<div class="css-17ih8de interactive-body"><style> .g-doc-page_paper:not(.g-doc-page_html) { padding-top: 129.41176470588235%; } .g-related-link { width: calc(100% - 40px); max-width: 600px; margin: 20px auto 16px; border-top: 1px solid #ccc; padding-top: 20px; } .g-related-link_header { font-family: nyt-franklin, arial, helvetica, sans-serif; font-size: 0.75rem; font-weight: 700; text-transform: uppercase; letter-spacing: 0.05em; color: #999; margin-bottom: 10px; } .g-related-link a { text-decoration: none; color: #333; } .g-related-link a:hover { color: #666; text-decoration: underline; } .g-related-link_text { font-family: nyt-cheltenham, georgia, 'times new roman', times, serif; font-size: 1.125rem; line-height: 1.375rem; font-weight: 700; color: #333; margin: 0; } @media (min-width: 740px) { .g-related-link_text { font-size: 1.1875rem; line-height: 1.4375rem; } } </style> <div class="g-graphic"> <div class="g-doc-wrapper g-ocr-ready"> <div class="g-item g-document"> <div class="g-doc-page_wrapper"> <div class="g-doc-page_container"> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-1"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 1 of 17" aria-describedby="page-1-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/1/output-1.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 1 of 17" aria-describedby="page-1-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/1/output-1.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-1-text">STATE OF NEW YORK PUBLIC SERVICE COMMISSION Proceeding on Motion of the Commission for Protections the Establishment of Extreme Heat, Protections, Practices and Procedures. Case 24-M-0586 I. REPLY COMMENTS OF THE NEW YORK ELECTRIC UTILITIES ON THE DEPARTMENT OF PUBLIC SERVICE STAFF REPORT AND RECOMMENDATIONS REGARDING UTILITY CUSTOMER PROTECTIONS DURING EXTREME HEAT EVENTS Introduction On May 20, 2025, the Department of Public Service Staff ("Staff”) filed a report and recommendations (the “Report”) on standardized utility procedures and customer protections during extreme heat events. In its Notice Seeking Comments, issued May 22, 2025, the Commission sought comments concerning the Staff Report. On August 4, 2025, several parties filed comments on the Report, including the New York State electric utilities (the “Utilities”),² 1 2 Case 24-M-0586, Proceeding on Motion of the Commission for the Establishment of Extreme Heat Protections, Practices and Procedures ("Extreme Heat Proceeding"), Department of Public Service Report and Recommendations Regarding Utility Customer Protections During Extreme Heat Events (filed May 20, 2025) (the "Report") Extreme Heat Proceeding, Comments of the New York Electric Utilities on the Department of Public Service Staff Report and Recommendations Regarding Utility Customer Protections During Extreme Heat Events (filed August 4, 2025) (“Utilities Comments”). The Utilities are Central Hudson Gas &amp; Electric Corporation ("Central Hudson"), Consolidated Edison Company of New York, Inc. ("Con Edison”), New York State Electric &amp; Gas Corporation (“NYSEG”), Rochester Gas and Electric Corporation ("RG&amp;E”), Orange and Rockland Utilities, Inc. ("O&amp;R"), and PSEG Long Island LLC (“PSEG LI") (collectively, "the Utilities"). PSEG LI is the agent for and service provider to the Long Island Power Authority ("LIPA") and submits its comments on behalf of LIPA. Pursuant to the New York State Public Authorities Law, LIPA is not generally subject to the jurisdiction of the New York State Public Service Commission (the "Commission") but seeks to align with state policy where possible. See N.Y. Pub. Auth. Law § 1020-s. 1</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-2"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 2 of 17" aria-describedby="page-2-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/2/output-2.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 2 of 17" aria-describedby="page-2-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/2/output-2.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-2-text">the Public Utility Law Project (“PULP”),³ and the City of New York ("New York City").4 In their individual comments, PULP and New York City offered proposals that would make customer protections more stringent and administratively burdensome, without consideration for the costs of suspending terminations for non-payment acknowledged in the Report. These reply comments address PULP's and New York City's recommendations and provide additional context for the Commission's consideration. Consideration of these comments will contribute to a clear and complete record in this proceeding. II. Response to Comments A. Heat Index Threshold and Suspension of Service Terminations Applicable Report Recommendations: Recommendations 2 and 7 1. Heat Index Threshold PULP recommends that the Utilities suspend residential service terminations on any day when the air temperature or heat index reaches 85 degrees as well as the following day, or two days for designated heat islands. PULP also suggests rounding forecasted heat index or air temperature measurements to 85 degrees when readings are at or above 84.5 degrees. The Commission should not adopt PULP's more restrictive proposals. The Utilities understand the challenge of rising costs which is why Utilities continue to implement proactive 3 4 Extreme Heat Proceeding, PULP Comments in Response to Department of Public Service Staff Report and Recommendations Regarding Utility Customer Protections During Extreme Heat Events (filed August 4, 2025) (the "PULP Comments"). Extreme Heat Proceeding, Comments of the City of New York on Staff Report Regarding Extreme Heat Protections (filed August 4, 2025) (the "NYC Comments"). 