Initial Thoughts on the New York State Energy Plan

Analysis by Jessica Azulay for Alliance for a Green Economy (AGREE)
Updated January 24, 2014

On January 7, the New York State Energy Planning Board released the long-awaited New York State Energy Plan draft documents. ( There will be a 60-day public comment period, which will include six public hearings around the state. Locations and dates to be announced.

A major objective for Alliance for a Green Economy (AGREE) has been to encourage New York State officials to plan for a 100% renewable energy system – one that phases out both fossil fuels and nuclear reactors. We have met with the Governor's office, NYSERDA, and various legislators to promote this objective. As a member of New Yorkers Against Fracking, we have advocated for a ban on fracking in New York, and we also support a federal fracking ban. AGREE is one of New York's premier nuclear watchdog organizations, particularly focusing on the state's four upstate nuclear reactors while acting in solidarity with groups working to shut down the Indian Point reactors downstate. AGREE is a coalition effort among several environmental and social justice organizations. AGREE's points of unity include not only advocacy for a carbon-free, nuclear-free energy system, but principles of social and economic justice and democracy. These principles and AGREE's advocacy work form the foundation for this evaluation of the 2014 draft New York State Energy Plan.

These comments are based on a first read of the Energy Plan. As such, there are inevitably things overlooked, both positive and negative. This review will be updated for improved accuracy and comprehensiveness as AGREE further analyzes the Energy Plan and works with allies to understand and provide official comment on the plan. See for the most recent analysis of the Plan.

Greenhouse Gas Reduction Goals

The Energy Plan reaffirms the state's commitment to 80% greenhouse gas reductions by 2050, with an interim goal of a 50% carbon-intensity reductions by 2030. This is pretty good news. Though it falls short of AGREE's vision of a 100% renewable energy system by 2050 (or before if feasible), the 80% reduction by 2050 is ambitious, and it represents a victory for the environmental movement that the state is not backing off from that commitment.

The plan is fairly light, however, on details for how that 80% reduction will be achieved and what the 2030 or 2050 energy mixes might look like. The only time we know of that the state has attempted to map out a plan in detail was with the controversial NY Climate Action Plan interim document, which was released in 2010 and never finalized. That interim plan relies heavily on nuclear power. It assumes that the current nuclear reactors in the state will continue to operate and/or new reactors will be built. It puts the state on the path for advocating nuclear construction and nuclear subsidies. AGREE opposes the construction of new nuclear plants. We also advocate for the near-term phase-out of all nuclear plants in the state, due to the potential for a catastrophic accident, the environmental and health impact of routine radioactive releases, and the intractable radioactive waste problem. We hope New York State energy planning will not rely on this flawed Interim Climate Action Plan as part of its strategy development.

Leaning on nuclear power as part of a greenhouse-gass reduction strategy in New York is simply unrealistic given current and foreseeable economic realities. All of the state's operating nuclear reactors' licenses will expire by 2050. These aging reactors are becoming increasingly expensive to operate and will see escalating equipment replacement, maintenance, and upgrade costs, which could put them out of business even before their licenses expire. In fact, the economics for nuclear power are so bad that two of the state's nuclear reactors (Ginna in Wayne County and FitzPatrick in Oswego County) are predicted to potentially close within the next couple of years due to inability to compete in today's electricity market.

Meanwhile, there are no new nuclear projects currently proposed for New York State. The last plant that was proposed (Nine Mile Point 3) would have cost $15 billion and would have needed 10-12 years for construction. This cost and timeframe for new reactors is unrealistic for meeting climate goals and would take resources away from renewables. New reactor technologies are even further off and less realistic, and will play no useful role. 

It is additionally important to note that any greenhouse-gas reduction plan that relies heavily on nuclear power will be vulnerable to a sea change in nuclear policy that could result from a catastrophic accident in the US. New York should learn from Japan, which saw all of its nuclear reactors immediately shut down as a result of the Fukushima nuclear accident.

The New York Energy Plan should clarify the target fuel mix for 2030 and 2050. Doing so would not only help with infrastructure and policy planning, but it will help energy experts and advocacy organizations better evaluate the plan.

