Environmental Performance
The company’s sustainability strategy is focused on two concepts regarding our environmental stewardship: mitigation and adaptation. From a mitigation standpoint, we strive to reduce our environmental footprint, making wise and effective use of natural resources. We also recognize that our climate is changing and that we must adapt our company to address the challenges of climate change and its impact on our business. We have identified five Key Sustainability Aspects related to our environmental performance and defined success in those areas as follows:
- Air: Reduce direct and indirect emissions to improve air quality
- Water: Enhance the efficiency of our water use and seek opportunities to improve water quality
- Habitat and Biodiversity: Manage our environmental legacy and minimize our impact to natural ecosystems
- Resource Conservation: Focus on reducing, reusing, and recycling to minimize consumption
- Climate Change: Design our work in consideration of climate forecasts
The following sections outline our progress in these areas, as well as the goals we look to achieve in the future as we strive to be a good environmental steward and corporate citizen.
Air
Since the 1990s, Con Edison has made significant strides in our efforts to reduce air emissions and our impact on air quality. As outlined in the 2013 IPCC Working Group One report, we recognize that greenhouse gas emissions impact climate change. For that reason, we have made substantial efforts to reduce our direct and indirect emissions of greenhouse gases. The company also continues to make significant progress in the reduction of criteria air pollutants such as nitrogen oxides and particulate matter.
DIRECT EMISSIONS
We are committed to curbing our company’s greenhouse gas (GHG) emissions, and have reduced our emissions by 47 percent since 2005 – surpassing our goal to reduce 40 percent of 2005 levels by 2020. 2014 GHG emissions were 7 percent lower than the previous year. The following is an overview of our GHG emissions:
- Carbon Dioxide: The primary driver of Con Edison’s CO2 emissions is the company’s steam business. In 2014, steam deliveries were 23,017 MMlbs, up from 21,923 MMlbs in 2013. Con Edison of New York produces its steam at the company’s one steam-electric generating station and four steam-only generating stations. We saw a decrease in CO2lbs/MMBTU from 125.22 in 2013* to 121.41 in 2014.
*Reflects an adjusted 2013 figure
In an effort to reduce costs to our customers and meet regulatory requirements pertaining to air quality, the company completed gas addition projects at its 59th Street and 74th Street stations in 2013. 2014 was the first full year of natural gas capability at the stations, and in addition to reducing fuel costs to our customers, CO2 emissions were reduced by more than 150,000 tons. These projects also contributed to a 17-percent reduction in the nitrogen oxide rate for the company’s steam business.
Along with efforts to reduce our emissions at the steam plants, Con Edison of New York participates in the Regional Greenhouse Gas Initiative (RGGI) for the emissions from its East River cogeneration plant. The second RGGI compliance period was 2012 – 2014, and during this time, allowances were purchased to cover emissions generated during the compliance period. Further information on RGGI and Con Edison’s involvement can be found in our Regulatory Impact and Policy Management section.
Finally, Con Edison’s vehicle fleet contributes approximately one percent of the company’s total CO2 emissions. We continue to reduce emissions by using biodiesel fuel, as well as expanding the number of hybrid and alternative fuel vehicles in our fleet. Currently, roughly half of our vehicle fleet is running on some form of alternative fuel or high-efficiency engine.
- Methane: CH4 is a greenhouse gas with 25 times the heat-trapping potential of CO2. Fugitive methane emissions originate from Con Edison of New York and Orange and Rockland’s natural-gas distribution systems.
In 2014, Con Edison of New York replaced approximately 65 miles of leak-prone pipe against an annual target of 60 miles. This achieved the main replacement performance measure required under its current gas rate agreement. Under the terms of its gas rate agreement, Con Edison of New York will be replacing 65 miles in 2015 and 70 miles in 2016. In 2014, O&R replaced over 17 miles of gas main, exceeding the goal to replace no less than 90,000 feet, and reduced active gas leaks to an all-time low.
Con Edison also replaced 32.3 miles of cast iron main in 2014 compared to a target of 30 miles required under the curent gas rate agreement. The total gas leak backlog in 2014 was 740 leaks compared to an annual Public Service Commission goal of 950. Finally, total incoming gas leaks identified in 2014 were 8,717. A total of 10,961 repairs were made resulting in the backlog of 740 leaks described above. Together, these activities resulted in an estimated reduction in methane emissions of 0.009 million metric tons of carbon dioxide equivalent (based upon greenhouse gas reporting per foot emission factors for pipe materials).
- SF6: In 1999, Con Edison entered into a memorandum of understanding with the EPA, voluntarily agreeing to reduce its emissions of sulfur hexafluoride (SF6), a colorless, odorless gas used in high-voltage circuit breakers and switches found chiefly in utility substations.
SF6 emissions from substations were estimated at 15,901 lbs. in 2014, below the 2014 goal of 16,000 lbs. This value represents an approximate 3.6-percent decrease from 2013, and a 92-percent reduction since 2005.
The company has already surpassed its goal to reduce its emissions below 25,000 lbs. of SF6 by 2020, and is on target to meet its new goal set in 2012 to reduce SF6 emissions an additional 25 percent by 2017.
INDIRECT EMISSIONS
While Con Edison is committed to reducing emissions related to our operations, we recognize that our customers’ emissions also impact the quality of the air throughout our service territory. At the regulated utilities, we are committed to helping our customers find ways that they can reduce their own carbon footprint:
- The cleanest megawatt is the megawatt that is never produced. Find out more about the energy efficiency offerings in our Customer Energy Efficiency section.
- Converting customers from oil to natural gas has made significant contributions to cleaner air throughout the city. Find out more about our conversion program in the Customer Oil-to-Gas Conversion section.
- Renewable generation installations, such as PV solar, are another way customers can reduce their emissions. Visit the Customer Distributed Generation page to find out more about how the utilities are assisting our customers to install and integrate more solar on the grid.
Additionally, the structure of the New York regulatory system means that other agencies may use money collected from our customers to implement clean technology programs. These include the following:
- New York State Energy Research and Development Authority (NYSERDA) and New York utilities are responsible for implementing the Energy Efficiency Portfolio Standard (EEPS) that supports energy efficiency, targeted demand-side management, and demand-response programs.
- NYSERDA is responsible for implementing the Renewable Portfolio Standard (RPS), entering into long-term agreements with developers and paying renewable premiums based on facilities’ energy output.
- The PSC uses the Systems Benefit Charge to support research and development efforts that serve as a feeder of new technologies to be incorporated into the state’s energy-efficiency and renewable energy programs. This program is also administered by NYSERDA.
RENEWABLE GENERATION
We recognize that in order to meet our stakeholders’ desire for cleaner energy, renewable generation must also be a part of the mix. Along with distributed generation initiatives at the regulated utilities, a focus on renewable generation in the competitive businesses is helping us to meet these expectations.
Con Edison Solutions
Con Edison promotes renewable energy development by offering renewable energy products through its Con Edison Solutions (CES) subsidiary. This product, called Green Power, consists of 100 percent renewable energy. Residential customers in the state of New York may purchase a mix of 65 percent low-impact hydropower and 35 percent wind energy, or purchase 100 percent wind energy for their full electricity requirements. For commercial customers, CES can supply between five and 100 percent of their electricity requirements with 100 percent wind energy. Con Edison Solutions also offers similar options to residential and business customers in Connecticut and to business customers in Pennsylvania, Massachusetts, New Jersey, New Hampshire, and Texas. Con Edison Solutions Wind Power is Green-e certified. Green-e is a leading national labeling program that sets consumer protection and environmental standards for environmentally superior electricity products.
In 2014, CES enrolled over 1,500 new customers into these various renewable products, for a total of over 19,000 customers and sales of more than 234,000 MWh.
In addition to its retail electric Green Power and its energy efficiency services, CES also owns renewable energy projects in Massachusetts, New York, Ohio, California, and New Jersey with an aggregate capacity of 30 MW (AC) which includes 20.4 MW operating and 9.1 MW under construction equaling an estimated annual production of 62 GWh of energy. Included in these numbers is the company’s first wind installation. Two wind turbines at a Honda Motors transmission plant in Ohio now produce approximately 10 percent of the plant’s electricity needs. This is the first major automotive manufacturing facility in the United States to obtain some of its electricity directly from wind turbines located on its property. To learn more, click here. Con Edison Solutions is accredited as an Energy Services Provider (ESP) by the National Association of Energy Service Companies (NAESCO).
