Speak Up to Protect
New York’s Energy Future 

The SEP confirms that natural gas will continue to play a critical role in meeting peak demand and ensuring reliability, especially during extreme weather and seasonal surges.

The SEP rightly prioritizes grid reliability, recognizing that natural gas infrastructure is essential for maintaining stable energy delivery across New York.

The SEP reflects a more inclusive approach, moving away from rigid electrification mandates and embracing a strategy that attempts to balance affordability, reliability, and emissions reduction.

The SEP acknowledges that inflation, supply chain delays, and federal policy shifts are slowing renewable deployment – reinforcing the need for natural gas as a stabilizing force.

The SEP encourages investment in natural gas systems to ensure safe, reliable service across residential, commercial and industrial sectors.

Modeling shows that electrification and efficiency upgrades are not cost-effective for all households, especially in colder regions like Western New York – where natural gas remains the most affordable and reliable option.

The SEP maintains aggressive renewable energy targets despite warnings from the NYISO that the grid lacks sufficient capacity to support full electrification. Policies like the NY HEAT Act, Cap & Invest, and the All-Electric Buildings Act ignore infrastructure realities and risk destabilizing the energy system. Legislative action should be recommended to fix emissions accounting methodologies and modify mandated timelines in the CLCPA. Failure to make these critical changes could have negative impacts on the state as individuals and businesses move to other states that can better ensure energy reliability and affordability.

The SEP still promotes aggressive electrification, which could lead to higher costs, reduced reliability, and loss of energy choice. This threatens economic growth in key sectors like AI, data centers, and manufacturing – industries that require consistent, scalable energy. “Neighborhood-scale” energy planning is problematic given the integrated nature of the natural gas system and could lead to significant reliability and affordability issues.

While natural gas is supported through 2040, its role beyond that is unclear. The SEP should more fully embrace the decarbonization potential of the gas system and recognize that Renewable Natural Gas (RNG) exists in sufficient quantities to serve more than the limited strategic areas identified in the Plan. RNG is fully interchangeable with conventional natural gas and can be used in existing infrastructure without modification, making it a cost-effective and scalable solution.

Hydrogen is essential for decarbonizing high-heat industrial sectors like steel and aluminum production, where electrification is impractical. When combusted, hydrogen produces only water, making it a clean fuel for industrial processes, transportation, and potentially power generation. It can be safely blended into the system in appropriate amounts to further decarbonization.

New York should explore pilot programs to test and validate differentiated gas, natural gas that is certified as having lower upstream methane emissions, especially for sectors where electrification is not feasible.

In regions like Western and Central New York, hybrid heating systems – combining electric heat pumps with gas backup – offer reliable heating during extreme cold when heat pumps alone may struggle. Hybrid heating maintains the proven reliability of the gas network while significantly reducing emissions. Full electrification can cost homeowners between $4,400 and $50,000 and hybrid systems can reduce upfront costs and avoid expensive grid upgrades during winter peak demand. Additionally, widespread adoption of electric furnaces would further increase electricity demand, challenging utilities as they rebuild the state’s electric grid to deliver higher electric loads and policymakers as they struggle to close a sizable future gap in winter electricity production.

Rising electricity demand is likely to outpace efficiency gains, resulting in electric rate increases that will become unsustainable over time. The SEP appears to make aggressive assumptions around the potential impact of energy efficiency measures, which would underestimate the demand for power from the electrification of buildings and transportation. Higher demand is likely to increase electric rates as more generation, transmission and distribution infrastructure is needed to reliably meet demand. Electric rates are already under pressure with the average statewide retail electric rates in NY having increased 51% since 2019.

Efficiency upgrades alone won’t offset this surge, especially when many households may not be able to afford retrofits or heat pumps.