Put Reliability First: Why New York’s PSC Should Pause and Recalibrate the CLCPA’s Renewable Obligations
New York’s energy transition must be pragmatic, but it must also be balanced. Today, the Public Service Commission (PSC) faces a pivotal decision: whether to convene a hearing under Public Service Law §66‑p(4) to determine if the Renewable Energy Program obligations established under the Climate Leadership and Community Protection Act (CLCPA) should be temporarily suspended or modified. The Coalition for Safe and Reliable Energy urges the PSC to hold that hearing now.
The Coalition for Safe and Reliable Energy, a diverse grouping of associations, chambers of commerce and organizations representing businesses, industries, manufacturers and constituencies from across New York as well as two members of the state’s Climate Action Council, has a straightforward case: the state’s current renewable targets, timelines, and procurement assumptions are out of step with on‑the‑ground realities, and they jeopardize safe and adequate electric service. A temporary recalibration does not walk back New York’s climate ambition; it keeps the transition on track by protecting grid reliability, affordability, and public confidence.
The CLCPA set a 70% renewables by 2030 target and a zero‑emissions grid by 2040. These goals galvanized investment, but recent data and experience point to a widening gap between aspiration and execution. Projects have slipped, costs have risen, interconnection timelines have stretched, and the retirement of aging fossil units is outpacing the reliable replacement of firm capacity. Meanwhile, load is increasing, driven by electrification mandates tightening reliability margins at precisely the wrong time.
Put simply: the state is unlikely to meet the 2030 target on schedule, and the commercially ready, firm, zero‑emissions resources needed by 2040 are not yet available at scale. Under PSL §66‑p(4), when renewable mandates impede safe and adequate service, the Commission has the authority to pause and adjust. That safeguard exists for a reason; it’s time to use it.
New Yorkers expect the lights to turn on, heat to stay on, and businesses to operate safely every hour of every day. That expectation is codified in the PSC’s obligation to ensure safe and adequate service. When reliability margins deteriorate, the consequences may ripple: higher outage risk, higher emergency costs, greater customer arrears, and erosion of public trust in the broader transition.
A hearing under PSL §66‑p(4) would allow the PSC to weigh current conditions, test assumptions, and consider targeted, temporary modifications that stabilize the system while preserving long‑term climate progress. The question before the Commission is not whether New York should continue to build renewables, as it should and will, but whether the pace and sequencing are aligned with grid reliability, affordability, and technological readiness.
The NYISO has been clear: until firm, clean alternatives are available at scale, reliable, dispatchable generation will be needed to maintain system stability. One pragmatic path is repowering existing plants to leverage modern technology to reduce emissions, improve efficiency, and bolster capacity without the land use, permitting, and interconnection challenges of entirely new builds.
Yet under current CLCPA targets, repowering is effectively discouraged: developers face the risk of forced retirement by 2040, undermining investment recovery and rendering a rational solution untenable. A temporary modification to the Renewable Energy Program obligations could enable a staged approach, where repowering complements accelerated investment in transmission, storage, and renewable generation thus buying time for new technologies to mature while safeguarding reliability.
Energy affordability and household stability are inextricably linked. As costs rise, ratepayers may shoulder the burden of schedule slippage, contract renegotiations, and infrastructure bottlenecks. Any PSL §66‑p(4) hearing should examine the relationship between program costs and customer arrears, ensuring the transition remains economically sustainable for families and employers alike. The goal is not to cut investment, it’s to target it smartly and sequence it responsibly.
Our Coalition supports New York’s clean energy goals, we do not seek to abandon them. A temporary suspension or modification of obligations under PSL §66‑p(4) would:
- Stabilize reliability while firm, clean technologies scale.
- Enable pragmatic solutions (like repowering) that reduce emissions now.
- Align timelines with realistic supply chains, permitting, and interconnection.
- Restore public confidence by demonstrating that the state can adjust when facts change.
This is responsible governance: update the playbook when conditions warrant, maintain momentum, and deliver on climate commitments without compromising reliability.
The PSC’s mandate is clear: ensure safe, adequate, and reliable electric service at just and reasonable rates. The evidence, ranging from project delays to tightening margins to load growth, demands a formal, transparent evaluation. We urge the Commission to:
- Open a §66‑p(4) hearing immediately to assess whether current Renewable Energy Program obligations impede safe and adequate service.
- Evaluate temporary modifications to targets, timelines, or compliance pathways that maintain reliability while sustaining climate progress.
- Consider flexible solutions, including repowering, targeted capacity retention, and accelerated investments in transmission and storage.
- Assess affordability and arrears, ensuring ratepayer protection remains central to program adjustments.
The energy transition succeeds only when it is reliable, affordable, and achievable. New York can lead, and keep the lights on, by calibrating its path with facts, transparency, and pragmatism.
The time to hold the hearing, and update the playbook, is now.
The Coalition for Safe & Reliable Energy:
Buffalo Niagara Builders Association
Buffalo Niagara Manufacturing Alliance
Buffalo Niagara Partnership
Builders Exchange of the Southern Tier
Business Council of Westchester
Capitol Region Chamber of Commerce
Center for Economic Growth
Commercial Real Estate Development Association – Upstate Chapter
Construction Exchange of Buffalo and Western New York
Engineers Labor Employer Cooperative 825
Greater Binghampton Chamber of Commerce
Greater Rochester Association of REALTORS
Greater Rochester Chamber of Commerce
Manufacturers Alliance of New York
Manufacturers Association of Central New York
Manufacturers Association of the Southern Tier
Counsel for Multiple Intervenors
National Federation of Independent Businesses
New York Construction Materials Association, Inc.
New York State Association of Plumbing, Heating and Cooling Contractors
New York State Builders Association
New York State Economic Development Council
Niagara USA Chamber of Commerce
North Country Chamber of Commerce
Northeastern Retail Lumber Association
Northeast Hearth, Patio and Barbecue Association
Power for Economic Prosperity
Rochester Technology and Manufacturing Association
Rockland Business Association
The Business Council of New York State
The Council of Industry, Manufacturers Association of the Hudson Valley
Western New York Association of Plumbing and Mechanical Contractors
Donna L. DeCarolis
Dennis W. Elsenbeck