5 PULP Comments, pp. 2-3. 2</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-3"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 3 of 17" aria-describedby="page-3-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/3/output-3.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 3 of 17" aria-describedby="page-3-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/3/output-3.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-3-text">programs to reach customers prior to them going into arrears. These initiatives include email and digital communications regarding levelized payments, budget billing and energy efficiency tips, tools, and programs to monitor and lower usage. In addition, termination of service is an absolute last resort. The Utilities generally try to resolve arrears through payments, payment arrangements, third-party assistance, or other options. The Utilities also offer programs to help our most vulnerable customers such as in-person events to help customers who are behind on payments, as outlined in each Utility's Outreach and Education Report. Additionally, outreach efforts are thorough and extensive, including letters, phone calls, and field visits. Finally, most customers are reconnected within 24 hours after service termination. While a last resort, service terminations are an important tool for engaging customers to address arrears balances. Lowering the threshold below the 90-degree heat index threshold proposed by the Report to 85 degrees would substantially increase the number of days when the Utilities suspend residential service terminations for non-payment and would upset the appropriate balance between standardized protections and long-term costs for customers. For example, in Con Edison's service territory, between June 1, 2025, and August 12, 2025, there were 37 days when the forecasted heat index reached 85 degrees, excluding Fridays, weekends, holidays and the day before a holiday (as the Utilities are already required not to terminate service for residential customers on these days), compared to 23 days when the forecasted heat index reached 90 degrees. Similarly, for PSEG LI in 2024, there were 27 days when the 6 See 16 NYCRR § 11.4(a)(4). 3</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-4"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 4 of 17" aria-describedby="page-4-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/4/output-4.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 4 of 17" aria-describedby="page-4-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/4/output-4.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-4-text">temperature reached 85 degrees, compared to 6 days when the temperature reached 90 degrees. Reducing the heat index threshold to 85 degrees would therefore increase the financial impacts to all utility customers, who must bear the cost of higher utility interest expenses and higher uncollectible arrears balances. An estimate of the potential cost impacts is illustrated in the Utilities' responses to Staff interrogatory IR-08 for a number of scenarios, including on days when the temperature reached 85 and 90 degrees Fahrenheit, respectively, as well as the day after. The Utilities' estimates of annual cost impacts in 2024 from suspended terminations in this scenario based on 90-degrees threshold ranged from approximately $423 thousand to more than $9.3 million per year. By comparison, for this scenario when suspending terminations based on an 85-degree threshold, the Utilities' estimates of cost impact for 2024 from suspended terminations ranged from $1.6 million to more than $19.5 million. 8 Moreover, for most of the Utilities, PULP's recommended thresholds represent an extreme downward departure from the current thresholds that the Commission has repeatedly approved as reasonable in utility rate plans. Absent a factual showing that the current utility thresholds are unsafe or unworkable, there is no reasonable basis for such a change. Indeed, Staff's proposed heat index thresholds are already far more protective of customers than those 7 8 Because historic heat index data was not available for most utilities, the comparison provided reflects information for temperature thresholds, which the utilities provided in response to Staff interrogatory IR- 08. As a heat index threshold (e.g., 90 degree heat index) would typically be reached at a lower temperature than a threshold of the same level based on temperature, the Utilities' cost estimates are conservative relative to a heat index threshold. Extreme Heat Proceeding, Report, Appendix D – Utility Interrogatory Responses, pp., 29-30 (Central Hudson); p. 77-78 (RG&amp;E). 