This page provides links to articles that conclude that a pause in the implementation of the New York Climate Leadership & Community Protection Act (Climate Act) is appropriate. The intent is to provide a reference for future articles that come to the same conclusion.
Dispatchable Emissions Free Resources
Experts, including those that are responsible for electric system reliability, agree that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary during periods of extended low wind and solar resource availability for the energy system envisioned by Climate Act proponents. These resources are not currently available commercially. A renewable-based electric system needs DEFR, the most likely DEFR solution is nuclear, but if you develop nuclear power then you don’t need renewables too. That makes renewables a dead-end approach. Clearly, the Climate Act should be paused until the most viable approach is chosen.
- DEFR Concerns Update November 20, 2024: Overview summary of issues related to DEFR
- JP Morgan Energy Study and the Climate Act March 25, 2025: Multiple reasons to pause including DEFR, affordability, and feasability
- Climate Act Safety Valve Filing August 13, 2025: Exhibit 5 – Dispatchable Emissions-Free Resources explains that the need for a resource that is not currently commercially available risks investments in false solutions.
- Renewable Reliability Risk Reasons to Pause October 14, 2025 – DEFR specification requires new and as yet unresolved reliability metrics.
Affordability
New York passed the Climate Act nearly six years ago but there still isn’t a clear, transparent, and well documented description of the costs, emission reductions, realistic implementation schedules, and expected revenue streams for the strategies proposed to meet the Climate Act mandates. Without that information no one outside of Administration insiders knows how much this will cost.
- New York Budget Articles March 15, 2025: My commentary on a Colin Kinniburgh article that describes how the Senate, Assembly and Governor stand on funding Climate Act implementation
- Governor Hochul and Climate Act Affordability February 15, 2025: Hochul’s response to public outrage over recent utility rate cases is hypocritical given the lack of documentation provided by her Administration.
- Peer Review and Costs of Building Electrification for Commercial Users March 8, 2025: Richard Ellenbogen shows that requirements for electrified heat in commercial buildings will cost more than using natural gas.
- Niagara Mohawk Rate Case Ignores Opportunity to Pause Climate Act May 14, 2025: There has been a statistically significant increase in the number of customers in arrears since the state of the Climate Act. This should trigger a hearing to determine if the the Climate Act should be temporarily suspended or modified per Public Service Law Section 66-p(4).
- Climate Act Safety Valve Filing August 13, 2025: Exhibit 1 – Trend in Company Customers in Arrears documents increasing trends in utility customer payment delinquencies, providing baseline data for the customers in arrears safety valve trigger. Exhibit 3 – Affordability-Focused Recommendations outlines specific policy recommendations to address energy affordability concerns, likely including proposals for cost transparency, alternative funding mechanisms, and enhanced low-income programs.
- Bait and Switch Draft Energy Plan Costs August 25, 2025 – Mitch Rolling and Isaac Orr describe a deceptive process used by EPA to minimize the projected costs of the Biden GHG power plant rule. NYSERDA uses the same technique to minimize projected costs of the Draft Energy Plan
Implementation Program Delays
There have been delays with programs that are necessary to meet the Climate Act targets. Those programs includes strategies that are intended to fund the control strategies like New York Cap-and-Invest Program (NYCI) and
- NYCI Status February 2025 February 13, 2025: This carbon fee proposal has been long delayed but was supposed to provide significant funding for implementation programs
- There is No Existential Threat from Climate Change April 4, 2025: This article explains why there is no reason to try to achieve the Climate Act schedule because there is no existential threat.
Definition and Application of Safety Valve Provisions
New York Public Service Law § 66-p (4). “Establishment of a renewable energy program” includes safety valve conditions for affordability and reliability that are directly related to the zero emissions resource. § 66-p (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”. Until such time that criteria for these three § 66-p (4) requirements so that there is a clear test to suspend or modify obligations there should be an implementation pause.
- Climate Act Safety Valve Filing Exhibits September 2, 2025: Provides details on the affordability and reliability exhibits in the filing.