Con Edison Development
Con Edison Development (CED) completed five solar projects in 2014, totaling 247 MW – bringing the total capacity of solar projects to 568 MW. These assets are located in Nevada, Nebraska, South Dakota, Texas, and California. Con Edison Development has long-term power purchase agreements in place for all these assets.
Con Edison Development embarked on its first wind project in 2014 when it partnered with Sempra U.S. Gas & Power on the 75-MW Broken Bow II project in Custer County, Nebraska. Under the sales agreement, Sempra U.S. Gas & Power and Consolidated Edison Development holding companies will each own a 50-percent interest in the wind facility. Sempra U.S. Gas & Power will continue to provide operations and maintenance services for the plant, which generates enough renewable energy to power about 30,000 Nebraska homes. To learn more, click here.
Con Edison Development also acquired another wind project in South Dakota. This 20 MW project generates enough electricity to power approximately 7,000 homes. Con Edison Development also completed three solar projects in Texas, California, and Nevada. These projects deliver a combined 190 MW, or enough electricity to power approximately 30,000 homes.
Con Edison Development continues to identify opportunities for renewable generation, and to build its renewable energy pipeline. During early development, CED works with local communities, and state and federal agencies. By addressing issues identified early in the process, CED can work with regulatory agencies and other stakeholders to resolve problems before construction begins.
REPORTING EMISSIONS
In 2008, Con Edison became a founding reporter of The Climate Registry. The Registry helps organizations calculate and report greenhouse gas emissions, and has developed standardized reporting and third-party verification protocols for creating an inventory of emissions. Con Edison has voluntarily submitted to third-party verification of its greenhouse gas emissions under the registry’s reporting protocols for five consecutive years. The most recent verification of emissions, occurring in 2013, was again verified under the registry’s Electric Power Sector Protocol, which requires disclosure of all direct and indirect sources at company locations. All emissions reports are available on the registry’s website, theclimateregistry.org.
The company also reports direct emissions through the U.S. EPA Greenhouse Gas Reporting system. In 2014, the company reported emissions from steam and cogeneration stations where fuel is combusted to produce steam and/or electric energy. The company also reported the emissions resulting from the combustion of natural gas delivered to its customers, methane emissions associated with the company’s natural gas delivery system, and SF6 emissions from the company’s electric substations. The company’s reported emissions are accessible through the EPA’s greenhouse gas data publication tool.
Voluntary reporting was also completed through disclosure to CDP.
Water
We strive to enhance the efficiency of our water use and seek opportunities to improve water quality. Con Edison is the second largest consumer of municipal water in New York, driven by Con Edison of New York’s steam business. In 2013, we consumed 3.6 billion gallons of municipal water, 3.5 billion of which were used to generate steam for heating and cooling customers throughout the city, and approximately 100 million of which was used for basic water and sewage services at our facilities.
Con Edison also uses water withdrawn from the Hudson and East Rivers for cooling at its steam generation plants. This water is returned directly to the river at quality levels specified in SPDES permits with limited to no impact to water quality or quantity as a result of this process. Our withdrawals of river water are reported to the New York State Department of Environmental Conservation on an annual basis as required.
We recognize that we face risks related to water. While parts of the country deal with droughts and concerns about water availability, flooding is a primary concern in the Northeast. Con Edison has made significant investments to mitigate the risk of infrastructure flooding, in preparation for increasingly severe and frequent storms like Hurricane Sandy, which brought historic tidal surges. To learn more, visit the Resiliency section of this report.
Resource Conservation
The wise and effective use of natural resources is one of Con Edison’s five key EH&S objectives. We have evolved our approach to resource conservation, moving from a focus on waste segregation to a more-encompassing focus on reducing, reusing, and recycling to minimize consumption. This applies to our use of materials as well as our use of energy and water.
WASTE
Con Edison’s goal is to manage materials at the beginning of their life cycle, to reduce waste down the line. To do that, we are shifting our employees away from a singular focus on waste segregation, to a broader understanding of resource conservation and materials management. We work to quantify how much reusable material we consume throughout the company, with a focus on the repair and refurbishment of equipment from the transformer shop, the electric and gas meter shops, and our Van Nest fabrication shop. By reconditioning and reusing equipment, we are contributing less to our waste stream, as well as avoiding costs from new purchases. When a material has reached its useful life and we must dispose of it, we first look to recycle it.
Con Edison of New York minimizes waste and reinforces waste material separation and recycling efforts across the company. A recycling manual, posters located throughout company facilities, training modules, and an internal resource conservation website, all include the various classes of waste found throughout company operations, and procedures for proper handling, collection, segregation, and disposal for each material type. Company facilities contain recycling stations for a variety of waste streams, with clear signage to sort refuse for recycling.
Orange and Rockland, too, is committed to protecting the environment and conserving natural resources. The company participates in and promotes programs that focus on resource conservation and waste minimization, and continues to explore alternative sustainable practices.
Orange and Rockland’s recycling program continues a long-standing partnership that employs workers from Rockland ARC, a local organization providing support and services to those with intellectual and developmental disabilities. Supervised ARC workers help to break down retired Orange and Rockland equipment into component parts for re-sale.
The ARC workers assigned to Orange and Rockland separate waste paper, bale used cardboard, and dismantle old cable, streetlights, reflectors, and meters. O&R then sells those parts to recyclers. The program also provides a useful work experience for ARC of Rockland’s workforce.
Since the program’s inception in 1991, Orange and Rockland and its
Rockland ARC partners have recycled more than three million pounds of paper, nearly a million pounds of cardboard, over a million pounds of steel and aluminum wire, and a half million pounds of assorted metals. Orange and Rockland estimates that this program has saved over a million cubic feet of landfill space.
ENERGY
We are always looking for ways to improve efficiencies, and we continue to see improvements in the consumption of both electric and natural gas. In 2014, Con Edison of New York used 313.8 billion BTUs of electricity and 155.8 billion BTUs of gas for the purposes of powering, lighting, heating, and cooling company facilities. This represents a 2-percent increase in electrical consumption, and a 4-percent decrease in gas consumption over 2013 totals of 307.6 and 161.9 billion BTUs, respectively.
WATER
At Con Edison, we are committed to the quality and efficiency of water use in our operations. To learn more about our water consumption in 2014, click here.
Habitat and Biodiversity
We aim to reduce our impact on natural ecosystems in order to protect habitats and biodiversity. Our Land and Vegetation Management program was developed, in part, to encourage biological diversity along our overhead transmission rights-of-way (ROW). This is achieved by three primary objectives:
- Selective management of vegetation to provide a diversified habitat as a means to enhance and maintain a diversified mix of wildlife on the ROW
- Disposal of wood waste on-site in a manner that provides cover and protection for a variety of birds, mammals, and reptiles
- Protection of site conditions and plants to encourage reproduction and spreading of desirable grasses, forbs, and shrubs
In 2013, five fine mesh screens were installed to filter fish, eggs, and larvae from the intake of the East River Generating Station. This measure, plus the installation of a dedicated fish-return system, helped to reduce the impact of the plant on the river, in compliance with governing regulations. In 2013, the screens remained, and we monitored to verify the system’s effectiveness.
The fish-return system uses a low-pressure spray wash to gently remove any aquatic organisms trapped on the new fine mesh screens, and delicately return them to the river. The system is currently undergoing tests, and we expect the results to confirm a considerable reduction in our station’s impact on East River aquatic life.
Managing our Legacy
Hazardous substances, including asbestos, polychlorinated biphenyls (PCBs) and coal tar, have historically been used or produced by Con Edison of New York and Orange and Rockland operations. Some of these sites (many of which are no longer owned by the company) still contain measurable levels of materials that are left over from historic operations. We have made substantial investments in investigating and, when necessary, remediating these sites, and we strive to do so with minimal impact to property owners and our neighbors.
We are working closely with local, state, and federal regulatory agencies to identify and address sites that may be impacted by historic operations. A substantial number of sites are addressed under voluntary cleanup programs, where we have committed to minimize adverse impacts on health and the environment. In addition, the company is working closely with the community, keeping the public informed and aware of current projects and programs, through regular meetings, signs and notices, and an informational company website. We work hard to minimize disruptions to the local community, and monitor our impacts on a real-time basis throughout our remediation projects.
The company is held financially responsible under state and federal laws for its impacts to these sites and the remediation of impacted areas. The company sets aside money for the investigation and cleanup of these sites. For more information, please see our annual 10K report.
