolution necessary was greater than the pressure to do so following scientific principles. They probably assumed that no reader would sift through the documentation and pick up on the fact that their modeling validation study was bogus. Of course, the fact that NYSERDA does not respond to comments means that they will just ignore the flaw that I documented here.
Conclusion
When I described this to one of my friends, he remarked that this is proof that science and NYSERDA cannot be used in the same science. I agree completely.
Stay tuned for a follow up post on this component of the Draft Energy Plan.
I believe that the New York Climate Leadership & Community Protection Act (Climate Act) has always been about politics. It was enacted to cater to specific constituencies and implementation will only change if politicians realize that the majority of New Yorkers have limited appetite for the effects on affordability and personal choice and modify the Climate Act. This post presents an opinion piece by Assemblyman Phil Palmesano (R,C-Corning) who argues that New York energy policies must ensure energy affordability, reliability, feasibility, safety, choice, and fuel diversity.
I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Net-Zero Aspirations
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.
In July the Draft Energy Plan was released for public comments. According to the New York State Energy Plan website: “The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers.” The driving factor for the updated Energy Plan is net-zero ambitions of the Climate Act. I have provided more background information and a list of my previous articles on my Energy Plan page.
The opinion piece released by Palmesano is in response to the Draft Energy Plan public stakeholder process. I present it in its entirety below. Assemblyman Palmesano represents the 132nd District, which includes Schuyler County, Yates County and Parts of Chemung County, Seneca County and Steuben County. He is the ranking member on the Assembly Energy Committee, a role he has held since 2013. For more information about Assemblyman Palmesano, please follow him on Facebook.
New York Leaders Need to Listen to the People
As you may have seen recently, I have embarked on a statewide energy tour, joining with my Assembly and Senate Republican colleagues at all locations across the state where the New York State Energy Research and Development Authority (NYSERDA) is holding public hearings on the state’s proposed energy plan. The goal of this tour is simple: to make the public aware that Gov. Hochul and Democrats in the Legislature are pushing policies that will continue to increase utility rates for New York families and businesses. The fact of the matter is the policies they continue to advance are designed to dismantle the affordable and reliable natural gas infrastructure, supply and delivery system. This, despite the fact that 60% of New Yorkers heat their homes with natural gas, and 40% of our generation comes from natural gas. Their policies are designed to take away consumer choice on how you heat your home, cook your food, power your buildings and the vehicle you drive. Their policies will jeopardize the reliability of the grid, leading to dangerous and deadly blackouts and will continue our nation-leading outmigration crisis of more families, farmers, small businesses and manufacturers leaving our state. The governor and Democrats in Albany are on mission to fully electrify our state’s energy grid with no concern for energy affordability, reliability, feasibility, safety, energy choice or fuel diversity.x`x`
NYSERDA also needs to expand its hearings to include Central New York, the North Country and the Southern Tier. Currently, in-person hearings are only being held in Buffalo, Rochester, Albany, the Hudson Valley, New York City and Long Island, along with three virtual hearings. It is completely unacceptable and unfair that the citizens and businesses of Central New York, the North Country and the Southern Tier do not get an opportunity to voice their input and concerns at an in-person hearing. Therefore, we have called on NYSERDA to schedule in-person public hearings at these three locations, as well as grant an extension of the public comment period by 90 additional days until January 4, 2026, so a more thorough process can be achieved. Given the far-reaching impact of our state’s draft energy plan, coupled with the radical energy/climate policies being advanced in Albany, it is critically important more time be granted for New York families and businesses to weigh in on our state’s energy future.
The state’s draft energy plan says we need an “all of the above” approach to our energy plan, including the use of natural gas, nuclear and fuel diversity. Unfortunately, the policies being pushed and advanced in Albany don’t match the words. Gov. Hochul and the Albany Democrat-controlled Legislature continue to side with far-left Green New Deal advocates instead of siding with everyday New Yorkers. Families and businesses across the state have already seen their energy bills sky-rocket while utilities continue to call for even higher rates because of the Democrats’ green energy mandates, with more to come. In fact, in July of 2023, the PSC approved $43B in future ratepayer increases to pay for green energy mandates. The comptroller and others have estimated these green energy mandates will cost more than a quarter-of-a-trillion dollars.
