Comments on New York’s Draft Energy Plan
Our Executive Director, Melissa Everett, submitted the following comment on New York’s Draft Energy Plan on Monday on behalf of Sustainable Hudson Valley. The energy plan is crucial for guiding the energy of the state for the next 15 years. To learn our stance on the draft plan read below!
Comments: NYS Energy Plan
Submitted October 6, 2025
By Melissa Everett, Ph.D.
Executive Director
everett@sustainhv.org/ https://www.sustainhv.org
Thank you for the opportunity to comment on New York’s Draft Energy Plan.
Created three years after the publication of the Final Scoping Plan for the
Climate Leadership and Community Protection Act, this plan acknowledges the
Climate Law’s requirements but unfortunately fails to outline a clear enough
path to achieving the legal requirements of the CLCPA.
These mandates are not arbitrary; they are based on modeling of greenhouse
gas emissions and concentration in the atmosphere, and the clear connection
with temperature increases, which gave rise to the notion of the carbon budget
– the amount of emissions we can’t exceed if we want to prevent runaway
climate change. 1 As one scientist put it, “We are blowing through our carbon
budget the way an addict blows through cash.”
I’m providing these comments on behalf of Sustainable Hudson Valley, an
organization that works on small, one-of-a-kind experiments to build public and
institutional receptivity to climate solutions. Highlights of our work include:
The 3-year, NYSERDA-funded Solarize Hudson Valley campaign in 2015 –
18 in which we used community workshops, spirited interactive events,
group purchase discounts with pre-selected contractors to open up the
marketplace with over 400 signed contracts, most of them for rooftop
purchases;
A smaller marketplace campaign, Drive Electric Hudson Valley, which
helped with early charger placement, consumer education and dealership
training in 2016-17;
Facilitation of a Regional Climate Action Road Map and Tool Kit, published
in 2023 (and soon to be updated), involving over 90 stakeholders, to
identify opportunities for regional collaboration.
Through creation of the Road Map, we identified a key disconnect that we
believe is at the root of New York’s challenges in transitioning to renewables.
That is: while utilities are required to plan for grid upgrades, they are in no way
required (or expected) to align those efforts with the parallel land use planning
efforts of municipalities. The sites with the greatest viability from a community
acceptance perspective – such as closed landfills, large parking lots and
commercial rooftops – are often at points of limited grid capacity for new
facilities. This is not news to NYSERDA, which created the Build Ready
Program; however, that program too has been limited by the inability to address
grid constraints at promising sites on already disturbed lands. In the Hudson
Valley, as an outgrowth of our Road Map, we have had a series of meetings
involving grid planning staff at Central Hudson Gas and Electric, and the town of
New Paltz and Ulster County as co-developers of a series of solar installations
expected to provide around 30 mW, including Ulster County’s new emergency
operations center. Discussions have revolved around what the utility can do, in
the current policy framework, to make sure that interconnection can be
accomplished in a timely and affordable manner. Options under discussion
include:
the utility’s ability, within the existing rules, to make minor adjustments in
its timelines for upgrade investments;
multiple developers cost-sharing interconnection fees;
the use of software to improve load management, and
flexible interconnection which can greatly reduce the costs of upgrades.
The Energy Plan should incentivize (or require) utilities to recognize
and make use of these options to make large projects more easily able
to connect to the grid. Benefits should accrue to utilities that innovate within
the existing policy space to accommodate the energy transition.
We are viewing this work with Central Hudson and New Paltz as an initial step
toward creating a pipeline of such sites that can be reviewed by the utility after
they have endorsement by the surrounding communities. I mention it here to
emphasize how much initiative can be taken at the community scale if policy
supports it. Proactive site identification and consensus building at the
local level is work, but it is the surest way to close the disconnect
between community and utility planning. Using a map analysis tool
developed for our region by Scenic Hudson, How to Solar Now, several cohorts
of local planners have begun to identify promising sites for medium-scale solar
installations. More structured funding and technical assistance for this
kind of planning was the aim of the SITED Act, passed in 2024, which if
fully implemented would increase participation and success.