- Climate Act Safety Valve Filing – Customers in Arrears Trigger August 15, 2025: Documents my filing to a generic PSC hearing that explains why the trigger to hold a hearing has been exceeded.
- Climate Act Safety Valve Filing August 13, 2025: Describes all the exhibits in a filing to a generic PSC hearing arguing that the safety valve must be considered
- Climate Action Council Member Letter to the PSC August 11, 2025: Two Climate Action Council members argue that PSL 66-4(p) hearing should be held because of current circumstances
- Personal Comments on National Grid Long-Term Gas System Plan Report April 18, 2025: The National Grid plan to transition off natural gas is unacceptable because it does not acknowledge the DEFR challenge or the enormous costs for the transition relative to te safety valve provisions.
- Does New York Need a Climate Act Feasibility Analysis November 24, 2024: Explains why the lack of a safety valve is a problem relative to DEFR
Feasibility Analyses
This section describes articles about issues related to specific program components of the Climate Act net-zero transition.
- Implications of the 2025 Spanish Blackout on the Draft Energy Plan September 5, 2025: The blackout in Spain in April 2025 illustrated the technical challenges associated with inverter-based resources and the unacknowledged costs necessary to upgrad the grid to resolve those challenges.
- Ellenbogen: Another Reason to Pause the Climate Act – Electric Trucks March 13, 2025: Ellenbogen and Menton describe why the provision that requires 7% of all 2025 model year heavy duty trucks in New York be “zero emissions” will be impossible to meet.
- Ellenbogen and Caiazza Comments on DPS Definitions February 5, 2025: It is currently not safe to build large battery energy storage systems in New York City due to the danger of fire.
- Spain and Portugal Blackout – Another Reason to Pause the Climate Act May 1, 2025: It is not clear whether the sudden loss of all the solar resources in Spain is a fatal flaw for electric systems relying on wind and solar. Even if it isn’t, it is not clear whether the NY plans for the “zero-emissions” electric system have incorporated a fix that work.
- The challenges of achieving a 100% renewable electricity system in the United States August 29, 2025: This article by NREL staff outlines engineering concerns related to an electric grid that is increasingly depedent upon wind and solar. The post notes that they underestimate the problem because they do not account for dark doldrums.
Climate Act Target Status
The fact that it has become obvious that certain targets will not be met is another reason to pause the process to determine what is going on.
- Time to Reconsider the Climate Act Press Release December 10, 2025: This post summarizes arguments from State Agencies that show it is time to amend the Climate Act.
- Energy Affordability Initial Thoughts at SEP Board Meeting on 12/1/2025 December 8, 2025: NYSERDA data show that for a moderate-income household in Upstate New York that uses natural gas the difference between replacement of conventional equipment and the highly efficient electrification equipment necessary for Climate Act compliance increases monthly average energy expenditures $593.
- Initial Thoughts on Energy Planning Board Meeting on 12/1/2025 December 6, 2025: NYSERDA admits that the 2030 40% GHG emission reduction goal and the 70% renewable energy mandate will not be reached until 2036 at the earliest.
- Implications of New York State 2025 GHG Emissions Inventory December 4, 2025: Results form the latest Statewide GHG Emissions Inventory reinforce the argument that the 2030 40% GHG reduction mandate cannot be met.
- New York’s Impossible 2030 GHG Emissions Target November 28, 2025: Comparison of the current status of GHG emissions realtive to the 2030 40% GHG reduction mandate shows that it is impossible to meet.
- Politicians Face Climate Act Decision November 3, 2025: Recent court decision requires the DEC to promulgate regulations that will cost too much and cause compliance issues unless the Legislature modifies the schedule.
- New York State 2024 GHG Emissions Inventory March 5, 2025: It is clear that the 2030 GHG emission reduction target cannot be met.
Various Reasons to Pause
- December Reasons to Pause December 18, 2025: New York’s attempts to show the nation that a clean energy transition can be reliable, affordable, and achievable will never succeed, Austrailian wind data suggest that weather-dependent resources have reliability risks, and the environmental impacts being shoved down rural areas is unconscionable.
