New York State Needs a PLAN to GET OFF GAS!!!
July, 2020

To: Secretary Michelle L. Phillips
CC: Governor Andrew Cuomo, John Rhodes, NYDPS Chair, Public Service Commissioners: Tracey Edwards, Diane X. Burman, James Alesi, and John Howard.

Re: Proceeding on Motion of the Commission in Regard to Gas Planning Procedures Case Number: 20-G-0131

The undersigned organizations support the process by the NY Public Service Commission to align New York’s methane gas system planning with New York’s legally mandated climate goals via an official proceeding launched on March 19th. A growing body of evidence demonstrates the outsized atmospheric warming impact of methane gas when upstream emissions and leaks are accounted for. The continued build out of gas infrastructure by the utilities is irresponsible from both a climate and fiscal perspective and if unabated will prevent New York State from meeting its greenhouse gas reduction targets outlined in the Climate Leadership and Community Protection Act (CLCPA).

The science is clear. Methane gas is a highly potent global warming agent, and approximately 62% of the gas used in New York is delivered directly to customers by gas utilities for heating, hot water, cooking. We must reduce our reliance on fossil fuels for these needs. Heat pump technology is available to make the switch to renewable heat and hot water and induction is an efficient alternative for cooking, but most households are unaware of these options and can not yet take advantage of these technologies due to cost and policy obstacles.

New York continues to allow utilities to socialize the costs of methane gas infrastructure across all customers, making most new gas hookups free for individual customers. Meanwhile, individual households that want to switch to renewable heat must bear the upfront costs of heat pump infrastructure largely on their own. An effective transition will need resources and planning at a utility scale, which can only be made possible by repurposing the billions of dollars invested by utility customers into the gas system and moving that money into renewable heating infrastructure and environmentally beneficial electrification instead. An important first step is to require a transparent, standardized reporting of new pipeline costs involved in connecting new customers to gas by all utility companies and an honest accounting of pipeline depreciation.

We urge the Commission to work with utilities, community organizations, engineers, scientists, and the heat pump industry to develop a comprehensive plan to make an orderly, equitable, and rapid decapitalization of the utility gas system. Particular attention must be paid to affordability and accessibility for low income New Yorkers. The utilities should be explicitly disallowed from investing customer money into gas infrastructure, other than for immediate safety repairs. Instead, the utilities should be required to begin decommissioning gas distribution pipelines, prioritizing the leakiest pipes and areas with impending gas shortages first. Renewable, efficient heating, cooking, and hot water technologies must become the default options going forward. Current incentives, while helpful in encouraging early adopters, are inadequate to meet the scale of the needed transition. Only with clear direction from the Public Service Commission can we make the urgently needed transition from fossil fuels to renewable energy.
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