Slavish Devotion to the Aspirational Goals of Its Climate Act Is Still the Goal of New York Energy Planning.
Guest Post by Roger Caiazza of Pragmatic Environmentalist of New York.
This is part of my continuing coverage of the New York State Energy Plan. My intent is to describe most of the sections of the June 25, 2025 meeting presentation. This article addresses the discussion of the electricity portion of the draft Energy Plan document. My friend Tom Shepstone described the natural gas section so I don’t have to do that one.
Energy Plan Overview
According to the New York State Energy Plan website (Accessed 3/16/25):
The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.
I have provided more background information and a list of previous articles on my Energy Plan page. Sad to say, but this process looks like a repeat of the Scoping Plan process where New York State Energy Research & Development Authority (NYSERDA) provides numbers that align with the desired political outcome and goes through the pro forma motions of a stakeholder process. In my opinion, stakeholder input should be treated as more than just an obligation.
There is no sign that NYSERDA considers stakeholder input because the only way to prove that input is considered is to provide a response to comments document that describes how comments were considered. This has been noticeably lacking in NYSERDA Climate Act documentation. Obviously, the Energy Planning Board needs to hear both sides of issues to provide a meaningful input to the process. Otherwise, the Board is just a figurehead entity that provides the appearance of deliberation but does not engage in actual review.
June 25, 2025 Board Meeting
The materials for the meeting include the following:
Board Meeting Recording Meeting Recording
I previously summarized the presentations that described the analyses conducted for the State Energy Plan and those that covered Energy Plan topic areas. I have included links to the locations of the video in the following descriptions. Also, note that a transcript of the presentations is included at the meeting recording video platform. There is a nice feature for this video. If you set auto scroll on then you can follow the presentation transcript. All quotes below come from that transcript.
This article will describe the electricity topic area in the draft Energy Plan document.
Topic Area – Electricity
David Coup, assistant director on NYSERDA’s Policy Analysis and Research team, and Jessica Waldorf, Chief of Staff and Director of Policy Implementation at the Department of Public Service read the electricity topic script. Waldorf set the theme of the presentation acknowledging “major challenges” in the first slide:
Waldorf stated:
“The electric chapter focuses on the key theme of needing to have reliable power at reasonable rates, because it is the backbone of the State’s economy and critical to our public health and safety.”
This is typical for New York State. The statement sounds good and addresses an absolute need, but the reality is there is no substance or follow-through to the commitment. In this instance if the State were committed to reliable power at reasonable rates, they would define what that means. Clearly there is some limit to what New York can afford to pay but the criteria for the safety valves for affordability and reliability have not been defined.
The presentation went on to describe six slides. One takeaway is this is the first acknowledgement of some key challenges that have not been mentioned before. However, in my opinion the presentation does not convey the myriad issues associated with some of the topics mentioned in passing.
All the topic slides have a similar format. There is a list of key existing state actions and related recommendations. However, the uncertainties and seriousness of the challenges for the recommendations are not mentioned. I think this gave the Energy Planning Board members a false sense of security.
The first slide title said “New York State will continue to support the deployment of clean energy resources including large scale renewables (LSR), distributed and community solar to meet demand and preserve reliability.” Earlier in the meeting the uncertainty and challenges of the deployment were mentioned. However, there was no explicit acknowledgement of the Biennial Report findings that found that the meeting the 2030 targets would not be possible until at least 2033.
Two of the recommendations are related and are of particular interest to me. The first acknowledges that planning is required for existing sources: “Continue to evaluate the State’s existing clean firm capacity resources since they will be critical to achieving a zero-emissions grid.” The second confronts the reality of New York City peaking power plants: “The State will need to be strategic about the pace of combustion unit retirements and/or replacements as it works to pursue achievement of its clean energy targets.” Waldorf explained:
This section of the chapter highlights the importance of the state needing to be mindful about managing the retirement of downstate units in a manner that won’t cause air quality to worsen and disadvantaged communities and will not cause negative system reliability impacts. It also discusses a statutory requirement that the New York Power Authority has, and as part of that, the requirement to conduct an air emissions analysis prior to any retirement of these facilities.
I described my position on peaking power plants on a dedicated page and asked Perplexity AI to compare my arguments against the Peak Coalition position. The implementation issue is that that a politically favored group has demanded that the peaking units be shut down but this presentation acknowledges there is an issue. Wordsmithing this problem and promising more analyses that cannot possibly affect the outcome will only postpone political accountability for the inevitable decision that shutting those units down to placate a political constituency is not going to keep the lights on.
The title of the second slide states: “The State will continue to leverage and expand the deployment of storage and demand side resources, including energy efficiency measures and flexible technologies, to lower the cost of the clean energy transition and to enhance grid reliability.” The lack of uncertainty descriptions and not including a rating of technological maturity and challenges for the proposed storage and demand side resources is a significant flaw. In my opinion, most of the recommendations are basically magical thinking.
The next slide title states: “The State will need to be strategic in identifying and integrating clean firm technologies that have the attributes necessary to support the achievement of a zero emissions electric grid by 2040.” This is the most egregious failure to admit the challenge of “identifying and integrating” technologies. This is a veiled reference to the Dispatchable Emissions-Free Resource that is an acknowledged prerequisite for the proposed weather-dependent electric system.
