Pragmatic Environmentalist of New York Summary Update July 14, 2025 – July 27, 2025
Summary of posts over the last two weeks
This is a summary update of posts at Pragmatic Environmentalist of New York over the last two weeks. 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.
Initial Thoughts on the Draft NYS Energy Plan
The biggest New York energy news is the recent release of the draft State Energy Plan. This article described my first impression of the draft. The Draft Plan was approved for public comment by the State Energy Planning Board at the July 23, 2025 meeting. Subsequently, the following information was released:
Volume I: Summary for Policymakers [PDF]
Volume II: Topic Area Chapters
· Acronyms and Glossary of Key Terms [PDF]
· Low-Carbon Alternative Fuels [PDF]
· Climate Change, Adaptation, and Resilience [PDF]
· Energy Security Planning and Emergency Preparedness [PDF]
· Economic Development, Industry, and Agriculture [PDF]
· Clean Energy Jobs and a Just Transition [PDF]
· Environmental and Climate Justice [PDF]
· Local, Regional, and Federal Governmental Collaboration [PDF]
· Energy Affordability Impacts Analysis [PDF]
· Health Impacts Analysis [PDF]
· Environmental Impacts Analysis [PDF]
Data Annexes:
· Pathways Analysis Technical Supplement: Inputs and Assumptions [XLSX]
· Pathways Analysis Technical Supplement: Key Drivers and Outputs [XLSX]
· Business Energy Intensity Data Annex [XLSX]
· Energy Affordability Outputs and Input Data [XLSX]
· Public Health Impacts Analysis Data Annex [XLSX]
My impression is that this is going to be like the Draft Scoping Plan process that was all style, little substance, and only went through the motions of pretending to listen to stakeholders. The last meeting was a vivid reminder that everything associated with the Climate Act is politically motivated. Everything was scripted at the meeting. Planning Board members claim to be concerned about affordability and reliability but until such time that criteria defining what that means are codified, then talking about affordability and reliability is nothing more than a political slogan.
I concluded that there are two critical requirements for a satisfactory Energy Plan. Defining metrics for affordability, reliability, and acceptable environmental impacts should be a primary component of the Energy Plan. Secondly, a transparent and comprehensive stakeholder process is needed for credibility. I do not expect that those requirements will be addressed.
Energy Plan 25 June 2025 Meeting – Economywide Results – 1
I was still trying to complete my description of the previous month’s Energy Planning Board the day before the latest meeting. This post described the load projections and the electric sector’s economywide results that are primary drivers of the Draft Plan.
There are indications that rather than providing clear and transparent costs to achieve the Climate Act mandates that the results will be provided only for programs mandated by the Climate Act. For example, the “No Action” scenario adds 3,174 MW of battery storage. In my opinion, were it not for the Climate Act no one would be building battery storage so calling that addition “no action” is questionable. When the costs to implement are calculated, it will be lower because of this misleading categorization.
In a major concession NYSERDA admits that while “Many aging combustion units retire over the model period. 6 GW are repowered, and the 17 GW fleet is converted to run on Hydrogen by 2040”. Assuming that hydrogen will be available in sufficient quantities in 2040 is magical thinking as is claiming that the combustion fleet will be smaller due to “availability of other firm resources, like storage and Tier 4 hydro imports”. If there is such a thing as wishful and magical thinking, then this bullet exemplifies it: “Zero emission resource definition is under development and hydrogen serves as an illustrative resource for firm dispatchable power”.
The presentation concedes that New York State is not on target to meet the 2030 70% renewable goal and probably will not meet it until 2033. The inclusion of an alternate scenario that keeps fossil-fired units in operation post 2040 is the “between the lines” admission that the present strategy is not going to work as envisioned by the authors of the Climate Act. That scenario is supposed to provide a zero-emissions grid by 2045, five years later than mandated by the law.
I concluded that New York is at a crossroads The inevitability of Climate Act implementation viability being a political liability has been acknowledged even by Governor Hochul. The modeling analysis concedes that the schedule and ambition of the Climate Act is not achievable. This is the perfect opportunity for politicians to stop a program that even they must realize is not working according to plan. The Energy Plan could be used to conclude the schedule, and the aspirations of the Climate Act need to be reconsidered. The political implications to that approach are significant, however.
