As I have mentioned here on a couple of occasions, I have joined with two colleagues to intervene in the regulatory proceeding where our local electric utility, Con Edison, has made its most recent request for a large rate increase. My colleagues in this enterprise are Roger Caiazza, who blogs as the Pragmatic Environmentalist of New York, and Richard Ellenbogen, a Cornell-trained engineer who as his day job runs a factory in Westchester County.
After a “deregulation” that took place in the 1990s, Con Edison almost entirely got out of the business of generating electricity, so this case is about the rates for delivery of the electricity, rather than generation. The basis for Con Edison’s request for a rate increase is substantially that it wants to build lots of new infrastructure, like additional cables, substations and transformers, to deliver incremental power to support widespread electrification of vehicles and buildings as part of New York State’s goal of “net zero” greenhouse gas emissions. That idea might make some sense if there were large amounts of zero-emissions electricity ready to be sent to New York City to be used for electrifying the buildings and vehicles. But in fact it is the opposite: a very large majority of the electricity that Con Edison delivers is generated by natural gas — which means that electrifying buildings and vehicles doesn’t reduce GHG emissions at all, and probably increases the emissions. New York State’s “climate” plans to generate lots of zero emissions electricity for New York City are almost completely dead. Its big program for off-shore wind generation in the waters off Long Island has been nixed by the federal government; and while the State continues to promote onshore wind and solar facilities in upstate New York, its plan to bring that power to New York City died, at least for now, in November 2024 when the new $11 billion Clean Path transmission line got canceled as uneconomic.
It’s actually great that these projects have died, because if they had gone forward they could have multiplied our electricity rates by at least double (before even getting started on huge costs of energy storage as penetration of intermittent renewables on the grid increased). Meanwhile, the death of the generation and transmission projects has made the whole idea of building and vehicle electrification useless, and indeed counterproductive (in terms of reducing GHG emissions, if you should happen to care about that). It doesn’t take an engineering genius to understand that burning natural gas on-site to heat a building uses less natural gas than burning it at a power plant, generating electricity, transmitting the electricity to a house, and then using the electricity at the house to make heat. But Con Edison — egged on by advocates ranging from environmental crazies to the religiously-committed New York City itself — soldiers on to try to build expensive new infrastructure to receive mythical zero-emissions electricity that does not exist and is in fact nothing but regular-old natural gas electricity.
The concept of Messrs. Caiazza, Ellenbogen and myself has been to see if we can inject some rationality into the process to prevent entirely futile and wasteful (and even counterproductive) spending in pursuit of the infeasible “net zero” goals. None of the three of us are being compensated in any way for this work. Basically, we are doing it as a hobby, to see if we can save New Yorkers from their own folly.
On Wednesday (November 26) we filed a document setting forth our position, titled “Statement of Independent Intervenors Roger Caiazza, Richard Ellenbogen, and Francis Menton In Opposition to the Joint Proposal.” To view our Statement, go to this link to the docket of the proceeding before the New York Public Service Commission, and click on Document Number 214.
Some procedural history on where we are: Con Edison started this rate proceeding back in January 2025, by requesting rate increases of about 10% each year for the years 2026, 2027 and 2028. Anybody with an interest in the matter (like a ratepayer) was allowed to intervene, and shortly there were about 100 parties, three of them being Messrs. Caiazza, Ellenbogen and myself. Other parties range from New York City, Westchester County, Amtrak, the MTA, and various advocacy and environmental groups, to state legislators and individual ratepayers.
In June the State Department of Public Service paused the proceedings to begin settlement negotiations. My colleagues and I opted to join those, but as the price of joining we were sworn to confidentiality as to the discussions. And thus I have had nothing to report for about five months. However, the settlement negotiations ended at the beginning of November when all the big players entered into what they call their “Joint Proposal.,” often abbreviated “JP.” The JP got filed on November 5, and is Item 183 on the Public Service Commission docket. The JP itself is some 300+ pages long, and I would not recommend trying to read it; however, a Summary of the Joint Proposal, 6 pages long, was filed the next day on November 6. It is item 185 on the docket.
