Two Takes on the Progress Of New York’s Energy Transformation

From THE MANHATTAN CONTRARIAN

Francis Menton

In the real world, the climate scam is rapidly falling apart, along with the related government-subsidized schemes for worldwide energy transformation. So how should New York react? After all, we claim to have the ultimate program of “climate leadership” for showing everyone else how easy it is to do this energy transformation thing. We’ve started with mandating under our Climate Act an electricity system having 70% of its generation from “renewables” by 2030 (a mandate known as “70 x 30”). The deadline for 70 x 30 is now just over four years away.

So, is this really happening? Fortunately, our Public Service Commission has just come out with a Report with the long title “NEW YORK STATE DEPARTMENT OF PUBLIC SERVICE SECOND CLCPA [Climate Act] INFORMATIONAL REPORT ON OVERALL IMPLEMENTATION OF THE CLIMATE LEADERSHIP AND COMMUNITY PROTECTION ACT, WITH CORRECTIONS,” bearing a date of September 23, 2025. Today, I will take a look at that to see what we can learn about New York’s progress toward its goals.

Separately, a different bureaucracy called the New York State Energy Planning Board a couple of months ago (July 25) issued something called the 2025 Draft Energy Plan for the state. I had a post discussing that document back on August 11 (“New York’s Official Energy Plan Is No Plan”). That Draft Energy Plan then became subject to a period for public comment, so I took the opportunity to submit my Comment on September 25.

Let’s say that the PSC’s Report and my Comment on the Energy Plan are two very different takes on the progress toward New York’s energy transformation.

I’ll start with the PSC’s Report. The Report came with a three-page press release announcing and summarizing it. Oddly, the press release does not contain any link to access the Report itself. Instead, if you want to review the Report, you are instructed to go to the Commission’s page for accessing its case documents, where you must then input the correct case number (22-M-0149) in a box provided, and then scroll through the docket entries until you find the Report. Why would they make finding this so difficult? I’ll bet you can guess.

A summary of both the press release and the Report itself is this: a lot of empty talk about all the wonderful plans, without any quantitative information on whether any progress is being made toward the 70 x 30 mandate, or toward any of the various other mandates (including 100% of electricity from zero-emissions sources by 2040, or “100 x 40.”). From the press release:

The New York State Public Service Commission (Commission) today received an update from Department of Public Service (DPS) staff regarding progress toward the clean energy goals of the 2019 Climate Leadership and Community Protection Act or Climate Act. The report details actions taken in pursuit of these ambitious clean energy goals while working to keep ratepayer costs manageable with benefits that are widely shared. . . . The Climate Act’s directives require the Commission to build on its existing efforts to deploy clean energy resources and energy storage technologies, implement energy efficiency and building electrification measures, and support electric vehicle charging infrastructure. This year’s update included: Progress on achieving the targets mandated within the renewable energy program.

OK, so the press release specifically says that the update includes “progress on achieving the targets mandated,” but what exactly does that progress consist of? There’s nothing about that in the press release, so we must go over to the Report itself. The Report is some 63 pages, including appendices. Most of it is about qualitative descriptions of the various schemes (e.g., “renewable energy and energy storage,” “transmission and distribution investment and development,” etc., etc.). Finally at page 37 we get to a section headed “Progress Toward CLCPA Green Energy Targets.” Surely, this is where we will get the quantitative information we are seeking on the progress toward New York’s plans? Here is the entire text of that section:

The subject of this subsection has been covered in depth in the Draft CES Biennial Review. 109

Wait a minute! I thought the press release had specifically said that the PSC Report itself contained an update on this progress. But in fact the update is completely missing. Following that footnote 109, we find out that this CES Biennial Review came out on July 1, 2024 — over a year ago — and must in turn be hunted down on another PSC docket, this one numbered 15-E-0302. This time the Report is some 98 pages long. If we make it to page 53, we find a section titled “The Path to the 70% Goal.”

This section of some 7 pages entirely discusses how many GWh of demand are in the state’s load forecast for 2030, and how many GWh of generation from renewables it will take to produce 70% of that. Excerpts:

Under the base case load forecast assumption of 164,910 GWh by 2030 as described above, the 70% goal equates to 115,437 GWh.