Energy Plan 25 June 2025 Meeting – Economywide Results 2
There was so much information presented at the meeting that I had to breakup my description of the economywide results into two posts. This article covered the gas system, emissions, and the takeaway highlights.
The gas system projections are similar to the electric system inasmuch as NYSERDA includes the descriptor “transformational” on many of the strategies included. It is not enough to say that it can be achieved. It is necessary to prove it. For example, why will gas customers be willing to change their consumption. What is it for them? Converting to electric heat is more expensive now and will get worse later and it is not as reliable because the likelihood of gas outages is less than electric outages.
I concluded that I cannot overemphasize the enormous difference between wishful thinking in the Pathways Analysis modeling and a feasibility analysis. Is a “significant transformation” possible or is it only a figment of modeling wishful thinking? I also noted that it is encouraging that the Hochul Administration has finally realized that the Climate Act schedule and ambition are impossible to meet. It will be fascinating to see how they extricate themselves for the impossible mandates and the Climate Act legal mandates.
RGGI Third Program Review Consumer Cost Impacts
As a follow on to an earlier article about the status of the Regional Greenhouse Gas Initiative (RGGI) program, I described how I think the cost for permits to emit a ton of CO2 (aka an allowance) affect consumer costs. The bottom line is that it is not currently, nor has it been an historic big cost adder. The following table lists my estimated monthly costs.
Monthly RGGI Residential Costs for 750 kWh per Month Electric Use
For typical consumers, the reason that you are not aware of RGGI is that it is just another hidden cost of environmental excess. The program successfully raised money over $2 billion since 2009 in New York alone. I have shown in the past that since the start of the RGGI program emissions from RGGI sources in New York would have been only 4.2% higher if the NYSERDA program investments did not occur. The looming problem is that the emission reduction trajectory is ambitious enough that the failure to prioritize emission reduction programs could lead to compliance issues.
More Reasons to Pause Climate Act Implementation July 15, 2025
There are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and figure out how best to proceed. This is another description of the reasons to pause.
Department of Energy Reliability Report
Isaac Orr and Mitch Rolling describe the relationship between retirements, demand growth and outages. The U.S. Department of Energy recently released a report entitled Evaluating the Reliability and Security of the United States Electric Grid, which concludes “the United States will experience a 100-fold increase in blackouts if coal and natural gas plants are retired amid rising demand from data centers.”
Orr and Rolling note that this report is an indication that the Department of Energy is stopping the “childish fantasy that America can shut down its reliable coal and natural gas plants and rely on wind, solar, and battery storage to meet surging electricity demand, it’s clear the energy adults are now back in charge.” It is also time for New York to stop its own childish fantasy that existing fossil-fired power plants can be shut down here.
Lessons from Europe - Germany
Brawl Street Journal (BSJ) explains how Germany’s energy policies are affecting neighboring jurisdictions. The article recounts the bureaucratic morass of European Union energy policy. The result of questionable decision-making is that German coal plants will have to run longer:
This creates the absurd situation that high-emission coal must run longer because support for lower-emission gas plants is being denied. It’s the kind of logic you’d expect from a socialist economy where outcomes don’t matter, only ideological purity.
This is exactly what is happening in New York. We already shut down the coal plants but there are many old, inefficient, and relatively high emitting gas units still in operation. The Hochul Administration blocked plans by several plants to repower their old turbines with modern and efficient combined-cycle turbines. The result is that high-emission units must run longer because support for lower-emission gas plants is being denied.
Media Energy Credibility
It may just be me, but it seems that the claims by clean energy zealots are becoming ever more hysterical and shrill in the face of evidence that the Trump Administration is advancing a practical, adult energy policy. The global energy transition is faltering but the media still is claiming otherwise. Robert Bryce describes “What The Media Still Won’t Tell You About The Energy Transition”. He shows that despite massive funding the amount of energy produced by solar and wind are not rising significantly. You don’t hear that too often. It is important because New York’s energy planners must openly address grid reliability, resource adequacy, and practical transition timelines. Until these fundamental concerns are resolved, pausing the Climate Act’s implementation is the only responsible course.
More Reasons to Pause Climate Act Implementation July 26, 2025
This is another post describing reasons to pause. I highlighted the following articles that included many similar themes.