- More Reasons to Pause Climate Act Implementation April 16 2025: Trump state overreach Executive Order, EV mandates are failing, green energy jobs are not materializing, and there are major nuclear deployment challenges.
- Wind Energy Reasons to Pause April 29, 2025: Wind curtailment costs, European experiences, turbine wakes decrease performance, wind lulls are challenging, eagle kills are unacceptable, France shutdown a wind farm for killing an eagle, but in the US laws to protect whales are being ignored.
- Roger Pielke Jr on Climate Variability May 6, 2025: Climate variability complicates the assessment of any weather dependent resource to the point that it may not be possible to adequately assess a safety margin for weather-dependent resources.
- More Reasons to Pause Climate Act Implementation June 1, 2025: David Turver explained the political implications of energy austerity, issues with hydrogen fuel cells, the Energy Bad Boys explained why the Arizona Public Service integrated resource plan will cost its ratepayers billions of dollars in unnecessary costs and undermine grid reliability, and the environ MENTAL blog had an article that described changes in the recent “One Big Beautiful Bill Act” (1BBB) passed by the U.S. House of Representatives that will have an immediate and substantial negative impact to New York’s renewable energy development plans.
- More Reasons to Pause Climate Act Implementation June 25, 2025: Robert Bryce shows why prices increase in Austrailia. Three reasons the science does not support a net-zero transition: Lindzen and Happer white paper explains the physics of climate change, Tselioudis et al found observational data that shows changes in cloud cover are responsible for much of the observed warming, and Judith Curry notes that funding, salary increases, and tenure are tied to agreeing with the ‘consensus.’
- More Reasons to Pause Climate Act Implementation July 12, 2025: Ed Reid argues that a demonstration project proving feasibility is a necessary first step, Michael Shellenberger explains why the arguments that the transition is necessary is unduly influenced by media disinformation, and Tom Nelson describes various reasons why the rationale is imploding.
- More Reasons to Pause Climate Act Implementation July 15, 2025: Isaac Orr and Mitch Rolling describe the relationship between retirements, demand growth and future outages, Brawl Street Journal describes German energy policy, Ed Reid lists questions raised by the blackout in Spain, and Robert Bryce eviscerates media energy policy credibility.
- More Reasons to Pause Climate Act Implementation July 26, 2025: Dennis Higgins filing gives five reasons to pause, JohnS evaluates the status of the California “model approach” to zero emissions and finds it wanting, Watt-Logic provides technical background and explains how a single faulty solar inverter caused the blackout in Spain, New Zealand Energy describes the narrowly averted crisis there when wind dropped dramatically, and Rafe Champion argues that we can go no futher with existing solar, wind, and energy storage technology to the net-zero transition is impossible.
- More Reasons to Pause Climate Act Implementation August 10, 2025: Interview with Steven Koonin emphasizes the importance of uncertainties and ISO-NE evaluation of wind and solar forecast results indicates that the challenge to balance generation and load on a near instantaneous basis in a system that depends on wind and solar is not going to be solved by weather forecasts.
- More reason to Pause Climate Act Implementation August 23, 2025: Institute for Energy Research article that describes the misleading nomenclature used by activists to describe clean and dirty energy, notes that Tisha Schuller says: “Get ready for an extinction burst of myth-making”, and references two Climate Discussion Nexus Newsletter items that address the root cause for the Climate Act transition.
- Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate August 27, 2025: DOE draft review report contradicts the rationale for action described in the Draft Energy Plan.
Other Calls for a Pause
This section describes other calls for a pause in the implementation of net-zero initiatives.
- Tom Shepstone wrote an article about a letter from 18 New York Republican Senators on July 12, 2025. The letter calls on Governor Hochul to declare a State of Emergency and “halt Climate Act mandates.”
- Time for Resets in California and New York January 8, 2025: Compares the pause arguments in the Breakthrough Journal article by Jennifer Hernandez and Lauren Teixeira entitled Time to reset California’s climate leadership to New York