A Central Hudson employee is listed as the author of filings that three other New York utilities submitted to state regulators in June, the Energy and Policy Institute has found. The filings were the utilities’ first attempt to map “heat islands” in their service territories – areas where the built environment traps and radiates excess heat. Under a rule adopted in March, customers in those areas get two extra days of protection from having their service cut off for nonpayment after an extreme heat event. Where the utilities draw the boundaries determines who qualifies for the additional protections.

The revelation comes at a time when several media outlets have exposed evidence of coordination among New York’s investor-owned utilities to limit strong consumer protections. 

Extreme heat is a major public health problem made worse by the climate crisis. In New York City alone, approximately 500 people die annually from heat-related causes. 

Coordinated advocacy

In response to a New York Extreme Heat Action Plan Working Group interim recommendation report filed in 2022, the Public Service Commission (PSC) commenced a proceeding in January 2025 to establish uniform standards and procedures related to extreme heat events. Fourteen months later, the PSC directed the utilities to submit “the details of the criteria for identifying heat islands, a list of potential heat islands, and details regarding the boundaries of the potential heat islands within their service territories.”

Four utilities filed on June 1: National Grid’s Niagara Mohawk; Consolidated Edison’s Orange & Rockland; Avangrid’s New York State Electric & Gas and Rochester Gas & Electric; and Central Hudson. EPI’s review of the metadata of these documents found the same author listed in each filing: Jake Reinert, a senior program manager for energy policy and regulation at Central Hudson. 

The PSC’s March order that gives additional protections to customers in heat islands also established a rule prohibiting utility disconnections for nonpayment on any day when the heat index is forecast to reach or actually reaches 90 degrees. The heat index combines air temperature and humidity to estimate how hot conditions feel. During extreme heat, the human body has difficulty cooling itself. Consumer and climate groups urged the PSC to set the disconnection threshold at a heat index of 85 degrees, which would have covered more days throughout the year and saved more lives. As these groups showed, in New York City roughly two-thirds of heat exacerbated deaths occur between 82 degrees and 95 degrees.

The adopted disconnection threshold was one that the utilities pushed for rather than the more protective standard urged by consumer and climate groups. 

Investigation opened

Shortly after the PSC decision, the New York Times revealed how the state’s utilities quietly teamed up to coordinate their advocacy for the 90 degrees threshold – the policy later adopted by the regulators. In an audio from a utility debt and collections conference, representatives from New York utilities Consolidated Edison and National Grid laid out their months-long strategy, which included sharing data, crunching numbers, and editing drafts of a proposal, crafted by a consultant, that was submitted to state utility regulators. 

Louise Yeung, New York City’s climate chief, told the Times, “No one should be put in harm’s way because they are struggling to make ends meet.”

Newsday further reported on the industry conference, where utility collections managers detailed cruel and aggressive tactics, such as a PSEG Long Island employee saying, to the audience’s laughter, “People think much better in the dark.”

In light of these media revelations, New York Governor Kathy Hochul called the comments by PSEG Long Island “completely unacceptable” and directed the PSC to investigate the utilities’ shut off practices. That investigation, which has commenced in a separate docket, is ongoing.  

“Serious concerns”

Shortly after the utilities submitted their heat island analyses on June 1, the Public Utility Law Project of New York (PULP) alerted the PSC in the proceeding that their filings contained identical language in several places. 

“The degree of similarity in language and posture across filings is concerning,” PULP’s Executive Director Laurie Wheelock wrote. “The overwhelming consistency raises serious questions about whether utilities independently analyzed and scrutinized the data and methodology they each presented.”

EPI’s metadata findings seem to support PULP’s suspicion of coordinated responses by the state’s utilities. 

In response to EPI questions, the utilities deny any wrongdoing. Spokespeople for Niagara Mohawk, Orange & Rockland, and Central Husdon said they worked together to formulate uniform criteria for identifying heat islands, as, they claim, the PSC ordered them to do, but that each utility applied the criteria for unique analyses in their respective service territories. 

“To support that statewide effort, a Central Hudson employee created and maintained an initial shared working document that served as a common template for utilities to work from as they developed their respective filings,” Central Hudson told EPI. “As a result, that employee’s information may appear in the document metadata associated with certain utility submissions. Each utility was responsible for evaluating its own service territory and submitting its own filing. The analyses, boundaries, and maps that were ultimately filed reflected each utility’s individual service territory and circumstances. The Central Hudson employee did not author or submit filings on behalf of any other utility.”

An Orange & Rockland spokesperson added: “Coordinating, particularly in instances like this, is a standard and necessary part of how the joint utilities help ensure consistent, accurate information for Staff and stakeholders.” Avangrid did not respond to a request for comment. 

PULP’s critique

PULP acknowledged in its letter to the PSC that some collaboration is to be expected among parties with similar interests. But it argued that the filings, “combined with utilities’ own recorded statements at a recent industry symposium, raise serious concerns about utility efforts to control the narrative above Staff and other stakeholders. These actions subordinate more-defensible methodologies that utilize public health data in favor of a consistent and uniform approach that will leave many New Yorkers unprotected from dangerous extreme heat … With utility filings seemingly templates of one another, that perception is flawed in this proceeding.”

Reached for comment, a PSC spokesperson told EPI: “We are reviewing PULP’s letter and the utility filings. Note that there are numerous Public Service Commission proceedings where individual utilities will identify and discuss shared issues and/or best practices and work collaboratively to submit joint filings.”

The PSC is accepting public comments on the utilities’ heat island analyses until September 8.