Many of Con Edison of New York’s current remediation sites were formerly the location of manufactured gas plants (MGP), where the company made and distributed manufactured combustible gas. From the early 1800s to the mid-1900s, Con Edison, like many other utilities of its time, manufactured gas in such plants and distributed it in parts of New York City and in Westchester County. At the time, this gas provided many benefits to the community, including heating homes and businesses, and lighting the city’s streetlamps. However, it is now known that some of the byproducts of this production may be harmful to human health and the environment. Through the end of 2014, investigations were started at all 51 Con Edison of New York MGP Sites, and were completed at all or portions of 32 of those sites. Remedial investigations have been completed at all seven Orange and Rockland MGP Sites. Orange and Rockland has received the New York State Department of Environmental Conservation’s decision regarding the remedial work to be performed at six of those sites, three of which have been completed.
During 2014, Orange and Rockland spent approximately $9 million for its remediation programs, including approximately $8 million for its MGP program, and Con Edison of New York spent approximately $20 million for its remediation programs, including approximately $9 million for its MGP program.
Climate Change
Con Edison acknowledges that climate change is a critically important challenge, and we are designing our work in consideration of climate forecasts. Addressing climate change will need to involve all sectors of the economy and all sources of greenhouse gas (GHG) emissions.
In support of this Key Sustainability Aspect, we have identified seven climate change principles:
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Work with federal, state, and local governments, and other stakeholders to address climate change.
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Maintain an inventory of the company’s direct and indirect GHG emissions.
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Consider the potential impact of business decisions on GHG emissions.
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Pursue improvements in energy efficiency in our operations to reduce our GHG emissions.
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Advocate, promote, and support energy efficiency improvements among our customers.
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Support new technology development in coordination with other key industry stakeholders.
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Support development of renewable sources of energy and other generation that reduces emissions, including GHGs.
There are two approaches to handling climate change – adaptation and mitigation. To learn more about our mitigation efforts, visit the Air Quality section of this report. To learn more about our efforts in adaptation, see the Resiliency section of this report.
Safety
At Con Edison, Zero Harm is our commitment to realizing injury-free work performance and getting the job done without harm to the public, our contractors, or our employees. We coordinate a robust safety program, communicate with our employees every day about the importance of identifying and mitigating hazards, and work to empower employees to take ownership of their own safety and that of their teammates. We also rely on our employees to identify ways that we can improve safety. These combined efforts resulted in another great year of safety performance, with Con Edison of New York achieving an OSHA rate of 1.31, and Orange and Rockland reducing their rate to 1.26. Also of note, Con Edison of New York saw a 50-percent reduction in the occurrence of high severity injuries. More about our efforts to keep the public and the contractors safe are discussed in this report’s Contractor and Public Safety sections.
Public
Con Edison is committed to public safety, and we incorporate safety considerations into our system planning, design work, and system operations. We conduct formal periodic inspections, testing, and maintenance of our electric, gas, and steam transmission and distribution infrastructure to ensure that system elements will continue to provide safe and reliable service. Our work in the street meets extensive requirements for work-area protection to keep our employees and the public safe from potential hazards. Our safety teams and committees meet regularly to identify and share best practices to quickly mitigate street-work hazards.
Con Edison of New York regularly communicates safety information to customers in the quarterly Customer News bill insert. Orange and Rockland customers receive an insert titled @home four times per year. Both publications include energy safety information, seasonal safety tips, severe weather safety advice, and reminders about staying safe around downed power lines. Both companies also send separate bill inserts throughout the year regarding energy safety and gas safety, along with other messages like gas pipeline safety, Call 811, storm preparation tips, Smell Gas/Act Fast, and CO safety.
Orange and Rockland and Con Edison of New York both offer safety tips on their websites, including information about residential electric and gas use, carbon monoxide, and generator safety. In addition, both companies use paid advertising online and in print to remind people what to do if they think they smell gas. Con Edison and Orange and Rockland also send emails to customers with energy safety tips and storm safety information before and during severe weather to remind customers how to report outages. Press releases on this subject are also issued and posted on the website.
Contact Voltage Testing
Con Edison of New York performs ongoing extensive contact-voltage testing. Contact-voltage is the presence of electrical energy where it should not be present, such as on traffic lights, lampposts, and sidewalk grates. We use a fleet of vehicle-mounted detectors to identify locations and sources of contact voltage. These high-tech vehicles are dispatched throughout the company’s service territory year-round, and are equipped with sensors to detect as little as 1 Volt.. Handheld devices are also used for manual detection of contact voltage.
The mobile contact-voltage-detectors have a distinct advantage over the manual testing technique. Because the mobile detectors do not require direct contact with objects to identify contact voltage, we can survey large geographic areas more quickly, and repeat the scans multiple times in any given year. The manual testing program surveys structures in New York City and Westchester County once each year. In 2014, our mobile detectors completed 13 system scans. These detection programs found and eliminated 3,298 cases of contact voltage. Of these cases, 1,288, approximately 39 percent, were on non-Con Edison equipment, such as streetlights, electric signs, and other structures.
Orange and Rockland carries out comparable contact-voltage testing in its territory. Orange and Rockland tested 17,796 overhead and 613 underground distribution structures in 2014, along with 2,501 traffic signals and streetlights. In 2014, there were five contact-voltage findings in excess of 1 V identified in the O&R service territory. They were corrected, and there were no associated injuries.
Structure Inspections
Our underground system has approximately 278,000 manholes, service boxes, transformer vaults, and above ground pad-mounted structures; approximately 24,700 miles of underground ducts; and approximately 95,000 miles of underground cable including primary, secondary, and service cables. High voltage (primary) network cables operating at primary voltages supply underground distribution transformers that step the voltages down to levels that are used to power customer equipment
The Commission’s Safety Standards require utilities to inspect all electric facilities at least once every five years. In addition, the Safety Standards require that defective equipment found during inspection be repaired. In accordance with the Safety Standards, Con Edison uses severity levels to establish priority for repairs and scheduling.
In 2014 the company completed approximately 84,000 underground inspections.
Leak Mapping
Driven by our firm commitment to safety, Con Edison and Orange and Rockland have always far exceeded requirements for communicating about the safe use of natural gas. For years, we have surpassed (INDUSTRY OR REGULATORY?) guidelines to include gas safety messages in two bill inserts per year. Instead, we developed a comprehensive and integrated multi-lingual campaign aimed to educate all New Yorkers about the importance of recognizing and reporting gas leaks year-round.
We include gas safety messaging in each issue of Con Edison’s quarterly Customer News insert, as delivered to all 3.3 million Con Edison customers. Gas safety is also included in O&R’s @Home bill insert, as delivered to all 430,000 O&R customers. An annual energy safety campaign includes a gas safety message in ads that run in local newspapers, on the radio, and in the subway. We produced a gas safety video describing how to recognize and report gas leaks and the hazards of carbon monoxide.
The automated on-hold messaging provides another gas safety emphasis opportunity. A gas safety message is played for all customers who are not immediately able to reach a customer service representative at our call center. The center fields approximately 6.5 million calls per year.
Our long-term partnership with Scholastic, Inc., teaches nearly 100,000 students in grades 3 through 8 about energy safety. Customer Outreach staff distribute brochures including gas safety information at community events. Our mobile apps include information about identifying and reporting the smell of gas. An annual mailing to contractors reminds them about the importance of calling 811 before they dig.
In 2014 we continued to expand our already-robust efforts to further broaden our reach to the 10 million people who live and work in our service area. Our audience includes our customers, the general public, first responders, and elected officials, as well as contractors who perform work around gas lines. In 2015 we also established a Con Edison Gas System Update website which shares the company’s understanding of the March 12, 2014 incident in East Harlem, highlights the interactive gas leak mapping we’ve developed for the public in the past year, and informs about our enhanced gas safety website.
We recognize that we serve the most diverse population in the world, in a crowded communications market. To make the biggest impact and ensure these important safety messages are reaching all customers, we have expanded our multi-lingual offerings from just Spanish to now include four more languages widely spoken among our customer base: Chinese, Korean, Russian, and Haitian Creole.
Our updated peel-and-sniff bill insert includes a language block with all five foreign languages, and a QR code offers a quick link to gas safety information on our website where Google translations are also available. In addition, our call center can arrange for translations of any language not spoken by our operators. We are also reaching out beyond bill inserts and our traditional energy education campaign to promote gas safety messages on social media and through ethnic radio stations and many print publications’ websites.