New York Grid of the Future
I outlined a submittal by Dennis Higgins in the Grid of Future Case 24-E-0165 proceeding that gives five reasons to pause, I think the North American Energy Reliability Corporation (NERC) description of risks to the bulk power system is another reason to pause. He explains:
A ‘renewable’ based grid will need a whole new transmission structure – bigger than the current grid -- which someone will have to pay for. It will need full-capacity dispatchable backup and expensive battery energy storage systems. Any wind, solar, and energy storage resources installed today will need replacement by 2050. New York may not be able to shutter significant fossil-fuel power plants but may, rather, be obliged to build more. California – two decades ahead of New York in pursuit of solar and wind -- has extended the operations of three gas power plants until 2026 to maintain energy reliability and affordable rates.
California Dreaming
JohnS has compiled a comprehensive evaluation of the status of the net zero transition in California. Given its climate conducive to solar, converting to a renewable-based system should be easier than New York. However, he notes: “Without an immediate and abrupt policy shift, California is not on a path to achieving its 2045 emissions goal. It’s impossible to predict how close they will get; it all depends on how much economic pain they can endure and how many ecosystems they are willing to sacrifice.”
He also describes a lesson for New York:
A key lesson for other regions is that solar power is a difficult path, even for a wealthy American state with sunny weather and deserts close to big cities. It will be even more difficult in other regions. For instance, New York State has a solar capacity factor of 19.5%, which means the cost of solar power there will be about 1.5 times higher than in California. And without deserts, finding locations for solar farms will be more difficult. Colder climates also have more severe heating needs. Tripling annual heating costs by switching to heat pumps will be more than a tough sell.
Iberian Peninsula Blackout
Watt-Logic wrote two articles about the blackout in Spain earlier this year. The first article described 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). The second post addressed what we know about the Iberian blackout. He explains that voltage control and reactive power limitations of the Spanish grid caused by over-reliance on wind and solar weakened the grid to the point where “single faulty solar inverter” caused the blackout.
Warnings from Down Under
The New Zealand Energy website described how the effects of a drop off in wind production caused a “wild ride” in their electric network. Addressing this issue raises a general problem for the New York wind, solar, and storage zero-emissions transition plan:
More backup and more complex control systems are required. This is exactly what Joesph Tainter described as the diminishing returns on complexity in his book “The Collapse of Complex Societies”.
Rafe Champion explains that the wind lull issues described in New Zealand have led to the situation where the jurisdictions still hell bent on a transition away from fossil fuels have not caught on to the reality that “We have already gone as far as we can go in that direction with existing wind, solar, and energy technology. The combination of wind droughts and the lack of feasible grid-scale battery storage makes the green energy transition impossible.”
Conclusion
There were a couple of common themes in these articles that support the need for a pause to reconsider the Climate Act schedule and aspiration. The results of electric energy systems that are further down the transition path than New York all are running into increasingly more difficult problems. To respond to the system problems, new and more complex technology is needed. In my opinion, it is folly to assume that an affordable and practical solution will be found for the challenge of operating a weather resource dependent electric system reliably during periods of peak system load.
Thank you for taking a thoughtful look at the state’s draft energy plan. I tried and found myself mired in disgust. For instance, obviously we’re not making the jump from 27% renewables in 2024 to 70% in 2030, but to pretend we’re doing it in 2033 (or whenever the new date is) is just politics-as-usual and makes me think what we’re seeing isn’t a state energy plan; it’s Son of Scoping Plan. Where is the accountability? Where are the DEFRs? Where are the alternatives to pricey li-ion battery storage?
Where is the acknowledgment that since we’re having trouble building out solar and wind WITH the benefit of generous financial incentives, it’s going to be even harder to get this done without them? NYS can’t pick up the slack in federal funding for renewables. We currently have about 1% of the grid-scale solar we’ll need by 2050. Are we expecting the solar fairy to make a very big delivery at some point?
One of the points you quoted struck me: the wind and solar buildout that’s happening now will be ready for retirement in 2050, just when we’re supposed to have met many of our targets. We have few laws, policies, incentives, etc. to deal with repowering. Are we prepared for the inevitable expense? I suspect not.