The good news about the JP, I suppose, is that Con Edison has been induced to reduce its request for a rate increase from about 10% per year to about 3% per year. (My own inference from watching the process is that Con Edison always knew that 3% was the most it could get, and only put up the 10% number at the beginning to have something to back off from.). The bad news is that there is still lots of spending in the Proposal to support “climate” things like building and vehicle electrification, and worse, they refuse to break out which of the spending is for these “climate” purposes versus the main job of assuring safe and reliable electricity.
So with that background, here are some choice excerpts from our submission. From the introductory section:
The Independent Intervenors object to the JP because it seeks to implement large rate increases for projects not necessary for or germane to reliability and safety of the electrical system and that are instead intended to support extraneous goals that are impossible and infeasible. The bases for the objections of the Independent Intervenors include:
• The JP supports spending for purposes of building electrification and vehicle electrification, but there is not enough zero-emissions electricity generation capacity available to the downstate region to accomplish those goals reliably, and therefore any spending on Company delivery infrastructure for these purposes is wasteful. The Independent Intervenors object to spending ratepayer money supposedly for the delivery of electricity, when the electricity does not in fact exist.
• Spending by the Company to support building and vehicle electrification is actually counterproductive for Climate Leadership & Community Protection Act (CLCPA) goals because there is and will be little zero-emission generation available to the Company service territory during and after the JP period. Therefore, building and vehicle electrification will increase rather than decrease GHG emissions.
And from the concluding sections:
THE JP IS UNJUST, UNREASONABLE, AND CONTRARY TO THE PUBLIC INTEREST
There is nothing “just” or “reasonable” in:
• Imposing on the ratepayers billions of dollars of costs for purposes having nothing to do with system reliability or safety, and instead supporting goals that are infeasible (as admitted by the State itself) and impossible to achieve such that the public’s funds will be completely wasted.
• Imposing huge costs on ratepayers to build new infrastructure for the delivery of new zero-emissions electricity that in fact does not exist and will not exist in this state during the time period of this rate case and for many years thereafter.
• Hiding and concealing potentially billions of dollars of costs in a rate increase that have nothing to do with system reliability and safety and instead are going for infeasible and impossible goals.
• Providing potentially billions of dollars of ratepayer funds to support electrification projects supposedly to reduce GHG emissions, but that will instead increase GHG emissions because of the characteristics of the system that cannot be changed in any relevant time frame.
In the intervening sections between the introduction and conclusion, should you be interested, there is lots of detail about such things as failure to get zero-emission generators or transmission lines constructed, and actual emissions data from the downstate electricity system showing that you actually increase emissions by banning natural gas heat.
I do not know if the objections of myself and my colleagues will get much if any traction in this proceeding. And even if we do get some traction, this proceeding is somewhat peripheral to the central goals of New York’s “climate leadership” initiative of generating lots of zero-emissions electricity (and, supposedly, showing the world how that can be done). Still, we may get at least some of the vast collection of New York energy bureaucrats to look critically at one corner of this ridiculous situation. Maybe.
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From the article: “It doesn’t take an engineering genius to understand that burning natural gas on-site to heat a building uses less natural gas than burning it at a power plant, generating electricity, transmitting the electricity to a house, and then using the electricity at the house to make heat.”
If I recall correctly, using natural gas to heat a home directly is about 60 percent more efficient than burning that gas in a power plant and then transmitting that electricity to the house to heat the house.
Propoonents of heat pumps argue differently but our arguments show that New York City electricity comes primarily from fossil fuels burned at old generating plants. The conclusion is the same that an efficient natural gas furnace is more efficient than a heat pump in New York City.
Dumb question- are heat pumps proposed to be used on large urban buildings?
Yup https://apnews.com/article/heat-pump-apartments-energy-climate-carbon-emissions-13d77974c10496fc7b2f9245c5084daf
Will they work in really cold weather, is there enough power to them, and did they account for building electric service upgrades – nope nope and nope
How about if those windmill and industrial solar facilities pay for their own infrastructure to get connected to the grid and leave the rate payers out of it?
Free beer tomorrow.
I will gladly pay you next Tuesday for a hamburger today.
J. Wellington Wimpy.
Of course then they’d have to charge way more for the juice and people might get wise to them.
“I do not know if the objections of myself and my colleagues will get much if any traction in this proceeding.”
Kudos to the author and to Caiazza and Ellenbogen for making a very logical filing opposing this rate proposal, because we must push back on the absurdity of the larger NY energy schemes wherever the legal processes allow it.