Research shows that the majority of New Yorkers are “very” or “somewhat familiar” with the smell of natural gas. Although they are routinely informed about the urgency of reporting a gas leak immediately, there is a gap between people’s understanding that it is an emergency and their behavior when it comes to reporting it.
More research, including focus groups and phone surveys, helped us to better understand the disconnect between identifying the odor and associating it with an emergency requiring immediate action. We learned that some people, especially apartment-dwellers, don’t make the call because they assume someone else already has. We also learned that some residents following their building’s protocol opt to call their building superintendent first instead of letting us know they suspect a gas leak. Still others expressed concerns about having to identify themselves to authorities if they made a call.
Based on the insights from that research, we launched the “Smell gas. Act fast.” campaign that featured bolder graphics and a clearer call to action, as well as instructions to call 911 or Con Edison/O&R right away, raising the level of urgency. We also let the public know that calls can be made anonymously. Further research conducted by the Northeast Gas Association confirmed our findings about these barriers.
Our revamped energy education campaign focuses on gas safety messaging for the print, outdoor (subway, phone kiosks, and bus shelters), and digital media outlets. To that end, we conducted an online digital ad campaign to test headlines and select copy based on audience engagement. Insight from our market research and this digital testing led us to a new headline for one of our gas safety print ads: “You thought they reported the gas leak. They thought you did.” Since June, our energy campaign has reached a print audience of 5.3 million, a digital audience of 17.8 million, a radio audience of 300 million, and subway impressions of 1.7 billion.
Most recently, Con Edison launched the first interactive online gas leak map that provides the location of current leaks on the system along with data indicating the severity of the leaks. Updated every 24 hours, the map provides greater transparency about gas leaks and reinforces the need to report the smell of gas.
Employee
Working toward an injury-free workplace requires commitment from all levels, from the CEO to the entry-level employee. Con Edison has made gains in establishing a strong safety culture that encourages employees to internalize and apply the corporate commitment to safety every day on every job.
As a result of their personal commitment to safety, many Con Edison employees, working independently or in teams, introduce significant innovations that can be applied company-wide. These initiatives substantially reduce safety risks associated with recurring work, or common tasks. Some employee-developed technologies are so distinctive that they are awarded patents, and in certain cases, the methods and technical innovations draw interest from other utility companies nationwide. Some examples include developing a matrix of error-avoidance tools to improve job planning and work performance, engineering means for inspecting structures before entering them, rethinking efficiency opportunities in oil management, and providing equipment manufacturers with feedback and alteration requests that will led to improved performance.
PERFORMANCE
Con Edison’s commitment to safety again drove performance improvement in 2014. Our safety program and communications support all personnel as they work together toward an injury-free workplace and to improve public safety. Con Edison of New York and Orange and Rockland share lessons learned and ideas through company communications, event reporting and various safety committees.
The OSHA Incidence Rate is a federal standard for quantifying the frequency of work-related injuries and illnesses. In 2009, Con Edison of New York committed to a five-year goal of achieving an OSHA Incidence Rate of 1.50 or lower by 2014. In 2014, the company surpassed its goal by achieving a rate of 1.31.
While our OSHA Incidence Rates were at an all-time low last year, we recognize that reducing the severity of injuries is most important. Two of Con Edison of New York’s 158 injuries in 2014 were categorized as a “significant high-hazard.” Although no high severity injury is acceptable, this level marks a 50-percent reduction from prior year’s performance, and the all-time lowest number since the metric was introduced in 2008.
Orange and Rockland achieved an OSHA Incidence Rate of 1.26 in 2014, bettering its goal of 2.50 or lower. At Orange and Rockland, programs and processes are designed to heighten safety awareness while reducing occupational injuries and preventable motor vehicle collisions. In 2014, these programs and processes included the following:
- Use of the No Injury Program (Close Call) to identify and mitigate risks prior to an incident. In 2014, Orange and Rockland revised their program to enhance mitigation and reduction of risk across the company.
- Continued use of physical and occupational therapists to reduce the potential for injuries related to strains, sprains, and ergonomic stressors.
- Supporting Safety Team ad-hoc committees in evaluating accident trends and developing recommendations for reducing both occupational injuries and motor vehicle collisions.
Job Planning
Safety is critical in every step of the job, especially during planning. Con Edison incorporates safety considerations in the planning process procedurally through the environment, health, and safety review of every project the company undertakes, ensuring the review of safety issues in the early planning and design phase. An evaluation of the task hazards and safety precautions is reviewed with employees during the job briefing prior to every job and whenever the job changes. We also coach on adherence to planning and observance of safety best practices during Job Site Safety Exchanges.
A Job Safety Analysis (JSA) identifies potential hazards associated with each step of a particular job or task, recommends steps to eliminate or reduce them, and specifies controls needed to perform the job or task safely. They are designed to be used during the planning phase of projects, and can also be used for job briefings as a means of evaluating each step of the task at hand. Supervisors can use the findings of a JSA to eliminate and prevent hazards in their workplaces.
The JSA program continued to grow in 2014, with an additional 19 tasks completed using the standard JSA template that was developed for all organizations. A majority of tasks reviewed and completed focused on electrical tasks in the Overhead area of Electric Operations.
In 2015, Con Edison is encouraging collaborative efforts related to safety improvements, and JSAs are being recommended as a way to achieve that Key Performance Indicator. To achieve a Zero-Harm culture across Con Edison, we will engage all employees in building shared values that prevent harm to one another, the public, and the environment. This program element will use the JSA as a tool/reference during the creation of job briefings, and as a reference during Job Site Safety Exchanges (JSSE).
Self Assessment
Analysis of injury trends shows that a significant portion of Con Edison’s safety incidents are caused by human performance factors, or human error. Human performance evaluates how certain behaviors or actions can result in errors, and how modifying those behaviors and actions can prevent them. We seek to identify the situations when errors are most likely to be made and apply the appropriate tools to prevent them. In addition, we analyze lessons learned from past events to avoid repeating errors. Tools we use to avoid errors include:
- Training
- Effective communication
- Questioning attitude
- Procedure adherence
- Self-check/peer-check
- Job briefings
In 2014, the focus was on “self-assessment.” This is the formal or informal process of identifying one’s own opportunities for improvement by comparing present practices and results with desired practices, results, and standards. Because no one knows how things are done better than those working in the organizations, “self-assessments” can be the most effective means of identifying latent weaknesses within the organization.
With the continued use of error-avoidance tools, we have seen tremendous improvement in areas such as operating errors, OSHA recordable injuries, and significant human performance incidents. Human performance initiatives have positively influenced our performance. Employees are much more aware of the human performance lapses that result in safety-related incidents, including motor vehicle collisions. The increase in human performance awareness coupled with the use of error-prevention tools has raised employees’ focus of “being in the moment,” and resulted in increased situational awareness and reductions in errors, injuries, and incidents in general.
In 2014, we developed the human performance awareness e-learning module. This was used as awareness training for all Central Operations’ employees, and as an introduction for new employees. Going forward, it is the intention that all organizations within the company will develop a similar approach, which will help strengthen our goal of becoming an injury-free company.
Communication
At Con Edison, open communication is critical to success and continued improvement in our safety and environmental performance. We communicate safety messages to employees through health and safety training programs, skills-training programs, and daily job briefings by supervisors and crew chiefs. We encourage employees to submit “Close Calls” – incidents that had the potential to cause injury, property damage, or environmental harm, but didn’t. Lessons learned from these events can prevent similar occurrences from happening again.
Con Edison communicates urgent safety and environmental need-to-know information such as recent incidents, or seasonal messaging to its employees through “EH&S Alerts,” which are targeted e-mails with a distinctive format that identifies them as priority communications. In 2015, we will improve our outreach to our field forces by expanding the reach of our messaging via new electronic screens at work locations.
Orange and Rockland’s Corporate Communications group continues to partner with its safety experts to reinforce important employee messages across all internal platforms. Themes ranging from slip, trip, and fall prevention to tick bite protection are covered via Orange and Rockland’s weekly newsletter, intranet, electronic messaging boards, posters, safety videos, and monthly Orange and Rockland update presentations. The (Think)(Ask)(Plan) program remains our brand for safety-related communications and was highlighted in a 2014 video series focused on worksite safety. We also communicate the importance of job briefings, signage, flagging, personal protective equipment inspection, seatbelts, wheel chocks, safety vests, and safety cones in 15-second video vignettes. These communications to employees on timely issues such as recent accidents or seasonal safety concerns supplement information distributed in “Safety Grams,” supervisor updates, and weekly and monthly reports.
