The Real Estate Board of New York to The Public Service Commission Regarding Con Edison’s Steam Decarbonization Study and Implementation Plan

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The Real Estate Board of New York (REBNY) is the City’s leading real estate trade association representing commercial, residential, and institutional property owners, builders, managers, investors, brokers, salespeople, and other organizations and individuals active in New York City real estate. REBNY appreciates this opportunity to submit comments to the Public Service Commission (PSC) on the Con Edison’s Steam Decarbonization Study and Implementation Plan (the Plan).

Many REBNY members own and operate buildings that are reliant on Con Edison’s district steam system to heat and, in some cases, cool their buildings, as opposed to using on-site equipment such as fuel-burning boilers. Although the district steam system is efficient, emissions from generating steam using today’s fuels would eventually mean that the buildings that use steam would be out of compliance with emissions limits such as those associated with Local Law 97. If, as a consequence of those emissions limits, buildings using steam had to switch to electricity for their heating and cooling needs, the expense to building owners and the cost of grid infrastructure upgrade needs would be enormous. Consequently, REBNY strongly supports Con Edison’s plans to decarbonize its district steam system.

That said, we do have two broad and related concerns. First, the issues covered in the decarbonization petition must be coordinated with the upcoming steam rate case. The proposal includes $332 million in capital investments. Costs of this magnitude should be included and further analyzed in the upcoming steam rate case. In addition, the technologies proposed to be piloted are at different levels of maturity. We would call for close PSC oversight of a phased implementation of these technologies, including independent engineering review, as needed, as well as annual reporting on emissions reductions and costs.