On page 56 in a Table 8, we find the amount of renewables “operational as of 2022” — 29,289 GWh. That’s barely one-quarter of the 115,437 needed by 2030, and by the way more than half of the 29,289 GWh comes from one source, Niagara Falls, that cannot be replicated. The same table on page 8 indicates that an additional approximately 36,000 GWh of renewable generation, consisting of onshore and offshore wind and solar, has been “contracted” by 2024. After substracting a few small miscellaneous items, they come up with a “gap to 70% (2030)” of 42,145 GWh. Then, after further assuming large additions to offshore wind and rooftop solar will provide about half of that, they get to this bottom line:

To achieve this pathway, just over 3,900 GWh of onshore large-scale renewables resources would need to be procured per year, or approximately 5,600 GWh per year with attrition.

Well, in the time since this CES document was issued in mid-2024, all of the off-shore wind has been shot down by the federal government, and all of the federal subsidies for additional wind and solar developments have disappeared. None of the 5,600 GWh per year of additional renewables procurements is in the works. All of this was known and obvious by the time the most recent PSC Report came out on September 23, and yet they don’t mention any of it. I guess they figure that nobody will take the time and effort to track through their references to figure out the problem.

And one more thing: There is not one word in these reports mentioning that wind and solar do not produce electricity at the same time that consumers use it, meaning that there must be storage or batteries or backup of some kind. The entire approach is to assume that if the amount of electricity generated is equal to the amount consumed, the two can be easily matched up somehow, without any issues or costs worth discussing.

In summary, New York’s PSC is entirely engaged in throwing up a smokescreen to obscure the fact that the state’s energy transformation is dead in the water.

Now let’s turn to my Comment on the Draft “Energy Plan.” Although I submitted it a couple of days ago, I can’t yet find it on the website, so I don’t have a link to provide. As an alternative, I’ll provide some extensive excerpts. The bulk of my Comment focused on a chart, Figure 19, appearing on page 22 of a portion of the Plan called the “Pathway Analysis,” purporting to show how the Climate Act mandates, like 70 x 30 and 100 x 40, would be achieved. Here is that Figure 19:

Here are some portions of my reactions to this chart:

• Installed capacity of natural gas power plants declines from about 25 GW today to about 15 GW in 2035 – and then completely disappears by 2040.  What will keep the lights on 24/7/365 when the natural gas generation is gone?  There is no answer here.
• In the same Figure, a new generation category called “Zero-Carbon Firm” suddenly appears in 2040, with 17.2 GW of capacity – about three-quarters as much as our entire current fleet of natural gas power plants.  They have no idea what this “Zero-Carbon Firm” category might be.  Text seems to indicate that they might be thinking about new nuclear or maybe so-called “renewable” gas from landfills.  In fact nuclear is completely blocked in this state, although Governor Hochul has supposedly started a process to build one 1 GW nuclear plant starting now.  That plant has not even yet gotten to the stage of site selection, and will not possibly be ready by 2040 even if construction started today.  And it is also only 1 GW, when the “Energy Plan” is saying that 17.2 GW of “Zero-Carbon Firm” is needed by 2040.  And landfills can produce only a tiny fraction of the gas they are talking about here, while meanwhile the Pathway Analysis admits elsewhere (see page 14) that this supposedly “renewable” gas does not count as zero-emissions under the Climate Act.
• Professor Lindsay Anderson of Cornell did an analysis of the New York electricity system, which found that if natural gas generation was eliminated and demand increased as projected, the actual amount of firm emissions-free resources needed to meet the state Climate Act mandates would be about 37 GW of capacity.  NYISO analysis of the same issue comes up with a requirement 35 GW of firm emissions-free generation.  Where did the Energy Plan come up with the ridiculously low figure of 17.2 GW?  I guess it doesn’t really matter, because the “firm emissions-free resource” is just magical thinking anyway, and does not exist in the real world.
• The same Figure shows a massive increase in capacity of solar generation, from about 7 GW today to supposedly 35.4 GW by 2040.  That capacity, if built (it won’t be), will be lucky to generate electricity at 15-20% of rated capacity over the course of a year in cloudy and snowy upstate New York, and will be next to useless to provide electric heat in the winter, when we have 15 hours of darkness per day.

My Comment goes on and on from there. Some concluding lines:

[T]he so-called “Energy Plan” is not an energy plan at all.  It would more accurately be described as random musings and wishful thinking by some completely incompetent people who have no idea what they are doing.  The so-called “Plan” envisions a future of a fully transformed energy system within the next 15-25 years.  Yet it contains no meaningful feasibility analysis, nor any meaningful cost analysis. . . . It’s time to start over, with some people in charge who know what they are doing.

So I think the vision of New York’s politicians and bureaucrats is to put their heads in the sand until this all falls apart, and then try to blame somebody else. We are living at peak absurdity.