On July 23, 2024, the New York State Energy Research and Development Authority (“NYSERDA”) released its much-anticipated Draft 2025 New York State Energy Plan (“2025 Energy Plan”). The 2025 Energy Plan provides insight into the State’s current thinking with respect to decarbonizing New York’s economy, and confirms that New York is no longer trying to meet the short-term emission reductions laid out in the Climate Leadership and Community Protection Action (“CLCPA”) [i.e. 40% reductions by 2030]. Rather, NYSERDA has embraced a policy that emphasizes reliability and affordability, while seeking long-term emission reductions and a clean energy economy.
This shift seemed inevitable after the New York State Public Service Commission (“PSC”) and NYSERDA issued the Draft Clean Energy Standard Biennial Review, which clearly exposed that New York would miss its statutory target of 70% renewable energy by at least three years, if not more. The 2025 Energy Plan accepts the inevitable and lays out a road map for reducing emissions, just not on the timetable established by the CLCPA. The 2025 Energy Plan highlights the current market uncertainties, from inflation to changing federal policies, as some of the roadblocks preventing greater emission reductions. But notably, the State recognizes that achieving aggressive emission reductions would impact consumers from an energy affordability standpoint, which in turn justifies (among other reasons) the pivot to embracing all forms of energy, including the continued reliance on natural gas (and petroleum).
With respect to natural gas, the 2025 Energy Plan specifically recognizes the need for continued investment in the natural gas system and the need to evaluate whether new generation is necessary and is compatible with long-term policy targets. Reliability is cited as the driving force, and that will necessitate New York continuing to support at least through the 2040 planning period, “the safe and reliable provision of natural gas and petroleum fuels to electric, residential, commercial, industrial, and transportation sectors.” This means continued investment in the natural gas system to ensure energy demands are met at peak load times.
While the 2025 Energy Plan recognizes a place for natural gas (and petroleum), at least through 2040, it does not abandon the goal to transition to a clean, emission-free economy. Specifically, considering the increasing energy demands, the 2025 Energy Plan highlights the need for a diverse mix of energy supplies that integrates wind, solar, and other renewable energy resources. According to the 2025 Energy Plan, the buildout of these resources would not only be cleaner but would also be more affordable and more reliable. Specifically, the 2025 Energy Plan opines, “[a]ccelerating the integration of wind, solar, and other renewable energy resources into New York’s energy system increases the resource diversity of the system, offering economic and reliability benefits, as well as important environmental and public health benefits from reducing the use of fossil fuels.” The 2025 Energy Plan lays out a number of measures to help support the clean energy transition, including ensuring adequate financing, investing in new technologies, and identifying policies that support the transition in an efficient and economic manner.
In addition to these broad goals and framework, the 2025 Energy Plan highlights the importance of Governor Hochul’s commitment to the development of Advanced Nuclear in New York, including the New York Power Authority’s (“NYPA”) effort to develop at least 1 GW of nuclear power generation. The 2025 Energy Plan also emphasizes the need for the deployment of viable clean firm technologies to address reliability needs, specifically the development of long-duration energy storage. The 2025 Energy Plan identifies the need for continued and increased investments in this area.
These are just a few of the highlights of the 2025 Energy Plan. Interested stakeholders should review it for greater insight into what New York State will be promoting and comment or attend a hearing to help shape the final plan.
The plan is currently available for public comment, and NYSERDA will be holding nine public hearings.
Below is the public hearing schedule:
Tuesday, August 19, 2025 | 2:00 p.m. - 4:00 p.m., Virtual
Wednesday, September 3, 2025 | 5:00 p.m. - 7:00 p.m., Buffalo
Thursday, September 4, 2025 | 11:00 a.m. - 1:00 p.m., Rochester
Wednesday, September 10, 2025 | 5:00 p.m. - 7:00 p.m., Albany
Tuesday, September 16, 2025 | 5:00 p.m. - 7:00 p.m., Hudson Valley
Wednesday, September 17, 2025 | 5:00 p.m. - 7:00 p.m., New York City
Thursday, September 18, 2025 | 11:00 a.m.- 1:00 p.m., New York City
Monday, September 29, 2025 | 5:00 p.m. - 7:00 p.m., Long Island
Tuesday, September 30, 2025 | 5:00 p.m. - 7:00 p.m., Virtual
Hodgson Russ will be tracking the public comments and potential changes to the 2025 Energy Plan as things proceed.
Disclaimer:
This blog is a form of attorney advertising. Hodgson Russ LLP provides this information as a service to its clients and other readers for educational purposes only. Nothing in this blog should be construed as, or relied upon, as legal advice or as creating a lawyer-client relationship.