Thank you sirs.
We appreciate the kudos. As Francis said – it’s a hobby.
Our electricity bill comes from Hydro One (HO) here in semi rural Eastern Ontario Canada. Like Con Ed, HO is a distribution business following deregulation years ago. It gets roughly half the annual revenue of Con Ed and I expect serves a more rural customer mix.
Recently HO produced a survey requesting customer feedback on its 5 year spending plans. Here is a link:
https://www.hydrooneworkbook.com/Media/1/HONI_PIN_2025.html?st=Ft/FRup4CGpYuraN3BTsZ0rEytDvQerrudirzhMiDHQ=&lf=False
The survey presents useful info about HO operations and plans, mostly true I expect. If you are not a HO customer please do not complete your submission at the end of the survey.
The reason for this post is to point out a big hidden mission creep and cost in the HO plan. They project battery backup installs at 1000 to 6000 substations across their network. The stated reason for this new expense is increased service reliability. We all want reliability. I am fairly sure the real motive is to backup locally connected wind and solar while hiding a big chunk of the cost in virtue signling reliability.
As terrific as this posting and the comments behind it are, I suspect that it will fall on deaf ears. Too many people, even smart educated individuals, are so invested emotionally in the climate change argument, and the follow-on arguments for wind, solar and batteries as the future of energy. As an example, I tried to explain to my brother, a chemical engineer, who is active in battery technology in California, that neither batteries nor adequate renewable power are available now and in the foreseeable future to make all of this happen. All he could say to me is that if what I say is true, then his contacts in that business are lying to him. Uh, yes, they are.
He is lying to himself as well. But for reasons which are perfectly explainable. It’s how one makes a living in California while living the California Dream.
My relatives in the Bay Area are living inside that same renewable energy dream. As their story goes, it will all come together if enough political will can be mustered to make it happen.
Economics and technology trump ‘political will’ every time. Vast sums of money are continually wasted through time in proving this truth over and over again. But politicians and bureaucrats never learn; they just blame others for their failures.
Because it’s not impossible doesn’t make it desirable.
And the knock-on effects. My Kali auto insurance rates are exploding because of infrastructure grid deficiencies causing wildfires! State Farm claims (haha) we auto rate payers aren’t bailing out the real estate side, yeah right.
Francis Menton posted a second article concerning this topic yesterday on the Manhattan Contrarian blog:
Some Other Parties Weigh In On The Con Edison Rate Case (November 30th. 2025)
In this second article, Menton notes that many of the officially-listed parties to the rate increase proposal endorse the proposal, for example New York City, while at the same time ignoring the larger issue of adding power distribution infrastructure to the grid for which there will be little or no additional generation capacity available to feed it.
He says at the close of his second article: “You might say, we already have a City government completely unconstrained by the real world, so how can it get any worse?”
Here is how it can get worse.
I’ve been reading a selection of the individual public comments listed on the NY-PSC’s docket page. Most all of the individual public letters oppose granting the proposed rate increase.
New York City Council member Shahana Hanif’s individual comments include themes which are common among these citizen letters: Hanif Letter pdf
Summarizing the common themes I’ve seen among these individual citizen letters:
— The rate increase will accelerate and worsen New York’s affordability crisis and its impacts on low income residents.
— Energy is both a necessity and a human right. It is inexcusable to approve a rate hike while Con Ed as a monopoly continues to receive billions of dollars of revenue.
— Increasingly extreme weather as a consequence of the climate crisis is causing a rise in energy demand while putting low-income residents at risk of suffering harm from heatwaves in the summer and severe cold weather events in the winter.
— In the face of the climate crisis, Con Edison continues to advance plans that perpetuate New York state’s dependence on fossil fuels.
— Con Edison is raising rates while failing to commit to fully transitioning away from fossil fuels in alignment with New York State’s mandate to reach net-zero emissions by 2030.
— Wind and solar backed by energy storage is cheaper than gas and nuclear. Continued reliance on gas and nuclear cannot be justified.
— New Yorkers deserve an energy system that is affordable, sustainable, and accountable; not one that prioritizes corporate profits over public well-being.