By supporting and proliferating these kinds of efforts, the Energy Plan can
bridge the disconnects in planning and political will to accelerate renewable
energy rollout. Three policy initiatives are especially recommended for this
purpose.
1. Fully implement the SITED Act to help communities take charge of
their plans for renewable energy and storage. The Act explicitly calls
for “procuring the services of service providers including regional
planning associations, non-profits, and community based organizations
to conduct outreach and education about clean energy benefits,
develop new renewable energy planning tools and resources, including
a clean energy development mapping tool, and to provide technical
assistance and training to municipalities to support the authority’s
responsibilities…” Such an educational campaign should be
implemented at the outset of the new Energy Plan.
2. Strengthen incentives and streamlined approvals for renewable
energy systems that do not impinge on farms, forests or
treasured community sites. These range from agri-voltaics and
float-o-voltaics to legalizing small-scale balcony-mounted PV systems
that can be used by apartment-dwellers.
3. Work with the Joint Utilities to pilot and then roll out flexible
interconnection, an approach to integrating new capacity onto the
grid that allows for discretionary loads to be disconnected during peak
times; this has been found to reduce grid upgrade costs by as much as
75%. Flexible interconnection is a key to making it practical for utilities
to upgrade the distribution grid more flexibly and cost-effectively, at
the actual locations where communities want to see renewable energy.
Over and above the education on renewable energy benefits and siting
discussed above and NYSERDA’s ongoing marketing efforts, New York should
fund an ongoing program of proactive, community-based education and
communication about the climate crisis and clean energy transition,
engaging trusted community messengers using sophisticated methods
and tools. This could take the form of funding to community-based
organizations and/or communications firms that go beyond promoting and
defending particular technologies and show understanding of how to influence
culture. The Clean Energy Hubs illustrate the kind of community partners that
could be engaged, but so far these programs are modest in their reach and
conventional in their approaches. Three examples of sophisticated
communications strategies --that reach people deeply and proliferate messages
smartly – are the work of:
The Years Project, a campaign support organization leveraging a
multi-year TV series using meaningful storytelling and compelling
spokespeople to achieve reach in the millions;
Spitfire Strategies, a national firm specifically focusing on trust
building and “majority making” communications strategies;
Action for the Climate Emergency, a new, fast-growth NGO
combining the above strategies with a program to leverage young
influencers and amplify messages across social media platforms,
reaching people with effective voices, where they actually get their
information.
The Energy Plan should include an investment in proactive education to
restore a sense of urgency about climate action, and an appreciation of
the boldness and brilliance of the innovators addressing it. Obviously,
NYSERDA has invested countless dollars in marketing and public relations, and
in incentive programs to reduce barriers to switching to renewable energy for
homeowners, business and others. This is fine but insufficient. Reducing
barriers does not make people care. Community-based initiatives should be
much better supported and recognized. We have reached a point in the
diffusion of clean energy innovation where early adopters have pretty much
decarbonized their homes, businesses and lives. The next wave, or early
majority, is a socially oriented group, taking cues from friends and neighbors.
We learned through the Solarize initiative that the social dimension of learning
about clean energy was a primary driver for many participating households, and
it can be again. The Clean Energy Hubs program appears to recognize this
reality, but a much broader engagement of communities is needed for planning
for all clean energy initiatives, from solar farms to BESS facilities to thermal
energy networks. In our region, which is a top achiever in the Climate Smart
program, most counties have only created government operations Climate
Action Plans and have faltered in developing communitywide plans. Potentially
this should be a requirement for eligibility for clean energy incentives, with
suitable assistance.
The focus of the draft New York State Energy Plan is on modeling possible
pathways to moderate decarbonization. It should be on specific strategies for
reducing barriers to clean renewable energy development and aligning
stakeholders to collaborate ambitiously on this essential goal.
Thompson, Andrea and Amanda Montanez, “Wealthy Countries Have Blown Through Their
Carbon Budgets,” Scientific American April 5, 2023.
https://www.scientificamerican.com/article/wealthy-countries-have-blown-through-their-carbon-
budgets/