4</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-5"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 5 of 17" aria-describedby="page-5-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/5/output-5.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 5 of 17" aria-describedby="page-5-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/5/output-5.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-5-text">adopted by New York City, which opens cooling centers only when the forecasted heat index exceeds 95 degrees for two consecutive days or 100 degrees at any point in time.⁹ Additionally, PULP's suggestion to have the Utilities check both the forecasted temperature and the forecasted heat index would increase their administrative burden without any apparent benefit. The heat index is lower than the temperature only in areas with very low humidity. In New York, by contrast, the heat index during warm-weather months is typically higher than the air temperature. As Staff has recommended using the heat index rather than the air temperature, customers already receive the benefit of the higher reading. For this reason, there is no additional benefit to having the Utilities track the air temperature in addition to the heat index. Finally, PULP's suggestion to round forecasted heat index or air temperatures falling within 0.5 degrees is not necessary as the National Weather Service's ("NWS”) already reports this information rounded to the nearest whole number.¹ 2. 10 Suspension of Service Terminations New York City recommends that Con Edison's current policy—which stops residential service shutoffs on the day before and the day of a forecasted heat index of 90 degrees or higher, and for two days after the heat index actually reaches 90 degrees— remain in place and be 9 See New York City, Cooling Centers, available at https://portal.311.nyc.gov/article/?kanumber=KA-02663 (last visited Aug. 13, 2025). 10 See, e.g., Official NWS forecast site for Central Park, available at https://forecast.weather.gov/MapClick.php?lat=40.78&amp;lon=-73.97 (last visited Aug. 13, 2025). 5</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-6"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 6 of 17" aria-describedby="page-6-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/6/output-6.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 6 of 17" aria-describedby="page-6-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/6/output-6.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-6-text">adopted statewide." Similarly, PULP also recommends suspending terminations one day before a forecasted heat event in areas designated as heat islands. 12 The Utilities disagree with these recommendations. As detailed in the Utilities' Comments, there is no data-driven justification for suspending terminations on days when the average heat index fails to meet the prescribed threshold. Service terminations should only be suspended on days when the heat index independently meets or exceeds the established 90- degree threshold. Indeed, as noted above, New York City's own policies do not provide for customer protections (in the form of cooling centers) except on the particular days when the heat index meets a higher threshold than that proposed here. Moreover, these recommendations would sharply limit the number of days on which the Utilities can terminate service for residential customers in arrears, thereby potentially exacerbating customers' arrears balances and increasing costs to other customers in the form of higher uncollectibles and interest expenses. For example, if the heat index exceeds the threshold on a Tuesday, a policy which suspends terminations both one day before and two days after the heat index day would prevent any service collection for the entire week, regardless of how cool the other days might be. This policy does not strike the appropriate balance identified in the Report between customer protection and arrears reduction and so should not serve as a model for the entire state. 11 City Comments, pp. 7-8. 12 PULP Comments, p. 9. 6</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-7"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 7 of 17" aria-describedby="page-7-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/7/output-7.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 7 of 17" aria-describedby="page-7-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/7/output-7.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-7-text">B. Weather Stations Applicable Report Recommendation: Recommendations 3, 4 and 5 1. Identification in Tariffs PULP supports the Report's proposal that each of the Utilities identify weather stations in their tariffs and further recommends that this information be published on each of the Utilities' websites. 13 As detailed in the Utilities' Comments, the Utilities oppose specifying weather station locations in their tariffs because it would add unnecessary administrative complexity and limit their flexibility to update station references, as needed. Having this information in tariffs would also make it more difficult for the Utilities to pivot in the unlikely event that the NWS becomes unavailable and the Utilities have to quickly identify an alternative source of weather data. For these reasons, this information should not be included in the Utilities' tariffs but should be posted on their websites, as suggested by PULP, which would allow for timely updates without the need for formal tariff amendments. 