Contractor
When Con Edison enters into a relationship with a service contractor (such as for excavation, construction, or system maintenance), we verify that the vendor has the financial resources and insurance to meet our needs. We then conduct a rigorous review of the vendor to validate its environment, health, and safety programs, including a review of environmental compliance violations, past safety performance, and any OSHA citations. Depending on the scope of work, we will also perform a telephone interview and ask targeted questions to ensure that the vendor can maintain compliance with applicable rules and regulations.
Contractors are expected to perform to the same level as our own workforce and must comply with Con Edison’s EH&S requirements, including the Rules We Live By and Time Out procedures. Further, Con Edison includes contractor injury incidence as a component of the Safety Index, setting a performance goal equal to that for company employees.
Contractor health and safety programs and site- and task-specific environmental, health, and safety plans (eHASPs) are reviewed by company subject matter experts and EH&S personnel before the contractor begins work. We offer several resources to help contractors develop suitable eHASPs, including online training, an eHASP template and numerous guidance documents. Where a contractor has experienced recent incidents or violations on Con Edison assignments, we may require them to hire a third-party monitor to ensure that they are performing work in accordance with applicable environment, health, and safety requirements.
Con Edison’s Supply Chain department issues a quarterly Newsletter for Contractors, covering recent violations, new regulations, and best EH&S practices employed by exemplary contractors.
Contractors regularly undergo on-site inspections by trained and experienced Con Edison personnel, whose observations form the basis of semi-annual report cards. We also maintain a Contractor Oversight System, and a special Action Line is in place for employees to report contractor environmental, health, and safety violations and potentially risky behavior. A Supply Chain committee reviews contractor violations and assesses disciplinary action (e.g. replace site manager or field personnel, undergo special training, or lose eligibility for further contracts for a specified period of time).
These steps help assure that contractors work safely on company assignments, and in compliance with applicable environment, health, and safety regulations. Achieving continuing improvement in contractor OSHA Incidence Rates is a key performance measure at Con Edison of New York. In 2014, the company’s contractors collectively had an OSHA Incidence Rate of 1.01, surpassing the goal of 1.50 or lower established for the year.
Orange and Rockland requires contractors to complete and submit an environmental, health, and safety program prior to commencement of work. These documents are reviewed and accepted by O&R’s EH&S department. This department, as well as the organizations responsible for the contractors performing the work activities, conducts field audits of work sites to ensure that the contractor is in compliance with their scope of work and associated work rules. Deficiencies or infractions are documented and entered into the Contractor Oversight System and used to negotiate future contracts.
Policy Management and Regulatory Impact
Con Edison operates in a highly regulated environment and is affected by regulatory and social policy adopted at the federal, state, and municipal level. A number of significant proceedings that may impact the sustainability of electric service in New York were initiated by or received significant focus from the New York Public Service Commission (NYPSC) in 2014. These proceedings include: Reforming the Energy Vision (REV), which assesses the impact of distributed energy resources on the utility business model; the Clean Energy Fund (CEF) which will consider the future path of clean energy activities implemented by the New York State Energy Research & Development Authority (NYSERDA); the Renewable Portfolio Standard program which funds renewable energy projects in the state; and the New York Green Bank, which seeks to remove barriers to using private capital to fund clean energy projects in the state. In addition, the US Environmental Protection Agency proposed a rulemaking that would seek to limit CO2 emissions from existing electric generation plants. The NYPSC also approved a settlement for rate filings affecting Con Edison’s electric, gas, and steam services.
The company seeks to provide input on state policy management and regulatory impact as we advocate our business positions and coordinate consistent regulatory and policy communications to meet the needs of our customers and shareholders.
Reforming the Energy Vision
In April 2014 the NYPSC established the REV proceeding with the purpose of examining the electric utility regulatory and business model in the context of the potential growth of distributed electric resources and the development of new technologies. The NYPSC articulated six core policy outcomes intended to better align the role and operations of utilities to enable market- and customer-driven change:
- Customer engagement
- Distributed market animation
- System-wide efficiency
- Fuel and resource diversity
- System reliability and resiliency
- Carbon reduction
In August 2014, the NYPSC issued its Straw Proposal on “Track 1” policy issues in the REV proceeding, focusing on the operational aspects of creating energy markets at the distribution level. In the proposal, markets would operate via a Distributed System Platform, addressing distribution system planning and operations issues with inclusion of a market operations role. Other issues contemplated in Track 1 include utility ownership of distributed energy resources, sharing of customer and system information, benefit-cost analysis, demonstration projects, and clean energy programs. Significantly, the Straw Proposal included consideration of the state’s utilities taking over the role of renewable energy procurement from NYSERDA. Con Edison has expressed interest in assuming this role, provided it is allowed to directly own renewable resources because such ownership is a less expensive way to procure renewable energy compared to long term contracts between utilities and private developers.
“Track 2” of the proceeding addresses New York’s regulatory framework and explores changes that could be made to better align utility interests with policy objectives. Issues under consideration include: rate and tariff design, alternate regulatory schemes such as the U.K.’s ‘RIIO’ regulatory model, and performance-based regulation. At a November technical conference on Track 2 sponsored by NYU for the Commission’s benefit, expert speakers counseled a measured approach to regulatory changes
Commission rulemakings have been issued on narrow and well-defined REV issues. The Commission issued an order in Track 1 on February 26, 2015. The order confirms that the incumbent utilities will operate the Distributed System Platform, establishes a separate track to consider the issue of large scale renewable energy in the state, but only allows utilities to own distributed energy resources in the cases of energy storage on utility property, to facilitate programs for low and moderate income customers, as part of demonstration projects and as a backstop if the market does not respond. A straw proposal on Track 2 is expected in the second quarter of 2015.
Specific issues receiving early attention include:
Deferring utility infrastructure investments-
Targeted use of distributed resources and energy efficiency has the potential to defer utility infrastructure investments. In line with the REV vision, the NYPSC recently approved a Con Edison proposal for the Brooklyn-Queens Demand Management program (BQDM) that would defer the need to build a major substation in an area with higher-than-forecast growth. The BQDM program aims to locate 52 MW of distributed resources, thus pushing the need for a new substation from 2017 until 2024. The NYPSC also approved the company’s proposal to earn a rate of return on the costs of the project and incentives related to achieving resource acquisition targets, supplier diversity, and lower costs for customer-side solutions. The NYPSC will allow Con Edison to install and own energy storage devices on its own property when directly integrated into utility distribution services as part of the program, but will only allow ownership of distributed generation if the market does not respond to requests for these types of resources.
Demonstration Projects-
Con Edison is currently developing a portfolio of demonstration projects designed to test REV concepts. Potential projects include electric vehicle charging, grid-connected community solar, multi-tenant advanced metering coupled with energy usage analysis, and variable pricing.
Stakeholder Processes-
Two stakeholder processes were launched in January 2015. The first is focusing on the technology platform needed to animate distributed energy markets, and the second is focusing on market design elements. The state’s utilities are participating in each process.
Clean Energy Fund
New York currently has ratepayer-funded public policy programs focused on energy efficiency (Energy Efficiency Portfolio Standard program, EEPS), renewable energy (Renewable Portfolio Standard program, RPS), and energy R&D (Technology and Market Development programs, T&MD). NYSERDA implements the RPS and T&MD programs entirely, and NYSERDA and the utilities implement the EEPS program. In total, these programs collect $368 million annually from Con Edison’s and O&R’s customers via a bill surcharge. They will expire at the end of 2015 unless reauthorized by the NYPSC. In May 2014, the NYPSC proposed to consolidate these funds into a single Clean Energy Fund (CEF) and, in the process, substantially change how NYSERDA uses these funds to align with the Reforming the Energy Vision (REV) proceeding. NYSERDA issued a Clean Energy Fund proposal in September 2014, but the NYPSC has required it to issue additional information on the Clean Energy Fund, which is due on June 8, 2015. NYSERDA also proposes collecting $782 million from PSC-jurisdictional electric customers to fully capitalize the NY Green Bank at $1 billion. NYSERDA has been reaching out to utilities and stakeholders for input on its proposed plan, and has indicated it will shift its focus to upstream market development and away from incentive-based programs. Utilities may take over energy efficiency programs and renewable energy procurement from NYSERDA.
