New York’s utility regulator is driving the plan to make the state’s utilities more resilient to climate change and the extreme weather that comes with it.
The New York State Public Service Commission has approved with modifications the Climate Change Resilience Plans filed by New York’s combined electric utilities. In its decision, the Commission directed the utilities to include proposed resilience investments as part of ongoing and future rate case proceedings, provide more explicit process and design changes with respect to climate change projections, define engagement strategies for proposed resilience measures that could impact telecommunication service providers, and include implementation- and outcome-based performance benchmarks for all proposed resilience measures in future updates to the plans and upcoming progress reports.
“These plans detail how each of the combined electric utilities will incorporate climate change into planning, design, operations, and emergency response efforts,” said Commission Chair Rory M. Christian. “Incorporating climate change into existing processes and practices will help manage climate change risks and build resilience.”
The Commission approved the resiliency plans of Central Hudson Gas & Electric Corporation, Consolidated Edison Company of New York, Inc., Niagara Mohawk Power Corporation d/b/a National Grid, and Orange & Rockland Utilities, Inc., and it directed New York State Electric & Gas Corporation and Rochester Gas and Electric Corporation to file revised plans within 90 days.
What spurred this action?
In its decision, the Commission noted that over the past 20 years, “severe storm events” have impacted New York, including Super-Storm Sandy, the two March 2018 Nor’easters, Tropical Storm Isaias, Hurricane Ida, the December 2022 Winter Storm, a microburst event in O&R’s service territory, and the more recent storms in July 2024.
The Commission initiated the proceeding to implement requirements of legislation signed by Governor Kathy Hochul that requires electric utility corporations to submit a climate change vulnerability study to evaluate each electric corporation’s infrastructure, design specifications, and procedures to better understand the electric system’s vulnerability to climate-driven risks. Given the potential impacts of climate change on the provision of utility services, it is necessary for utilities to earnestly consider these impacts as part of their future decision-making. Both the studies and the plans were made available for public review and input.
Each corporation must file an updated climate change resilience plan with the Commission for approval at least every five years. The Long Island Power Authority board will be considering the issue separately. The costs for implementing the plan will be recovered in each utility rate proceeding.
The Commission found that the plans filed by Con Edison, O&R, and National Grid mostly satisfied the requirements, but it argued that some of the projects identified in the utilities’ plans were “improperly classified” as pertaining to climate change resiliency, including plans for a Storm Resilience Center. Thus, the Commission directed those utilities to modify their plans. Additionally, the Commission found that the plans submitted by NYSEG and RG&E “fail to address” all of the requirements, and also directed those utilities to update their plans accordingly.
What’s in the plans?
The utilities are required to file a plan that, among other things, includes the following:
- Proposed storm hardening and resiliency measures for the next 10 years and 20 years, focused on mitigating the impacts of climate change to utility infrastructure, reducing restoration costs and outage times associated with extreme weather events, and enhancing reliability during those events;
- Incorporation of the “impacts of climate change” into the utility’s planning, design, operations, and emergency response, in addition to the utility’s existing processes and practices;
- Details on how the plan is expected to mitigate the impacts of climate change, reduce restoration costs and outage times, and enhance reliability;
- Information concerning the extent to which storm protection and hardening of transmission and distribution infrastructure is “feasible, reasonable, or practical” in certain areas of the service territory;
- An estimate of the costs and benefits of the improvements proposed in the plan, especially regarding undergrounding electric transmission and distribution lines;
- An implementation schedule for each of the storm hardening and resiliency measures, and “major performance benchmarks” to measure the plan’s effectiveness;
- Estimated rate impacts resulting from the implementation of the plan;
- A “multi-pronged strategy” including, but not limited to, vegetation management, improvement of system practices, undergrounding, replacement of obsolete cables, wires, and poles, automation and circuit reconfiguration, infrastructure investments, deploying distributed energy resources, and fortifying critical facilities;
- Identification of opportunities for third-party coordination with municipalities, customer advocate groups, other utility and telecommunication service providers, and the climate change resilience working group.
The related legislation specifies that each utility is required to establish a climate resilience working group meant to advise and make recommendations regarding the development and implementation of the utility’s plan.
Additionally, the Commission may allow each utility to recover the prudent costs of implementing the plan, as approved or as modified by the Commission, in each utility’s subsequent rate proceeding. For capital projects placed into service and for additional unrecovered costs incurred prior to base rates being reset in a rate case, the costs may be recovered through a climate resiliency cost recovery surcharge.
