Pragmatic Environmentalist of New York Summary Update October 5, 2025 – October 19, 2025
This is a summary update of posts at Pragmatic Environmentalist of New York for the two weeks ending on October 19. 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.
Draft Energy Plan
On October 6 comments were due on the draft State Energy Plan prepared by the New York State Energy Research & Development Authority (NYSERDA). According to the website “All comments will be posted on as soon as practicable.” The comments submitted by the New York State Independent Operator (NYISO) were so good that I posted two articles describing them.
Draft Energy Plan Comments Made by the NYISO
This post summarizes the comments submitted by the NYISO. The NYISO comments point out that there are three “structural trends” that create significant uncertainty about the future electric system: “The New York grid is at an inflection point, driven by the convergence of three structural trends: the aging of the existing generation fleet, the rapid growth of large loads, and the increasing difficulty of developing new dispatchable resources.
The comments describe four concerns associated with these trends that contradict the beliefs of many:
1. Electric Grid Concerns Exist Today
2. Repowering Existing Generation and Introducing New Generation Will Prove Critical to Maintaining Electric System Reliability
3. Existing Nuclear Generation is Critical to Meeting the Demands of New Yorkers
4. Emerging Technologies and Other Resource Development
The comments pointed out two existing grid concerns. Reliability margins are eroding because more generating capacity is being retired than being brought online. The problem is compounded by the fact that units that can be dispatched as necessary to match load are retiring and units that depend on the weather and time of day are being brought online. NYISO noted that the Draft Energy Plan responded to this concern by stating:
Combustion generating units will remain essential parts of electric grid reliability and affordability. Retirement of these units will not be able to occur until resources that provide the same grid reliability attributes are put in place.
This is important because it is the first time NYSERDA has admitted that existing fossil units must not retire until in kind replacements are available. Anyone who thinks existing fossil units are not necessary is wrong. Period.
The other structural concern address the fact that energy intensive development is driving up demand for electricity. NYISO explains development projects, “such as microchip fabrication, bitcoin mining, and data centers, are projected to be major drivers of load growth, in addition to the electrification of the building and transportation sectors”. The NYISO comments point out that “Access to renewable generation resources, sufficiency of overall generation available, and a robust transmission network should increasingly be an integral part of the consideration of where to locate large load projects.”
In the NYISO discussion of concerns they suggested that “Repowering existing generation can offer a bridge between old and new, the past and the future” and “Integrating new efficient fossil-fuel-based generation (which may be capable of operating with lower- or zero-emissions fuels in the future) will immediately improve electric system reliability and reduce total emissions”. Ideologues who insist that the Climate Act precludes any new fossil infrastructure because it is unnecessary ignore the reliability risks that NYISO raised.
The remaining NYISO points of emphasis also contradict the core beliefs of devoted proponents of the Climate Act transition. The NYISO comments note that “existing nuclear generation is critical to meeting the demands of New Yorkers” is certain to upset a vocal minority who believe that nuclear is unnecessary. A key to their faith-based transition is that no new technology is needed but NYISO states that the development of not yet commercially available at scale technologies “must start now as these technologies need to be proven and deployed to the electric grid before the resources that currently supply the energy that consumers demand and the reliability attributes needed to support the grid can be retired.”
NYISO Draft Energy Plan Comments Recommendations
I did a second post that addressed the NYISO recommendations in their comments. These recommendations address the concerns described in the previous article. I will just list the recommendations and refer readers to the blog post for details.
The final State Energy Plan must include a recommendation consistent with the Draft Plan observations that combustion generating units “remain essential parts of electric grid reliability and affordability, and retirement of these units will not be able to occur until resources that provide the same grid reliability attributes are put into place.”
The electric system needs all existing generation resources and needs new generation resources before the current fleet suffers a catastrophic failure that jeopardizes the health, safety, and welfare of New Yorkers. The final State Energy Plan must include a recommendation removing barriers to new resources to address the age of the generation resources that are critical to maintaining electric system reliability.