2. Regional Geographic Areas In contrast to the relatively straightforward, easy-to-administer geographic boundaries included in the Report, PULP recommends determining when and where to suspend terminations based on more granular distinctions that do not correspond to the operating areas that the Utilities use to staff their field crews. For example, in Con Edison's service territory, PULP proposes either the use of the highest daily heat index forecasted among the four primary Automated Surface Observing System (ASOS) stations, or the adoption of Downtown- 13 Id., p. 3. 7</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-8"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 8 of 17" aria-describedby="page-8-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/8/output-8.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 8 of 17" aria-describedby="page-8-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/8/output-8.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-8-text">Manhattan/Wall Street heliport (KJRB) as the primary downstate reference station. For central and upstate Utilities, PULP recommends the use of each county's Mesonet data. If this data is not available, PULP further proposes that the Department of Public Service convene meteorologists and other experts to audit every weather station currently in use and recommend adjustments or supplemental stations as necessary. 14 The Utilities disagree with these recommendations. The use of NWS data, which is standardized and based on well-developed tools designed specifically for forecasting at NWS locations to provide data quality and accuracy, offers the most reliable basis for decision-making. Localized stations, such as the New York State Mesonet, can lack uniform data measurement and collections tools, which may result in less forecasting accuracy and thus lead to discrepancies in when protections are applied across different neighborhoods. Additionally, incorporating multiple data sources or requiring audits of local weather stations would introduce unnecessary complexity and would require additional resources. The Commission should therefore reject PULP's proposal. 3. High Winds and Severe Storms PULP further recommends an automatic halt on terminations whenever the NWS 15 forecasts high winds or the potential for tornadoes. PULP likewise recommends a statewide review of service termination suspensions in the days preceding forecasted severe storms. While the Utilities appreciate PULP's concerns, they are already addressed under the state's 14 Id., pp. 5-6. 15 Id., pp. 6-8. 8</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-9"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 9 of 17" aria-describedby="page-9-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/9/output-9.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 9 of 17" aria-describedby="page-9-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/9/output-9.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-9-text">emergency response framework¹ and do not require further modification in the Commission's current proceeding. C. Heat Island Analysis Applicable Recommendation: Recommendation 6 Both PULP and New York City oppose Staff's recommendations that the Utilities conduct studies of heat islands in their service territories. PULP recommends that the Utilities should not conduct heat island studies or be tasked with mapping heat-vulnerable areas but rather apply existing datasets—including the Department of Health's Heat Vulnerability Index (“HVI”)—to zip code and census tract data. Additionally, PULP advises that areas identified in the HVI with "moderate" heat risk or higher should also be designated as heat islands for utility shut-off protections. 17 Similarly, New York City opposes giving the Utilities the authority to define heat islands and instead recommends the use of the Environmental Protection Agency's definition of heat island and treatment of all of New York City as a heat island. Finally, New York City recommends that the Utilities collaborate with the Department of Environmental Conservation (“DEC”) to identify areas as heat islands. 18 The Utilities acknowledge that using these standardized indices may promote efficiency. The Utilities are not proposing to define or map heat islands independently but instead intend to engage with Staff to align methodologies and data sources for their heat island studies and to 16 See Case 13-M-0061, In the Matter of Customer Outage Credit Policies and Other Consumer Protection Policies Relating to Prolonged Electric or Natural Gas Service Outages, Order Establishing Policies (issued November 18, 2013). 17 PULP Comments, pp. 8-9. 18 City Comments, pp. 10-12. 9</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-10"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 10 of 17" aria-describedby="page-10-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/10/output-10.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 10 of 17" aria-describedby="page-10-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/10/output-10.