Pragmatic Environmentalist of New York Summary Update June 29, 2026 – July 19, 2026

Summaries of my posts over the last three weeks

This is a summary update of posts at Pragmatic Environmentalist of New York for the last three weeks. The intent of this report is to summarize my articles and include links if you want to get into the details. I have been writing about the pragmatic balance of the risks and benefits of environmental initiatives in New York since 2017 with a recent emphasis on New York’s Climate Leadership & Community Protection Act (Climate Act). A pdf copy of the following information and previous summaries are also available. The opinions expressed in these articles 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.

I used Perplexity AI to generate draft summaries of the descriptions in this document. I asked Perplexity to provide a summary of the following posts, edited the output for consistency and accuracy, but shamelessly plagiarized much of the text provided.

RGGI Cheerleaders and the Consumer Carbon Cash Grab

In this article I revisit my long-running critique of the Regional Greenhouse Gas Initiative (RGGI) considering the recent spike in allowance prices following Virginia’s decision to rejoin the program. I explain that higher allowance prices are not “free climate money” but a regressive, opaque tax on electricity that flows through wholesale markets and lands on ratepayers’ bills. Based on my New York cost analysis, I found that direct allowance purchases now run roughly in the $0.7–1.1 billion per year range, with total ratepayer impacts plausibly in the $1.8–3.2 billion range once wholesale price uplifts are counted, leaving a $1.1–2.1 billion consumer deficit after auction proceeds are invested or returned to ratepayers.

I contrast this reality with the “climate cash” narrative in a recent E&E News article, which celebrates record auction revenues as a “big opportunity” for more climate programs and rebates. I argue that rebates simply refund a portion of what ratepayers already paid via higher prices, are politically fragile, and do not change the structural carbon cost adder embedded in wholesale markets. I also emphasize that RGGI-funded investments have only accounted for about 8.7% of observed CO₂ reductions; most reductions came from fuel-switching from coal and oil to gas.

The bottom line is that rising RGGI prices primarily function as a consumer carbon cash grab rather than an affordability strategy, and that honest policy assessment must compare proceeds to full system costs and ask whether households are actually better off. New York ratepayers could save at least one billion annually if we withdraw from RGGI.

RGGI Investment Proceeds June 2026 Update

This article continues my annual review of RGGI’s “Investments of Proceeds” report, focusing on the 2024 data released in June 2026. I summarize the official story: $856 million in proceeds invested in energy efficiency, clean and renewable energy, beneficial electrification, greenhouse gas abatement and climate adaptation, and direct bill assistance, with efficiency again taking the largest share and claimed lifetime bill savings of $2.6 billion and 4.4 million tons of avoided CO₂.

Drawing on my long involvement with RGGI program design and auctions, I compare those claims to actual emission outcomes. My analysis shows that since RGGI began, control programs funded by auction proceeds explain only a small fraction of observed power-sector CO₂ reductions—just 8.7% in 2024—while fuel switching from coal and oil to gas did the heavy lifting. I then calculate cost-effectiveness by dividing total investments by estimated avoided emissions and show a troubling trend: roughly $949 per ton of CO₂ reduced in 2022, $1,854 per ton in 2023, and about $3,200 per ton in 2024. Avoided annual CO₂ fell 42% in 2024 even as spending stayed high, suggesting that investments are becoming less efficient over time.

I point out that documentation is too thin to fully explain these swings, but note that if the RGGI states truly prioritized emission reduction efficiency, they would focus on reversing this trend, not just celebrating larger spending totals. I conclude that RGGI remains very good at raising money but poor at delivering cost-effective, durable emission reductions.

Comparing the New York Energy Transition Against the World

In this post I use Roger Pielke Jr.’s latest global energy transition analysis and the Energy Institute’s 2026 Statistical Review as a benchmark to see how New York’s “net zero” ambitions stack up against reality. I revisit my long-standing view that full implementation of the Climate Act mandates—especially a zero-emissions grid dependent on wind, solar, and storage—risks both reliability and affordability.

Using the Kaya Identity framework that Pielke highlights, I updated my own prior Kaya analysis of New York, extending earlier work I did through 2008. I constructed a New York dataset from NYSERDA’s Patterns and Trends reports, noting that recent editions have become less data-rich and more narrative-driven, which complicates transparent evaluation. With those data and Pielke’s methods appendix, I compared New York’s decarbonization trajectory, energy mix, and demand growth to global trends.

The analysis shows that New York is pursuing more aggressive statutory targets than most of the world despite facing similar structural constraints: rising loads, limited firm zero-carbon options, and political resistance to needed infrastructure. I also discuss how the Climate Act’s evolution—from Governor Paterson’s non-binding 80% by 2050 goal, to the statutory “net zero” framework, and now to recent budget amendments—has not resolved the underlying feasibility challenge of replacing dependable thermal generation at scale.

Overall, I argue that when you test New York’s transition against Kaya-based metrics and global experience, the gap between aspirational law and practical implementation becomes stark, and that serious policy must start from those numbers.

New York Court Refuses to Block State’s Plan for a Renewables Program

This article describes an Article 78 proceeding that Richard Ellenbogen and I filed, with attorney Mathew Hardin, challenging the PSC’s order approving NYSERDA’s Tier 4 Implementation Plan under the Climate Act. I explain that Tier 4 is billed as a way to reduce New York City’s reliance on fossil-fired generation, but our comments and petition argued that the plan’s Renewable Energy Credit trading schemes and clean energy standard mechanics would not materially cut emissions and would increase reliability risks by ignoring firm generation needs.

