Some Other Parties Weigh In On The Con Edison Rate Case

In my last post I linked to, and quoted portions of, the objection submitted by myself and two colleagues to the pending settlement of the rate increase request of our local utility, Con Edison. The gist of our objection is that the ratepayers should not be forced to pay to build infrastructure for delivery of “renewable” electricity that does not exist.

Our objection was filed on the day before Thanksgiving, November 26. That day had been set as the due date for all statements either in support or opposed to the pending settlement, which is referred to as the Joint Proposal of “JP.” And thus, on the same date, numerous other parties to the proceeding also filed statements, either in favor or opposed to the JP. The large majority were in favor — which is not surprising, given that to reach a settlement that might stick they needed the support of a large majority of the parties.

Most of the parties who had joined the case had sought from the outset to characterize their position as standing up for the ratepayers by opposing excessive revenue demands from Con Edison. And yet here at the settlement phase we find nearly all of these parties signing on to large amounts of spending by Con Edison that are completely wasteful, in that they provide for delivery of non-existent electricity and support for impossible Climate Act goals that are not happening. One could accurately say that the only real purpose of such spending is to enrich Con Edison shareholders. Granted, as our curmudgeonly commenter Mr. Greene points out, the incremental wasteful spending in this particular proceeding will represent only a few percent of a prospective Con Edison bill. But still, the amount of wasteful spending getting put to the ratepayers by this JP is at least in the hundreds of millions of dollars, if not billions (the utility and its settling henchpersons have refused to specify how much).

So how do these formerly virtuous participants justify their caving, at least in part, to the utility’s demands? I thought readers might be interested in a couple of examples. The short version is that they just avoid grappling with the only important issues.

Consider, for example, one of the environmentalist intervenors. There were several of those. A representative statement of support comes from one called Alliance for a Green Economy (they call themselves “AGREE”). (This statement can be found at Item 210 on the Public Service Commission docket of the proceeding.). The focus of the AGREE statement in favor of the JP is that the settlement provides infrastructure to support electrification of buildings via installation of heat pumps, as well as further incentives for heat pumps via the rate structure. Heat pumps, you see, are good, because they are “highly efficient” and “do not combust fossil fuels.” Excerpt:

To achieve the greenhouse gas emissions reductions required by the CLCPA (40% reduction from 1990 levels by 2030 and 85% reduction from 1990 levels by 2050), New York’s Climate Action Council found that most buildings need to switch to heat pumps. Heat pumps are highly efficient heating and cooling appliances that use electricity to move heat into and out of buildings. They do not combust fossil fuels to operate, and their high efficiency means that they use less electricity for heating than electric resistance heating and less electricity for cooling than non-heat-pump air conditioning units.

AGREE notes that Con Edison has a special rate category for heat pumps, that predates the current JP, and is known as SC1 Rate IV, to encourage consumers to make the switch. However, so far few have taken advantage of the special rate, so AGREE applauds new provisions in the JP to encourage uptake:

[T]he Company commits to a variety of improvements to its education and outreach to customers about their rate options, including a “Heat Pump Operating Economics Customer Engagement Plan” (“Engagement Plan”). The Engagement plan will include promotion of rate options in the Clean Heat program literature and educational initiatives for contractors.

OK, but how about the issue that the electricity used by the heat pumps comes almost entirely from fossil fuels, and will continue to do so during the rate period, meaning that conversion from on-site combustion to heat pumps will actually increase rather than decrease emissions of CO2? There is no mention of that issue here. That kind of analysis is way, way too complex for the IQ level over at AGREE. And then there is the issue that in the absence of large increases in generation of electricity consumers converting to electric heat risk freezing to death in the winter when the electricity supply falls short. What about that one? That’s another issue that AGREE does not address. In other words, they just skip over the only significant issues.

For another example, the statement of New York City in favor of the JP can be found as Item 204 on the PSC docket. The City has served up a relatively long statement of support, some 31 pages. But the bulk of it addresses issues peripheral to the fundamental question of whether the overall amount of the rate increase is justified. Rather than addressing that central question in any detail, the City devotes its statement mostly to things like protections for low income customers struggling with their bills, outreach to non-English language speakers, reporting requirements as to “disadvantaged communities,” bill “transparency,” “streetlight issues,” the level of incentives to Con Edison shareholders, and the question of “estimated, delayed and anomalous bills.”

On the central question of the overall level of rates, the City in its 31 page statement has space for only a handful of general nostrums. From page 2:

[A]s buildings and transportation electrify and system-wide electricity demand increases, and because of current economic conditions and the critical need to maintain safe and reliable infrastructure, a rate freeze was not possible.

From page 3:

In New York City, electric service is a basic human need. For this reason, Con Edison’s provision of safe, adequate, reliable, and resilient electricity is of paramount importance and essential to health, safety, and livability. The recommended electric rate plan provides sufficient funding to ensure that Con Edison is able to continue to provide such service and address important public policy goals including, in particular, reducing greenhouse gas emissions.

In other words, the City will just go along with utility rate increases, as long as they are not so high as to get the voters outraged, and as long as they are accompanied by vague statements about “building and vehicle electrification” and “reducing greenhouse gas emissions” to give some kind of general impression that the “climate” agenda is still on track. The City can’t be bothered to do any serious analysis of questions like whether greenhouse gas emissions will actually be reduced, let alone whether there is enough electricity getting generated to enable the buildings and vehicles to get electrified.

This of course is the City’s statement during the last days of an Eric Adams administration. I can’t wait to see what position a Zohran Mamdani administration might take on this JP, or the next one. You might say, we already have a City government completely unconstrained by the real world, so how can it get any worse?