Promoting Renewable Development and Energy Efficiency

The state has made laudable progress in recent years in the development of renewable energy and the implementation of energy efficiency measures. The Energy Plan explains these initiatives and the progress that has been made, and it provides a fairly comprehensive understanding of the state-supported programs being implemented now or planned by the Cuomo administration. Of particular note are the evaluations of the Renewable Portfolio Standard (RPS) and the Energy Efficiency Portfolio Standard (EEPS) – two initiates with clear goals and clear timelines that are achieving some measurable success. While progress has been made toward the goals of these programs, neither program is currently projected to reach their benchmarks. The stated commitment in the Plan to expand and extend these programs through 2025 (RPS) and 2020 (EEPS) is good news. However, the Plan does not explicitely commit to meeting the current goals of these programs and it does not include any specifics about what the goals for extended versions of the programs would be.

Most of the proposed initiatives described in the Energy Plan are relatively vague. The plan lists several promising actions planned by state agencies, some of which may have the potential to dramatically change the energy system in positive directions. Yet the plan lacks detail for most of those initiatives. Further, it does not provide a comprehensive analysis of how they will work together on a grand scale to achieve the systemic transformation we need to in order to meet the ambitious greenhouse-gas reduction goals stated.

In general, the model emphasizes promoting preferred outcomes through the market, using tax credits and incentives, encouraging consumer choices, and encouraging private investment in green energy projects. There is much less emphasis on a complementary approach that would discourage polluting energy sources with regulations or tax policies aimed at shuttering dirty plants to make room for renewables. This is not to say such policies are totally ignored. For instance, the plan discusses the relative success of the Regional Greenhouse Gas Initiative (RGGI), a regional cap and trade policy designed to reduce carbon emissions from fossil-fuel plants. It also describes initiatives to enforce energy efficient building codes and regulations on methane emissions from natural gas infrastructure. However, popular proposals like a carbon tax that could dramatically change the market in favor of renewable energy and efficiency, are not discussed in the Energy Plan.

Natural Gas and Fracking

While the Energy Plan lacks any hint of where the administration may ultimately come down on the issue of fracking in New York, it is not vague in its endorsement of natural gas as a major part of New York's energy mix. The Energy Plan does acknowledge the possibility that fracking won't happen in New York, yet it embraces fracked gas from outside the state with little to no reservations. This is not an approach AGREE can get behind given our position on a US fracking ban, nor is it an ethical approach to energy policy. We can't advocate polluting someone else's backyard to save our own. The plan promotes the replacement of other fossil fuels with natural gas as a strategy to reduce carbon emissions. Natural gas is also mentioned as a replacement fuel for Indian Point nuclear reactors, which the state wishes to see decommissioned. It is clear the state is not planning for a transition away from natural gas, and is instead planning for a transition toward gas to replace other undesirable energy sources.

As such, the Energy Plan describes increases in natural gas pipeline and storage infrastructure throughout the state. The construction of additional infrastructure to support natural gas as a major energy source in New York is contrary to the goal of switching to a 100% renewable energy system, and it ignores the environmental damage caused by gas drilling in other states. There appears to be a contradiction between the Energy Plan's stated greenhouse gas reduction goals and its intentions regarding the increased importation and use of natural gas.

In order to reach ambitious climate goals, New York needs to build energy infrastructure that will promote and accommodate large-scale renewable energy from both centralized and distributed sources. Without a clear description of the renewable energy system the state is working toward or a comprehensive understanding of the siting of such resources, it is difficult to chart the proper infrastructure needed. Based on the existing visions for renewable energy systems, it is likely that a future system will rely on electricity generation and geothermal energy for space heating. Therefore, increasing the amount of space heated by natural gas is going in the wrong direction. We should advocate for the phase-out of natural gas from today's levels, along with the phase-out of other dirty fossil fuels and nuclear. Ramping up natural gas pipeline construction and storage facilities will not help the transition, but will hinder it.


Nuclear power is a dominant electricity source in New York, yet it receives relatively little attention in the Energy Plan.

In keeping with recent state policy, the Energy Plan examines the potential for the shutdown of the Indian Point nuclear reactors. Of particular concern, though, is the projection that Indian Point power would need to be replaced by increased natural-gas-powered electricity generation. The replacement of the Indian Point reactors with natural gas is not in keeping with the state's climate goals. Instead, the state should be planning for replacement with a combination of energy efficiency measures and renewable energy development. AGREE needs to analyze this point further to see how this compares to the Public Service Commission's Indian Point replacement plan, which is based on transmission upgrades and energy efficiency.