Some of these costly policies include the following. First, you have the CLCPA (New York Green New Deal), which requires net-zero generation by 2040 regardless of the costs, feasibility or how it jeopardizes energy reliability for families and businesses. In addition, the All- Electric Buildings Act will deny new home construction as of January 2026 the ability to use natural gas or propane and be fully electrified. Then there is the mother of all unfunded mandates, the Electric School Bus Mandate, which is as much as three times more expensive than a near-zero emission-free diesel school bus, which is estimated by the Empire Center to increase replacement costs by as much as $15 billion for school property taxpayers, not to mention the billions of dollars in charging infrastructure and energy grid upgrades. New York is requiring school districts to convert their entire bus fleets to electric by 2035, a full five years before the state is required to convert its fleet. In what world does this make any sense? Why should school districts be the guinea pig for this social experiment? There is Cap and Invest (or Carbon Tax), which is estimated to increase gas prices at the pump by 62 cents per gallon and natural gas home heating by 80%, according to former DEC Commissioner Basil Seggos. The new electric vehicle purchase requirements, including the Advanced Clean Truck Rule and Advanced Clean Car II rule that mandate electric vehicle and truck purchases regardless of the lack of infrastructure in place, range issues, costs or preferred choice of New Yorkers, just to name a few. In addition, for perspective, the residential electricity rate for New Yorkers in 2019 was 17 cents/kw hr. Today, it is 25 cents/kw hr. or 40% higher than the national average. This is completely unsustainable for New York families and businesses.
To make matters even worse, this plan will barely impact global emissions. New York is already one of the cleanest energy producers in the world; in fact, we contribute just 0.4% of global emissions while China contributes 30%, has 1,000 coal plants and is building more every week. We could literally cut our emissions to zero and have no effect on worldwide global emissions. All this shows that Gov. Hochul is more worried about looking good to her far-left base ahead of next year’s gubernatorial election rather than doing the right thing to advance policies that actually protect ratepayers while ensuring an energy plan that is affordable, reliable, feasible, safe and protects fuel diversity and energy choice. That is what New Yorkers want.
In fact, there was a poll this past summer where 71% of New Yorkers strongly indicated they did NOT want a ban on natural gas, including 76% of independents. In addition, 66% of New Yorkers indicated they want a balance between renewable energy resources and natural gas, including 74% of Democrats. The decision is clear. New Yorkers want energy choice and the use of natural gas to cook and heat their homes.
It’s long past time for Gov. Hochul and Democrats in Albany to finally listen to New York families and businesses when it comes to our state’s energy plan and policies instead of virtue signaling for votes.
Conclusion
One politician gets it. I do not know what it will take for enough politicians to accept the inevitable that the Climate Act will adversely affect affordability, reliability, and personal choice for no tangible benefits. At some point the perceived political benefit of supporting the Climate Act will become an inescapable liability. To achieve this goal New Yorkers need to know what is happening and then speak up. Palmesano’s op-ed is a good contribution to that goal.
On April 28, 2025, a problem at a photovoltaic plant in Spain triggered a blackout over the Iberian Peninsula. I believe that this event should be considered in the New York Draft State Energy Plan.
I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Background
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda” was based on an Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA).
The Draft State Energy Plan is being updated for the first time since the Climate Act was promulgated. 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.” I have provided more background information and a list of previous articles on my Energy Plan page. Because of the importance of this process on the future energy system of New York I am following it closely and have been developing comments.
Blackout
The authors of the Climate Act had a very superficial knowledge of the electric system. The presumption in the academic energy studies that guided the Climate Act is that generation and load are sufficient aspects of the electric system for projecting electric system changes. They believe that if there is enough generation, no matter the source or where it is located, to balance the load then the system will work. Meredith Angiwn authored an entire book Shorting the Grid – The Hidden Fragility of Our Electric Grid devoted to the unacknowledged difficulties associated with wind, solar, and energy storage resources shortcomings related to maintaining voltage and overall system reliability not considered in the Climate Act. The Spanish blackout should be a wakeup call to New York politicians that the technical experts at the New York Independent System Operator and New York State Reliability Council should be fully integrated into the Energy Plan process. They are trying to resolve the myriad technical issues associated with integrating wind, solar, and energy storage into the grid and I am uncomfortable that the NYSERDA Draft Energy Plan addresses all their concerns.
Two recent posts at the Watt-Logic blog describe the blackout this spring on the Iberian peninsula that affected Spain, Portugal, and France that I think needs to be considered in the Draft Energy Plan. The first article looked at the physics of power grids and the general behavior of both synchronous generation (gas, hydro and nuclear) and inverter-based generation (wind, solar and batteries). Watt-Logic gives an overview explanation of the “importance of voltage control and reactive power” that were the root cause of the Spanish blackout. In short, the existing system depends upon synchronous generators that convert mechanical energy (spinning turbines) into electrical energy, producing alternating current that matches the frequency of the electric grid. These generators inherently provide important electric grid functions that are difficult to replicate with inverter-based resources like wind, solar, and energy storage. The problem is that not only do inverter-based resources not perform many of these functions, but they can also de-stabilize the grid in certain, poorly understood circumstances.