The age of the existing generation fleet and the lack of viable alternative technologies require steps to use the best technology currently available. The final State Energy Plan must include a recommendation to facilitate development of natural gas-fired combustion generation to immediately support electric system reliability and be available until new, dispatchable, emission-free generating technologies are commercially available to support electric system reliability, e.g., hydrogen and advanced nuclear.
The reliability attributes and overall energy production that nuclear resources provide to the electric system unquestionably demonstrate the need for these resources to remain available in New York.
Given the significant need for resources demonstrated by the Outlook and contemplated in the Draft Plan, the final State Energy Plan should explore all emerging technologies, while focusing on promising technologies that will be readily available sooner and continuing to invest in current technologies including repowering fossil-fuel-fired generation to support fuel diversity and overall electric system reliability.
The NYISO is responsible for keeping the lights on. Thomas Sowell has been quoted as saying: “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong”. In this instance, there is nothing more stupid or dangerous than ignoring the recommendations by the people who will pay the price if there are problems with the electric system.
RGGI Investment Proceeds July 2025 Update
RGGI Investment Proceeds Report Implications in Watts Up With That
Dealing with the Regional Greenhouse Gas Initiative (RGGI) regulatory and political issues is challenging enough that affected entities seldom see value in speaking out about fundamental issues associated with the program. I have been involved in the RGGI program process since its inception and have no such restrictions when writing about the details of the RGGI program. I published two versions of an article describing the RGGI annual Investments of Proceeds report. The Watts Up With That version is less technical.
The usual suspects believe that market-based programs like RGGI are a magical solution that raise money, reduce emissions, and provide funding for meaningful investments. I showed that despite claims about the success of RGGI, the reality is that the only thing it is good at is raising money. Suggestions that RGGI has been responsible for the observed reductions in CO2 emissions over the life of the program ignore the importance of fuel switching and the poor performance of RGGI auction proceed investments in reducing emissions.
The results support my conclusion that RGGI can only claim to raise money effectively. This article documents the following. The investment costs exceed the expected societal benefits. The amount raised falls far short of the funds necessary to reduce RGGI emissions in accordance with Third Program Review requirements. Investment priorities are inconsistent with the emission reduction objectives. Finally, emission reductions associated with RGGI investments only account for 7.6% of the observed reductions.
Renewable Reliability Risk Reasons to Pause
This article highlights a couple of recent documents that describe the reliability challenges introduced by wind and solar resources. These reports are another reason we need to pause implementation because I think they make an argument that these problems are unreconcilable.
I addressed another aspect of the NYISO recommendations for reliability metrics in their Draft Energy Plan comments. NYISO addressed the following recommendation related to the Electricity Chapter of the Draft State Energy Plan:
Consider whether the current reliability-related metrics should be supplemented given the evolving nature of the grid and increased risks of high-impact reliability events. New York should consider whether the current reliability-related metrics (i.e. loss of load expectation) should be supplemented given the evolving nature of the grid and the increased risks of high-impact reliability events.
In my opinion, this is a critical recommendation. I believe the biggest unresolved reliability risk associated with Climate Act implementation is the new Dispatchable Emissions-Free Resource (DEFR) technologies needed to make a solar and wind-reliant electric energy system viable during extended periods of low wind and solar resource availability. I do not believe that policy makers understand the ramifications associated with a fundamental planning component of this resource – how much is needed. My article describes the significant challenge caused by the tradeoff between the enormous costs of this necessary but infrequently used resource during the worst case and the risks if insufficient electric energy is available when the de-carbonized energy system is completely electrified.
The second article addresses another problem. Until now, my concerns about the wind and solar dependent system have focused on supply during low resource periods. The Iberian Peninsula blackout was caused by the characteristics of wind, solar, and energy storage. Deric Tilson writing at the Ecomodernist delves into the minute-by-minute description of exactly what caused the April 2025 blackout in Spain. He includes an excellent description of the technical causes of the blackout.