The plan notes some of the dangers associated with nuclear power generation as well as the environmental and human health challenges posed by the nation's nuclear waste storage problems. The plan also mentions some of the issues likely to be confronted in the decommissioning of nuclear reactors. However, the plan does not acknowledge the increasing unreliability of the state's aging nuclear reactors or the possibility of early nuclear retirements in Upstate New York. Given numerous predictions from various financial analysts that FitzPatrick and Ginna are at risk of early retirement due to economic losses, this is a major oversight in the Energy Plan. The state should be planning for the eventual closure of all nuclear plants, with a particular focus on these potential early retirements. If planned for properly, these retirements would create an opportunity for massive renewable energy development in the state.

Just Transition Issues

The retirement of dirty and dangerous energy sources will see a need for particular attention to a host of transition issues related to social justice. The economic and social impacts on communities that have built their employment and tax base on fossil-fueled or nuclear-fueled plants cannot be ignored. These issues must be addressed in any comprehensive energy plan. Even though there are major economic, health and social benefits associated with the implementation of a renewable energy system, these benefits will not automatically erase the negative effects of plant retirements on some individuals and communities.

With proper planning and attention to just transition issues, these impacts can be decreased and addressed. Unfortunately, the Energy Plan does not mention these issues.

Overall Approach

New York State energy plans have traditionally focused most clearly on near and medium-term planning, and this plan is no different. It provides some sense of where New York planners want to end up and what state agencies plan to do in the near term to put us on that path. But as a long-term planning document to chart steps to achieve long-term goals, the Energy Plan is less useful.

The implementation of a renewable energy system will require nothing short of the wholesale transformation of the way we produce, transport and consume energy. This transformation will need to happen in space heating, electricity generation, and transportation throughout the residential, commercial, and industrial sectors. The Energy Plan does include some visionary sections that acknowledge the needed systemic changes. For instance, there is a large section on “Smart Growth” development away from sprawl and toward compact communities that conserves resources. There is also attention to distributed generation, smart grids, community aggregation, and research and development for energy storage technologies.

Too much of the plan, however, is focused on preserving and improving our current energy sources and infrastructure. Many of the Plan's hundreds of pages focus on how our state's current energy system operates – what fuels we use, where they come from, how we use them, and how they are transported. While this information is useful for understanding the system we are starting from, the plan falls short of providing an equally clear vision for the future system we are striving for.


For environmental and social justice activists, there is a lot to like about the Energy Plan: the commitment to major greenhouse-gas reductions, the new initiatives and policies to promote renewable energy development and energy efficiency, the strategies for affordability and increased consumer choice in the system. Additionally, there is a lot of valuable information about the environmental impacts of our current energy system, including environmental justice impacts, and the Plan includes clear rhetoric promoting a transition to a greener, cleaner and more equitable system.

There is also room for major improvement in state energy planning in general and in the new State Energy Plan in particular. An increasing body of research has shown that a carbon-free and nuclear-free energy system is possible on a national level and on a state level. Given the ecological, social and economic destruction promised by catastrophic climate change and the incredible risks posed by nuclear power, there is no reason why New York should not chart a path to a 100% renewable energy system and then implement ambitious state policy to get us there.

The initiatives described in the State Energy Plan may put us on this path, but the Plan falls short of being the clear roadmap for the renewable energy system AGREE has been asking for. Without information about the 2030 and 2050 energy generation mixes, and without better clarity on the specific objections of the policies and programs described in the plan, it's hard to know how far the Plan will take us on the path to a renewable energy system. Add to that the unrealistic reliance on nuclear power and the planned increase in natural gas use and infrastructure, and there is a lot to be concerned about for environmentalists.

This is not surprising, given the traditional scope of the State Energy Plan and the dual and sometimes competing goals of preserving the integrity of the current system and putting forth visionary policy. This is why AGREE has proposed that the state fund an independently researched carbon-free, nuclear-free energy study that can chart a path to a 100% renewable energy future. We believe such research would complement and inform the work of the Energy Planning Board and could address some of the issues lacking in the current energy planning process.