The second post addressed what we know about the Iberian blackout. Watt-Logic explains that the blackout “demonstrated the importance of voltage control and reactive power, and how a weak grid, with poor controls, was brought down by a single faulty solar inverter.” The basis of the blog post was a “concise but informative report produced by Red Eléctrica de España (“REE”), the Spanish Transmission System Operator (“TSO”), which is more accessible than the much longer government report (available only in Spanish – rough English translation here).”
Watt-Logic lists the key messages from the REE report:
The blackout was triggered by a PV inverter–induced voltage oscillation
Inappropriate disconnections of wind and solar generation, and widespread failure of reactive power support, escalated the disturbance
REE relied on static controls and failed to deploy dynamic response assets
Grid code non-compliance was widespread among renewables, conventional generators, and even REE itself (via non-compliant transformers)
The collapse exposes systemic risks in low-inertia grids with high levels of inverter-based resources (“IBRs”) and inadequate voltage control
It is notable that, despite confident denials from some renewables advocates in the immediate aftermath, it was in fact a malfunctioning solar installation that triggered the voltage oscillation initiating the collapse. Wind and solar generators failed to meet fault ride-through obligations, and both inverter-based and conventional generators failed to provide the required reactive power support. Crucially, conventional generators did not trip prematurely – they remained online until system conditions breached their design tolerances.
If you want more information about this event then I recommend reading the post. For the purposes of this article, there are no references in the Draft Energy Plan to the blackout. That is understandable given that the blackout occurred a couple of months prior to the release of the document. On the other hand, the consequences of this event have serious implications to New York’s 2040 zero-emissions mandate.
Solar Costs
The second reason that the Spanish blackout should be considered in the Draft Energy Plan is because of the cost implications. Most of the public still believes the charlatans who claim that solar is the cheapest form of energy. A recent Doomberg blog explains that after the blackout in Spain earlier this year “the true cost of solar can no longer be hidden from the public.”
The Doomberg post describes the blackout and the attempts by Spanish authorities to deflect blame away from the possibility that the problem was due to the solar facilities. Their post goes on: “As the results of the investigation became undeniable, responsibility was pinned not on solar but on the grid operators who had failed to make the necessary investments to handle the rapid influx of green electricity.” They stated that:
Last week, an expansive article in Bloomberg Green—confessionally titled “The Fix For Solar Blackouts Is Already Here”—captured this sentiment. It lamented that the penetration of solar and wind has outpaced the buildout of stabilization technologies such as synchronous condensers and grid-forming inverters. In other words, the renewables worked as designed, but the infrastructure to integrate them safely at such high percentages of supply lagged far behind:
“The result is huge spending on new wind and solar capacity, but not enough on grids. The 27 members of the European Union and the UK invest on average $0.7 in grids for every dollar spent on renewables, according to BloombergNEF. Spain ranks the lowest, with only $0.3 spent for every dollar.
Blackouts are causing political backlash against renewables that politicians cannot afford right now. ‘Here’s the problem: Investments in the right infrastructure are not keeping up,’ said António Guterres, head of the United Nations, in a July speech. ‘That ratio should be one to one.’”
When you hear someone claim that solar is cheaper than natural gas, tell them that the head of the United Nations says that for every dollar spent on solar capacity, another dollar must be spent on transmission upgrades to prevent blackouts. Then point out that because of night, another dollar must be spent on energy storage.
Doomberg sums it up:
In reality, while the marginal cost of sunlight is zero, the true system cost of integrating solar into a modern grid includes the heavy and ongoing capital expenditures needed for transmission, stabilization, balancing services, and energy storage. Without those, the electricity produced cannot be delivered reliably, making it far less “cheap” than advocates claim.
Discussion
This post provides more reasons why solar is not the solution that many believe it to be. It is time that New York politicians insist that the technical experts at the New York Independent System Operator and New York State Reliability Council be fully integrated into the Energy Plan process. The experts responsible for providing reliable electricity are working to resolve the myriad technical issues associated with integrating wind, solar, and energy storage into the grid. I am uncomfortable that the NYSERDA Draft Energy Plan addresses all their concerns.
The Draft State Energy Plan is being updated for the first time since 2017. While the mandate for the Energy Plan calls for more frequent updates there is no need to rush this update. This is the first update since the Climate Act was promulgated in 2019, so it is more important that this edition get it right than to meet an arbitrary deadline. Therefore, the fact that this consequential event is not addressed in the Draft is an important reason to delay the deadline for comments on the draft.
In my opinion, addressing this event and the changes to Federal support for renewable deployment are important enough that there should be a second draft prepared for comment. The NYSERDA response to the extremely uncertain current situation could result in a significantly different energy plan. New Yorkers should have the opportunity to address a draft that addresses these issues.
Conclusion
The Spanish Blackout has important implications for New York’s electric energy plan. The issues raised here should be addressed and resolved before the Energy Plan is finalized.
Pragmatic Environmentalist of New York 