EPA Proposed Carbon Emissions Regulations
In June 2014, the EPA proposed limits on CO2 emissions from existing fossil fuel-fired generators above 73 MW under §111(d) of the Clean Air Act. The proposal seeks a 30-percent reduction in CO2 emissions from the nation’s 2005 levels by 2030. To determine achievable reductions for each state, EPA modeled a “Best System of Emissions Reduction” using four “Building Blocks”: 1) improved heat rates for coal-fired plants; 2) increased utilization of natural gas combined cycle plants; 3) generation from nuclear and renewables; and 4) energy efficiency. New York’s target is a 44-percent reduction from 2012 levels by 2030. States do not have to follow the building blocks in their compliance strategy and have considerable flexibility in implementing the rule, including regional implementation plans. EPA highlighted RGGI as an example of a regional implementation plan. On December 1, Con Edison submitted joint comments with other NY transmission owners, generators, and national and regional clean energy groups. We also participated in EEI and AGA comments. EPA scheduled the final rule for release in June 2015.
New York has few coal-fired plants and already relies heavily on natural gas generation; accordingly, increased renewable generation (including Canadian hydro) and energy efficiency could be the primary means for meeting the target. In its projection, EPA anticipates energy generated by non-hydro renewables in the state will increase by approximately five times 2012 levels, and assumes energy efficiency will reduce end-use by 11 percent by 2030 when compared to business-as-usual forecasts. The NYISO has expressed concern about the implications of these changes on reliability.
Con Edison is generally supportive of EPA’s efforts to reduce greenhouse gas emissions, while allowing for the continued reliable operation of the power grid. EPA should modify its “best system of emissions reduction” to better reflect the operational realities of the power system, ensure equity among state targets, and recognize the reductions already achieved by early-action states like New York. EPA should accept RGGI as New York’s compliance mechanism.
The rule will likely result in encouraging the development of large-scale renewable resources and expanded transmission projects within the state. NY Transco, a partnership of the state’s investor-owned transmission companies, will facilitate transmission development that can access renewable energy, and Con Edison is prepared to take on the role of procuring renewable energy for its customers.
Rate Case
At the close of 2013 parties to Con Edison’s rate cases for electric, gas, and steam agreed to a Joint Proposal (JP) resulting in a two-year electric rate plan and three-year rate plans for gas and steam effective January 1, 2014. The result was a revenue requirement freeze for electric, gas, and steam over the term of their respective rate plans.
Major components of the joint proposal include the following:
- Investment in capital projects and programs to address reliability, storm hardening and resiliency, new business and oil-to-gas conversions
- Continuation of revenue decoupling mechanisms for electric and gas
- Enhanced low-income discount programs for electric and gas customers
- Modifications and additions to the electric, gas, and steam safety and reliability performance and customer service metrics
- Additions to the leak-prone gas pipe replacement program and new reliability program to target replacement of leak-prone pipe in flood zones in New York City and Westchester County
- Improvement and expansion of the oil-to-gas conversion program
- Approval of current storm hardening projects and programs, and conditional approval of future projects that are reviewed by an ongoing stakeholder collaborative
- Consideration of non-wires alternative plan (e.g., distributed resources) for the Brownsville section of Brooklyn, expecting significant load growth
- Company study of future use of Hudson Avenue Property
- Steam customers now eligible for bill credits (in place now for electric and gas customers) in certain circumstances of a storm outage
The Joint Proposal was supported by the following signatories:
- Con Edison
- Department of Public Service Staff
- City of New York
- Consumer Power Advocates
- New York Energy Consumers Council, Inc.
- New York Power Authority
- Utility Intervention Unit (NY Department of State)
- Astoria Generating Company, L.P.
- Pace Energy and Climate Center
- Columbia Center for Climate Change Law
- Environmental Defense Fund
- NRG Energy
Subsequently, on February 21, 2014, the PSC issued an order approving the rate plans in the joint proposal with two relatively minor modifications. The full Joint Proposal and PSC Order can be found on the New York Public Service Commission Site.
Energy Highway and the Indian Point Contingency
In 2012 Governor Cuomo championed the Energy Highway Initiative promoting public-private partnerships to renew the State’s energy infrastructure while protecting the environment and creating opportunities for economic growth and job creation. Accordingly, the PSC initiated two proceedings seeking 1,000 MW of AC transmission upgrades to reduce transmission constraints from upstate to downstate, and transmission, generation, and demand side management solutions to maintain reliability in the event the nuclear power plants at Indian Point are shut down. Con Edison and the New York Power Authority (NYPA) were directed to develop an Indian Point Contingency Plan for solutions to address a possible 2016 Indian Point retirement.
In response to the Energy Highway initiative, the New York State transmission owner (NYTOs), including Con Edison and Orange and Rockland, proposed to create and jointly own a transmission company, New York Transmission Company (NY Transco) to develop, construct, and own transmission facilities in New York State. On behalf of NY Transco, the NYTOs submitted responses to the PSC proceedings. Con Edison and NYPA also submitted three Transco projects in the Indian Point proceeding. More information is available at the NY Transco website.
In November 2013, the PSC approved the three NY Transco projects proposed by Con Edison with NYPA and New York State Electric and Gas Corporation (NYSEG) to prepare for potential Indian Point shutdown in 2016. Two of the projects, Ramapo to Rock Tavern and Staten Island Unbottling, will be developed by Con Edison until they can be transferred to NY Transco. In its order, the PSC also endorsed the NY Transco cost allocation for these projects and supported the plan to file with Federal Energy Regulatory Commission (FERC) for rate recovery for the three Indian Point Projects. In a separate order in the same proceeding, the PSC approved a proposal filed by Con Edison and New York State Energy Research and Development Authority (NYSERDA) to reduce load by 100 MW by the summer of 2016 using energy efficiency and demand reduction projects, plus another 25 MW through new combined heat and power projects.
In response to the Energy Highway initiative, It was originally envisioned that New York State Transmission Owners (NYTOs) would form a public-private partnership to create and jointly own a transmission company, New York Transmission Company (NY Transco), which would develop and own transmission facilities in New York State. Legislative authority needed by NYPA and LIPA to join has not been enacted. As a result, the investor-owned NYTOs created the NY Transco in Fall 2014. The NY Transco filed with the FERC on December 4, 2014 for transmission rates, including incentives, cost allocation, and permission to assume utility assets.
- In October 2013, NY Transco filed a transmission siting application with the NYPSC to build four transmission projects totaling $1.3 billion that address congestion from upstate to downstate. The proceeding is competitive, with other developers seeking Article VII certificates to build similar upstate/downstate transmission solutions.
- In November 2013, the NYPSC approved the three NY Transco projects proposed by Con Edison, NYPA and NYSEG to prepare for potential Indian Point shutdown in 2016. In its order, the NYPSC also endorsed the NY Transco cost allocation for these projects and supported NY Transco’s plan to file with FERC for rate recovery. In a subsequent order the NYPSC endorsed a different cost allocation for projects resulting from the AC Transmission proceeding.
- Responding to a PSC request for transmission developers to revise their proposals to minimize customer impact, in January 2015 the NY Transco filed updates to its projects so that the visual impact of transmission towers will be mitigated and all transmission will be constructed on existing rights of way or utility owned property.
- More information is available at nytransco.com.
As part of the Commission’s approvals in November 2013, Con Edison was authorized to work jointly with New York State Energy Research and Development Authority (NYSERDA) to implement demand-side management and combined-heat-and-power programs, using direct financial incentives, as part of a “no regrets” solution in response to the Indian Point Contingency Plan. The company and NYSERDA now administer the Demand Management Program, targeting 125 MW of permanent, peak-coincident electric load reductions by June 2016 through energy efficiency and demand reduction projects as well as new combined-heat-and-power projects. The total investment is estimated to be $285 million (consisting of incentives and administrative costs), excluding carrying costs. The company was authorized to recover all costs from its customers on a deferred basis over a 10-year period and the company will accrue the cost to finance the deferred expenditures using its allowed pre-tax weighted cost of capital rate.
Regional Greenhouse Gas Initiative
Since 2009, Con Edison has been subject to carbon dioxide emissions regulations established by New York State as part of its participation in the Regional Greenhouse Gas Initiative (RGGI). The Initiative, a cooperative effort by nine northeastern and mid-Atlantic states (RGGI States), established a decreasing cap on carbon dioxide emissions from electricity generation that will lead to a 15-percent reduction in regional emissions between 2014 and 2020. Under RGGI, affected electric generators are required to obtain emission allowances to cover their carbon dioxide emissions, available primarily through auctions administered by participating states or a secondary market.