His conclusion exposes the risk of the Climate Act monomaniacal focus on limiting future electric energy sources to wind, solar, and energy storage:
Some are waiting expectantly for the results of official investigations into what caused the Iberian blackout; they want some person, policy, or technology to blame. But, electrical systems are not so simple as to care about your pet policies. We need a wide variety of generation sources and types: stable baseload power to always be on and provide generation in all hours of the day; quick, responsive power for when demand is changing rapidly; and emergency power for when there are outages. Grids are more reliable when there is diversity. Nuclear, natural gas, wind, hydroelectric dams, diesel, geothermal, and coal can all contribute to a resilient system.
Ellenbogen on Recent NYISO Reliability Concerns
On October 13, 2025 the New York Independent System Operator (NYISO) released its quarterly assessment of reliability of the bulk electric system. The analysis found a deficit in reliability margins for the New York City area beginning in summer 2026. NYISO also released the draft 2025-2034 Comprehensive Reliability Plan (CRP), that provides a plan to maintain a reliable electric grid over a ten-year planning period. I am working on posts about these documents but, given the importance of the analyses, published Richard Ellenbogen’s take on a viable approach to address the issues raised. I have previously published other articles by Ellenbogen including a summary description of his issues with the Climate Act. In addition, he and I have submitted several joint filings in different venues.
In my opinion, the biggest reason to pay attention to Ellenbogen is because he walks the walk. He has reduced GHG emissions at his home and factory while at the same time reducing costs and improving reliability. The article describes his recommendation for a viable future energy system approach to address the problems identified by the NYISO reports. He explains that he relies on natural gas for this personal success and describes how that approach could be used for the New York energy system. For example, “Repowering three Long Island Power Plants, Port Jefferson, E F Barret, and Northport, could increase their energy output and reduce their carbon emissions by about 50%.” Note that his recommendations are entirely consistent with the NYISO Draft Energy Plan.
The problem with this approach is that it is inconsistent with the Climate Act’s aspiration to go to net-zero GHG emission levels. Ellenbogen’s article argues that the rationale used to vilify natural gas and go to zero is flawed. His article goes on to describe other strategies that could significantly reduce emissions and costs. So far, despite presenting those strategies in proceedings they have been ignored.
His basic message is that significant improvements are possible but mindless adherence to ideological control strategies is counterproductive. “That fantasy is now running headlong into reality and maybe now, people will finally understand what I have been warning about for six years.
New York Solar Siting Travesty
In my opinion, the deployment of solar resources exemplifies the poor planning inherent in the Climate Act net-zero transition plan. One of my concerns is that the state process is not emphasizing responsible solar siting because facilities have been built on prime farmland. I recently found out about a project that is going to be built adjacent to Department of Environmental Conservation (DEC) protected grasslands.
I have been tracking solar permitting and its impact on prime farmland. It is extremely disappointing that ORES has ignored guidance from other state agencies. My latest article provides background on solar mandates I also have a solar siting issues page that documents my concerns. I keep track of the status of projects with the Department of Agriculture and Markets guidelines to protect prime farmland with a Prime Farmland Scorecard. In May 2025 only 12 of the 25 facilities with data available at the Office of Renewable Energy Permit Applications site meet those guidelines. Two facilities had no impacts on prime farmland. If they can do it, why can’t others.
Alexandra Fasulo writing at the House of Green Substack has described another land use issue She posed the obvious question why is it acceptable to build a massive solar energy facility on the same type of grasslands as an adjacent New York State DEC Grassland Wildlife Management Area designed to protect this kind of land?
This is Fasulo’s first introduction to New York’s renewable energy siting process and I think it is safe to say she was shocked about the details. I have allied myself with the Stop Energy Sprawl coalition because of our shared concerns. We all share the same vision of a clean environmental legacy but are convinced that New York State’s implementation of the Climate Act is causing significant and irreparable harm to rural communities because the Office of Renewable Energy Siting (ORES) has authority to override local zoning and land use laws for major renewable energy facilities. It is bad enough that ORES ignores local concerns, but they also ignore other agency guidance. This can all be traced to the lack of a comprehensive plan to implement the transition mandated by the Climate Act. The authors of the Climate Act thought the transition was only a matter of political will and they were wrong.
This is another example why I believe the current Climate Act implementation process will do more harm than good. It is time to hold the politicians who were responsible for this debacle accountable for their actions. Revisions to the laws are necessary to prevent further harm.