Joint Utilities' Initial Comments on Petition to Study Climate Change Impacts on Utility Infrastructure

New York State's Department of Public Service and the Public Service Commission are considering a petition from the City of New York, Environmental Defense Fund, Natural Resources Defense Council, and Sabin Center for Climate Change Law to comprehensively study the impacts of climate change on utility infrastructure. In response, the Joint Utilities have filed their initial comments, recognizing the importance of utility planning that incorporates the effects of climate change and supporting the development of climate vulnerability studies and climate adaptation implementation plans. The Joint Utilities highlight their ongoing efforts to plan for climate change impacts and propose a formal process to review all climate change impact efforts in the State to create a common set of climate impact information and models for utilities to incorporate into utility-specific studies and plans.

Key Takeaways:

• The Joint Utilities support the development of climate vulnerability studies and climate adaptation implementation plans, but request that the Commission not take final action on this petition until Governor Cuomo acts on the above-referenced legislation.
• The Commission should establish a formal process to review all climate change impact efforts in the State to determine and create a common set of climate impact information and models for utilities to incorporate into utility-specific studies and plans.
• The Joint Utilities propose that the Commissioner should establish a cost recovery process, such as a surcharge, for development of the climate vulnerability studies and adaptation implementation plans as well as for actual implementation efforts.
• Con Edison has completed its Climate Change Vulnerability Study in 2019 and finalized a Climate Change Implementation Plan in 2020, which worked well and could serve as a framework for a statewide effort for all utilities in the State.
• The Joint Utilities agree that it is essential to use the most current climate change science to develop resilience designs and other adaptive measures for their systems.
• Each of the Joint Utilities has efforts underway to plan for climate change impacts, including work by Con Edison in this area over the last five years.

Statistics:

• 7 electricity and gas utilities are part of the Joint Utilities, which include Central Hudson Gas & Electric Corporation, Consolidated Edison Company of New York, Inc., National Fuel Gas Distribution Corporation, New York State Electric & Gas Corporation, Niagara Mohawk Power Corporation, Rochester Gas and Electric Corporation, and Orange and Rockland Utilities, Inc.
• The Joint Utilities' efforts to plan for climate change impacts have been ongoing, with Con Edison's Climate Change Vulnerability Study and Implementation Plan being completed in 2019 and 2020, respectively.
• 100% of the Joint Utilities agree that using the most current climate change science is essential to develop resilience designs and other adaptive measures for their systems.

Sources:

• Case 21-M-0199, Petition of City of New York, Environmental Defense Fund, Natural Resources Defense Council, and Sabin Center for Climate Change Law to Comprehensively Study the Impacts of Climate Change on Utility Infrastructure (Climate Change Proceeding)
• Case 20-M-0499, In the Matter Regarding the Need for Reporting Risks Related to Climate Change, Joint Utilities' Comments Regarding the Public Service Commission' s Inquiry Related to Reported Risks Related to Climate Change (filed December 15, 2020)
• Joint Utilities' Initial Comments on Petition to Study Climate Change Impacts on Utility Infrastructure, Case 21-M-0199
• Con Edison's Climate Change Vulnerability Study, http://www.coned.com/-/media/files/coned/documents/our-energy-future/our-energy-projects/climate-change-resiliency-plan/climate-change-vulnerability-study.pdf?
• Con Edison's Climate Change Implementation Plan, http://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={F59D306D-F332-4669-B023-4EFE980F65E9}