While Con Edison sold most of its power plants in the late 1990s, the company still owns one power plant that is subject to the RGGI cap: the East River Generating Station. Con Edison of New York met its requirement of 6.3 million allowances for the first RGGI compliance period (2009—2011) and is managing auction purchases in preparation for complying with the second compliance period (2012—2014).
In February 2013, after a comprehensive stakeholder review, the RGGI States proposed major changes to the RGGI program, including a one- time, 45-percent reduction in the regional emissions cap for 2014, and further reductions of 2.5 percent each year from 2015 to 2020. Additionally, the RGGI States implemented a new cost containment mechanism, supported by Con Edison, which will limit the impact of allowance price spikes on the supply portion of our customers’ bills. New York State adopted the new rules, and the lower, 91-million ton cap is effective as of January 1, 2014.
Under the revised RGGI emissions cap, New York will receive incremental revenues from allowance auctions, above and beyond the $728 million it has collected through the first 26 auctions. As agreed upon in the original “model rule” of the RGGI partnership, each participating state directs its own strategy to invest its auction proceeds in a manner that supports its unique policy objectives, needs, and circumstances. This policy raises redistribution concerns if states invest funds in programs outside of the electric sector. In New York, for example, more than half of the RGGI-funded investments to date were allocated to programs that either indirectly benefit electric customers, or do not benefit them at all.
Renewable Portfolio Standard
New York’s Renewable Portfolio Standard (RPS) goal is to obtain 30 percent of state electricity consumption from renewable resources by the end of 2015 (from a base of 19 percent in 2004). Currently, NYSERDA implements the RPS program for the customers of investor-owned utilities, using funding of $3 billion from electric customers. The company’s customers provide about half of the total funding. LIPA, NYPA and the voluntary green energy purchases by consumers also are expected to increase renewable energy consumption in the state.
NYSERDA administers two primary programs to provide incentives to renewable energy projects: the ‘Customer-Sited Tier’ program funds renewable energy resources (mostly solar) installed on customer property behind the customer’s meter; the ‘Main Tier’ program competitively solicits large renewable resources, offering 20 year contracts for their renewable energy attributes. 92 percent of the program’s renewable energy comes from the Main Tier.
NYSERDA has achieved about half of its portion of the 2015 goal, but in a recent review acknowledged that it was likely to fall short of achieving the 30 percent goal by the end of 2015. NYSERDA’s CEF proposal does not contain any funding for large renewable resources. DPS Staff has proposed having the utilities take over the Main Tier program and purchase both the renewable energy attributes and power from new renewable projects through long-term contracts. The state’s utilities are willing to procure renewable energy, but have advocated strongly of favor of allowing utilities to own renewable energy resources as a primary procurement method. DPS Staff will issue a large-scale renewables options paper in mid-2015.
In 2014, NYSERDA reported that the environmental benefits of electricity generated by renewable generation from 2006 through 2013, as opposed to the State’s “system-mix,” amounts to reduced emissions of approximately 5,400 tons of nitrogen oxides, 10,600 tons of sulfur dioxides, and 5.3 million tons of carbon dioxide.
NYSERDA issued one solicitation for new renewable resources in 2014, and announced in November 2014 that it would procure 164 MW of incremental renewable energy from wind and hydro resources in New York State. NYSERDA has issued one RPS solicitation in 2015 and plans to issue another RPS solicitation in 2016.
Systems Benefit Charge
The System Benefits Charge (SBC) program funds technology and market development (T&MD) activities relevant to the energy system. The PSC uses the SBC to support research and development efforts that serve as a feeder of new technologies to be incorporated into the state’s energy- efficiency and renewable energy programs. The New York State Energy Research and Development Authority implements the program under the PSC’s supervision.
When the program was reauthorized by the PSC in 2011 through 2016 it was estimated that collections from our customers will provide at least $150 million over the five-year term of the program. In 2013, $26.3 million in SBC charges were collected from the utilities’ electric customers.
The T&MD programs currently funded by the SBC are expected to continue after 2016, funded under the Clean Energy Fund collections once those are approved by the NYPSC.
New York Green Bank
On October 28, 2013, the companies and other investor-owned utilities in New York State made a joint filing to the PSC supporting the establishment of the New York Green Bank, an entity with the mission to advance the state’s clean energy goals by reducing or eliminating financing-related barriers to clean energy adoption by customers. Con Edison offered comments related to future funding for the Green Bank, such as using RGGI funds. On December 19, 2013, the PSC approved the establishment of the New York Green Bank, with an initial capitalization of $218 million, comprised of $165 million of funds from NYSERDA and utility energy efficiency and renewable energy budgets, and $45 million of RGGI funds allocated to the New York Green Bank by NYSERDA. The New York Green Bank has stated that it has a goal of reaching a capitalization of $1 billion, and in December 2014 NYSERDA submitted a petition to the NYPSC requesting $781 million in funds (to be provided over four years, 2015-2018) to achieve the Green Bank’s capitalization goal. The company filed comments supporting the overall goals of the Green Bank but expressed concern about the impact on customers and suggested a number of ways to mitigate that impact, including raising a portion of the funds from other electric customers who might not otherwise contribute to the Green Bank, such as LIPA and NYPA customers, and relying on RGGI funds to provide a portion of the requested capital.
Political Engagement
Public policy decisions at all levels of government can have significant implications for the companies’ customers, the energy systems we manage, and the future direction of the companies. Accordingly, Con Edison exercises its fundamental right and responsibility to participate in the political process. We adhere to all applicable national, state, and local laws and regulations governing the public policy process, and have internal policies and practices so that we adhere to applicable reporting requirements.
Our engagement in the political process is grounded in and guided by our commitment to our Standards of Business Conduct. Our efforts in this regard meet high ethical standards, are done in accordance with strict company procedures and guidelines, and in a manner that demonstrates accountability and transparency.
No corporate funds are used for political contributions to candidates or political parties. The companies do not make independent expenditures in support of or in opposition to a candidate or political party. No corporate payments have been made, nor do we intend to make payments, to influence the outcome of ballot measures.
Con Edison Political Action Committee
The Consolidated Edison Inc. Employees’ Political Action Committee (CEIPAC) is a non-partisan political action committee.
- The CEIPAC is funded entirely through voluntary contributions from eligible employees; employees are not reimbursed, directly or indirectly, for political donations or expenses. Contributions are reported to relevant federal, state and local campaign finance agencies, as required by law.
- Political disbursements made through the CEIPAC are made without regard to the personal or political preferences of Company officers and executives.
- The current members of the CEIPAC Executive Committee are the: Vice President & Controller of Con Edison of New York (CECONY), Senior Vice President Public Affairs of CECONY, Vice President Government Relations of CECONY, President and Chief Executive Officer of Consolidated Edison Solutions, and President and Chief Executive Officer of Orange and Rockland Utilities.
- The CEIPAC Executive Committee factors in many criteria when deciding whether to approve contributions, including a candidate’s position on issues; voting records; incumbents leadership on key committees; and the extent of a member company’s presence in a district.
- Con Edison’s internal auditing department conducts periodic reviews of CEIPAC’s practices and procedures, and an independent auditing firm audits the financial statements of the CEIPAC on a yearly basis.
Grassroots Advocacy Network
Con Edison’s Grassroots Advocacy Network engages employees and retirees in the evolving political landscape, educating them on issues important to them and the company. Through the Grassroots Network, employees and retirees receive monthly newsletters, updates on policy and political issues and information on elections and voting. The Grassroots Network also provides opportunities for employees and retirees to attend events on emerging topics of interest and engage their local elected officials by taking action on relevant issues that come up throughout the year.
Governance and Business Ethics
At Con Edison we recognize the need for strong corporate values. Through the years, one of the most important lessons we have learned is that having a strong financial foundation and operational excellence are only part of what it takes to continue a company’s success. We firmly believe that doing business in an open, ethical, and fair manner creates business success that benefits all our stakeholders — our investors, our customers, and our employees.
Governance
The Environment, Health, and Safety Committee of the Board of Directors governs Con Edison’s overall EH&S programs. Since its inception in 1995, this committee has met four times per year to review the status of Con Edison’s EH&S efforts. Typically, Con Edison’s chairman, utility presidents, general counsel, and EH&S vice president participate in these meetings.