Rather than re-writing the entire story, I highlight and reproduce Francis Menton’s detailed Manhattan Contrarian summary of the case and outcome. Menton walks through how the PSC dismissed substantive critiques about resource adequacy, costs, materials and labor constraints, and unrealistic timelines, then how the court ultimately disposed of our challenge on technical grounds. The court first held that NYSERDA was a “necessary party” that had not been named within the four-month statute of limitations, and second by questioning our standing because our injuries were not “particularized” enough.

I underscore that the decision says nothing meaningful about the merits; it simply avoids confronting the “arbitrary and capricious” nature of Tier 4 by hiding behind procedural hurdles. In concluding remarks, I echo Menton’s view that even a loss lays down important markers, mathematical, physical, and economic—that bureaucrats and courts will find increasingly hard to ignore as the Climate Act’s practical contradictions accumulate. Since the article was published, we have decided not to appeal the decision but intend to file another Article 78 the next time the State approves a ruling that does not stand up to scrutiny.

2026 Draft CES Biennial Review: How It Addresses Prior Concerns

Here I review the Draft 2026 Clean Energy Standard (CES) Biennial Review released by Department of Public Service (DPS) and New York State Research & Development Authority (NYSERDA} and assess it against concerns I raised in the 2024 review and elsewhere. I note that the report offers a thorough recap of statutory and regulatory background and is meant to inform the Commission’s evaluation of progress toward renewable and zero-emission goals, including load-zone distributions and funding.

I highlight that while the 2024 review already admitted that the 70% by 2030 target was unlikely (projecting only 41% renewables), the 2026 draft revises load forecasts higher—171,050 GWh for 2030—and now projects only 40% of that load will be met by operational and contracted renewables once attrition is applied. Large new loads such as data centers and manufacturing add about 21.4 TWh that were never envisioned when the Clean Energy Standard was created, yet there is still no realistic revised schedule or feasibility-based reassessment.

I then point out a major disconnect: the 2026 enacted budget changed the Climate Act’s interim target from a 40% GHG reduction by 2030 to a 60% reduction by 2040, updated Global Warming Potential accounting, and relaxed several deadlines, but the draft Biennial Review makes no mention of these statutory changes and continues to frame progress against the original 2030 metrics. In my view, that omission undermines the report’s credibility.

Finally, I note that while the report adds a new reliability section acknowledging New York State Independent Operator Short-Term Reliability Assessment findings and generator deactivation risks, it still stops short of the structural reforms and explicit “safety valve” definitions needed to protect reliability and affordability.

June 29–July 4, 2026 Heat Wave: New York Grid Impacts

This post analyzes how New York’s grid performed during the late-June/early-July 2026 heat wave, using NYISO real-time fuel-mix data and my longstanding concerns about Climate Act-driven reliance on weather-dependent resources. I describe the meteorology: a strong, persistent upper-level ridge and associated surface high forming a classic summer pattern—now branded a “heat dome”—that trapped hot, humid air and stressed electric systems nationwide.

I then explain my approach: pulling five-minute generation data from NYISO’s Real-Time Dashboard, aggregating to hourly averages, and examining contributions by hydro (including pumped storage), wind (mostly land-based plus 136 MW offshore), “other renewables” (solar, storage, waste), nuclear, natural gas, dual-fuel, and oil. The resulting fuel-mix profile over the heat wave shows nuclear at 16% and fossil fuels at 64%, meaning 80% of energy came from non-renewables; renewables provided 20%, but hydro alone was 15%. Wind and solar only provided 5% of the energy when needed most.

I use those numbers to contrast actual operations with statutory mandates—70% renewables by 2030 and 100% zero-emissions by 2040, still on the books despite recent budget revisions. The data make clear that under classic high-load, low-wind conditions, New York remains heavily dependent on thermal generation, and that building a reliable peak system around wind, solar, and storage alone would be extremely challenging.

This case study complements my earlier work on the January 2026 cold snap and underscores that both winter and summer extremes expose the same weakness in a weather-dependent grid design.

When Physics Meets Advocacy: Ellenbogen’s Take on Advocate’s Heat Pump Plan

In this article I summarize Richard Ellenbogen’s response to AGREE, EDF, and Rewiring America’s comments on Con Edison’s Draft Heat Pump Operating Economics Customer Engagement Plan. I explain that advocates want Con Edison to use analytics, AMI, and rebate programs to steer customers into “heat pump-friendly” rates like SC 1 Rate III and IV, promising bill savings while electrifying heating.

Ellenbogen, drawing on his engineering background and experience as an early adopter of renewables, systematically shows that in the Con Edison service area the math and physics don’t support those promises. He argues that most gas-to-heat-pump conversions will increase winter bills and upstream fossil generation, particularly because constrained gas pipelines force dual-fuel plants onto oil during cold snaps, increasing emissions by roughly 50% and adding particulate matter. He also highlights that peak-load impacts from heat pumps drive costly grid rebuilds—conductors, transformers, and building circuits—already reflected in Con Edison’s rate case and future NYISO projections showing peak load rising to 40 GW by 2036 and 68 GW by 2054, without firm zero-carbon resources ready.

On the customer side, he cites studies suggesting full electrification retrofits can cost $50,000–$150,000 per unit, adding $300–$900 per month in carrying costs in a city with high rent burdens and over $1.7 billion in utility arrears. He does identify niches where heat pumps make sense (especially oil-to-heat-pump) and emphasizes lower-cost, fuel-neutral efficiency measures as smarter first steps. I close by noting his self-description as “anti-stupidity, not anti-electrification,” and link his critique to Scott Endler’s guest post on better rate design that supports his conclusions.