Editor’s note: Roger Caiazza is an adjunct fellow at the Empire Center. He has a long and deep private industry background in environmental regulatory analysis and compliance. His frequently updated personal blog on New York State environmental policy is Pragmatic Environmentalist of New York.

Governor Hochul’s newest energy initiative acknowledges a problem critics of New York’s climate agenda have identified for years: the state lacks a coherent plan for building a reliable, affordable electric system. Unfortunately, the initiative does not provide that plan, and the first comprehensive version will not arrive for more than three years.

On September 22, the Governor announced an Energy Infrastructure Development Plan (EIDP) as part of her Clean, Highly Affordable, Reliable, Grid Expansion (CHARGE) agenda. The EIDP directs the State Energy Planning Board to coordinate planning across the electric system and produce an “actionable blueprint” intended to preserve reliability, advance a zero-emission grid, and control costs. An Interim Plan is due in 2027, but the first comprehensive plan is not due until December 2029.

The diagnosis is sound. New York’s major energy decisions are made through separate processes: Climate Act targets, New York Independent System Operator (NYISO) reliability studies, utility rate cases, NYSERDA procurements, transmission proceedings, and local siting decisions. No single entity is responsible for ensuring that these decisions collectively produce a reliable and affordable electric system. The EIDP also recognizes that growing demand from manufacturing, electrification, and data centers requires a different approach from the flat-demand assumptions of the past. By making reliability and customer costs—not only emissions targets—central to grid decisions, the EIDP moves closer to genuine system planning than either the 2022 Climate Act Scoping Plan or the State Energy Plan approved last December.

But the announcement promises reliability and cost control without specifying the criteria for determining whether those promises are met.

Most notably, the EIDP does not address the Climate Act’s hardest reliability problem: how New York will meet its requirement for zero-emissions electricity by 2040 while maintaining dependable power during periods when wind and solar output are low.

NYISO’s 2023-2042 System & Resource Outlook projects that the state will need “at least 20 GW” of dispatchable emissions-free resources (DEFR) by 2040 to replace 25.3 GW of fossil generation, and that the need could reach “upwards of 40 GW.” These resources would have to produce electricity when required, unlike weather-dependent wind and solar generation. Yet none of the leading candidates—long-duration batteries, small modular reactors, hydrogen-fueled generators, or fuel cells—is commercially available at the required scale today.

The EIDP announcement does not mention DEFR, nuclear power, or firm dispatchable capacity. Wind, solar, storage, and transmission alone cannot guarantee dependable generation during a multi-day winter cold snap with little wind and limited sunlight. A credible plan must quantify how much firm capacity is needed and when, establish development milestones, and identify an off-ramp if DEFR does not arrive on time. That off-ramp should include repowered or new natural gas generation, and the pipeline capacity needed to fuel it.

The EIDP treats affordability just as vaguely. A promise to control costs is meaningful only if the public can compare the full cost of competing pathways and see how each would affect customer bills. For every pathway, a serious plan would publish projected capital costs; transmission, backup, and balancing costs; distribution upgrades; land requirements; carbon-program costs; and the resulting residential and business bills. It would also specify how much of the cost of serving data centers and other large new loads would be paid by those customers rather than shifted to existing ratepayers.

The Governor’s pledge to “cut through red tape” cuts both ways. Faster approval of genuinely needed projects is welcome. But for utility-scale solar, the permitting process is often the only place where agricultural, land-use, and community impacts get any consideration. Streamlining without siting safeguards simply accelerates energy sprawl.

Finally, the schedule does not match the emergency we are facing. This past January and February, New York consumers bore energy prices reaching $800 per megawatt-hour, emergency winter dispatches of demand-response resources, and high uplift charges as an aging generating fleet strained to keep up. Decisions on retaining existing plants, starting new natural gas and nuclear development, expanding fuel delivery, and committing to transmission must be made now, not in 2029, if new resources are to be in service in time to meet growing demand.

For the 2027 Interim Plan to be more than another policy document, it should at a minimum:

• adopt a reliability standard based on NYISO and New York State Reliability Council criteria that explicitly accounts for extreme winter weather and multi-day renewable lulls;
• separate committed load growth from speculative data-center announcements;
• bar the retirement of any dispatchable unit until its replacement is operating and has proven dependable, not merely been contracted or permitted;
• include a full-system affordability test with published customer bill impacts; and
• publish its assumptions, models, and data for independent review.

Even that will not be enough without changes in law and regulation. The EIDP can succeed only if Albany also revisits the 2040 zero-emissions mandate, removes regulatory barriers to new dispatchable generation, and allows expansion of the natural gas delivery system needed to support it.

The EIDP is a welcome admission that disconnected planning has failed. But a process commitment is not a reliability plan. Unveiled six weeks before Election Day, with nothing substantive due until well after it, the announcement so far is rhetoric rather than a plan.

If the final product relies on hoped-for technologies, vague affordability claims, and renewable nameplate capacity instead of demonstrated dependable resources, it will simply repackage the state’s existing planning failures under a new name, and New Yorkers will keep paying for them through higher bills and lost economic opportunity, especially upstate.

For a more detailed comparison of the EIDP announcement with a reliability-first, affordability-driven planning approach, including a full list of recommendations for the Interim Plan, see the full post at Pragmatic Environmentalist of New York.