The State is studying the issue but there is no timeline for definitive recommendations how the state should go forward. I think that the Energy Planning Board needs to know that the chances are essentially zero that technologies that are not commercially viable and must be tested, permitted, and deployed at the scale projected on a timeline consistent with the Climate Act mandates will be availble. This should have been discussed.
Furthermore, consider the key existing state actions. The zero emissions by 2040 Proceeding is in place but nothing has happened since early 2024 so there is no apparent sense of urgency regarding plans for DEFR. The DPS Staff Whitepaper refers to a November 2024 technical document that defined zero emissions and the statewide electrical demand system and recommended how to treat imports. The PSC has not yet acted on the paper. The zero by 2040 techno-economic study refers to an on-going research study. In my opinion all these efforts represent the starting point of a planned transition. Implementing them as we go along does not bode well.
The fourth slide headline notes “The State will continue to advance smart and strategic energy system planning to enhance system reliability and drive down the cost of necessary transmission and distribution system investments.” This slide is bafflegab, i.e., wordy jargon whose purpose, in this instance, is to obscure the challenge of maintaining current reliability standards while massively implementing unprecedented changes to the system.
The Coordinated Grid Planning Process is a great example of what needs to be done but the reality is that it should have been set up before New York embarked on this transition. Moreover, it only addresses transmission. They mention that we should “pursue integrated electricity and natural gas system planning” recognizes that something similar is needed in that realm. Implementation planning in retrospect is not a recipe for success.
The next slide’s headline states: “The State needs to evaluate wholesale market and retail rate structures to ensure they properly value and compensate new energy resources and market services and prioritize energy affordability for consumers.” Coup acknowledges that “There’s a lot of things here on this slide that talk about assessing, exploring, and evaluating.” In other words, we are not doing this now. This is another example of the lack of planning inherent in CLCPA net-zero transition planning to date.
The final slide title states: “Future investments in our energy system must be designed to withstand the impacts of a changing climate.” This slide and Coup’s description frustrates me to no end as a meteorologist. New York State climate change doctrine is completely consistent with the media narrative. Roger Pielke, Jr. just reposted an article describing the media’s narrative. His section on extreme weather is consistent with Coup’s statement and encapsulated my concern:
Weather is a renewable resource. It happens every day, and somewhere it is extreme. Hurricanes, tornadoes, floods, drought, hail, oh my! It has become fundamental to the climate beat to associate, link, connect — pick your favorite — the extreme event that just happened with climate change. Forget the IPCC and rigorous standards of detection and attribution. There are studies to cherry pick, quotable experts and a new cottage industry of rapid event attribution studies. Extreme weather is no longer about the weather.
The solution is simple – “withstand the impacts of a changing climate” should be changed to “withstand the impacts of extreme weather”. We are not even planning for the past now. My message to NYSERDA is to get back to me when you have accounted for past extreme weather and then we can discuss climate change impacts.
Discussion
I have takeaway messages for the Energy Planning members. The impression I got from the presentations at the 25 June 2025 Energy Plan meeting is that NYSERDA and DPS have the implementation of the Climate Act under control. It cannot be emphasized strongly enough that the reality is different. In the real world the presentations only scraped the surface of the number and magnitude of the issues facing New York’s implementation of the Climate Act.
For an example of the complexity not acknowledged, consider the statement in the last slide in the presentation that stated that “Establishing criteria for metrics like expected unserved energy (EUE) may help supplement traditional LOLE-based criteria by providing information about risks of long-duration outages.”
EUE stands for Expected Unserved Energy. It is the summation of the expected number of megawatt hours of demand that will not be served in a given time period as a result of demand exceeding the available capacity across all hours. This parameter addresses issues associated with the long duration wind and solar resource lulls that is the driver for the need for DEFR. I have concluded that this issue causes insurmountable reliability risks.
Eventually there will be an unusual set of weather conditions and load requirements that exceed the EUE criteria. When that happens for the future net-zero system there won’t be enough energy for all the electrified sectors and a catastrophic blackout will result. In my opinion, the Energy Planning Board should consider risks like this for the proposed Energy Plan. I do not expect that NYSERDA or DPS will willingly raise this issue.
Reading between the lines reveals that the draft Energy Plan concedes the electric system transition is not well planned. Consider that New York State will “advance smart and strategic energy system planning“ is predicated on coming up with ways to do that. If they are “assessing, exploring and evaluating” ways to be smart, then what does that say about current planning? My Google AI Assistant says the opposite would be “unstructured or haphazard planning, which lacks clear goals, measurable outcomes, and a coherent approach to achieving objectives”. I agree.
Finally, there are multiple references to stakeholder input in this presentation. Until NYSERDA documents how they treated stakeholder input, the implication that they value this input rings hollow.
Conclusion
There is every indication that slavish devotion to the aspirational goals of the Climate Act is still the goal of the Energy Plan process.
At the same time NYSERDA and DPS claim that the transition “must be managed within the constraints imposed by Federal and State reliability requirements and at a justifiable cost to ratepayers.”
There are no quantifiable criteria for affordability and reliability. If there were safety valve criteria, then I have no doubt that they would be exceeded because a weather-reliant electric system will never be affordable or safe.
#ClimateAct #NewYork #Electricity #Caiazza #ClimateChange #EnergyPlanning
Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York. This post represents his opinion alone and not the opinion of his previous employers or any other company with which he has been associated. Roger has followed the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and has written over 500 articles about New York’s net-zero transition.