The vice president of corporate EH&S is responsible for developing programs to ensure compliance, and to work toward EH&S excellence. In addition, corporate EH&S supports the operating departments responsible for maintaining day-to-day compliance with standards. The corporate EH&S vice president reports directly to Con Edison of New York’s president.
Throughout 2014, the EH&S vice president headed an EH&S Committee to oversee and implement the company’s strategic plan. The team consists of the Senior Vice Presidents from operating departments, the Chief Ethics and Compliance Officer, and leaders from the Law Department, Occupational Health, Human Resources, Auditing, and EH&S. This committee also develops strategic and annual goals that help drive the company’s EH&S and sustainability efforts.
The EH&S vice president and appropriate EH&S leaders meet quarterly with Con Edison’s chairman and monthly with the president of Con Edison of New York to review the status of major EH&S projects and issues.
As a part of senior management’s commitment to EH&S excellence, the following strategic independent oversight functions have been established.
Office of the Corporate Ombudsman – provides employees with an independent office to which they can confidentially refer suspected violations of Con Edison’s Code of Conduct, including EH&S requirements, or ethical and legal concerns. The ombudsman and the deputy ombudsman have the authority to either investigate these matters or refer them to appropriate authorities within the company.
Environment and Safety Review Board– consists of outside consultants who are independent attorneys. The board reports to the chairman on components of EH&S programs and the status of efforts to attain EH&S excellence.
Business Ethics
Strong business ethics are a core value of Con Edison. Through the years, one of the most important lessons we have learned is that having a strong financial foundation and operational excellence are only part of what it takes to continue a company’s success. We also recognize that our Standards of Business Conduct are an integral component of a sustainable company. Reflecting the company’s continuing commitment to ethical operations, the Business Ethics and Compliance group was significantly restructured and strengthened in 2012, and further expanded in 2013 and 2014.
Con Edison’s Standards of Business Conduct are founded upon our values of service, honesty, concern, courtesy, excellence and teamwork, and our commitment to our major stakeholders: our customers, fellow employees, communities, and shareholders. The Standards set forth the basic principles that employees must follow in their day-to-day work, which allow the company to carry out our commitments to our customers, our communities, our fellow employees, our shareholders, our business partners, and the public. We completed an update of the Standards of Business Conduct, which was released to all employees of Con Edison of New York, O&R, and the competitive energy businesses in early 2013.
Training on various ethics topics is completed annually by all employees of Con Edison of New York, O&R and the competitive energy businesses. We also conduct ethics and compliance training for new employees, new supervisors, and new managers, and administer FERC-required ethics training.
The department also increases the visibility of our ethics messages among all CEI companies through coordinated, themed communications campaigns. In 2013, Con Edison began the Values in Actions (VIA) Advisors network with 15 representatives. This network of employees, nominated by their officers, assist with the dissemination of ethics and compliance messages and act as a resource for fellow employees regarding integrity-related issues within the business units. In 2014, we expanded the VIA Advisors network to include employees from 27 company organizations and each of our major business units – providing greater representation throughout the company.
We encourage employees to seek advice, ask questions, and report concerns. We provide several resources, including a confidential Ethics Helpline, webform, and email address, for employees to contact their ethics and compliance office. Employees may also contact their supervisors or managers, or the Corporate Ombudsman, among others, to raise issues. A group of individuals within the Business Ethics and Compliance group is dedicated to investigating allegations of employee misconduct.
Department members are active members of the Ethics and Compliance Officers Association, and the FERC group of the Edison Electric Institute. A Con Edison of New York employee has served as chair of the Ethics and Compliance Officer Association’s (ECOA) Utilities Industry Group, and others have presented and participated at the ECOA’s annual conferences. BEC employees are also representatives on the company’s Enterprise Risk Management Committee, the Compliance Risk Management team, the Contractor Compliance Committee and the Contractor Oversight Steering Committee.
Just as we keep our employees knowledgeable of their ethical responsibilities, we also work to educate our vendors and contractors on the Standards of Business Conduct. Our Vendor Outreach Program, launched in 2014, provides assistance to Con Edison vendors in developing their own ethics and compliance programs.
Auditing and ISO Certification
To ensure the effectiveness of financial systems and operational performance, our auditing department provides an independent, fair, and objective appraisal of our facilities, operations, systems, and programs. These audits are performed in accordance with priorities established by the General Auditor in consultation with the CEO and the board’s audit committee. Additionally, we recognize that third-party verification of our efforts is also of value and so we have our EH&S management system ISO-14001 certified.
Auditing
Consolidated Edison, Inc. (CEI) conducts an auditing program for all affected subsidiaries and affiliates. Both facility operations and companywide programs undergo periodic audits to determine compliance with regulations and procedures, as well as the adequacy of EH&S management systems in use.
EH&S audits are conducted by a division of Con Edison of New York’s Corporate Auditing department. Under corporate audit policy, this group audits facilities and programs. The EH&S Auditing Group is staffed with personnel experienced in auditing protocols, regulatory requirements, and company procedures. The EH&S Auditing Group has developed standard protocols tailored to each area of concern that may be encountered at facilities operated by the company to ensure comprehensive and consistent audits. Formal audit reports are prepared and distributed to all officers whose organizations have responsibilities for corrective actions based on audit findings. Senior officers receive copies of audit reports. The ombudsman, independent auditors, and the Environmental Quality Review Board also receive EH&S audit reports. The board’s audit committee receives a summary of all audits performed on a quarterly basis.
Environmental, Health, and Safety Protocols |
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In addition, we have established a formal self-assessment program for company organizations to monitor their own compliance systematically. The EH&S Auditing Group administers this program by developing the self-assessment protocols, training personnel in their use, and monitoring compliance with program guidelines.
Iso Certification
The International Organization for Standardization (ISO) was created to standardize products, manufacturing processes, and management systems. Certification to the ISO Standards provides stakeholders a means of validating that Con Edison is operating effective management systems. Additionally, ISO Standards provide a framework for continual improvement throughout the company.
Con Edison of New York’s Environmental Management System is certified to the ISO 14001:2004(E), Environmental Management Systems Standard and the company’s Chemical Laboratory operations are certified to the ISO/IEC 17025:2005(E), general requirements for the competence of testing and calibration laboratories standard.
It is the policy of Con Edison to be a leader in protecting the environment and ensuring the health and safety of employees and the public. The company is committed to improving safety and environmental performance; strengthening environment, health and safety (EH&S) compliance; enhancing relationships with its stakeholders; identifying and reducing significant EH&S risk potential, and promoting wise and effective use of natural resources. In addition to complying with all applicable laws and regulations, Con Edison will:
- Pursue opportunities to improve the effectiveness and efficiency of Con Edison programs that protect people, property, and the environment.
- Be responsive to the concerns of its stakeholders, both internal and external.
- Integrate EH&S considerations into its work and project planning.
- Model sustainable behaviors internally, promote sustainable behavior externally, and maintain a commitment to the prevention of pollution.
- Pursue opportunities, programs, and policies that support sustainable business practices and the reduction of EH&S risk.
- Provide the leadership and training for employees to exercise their initiative and achieve EH&S expectations.
- Manage an integrated health and wellness promotion program that fosters a healthy, engaged, and motivated workforce.
- Promote a “predict and prevent” mindset through proactive self-assessment.
- Set metrics and targets to drive continual improvement and review them on an annual basis to measure and assess Con Edison’s EH&S performance.
- Utilize an EH&S management system to enhance its efforts.
Cost Management
As part of our promise to provide our customers with safe, reliable service, we also recognize that every dollar that we invest has an impact on their bill each month. As a responsible corporate citizen and as a competitive business, we need to invest in our system wisely, choosing which challenges to pursue, and following the most cost-effective options to overcome those challenges. Choosing the best cost-management strategies demonstrates that as a company we’re getting the best return possible on the dollars we spend.
Our excellence in cost management is achieved through communication, a collaborative approach to planning and implementation, as well as the application of ongoing and forward-looking analysis. It requires us to work each day in a more efficient and productive manner, and make a personal commitment to be accountable for the impact we have. We are also focused on cost consciousness, or the basics for productivity and cost control. We will ensure that expectations are established, communicated, and enforced, and that contracts and material costs are effectively controlled. Con Edison achieves cost-management excellence through the improvements in work volume and cost efficiencies, optimized use of overtime, reduced contractor costs, service and maintenance cost reductions, procurement of the most cost-effective energy supplies, elimination of work, and reduction in tax liabilities and other assessments.