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-10-text">determine how best to use the results of these studies. By consulting with Staff, the Utilities aim to help shape a statewide framework that is both scientifically sound and operationally practical. D. Enhanced Customer Communications and Outreach Applicable Recommendations: Recommendations 9, 10, 12 and 13 1. Additional Outreach to Customers at Risk of Disconnection PULP offers a number of recommendations for additional outreach activities by the Utilities. To that end, it recommends that the Utilities engage in costly and repetitious outreach to at-risk customers during extreme heat events, including notifications to vulnerable customers within 24 hours of a forecasted heat event, year-round SMS extreme heat alerts, quarterly reporting of outreach metrics, in-person efforts focused on high-risk areas, and a dedicated hotline for reconnections during extreme heat emergencies. 19 The Utilities acknowledge the importance of proactive outreach and already incorporate several of PULP's recommendations into existing operations. For example, the Utilities send text messages related to weather and outages to customers year-round as part of existing communication protocols. Other strategies for engaging vulnerable customers and addressing weather-related emergencies, such as community events, proactive communications, and emergency response efforts, are detailed in each Utility's Annual Outreach and Education Plan. Customers in need of reconnection during emergencies can contact the Utilities' call centers. Many of PULP's recommendations, however, would add costs without corresponding benefits. For example, it is not beneficial for a Utility to contact all vulnerable customers in 19 PULP Comments, p. 10. 10 10</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-11"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 11 of 17" aria-describedby="page-11-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/11/output-11.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 11 of 17" aria-describedby="page-11-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/11/output-11.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-11-text">advance of a heat-related suspension of terminations, including those who are not subject to termination; any suspension would affect only a small portion of those customers, and such a notification would likely prompt confusion among customers who would be led to believe that they would have been terminated but for the heat event and may therefore be terminated immediately after the heat event ends. It also does not make sense for the Utilities to establish separate phone lines (presumably with dedicated staffing) for reconnections during heat events absent any showing that their regular, well-publicized customer service lines are unable to address customer concerns during heat events. Additionally, PULP does not supply any reason for utilities to incur the cost of reporting metrics related to customer outreach specifically related to heat events. 2. Alternative Methods for Additional Communication with Vulnerable Customers PULP recommends that the HEFPA “diligent effort” requirement to contact an adult resident at least 72 hours prior to a scheduled service termination be expanded to include the use of all approved communication channels. PULP also recommends that the Utilities conduct outreach through each customer's preferred method for all programs that may prevent termination for heat emergencies. Additionally, PULP recommends allowing customers to designate emergency contacts when they are unreachable, collecting communication preferences related to heat protections at account opening, and providing clear notifications about when such protections apply. Finally, PULP suggests using push notifications, robocalls, website updates, 11</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-12"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 12 of 17" aria-describedby="page-12-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/12/output-12.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 12 of 17" aria-describedby="page-12-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/12/output-12.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-12-text">social media, and partnerships with local agencies to disseminate information on impending heat events, available cooling centers, and bill assistance programs.2 20 While the Utilities support efforts to increase customer awareness of heat events, particularly for vulnerable populations, PULP's recommendations would be operationally and logistically challenging to implement and do not properly balance the additional costs of implementation against any potential benefits. First, PULP's recommendation to define “diligent effort" would not be limited to extreme heat events and therefore falls well beyond the scope of this proceeding and should be rejected by the Commission. Further, however, annual verification of contact information and the use of all approved communication channels would require considerable resources, especially across large and diverse customer bases. In some cases, customers' preferred methods also may not be compatible with current processes or may slow down time-sensitive communications during heat events and other emergencies. The Commission should therefore reject PULP's proposals. 