NY Public Service Commission Illustrates the State’s Terminal Condition

CELDF - report on Mora countyTom Shepstone
Shepstone Management Company, Inc.

If you want to appreciate just how much damage Andrew Cuomo has done to New York take a quick look at the machinations of his Public Service Commission.

Last month, as the potential for a moratorium on natural gas connections in the New York City metro area loomed, the New York State Public Service Commission illustrated the problem. It is simply an inability to think clearly. The Commission is totally under the thumb of Andrew Cuomo and is not allowed to think, in fact. It can only obfuscate. That much is sadly clear from its February 19 order regarding ConEd’s proposal to implement “non-pipeline solutions” as the alternative to doing what must be done.

Public service commission

What must be done, of course, is to simply stop the insanity; stop trying to kill all the pipelines absolutely necessary to deliver natural gas to the New York City metro area. Every reasonable person understands this is the problem but no one who works for the emperor is permitted to mouth the words. And, make no mistake, the members of the Public Service Commission work for the Andrew Cuomo. Any semblance of independence disappeared long ago, when he brought the agency totally under his control.

The PSC was, as recently as 2012, independent and boldly acknowledged the benefits of natural gas. Now, it’s nothing more than a fractivist tool for Andrew Cuomo in burnishing his green credentials as the nation’s most progressive governor in fighting global warming; helping him set the stage for grabbing a Presidential nomination someday.

Facts, reason and science have been literally thrown to the wind as the Public Service Commission deliberately twists itself into a Gordian Knot for the sake of positioning Cuomo arriving as a modern day Alexander the Great to cut it in half. Unfortunately, Andrew is no Alexander and has no such sword. Rather, he’s Gordious, the knot-maker, a truly Machiavellian twister and tangler, whose schemes never work out quite the way he hopes as SolarCity/Tesla and a dozen other schemes have demonstrated.

If you have the fortitude, try wading your way through the PSC order to see what I mean. It’s a masterpiece in obfuscation by both the ConEd, the obsequious applicant, and the Commission. Here are a few excerpts (emphasis added):

On September 29, 2017, Consolidated Edison Company of New York, Inc. (Con Edison or the Company) filed a petition (Petition) for approval of its Smart Solutions for Natural Gas Customers Program (Smart Solutions Program). In its Petition, Con Edison proposed to implement a multi-pronged program to address its forecasted growing shortfall of peak day pipeline capacity. To meet the growing peak day demand needs of its firm customers, Con Edison has increasingly relied on expensive delivered services, also known as peaking contracts, and expects to continue to do so as peak day demand increases. 

Therefore, the Company proposed an Enhanced Gas Energy Efficiency Program (Enhanced Gas EE Program), a Gas Innovation Program, a Gas Demand Response Pilot (Gas DR Pilot), a Non-Pipes Alternative (NPA) Portfolio and associated shareholder incentive, and requested authorization to recover pipeline development costs on an expedited schedule. Subsequently, Con Edison filed additional detail regarding its NPA Portfolio and shareholder incentive mechanism (NPA Incentive Mechanism) on September 28, 2018. Con Edison notes that, absent Company actions, it may be unable to meet demand from new firm gas customers on peak usage days, and, therefore, may need to institute moratoriums on attaching new firm gas customers where pipeline capacity is not available

In its NPA Portfolio, Con Edison proposes that the Commission approve a $305 million budget (excluding commodity and capacity charges and Operation & Maintenance (O&M) costs) for a portfolio of non-pipeline projects, including: (1) targeted gas energy efficiency proposals for low income customers and government buildings that provide critical community services; (2) renewable thermal electrification proposals for residential geothermal heat pumps in Westchester County and air source heat pumps for multifamily customers in the Bronx; (3) renewable natural gas (RNG) production plants in Westchester County and New York City; and, (4) trucked supplies of compressed natural gas (CNG) and liquified natural gas (LNG) in Westchester County. The proposed budget includes the cost of the proposals, along with the funds needed for administration, measurement and verification (M&V), and gas system interconnection for the gas supply projects.

The first two proposals are for rationing and gimmicks that will make little or no differenced and only increase the pain vis-a-vis moratoriums and the like.

The third proposal for renewable natural gas, of course, is about gas made by burning garbage, wood or some other “bio-fuel,” or landfill gas. The prospects for creating these facilities in the NIMBY culture metro area are on the order of winning the Mega Millions lottery three times in a row, which is why New York City challenged this part of the ConEd plan noting that while “it is supportive of creating a viable local market for renewable natural gas, it is concerned about the possibility of cost over-runs if developers experience significant difficulty in siting RNG projects in New York City and Westchester County.” That’s code for “there’s no damned way.” And, on top of this is these footnoted facts regarding a benefit/cost analysis (BCA):

BCA reference case results are shown in table 2 of the NPA Portfolio filing and do not include any avoided pipeline capacity costs as a benefit due to the inability of the Portfolio to enable Con Edison to eliminate or defer additional pipeline capacity needs. This relies on the Company’s assertion that the “renewable gas” component would meet a policy standard such that it be treated as “carbon free.” Without this, the BCA would only drop to 0.98, which is indistinguishable from 1.0, given the myriad of assumptions that must be made in any BCA.

Renewable natural gas projects are not only politically dead in the water, but also make no sense economically.

And, if anyone imagines the fourth option, “trucked supplies of compressed natural gas (CNG) and liquified natural gas (LNG) in Westchester County” are going to be any less controversial than pipelines, they haven’t experienced New York politics. Moreover, it makes no economic sense to truck in what can be delivered by pipelines, which are safer, generate no additional carbon emissions and are less expensive.

See what I mean by being tied up in knots of green political correctness. None of what has been proposed makes any economic or environmental sense whatsoever. It’s all green political posturing forced on New York consumers by Andrew Cuomo’s political ambitions and desires to be a green hero. And, there are none to oppose his madness because he’s eliminated them, forcing everyone to play his stupid green games.

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