POST-HEARING LETTER - AARP New York Comment on Cases 22-E-0064 and 22-G-0065

Sep 19, 2026

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Post-hearing correspondence from AARP New York to New York State Public Service Commission leadership addresses a proposed rate increase for Consolidated Edison’s electric and gas service. AARP argues the Joint Proposal contains serious flaws, including an alleged failure to address under-enrollment in Con Ed’s EAP low-income discount program. The letter cites OTDA HEAP authorization and compares them with reported EAP enrollment, discusses gaps likely related to renter participation and Medicaid data-matching exclusions, and urges corrective consideration.

LanguageEnglish

CategoryLetters

FormatPDF

Pages9

Reading Time3 min

AccessFree to download

Re: POST-HEARING LETTER

Concern Over the Proposed Increase

The JP’s Failure to Address EAP Under Enrollment

HEAP Authorization vs. EAP Enrollment

Likely Reasons for Enrollment Gaps

99 Washington Ave. | Albany, NY 12210 1-866-227-7442 | Fax: (518) 434-6919 | TTY: 1-877-434-7598 [aarp.org/ny](aarp.org/ny | nyaarp@aarp.org | twitter: @aarpny)[ |](aarp.org/ny | nyaarp@aarp.org | twitter: @aarpny)[ nyaarp@aarp.org](aarp.org/ny | nyaarp@aarp.org | twitter: @aarpny)[ |](aarp.org/ny | nyaarp@aarp.org | twitter: @aarpny)[ twitter: @aarpny](aarp.org/ny | nyaarp@aarp.org | twitter: @aarpny)[ ](aarp.org/ny | nyaarp@aarp.org | twitter: @aarpny)[facebook.com/AARPNY](facebook.com/AARPNY) May 5, 2023 Hon. Michelle Phillips Secretary Hon. Ashley Moreno and Hon. James A. Costello Administrative Law Judges New York State Public Service Commission Three Empire State Plaza Albany, New York 12223 Re: POST-HEARING LETTER Case 22-E-0064-Proceeding on Motion of the Commission as to the Rates, Charges, Rules and Regulations of Consolidated Edison Company of New York, Inc. for Electric Service. Case 22-G-0065 – Proceeding on Motion of the Commission as to the Rates, Charges, Rules and Regulations of Consolidated Edison Company of New York, Inc. for Gas Service. Dear Secretary Phillips and Judges Moreno and Costello: AARP New York appreciates this opportunity to comment on evidence presented at the evidentiary hearing held on April 18, 2023. Testimony given by Department of Public Service (DPS) Staff, the City of New York (City), Consolidated Edison (Con Ed or Company), Public Utility Law Project (PULP), and AARP New York, as well as the exhibits proffered by several of those parties, not only confirm but actually strengthen the analyses and conclusions about the Joint Proposal’s (JP) serious flaws we presented in our initial and reply statements. The proposed increase is too high, and these flaws only serve to compound the harm to middle-, moderate-and low-income households that would result were the Commission to approve the JP’s recommended residential delivery and fixed charge increases: electric delivery and fixed charges totaling approximately 25 percent, gas heating delivery and fixed charges totaling 1 approximately 14 percent, and gas cooking delivery and fixed charges totaling approximately 36 percent.1 The JP IS Flawed Because It Fails To Address EAP Program Under Enrollment There is no question that Con Ed’s low-income discount programs are under enrolled, although it is not known by how much. Inasmuch as the Settling Parties recommend substantially increasing the delivery rates of residential customers, it is inexplicable that the JP is silent about reaching out to the potentially hundreds of thousands of low-income customers who are not enrolled in the Company’s EAP discount program. As presented in Exhibit 604, Office of Temporary and Disability Assistance (OTDA) data shows that, during the federal fiscal year of October 1, 2021 – September 30, 2022, 934,913 New York City households were authorized to receive Non-Emergency HEAP benefits (843,913 “Autopay”and 91,452 “Regular Non-Autopay”) and 34,873 Westchester County households were authorized to receive Non-Emergency HEAP benefits (33,186 “Autopay” and 1,687 “Regular Non-Autopay”) .2 Added together, the OTDA data indicates 970,238 households in New York City and Westchester County were authorized to receive Non-Emergency HEAP benefits during the federal fiscal year ended September 30, 2022. In contrast, Con Edison’s December 2022 Energy Affordability Policy Report indicates EAP low-income program enrollment of 470,363 (326,111 electric only; 3,632 gas-only; and 140,620 combination) .3 AARP New York appreciates that it is likely that a large portion of the 460,000 difference between the number of HEAP recipients and the number of EAP program enrollees is due to the category of “renter’s HEAP.” That is, people receive a small stipend to offset a portion of their rent if heat is included in the rent. It is equally likely, however, as PULP testified regarding its analysis of United States Census American Community Survey data, some

FAQs

What does AARP New York argue about the proposed rate increase?

AARP New York states the proposed increase is too high and that the Joint Proposal’s flaws would compound harm to middle-, moderate-, and low-income households.

What is AARP’s main criticism of the Joint Proposal (JP)?

AARP New York argues the JP is flawed because it fails to address the under-enrollment of Con Ed’s EAP low-income discount program.

How does the letter compare HEAP recipients with EAP enrollment?

It cites OTDA data showing large numbers of households authorized to receive non-emergency HEAP benefits, and contrasts this with Con Edison’s reported EAP low-income enrollment in December 2022.

Sep 19, 2026

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