3. External Communications Plans for Customers and Municipal Officials PULP encourages the Utilities to broadly share information with the public about heat events and any associated suspension of service terminations. PULP further recommends that these communications include information about financial assistance, reducing energy consumption, and minimum deferred payment agreements, as well as recommendations to local non-Utility resources such as food banks, rent assistance programs, and cooling centers. 21 20 21 Id., pp. Id., p. 11. 10-11. 12</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-13"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 13 of 17" aria-describedby="page-13-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/13/output-13.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 13 of 17" aria-describedby="page-13-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/13/output-13.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-13-text">The Utilities support increasing customer knowledge and awareness, but caution that such expansive outreach—especially across multiple platforms and under rapidly changing conditions- -can be difficult to execute efficiently and will likely overburden customers with excessive numbers of messages that are not directly related to extreme heat events. For example, including detailed financial assistance information in every communication could result in overly complex messages that risk causing confusion. Integration of other information into these targeted communications, such as that related to energy efficiency and community resources external to the utility, will make communications lengthy and is limited by technology in some instances. Finally, the need for timely communications to all customers during extreme weather events may ultimately make comprehensive implementation of such far-reaching communications not only impractical but ineffective. 4. Enhancement to Webpages PULP supports the use of dedicated “Extreme Heat Protections” webpages and recommends enhancements to make these pages more accessible and transparent. These enhancements include making the pages mobile-friendly, compliant with WCAG 2.1 AA standards, and available in the six most spoken languages within each utility's service area. PULP also calls for updates within 24 hours of any changes to a heat moratorium, with clear date stamps and a three-year archive of all revisions. PULP further recommends that the Utilities apply search engine optimization ("SEO") so the pages appear in top search results and submit annual screenshots to confirm search performance. PULP also proposes that links or QR codes to these webpages be included in customer touchpoints such as IVR systems, call center scripts, hold messages during heat events, bill inserts (paper and electronic), email signatures, and social 13</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-14"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 14 of 17" aria-describedby="page-14-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/14/output-14.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 14 of 17" aria-describedby="page-14-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/14/output-14.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-14-text">media posts during advisories. Lastly, PULP requests that the Utilities report on webpage engagement, including metrics such as page views, bounce rates, click-throughs to cooling center information, and updates to language or accessibility features. 22 The Utilities are aligned with PULP on the importance of providing comprehensive and accessible online resources. However, implementation of this lengthy list of recommendations would require costly operational and technological adjustments. Frequent website updates, multilingual translations, and SEO maintenance demand substantial coordination and financial investment beyond the scope of this proceeding. Embedding webpage links across every customer-facing platform, as well as compiling engagement metrics and maintaining archives, adds further complexity—particularly during periods of extreme weather when internal resources are already stretched. The Utilities remain committed to expanding communication strategies for vulnerable customers but emphasize the need to make such strategies feasible with existing Utility infrastructure and resource limitations to contain costs and maintain operational focus during heat events. The Commission should therefore adopt Staff's recommendation for the Utilities to continue to maintain and update their current dedicated webpages for extreme weather protections but reject PULP's long list of additional requirements. E. Public Posting of Daily Heat Index Logs Applicable Recommendation: Recommendation 11 In addition to supporting the Report's recommendation for the Utilities to document the daily heat index and retain these logs for at least five years, PULP also recommends that these 22 22 Id., pp. 11-12. 