Shahana Hanif is a highly-committed socialist. Her politics are geared towards young voters and towards the recently-arrived immigrant population of New York City, both legal and illegal.
https://en.wikipedia.org/wiki/Shahana_Hanif
IMHO, full-blown socialism as pushed by politicians like Zohran Mamdani and Shahana Hanif is the future of governance politics in New York state. For example, Mamdani received 85% of the under-30 female vote, and 78% of the under-30 male vote.
The lack of affordability of basic life needs is the socialist’s ticket to power. They are making effective use of the issue not only in New York state, but also around the country in blue and purple states.
Once the fully-committed socialists are in full control of New York state government, which I expect to happen before this decade is out, will these ardent socialists still allow privately-owned power generation and distribution corporations to operate in New York?
Maybe, maybe not.
If all power generation and power distribution assets inside New York have been fully expropriated by the state, then socialist politicians will no longer have private corporations like Con Edison to blame for the rising costs of energy and for the visible lack of progress in reaching the Climate Act’s mandated targets. Or for the inevitable power blackouts.
I would not be surprised if socialist politicians are nominated for state-wide offices and attempt to run on the platforms described. I am optimistic that if that happens the affordability issue will be a major issue. I am also optimistic that the claim that solar and wind are cheaper can be debunked well enough that moderates in the cities combined with rural voters will elect non-socialist politicians worried about affordability
I wish I could share your optimism. I think what it is going to take is an extended power blackout and probably some deaths due to it. My husband’s relatives in NYC are all in on what ConEd and the state are proposing, mostly because they do not know any better.
Once that is over, maybe there will be changes, but even then, I doubt it.
PS–We are forwarding this post to our relatives in NYC in the hopes that they see at least a little of the light.
Tell them to read this site on a daily basis. It takes a while. When I first started reading this site, I was a brainwashed resident of Wokeachusetts. I didn’t get it for awhile. You have to read many essays here until it sinks in that the green energy thing is nuts.
Tell them about my blog because I focus on the NY insanity http://pragmaticenvironmentalistofnewyork.blog/
“In the face of the climate crisis, Con Edison continues to advance plans that perpetuate New York state’s dependence on fossil fuels.”
So if we’re dependent on fossil fuels. We’re also dependent on farmers, grocers and countless other entities. NY state could produce far more natural gas if they only allowed drilling for it- then there would be little dependency of out of state energy sources.
According to AOC we don’t need farmers or ranchers because food comes from the grocery store. If this is what a majority of New Yorkers think, they truly deserve what they get.
Oh, well- let Mamdani do his thing, then it’ll fail miserably showing the younger generation that you don’t benefit from socialism.
It sounds like an expensive pre build campaign for when they do get access to political offshore wind power. It’s marking time at your expense before getting access to the very expensive offshore wind. That makes it a negotiated path forward for the utility knowing all leaders are good with high rates and just in time excuse teams.
Very nice Francis, you guys are doing a great service for the rest of us. Here is what bothers me three percent or ten percent if they are given a rate increase for specific reason (they are saying for EV and electrification) and that plan doesn’t pan out then why shouldn’t we get our money back with interest. If I borrowed money for one purpose and spent it on something else I would be in trouble wouldn’t I? They are asking for a raise for a specific purpose if that doesn’t work out but they still keep their raise then they are nothing but liars and cheats. I don’t like being lied to or cheated that has to stop.
You may well be ignored but at least yiu are on the record. Would it not be great if when it all goes tits up in the future the perpetraitors were sat done and asked why they ignored your objections.
A solar or wind farm connects to the grid at a POINT. From that point, equipment must be built to support the spiderweb of distribution. Unless one knows where the generator will be connecting, one cannot properly design the distribution network of substations with transformers and other components.
Any money spent now before knowing the starting points is money that will quite likely be stranded in the future.
Socialist and socialism are often used in there discussions. I believe there is a better, more accurate word: Illiberal.
“The main difference is that illiberalism is a political ideology focused on a strong, often authoritarian, leader and a disregard for individual rights and democratic norms, while socialism is an economic and political system centered on social ownership and control of the means of production and a focus on equality. An illiberal system prioritizes the state or community over the individual and may have elections, but they are not free and fair, whereas a socialist system aims for economic equality through social ownership.”
I really cannot see how a socialist system can be implemented without a hefty does of illiberalism. It seems to me that socialism requires buy-in from the general population, which is not what we are seeing.