14</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-15"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 15 of 17" aria-describedby="page-15-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/15/output-15.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 15 of 17" aria-describedby="page-15-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/15/output-15.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-15-text">logs be posted on each Utility's website. 23 While posting heat index logs publicly may enhance transparency, PULP does not provide justification for posting the temperature logs on each Utility's website. Accordingly, the Utilities recommend that, if the Commission deems it necessary for this information to be posted publicly, then, to avoid the cost of frequent website updates, it should be filed with the Commission and posted no more than annually. F. Effective Date of Policies and Procedures Applicable Recommendation: Recommendation 14 PULP supports the proposal that any new Commission action should override current utility rate plan provisions, but argues that if a utility's existing extreme heat procedures offer stronger protections, those should remain in effect until the current rate plan expires.24 The Utilities disagree with this recommendation. To promote customer awareness of these protections, avoid customer confusion, and promote uniform protections statewide during heat events, any protections ordered by the Commission should apply consistently and contemporaneously across the state, as recommended by Staff. III. Conclusion New York City's and PULP's recommendations would increase the cost and burden of implementing uniform statewide heat protections, with limited demonstrable benefit to consumers. As Staff correctly noted in the Report, customer protections must be balanced against the need for the Utilities to be able to undertake the full scope of collections activities to address 23 Id., p. 11. 24 Id., p. 12. 15</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-16"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 16 of 17" aria-describedby="page-16-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/16/output-16.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 16 of 17" aria-describedby="page-16-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/16/output-16.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-16-text">their current unprecedented levels of arrears, which impose costs on all customers. The Utilities' recommendations in the Utilities Comments and these Reply Comments best strike that balance. Dated: August 19, 2025 Respectfully submitted, CENTRAL HUDSON GAS &amp; ELECTRIC CORPORATION By: /s/ Marina W. Chu Marina W. Chu Regulatory Attorney - Regulatory Affairs Central Hudson Gas &amp; Electric Corporation 284 South Avenue Poughkeepsie, NY 12601 Tel: (845) 452-2000 Email: mchu@cenhud.com CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. By: /s/ Edward Sherwin Edward Sherwin Associate Counsel Consolidated Edison Company of New York, Inc. 4 Irving Place, 18th Floor New York, NY 10003 Tel: (212) 460-6300 Email: sherwine@coned.com 16</p> </div> </div> </div> <div class="g-doc-page g-doc-page_image" data-hasannotations="false" id="page-17"> <div class="g-doc-page_inner clearfix"> <div class="g-doc-page_paper doc-shell"> <img alt="Page 17 of 17" aria-describedby="page-17-text" class="g-doc-image lazyload" data-src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/17/output-17.png" height="2200" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png" width="1700"/> <noscript> <img alt="Page 17 of 17" aria-describedby="page-17-text" class="g-doc-image" height="2200" src="https://static01.nyt.com/newsgraphics/documenttools/6c197054c1b2dffd/17/output-17.png" width="1700"/> </noscript> <p class="g-doc-text" id="page-17-text">ORANGE AND ROCKLAND UTILITIES, INC. By: /s/ John L. Carley John L. Carley Associate General Counsel Orange and Rockland Utilities, Inc. 4 Irving Place New York, NY 10003 Tel: (212) 460-2097 Email: CarleyJ@coned.com NEW YORK STATE ELECTRIC &amp; GAS CORPORATION and ROCHESTER GAS AND ELECTRIC CORPORATION By: /s/ Amy Davis Amy A. Davis Senior Regulatory Counsel Cell: 585.866.9675 Email: amy.davis@avangrid.com PSEG LONG ISLAND LLC By: /s/ Sarmili Saha Sarmili Saha Assistant Counsel - Regulatory 333 Earle Ovington Boulevard Uniondale NY 11553 Tel: 516-286-0236 Email: Sarmili.Saha@pseg.com 17</p> </div> </div> </div> </div> </div> <div class="g-doc-footer"> <p class="sr-only">A PDF version of this document with embedded text is available at the link below:</p> <a class="g-download-link" href="https://static01.nyt.com/newsgraphics/documenttools/a2e0d18b8abb72a9/69f61304-full.pdf" target="_blank"> <h2>Download the original document (pdf)</h2> </a> </div> </div> <div class="g-img-overlay_container" id="g-img-overlay"> <div class="g-img-overlay"> <div class="g-img-overlay_inner"> <img alt="Image of the selected page" class="g-img-image" src="https://static01.nyt.com/packages/flash/multimedia/ICONS/transparent.png"/> <div id="g-img-close"> <span class="g-img-icon-text">Close</span> <span class="g-img-icon g-close">×</span> </div> </div> </div> </div> </div> </div> </div>