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Policy Regarding Evaluation of Direct and Indirect Lobbying Related to the Clean Energy Commitment

Con Edison Lobbying

Consolidated Edison, Inc. (“Con Edison,” “the Company”) and its representatives directly and indirectly lobby policy makers at all levels of government both in our own name and via trade and other associations.

When lobbying in our own name, the Company typically evaluates how and on what issues to lobby on, based on its operational responsibilities and corporate values. Con Edison’s primary operational responsibility is to ensure the safe and reliable delivery of electricity, gas, and steam service to its customers throughout its service territory.

The Con Edison Clean Energy Commitment (CEC) serves as the primary guidance document for Con Edison’s corporate values pertaining to clean energy, sustainability, and climate change. Through the CEC, Con Edison has committed itself to taking a leadership role in the delivery of a clean energy future for our customers by building, investing, and operating reliable, resilient, and innovative energy infrastructure, while advancing electrification of heating and transportation, and aggressively transitioning away from fossil fuels to a net-zero economy by 2050.

The CEC has been institutionalized within Con Edison and serves as a primary filter and an anchor for the Company’s overall values, priorities, public messaging, and lobbying. Con Edison’s Corporate Affairs Department holds primary responsibility for all the Company’s lobbying and other external communications. Preparation and review of any Company policy positions, messaging, or other communications are carefully considered and reviewed to ensure compliance with and/or furtherance of the CEC.

Issues on which Con Edison lobbies can be divided into two primary groups: reactive and proactive.

Reactive issues are those that arise separately from, or external to, Con Edison requests. These issues are often advanced by policymakers and advocacy groups without consultation with Con Edison. When confronted with a reactive policy issue, the Company first evaluates the proposal(s) to determine if it is in alignment with our operational responsibilities and corporate values. If the proposed policies restrict Con Edison’s ability to fulfil its responsibilities or conflict with its corporate values, the Company will develop an engagement plan to lobby policymakers, often communicating our concerns directly to those individuals and endeavoring to either find alternative solutions or prevent the policy from taking effect.

Proactive issues, however, are those that arise at the behest of Con Edison based on our corporate priorities and present needs. Such proactive policy changes are typically sought to support the Company’s ability to fulfil its operational responsibilities and/or advance its corporate values. Regarding proactive issues, Con Edison first identifies the enterprise need for potential policy changes, then we evaluate the alignment of the issue against advancing the Company’s responsibilities and values, and finally, we evaluate the feasibility of achieving the proposed change. If, based on this evaluation criteria and relevant political analysis, Con Edison decides to pursue the policy change, the Company will develop a lobbying and engagement strategy to pursue enactment of the subject policy change.

Trade Association Lobbying

Con Edison and its subsidiaries are members of numerous trade and other associations, and some of these associations lobby indirectly on the company’s behalf. Con Edison approaches lobbying conducted by its member associations differently than lobbying done in its own name.

As a threshold matter, it should be noted that as a matter of policy, Con Edison does not engage in grassroots lobbying nor do we engage in independent expenditures.

Generally, Con Edison pursues membership in these trade and business organizations to:

  • access additional operational resources and expertise, and/or;
  • leverage the power of collective action to lobby for policies that advance the Company’s corporate values and/or operational responsibilities.

When considering joining a new association or business group, Con Edison performs an initial review of the organization’s public statements, policy documents, membership lists, and other relevant materials to assess alignment with the Company’s operational responsibilities and/or corporate values. The Company then communicates directly with association staff with any questions or to gather additional information as needed. If alignment—or substantial alignment—is found the Company will decide whether to join the organization in question.

If, during the above review, conflicts, or potential conflicts, with the trade association in question are identified, the Company will evaluate the degree to which Con Edison can separate itself from these conflicting positions of the association. If the conflicts are substantial, such that the association’s lobbying or other activities would significantly undermine the Company’s operational responsibilities or corporate values, Con Edison will not join the group.

More minor conflicts with prospective trade associations can typically be addressed via direct discussions with the association staff and the establishment of procedures to allow Con Edison to be distinguished from the larger group’s positions when necessary. The most common of these procedures are Con Edison issuing its own statements or comments separate from the association and/or explicitly indicating Con Edison’s difference of position when necessary.

After joining an association, Con Edison typically designates specific employees to serve on committees, attend meetings, and generally monitor and engage with the association’s policy development and lobbying. Through this engagement the Company can ensure its perspectives are fully represented, help shape the association’s policies when necessary, and ensure proper actions are taken to address any potential conflicts. If new significant conflicts with an association arise that cannot be addressed to Con Edison’s satisfaction the Company may end its affiliation with the group, once all the appropriate factors are weighed.

Regarding certain trade associations in which Con Edison is a leading member, such as the Edison Electric Institute (EEI) and the American Gas Association (AGA), senior Con Edison executives serve on the Board of Directors and other governing bodies of the organizations. In addition to the trade association evaluation discussed above, Con Edison also utilizes its executives’ engagement in the associations’ leadership to further enhance its influence over association policies to ensure they align with the Company’s values, priorities, and responsibilities. These trade associations are aware of Con Edison’s CEC and we seek alignment with the CEC and an associations' positions when required. There may be times, when consensus cannot be reached on issues concerning Con Edison’s corporate values, where the company will ask a trade association to include a footnote in an official comment that states Con Edison’s opposition to or disagreement with the overall association position being outlined.

It should also be noted that Con Edison is a leading member of the Energy Coalition of New York (ECNY), a New York State–based trade association consisting of the State’s investor-owned utilities. Because ECNY is a New York State–specific trade association the operating rules of the organization allow for Con Edison, along with the other individual members, to maintain a veto over any public statement or advocacy positions that ECNY takes. Con Edison takes an active role in ECNY to forge consensus on issues, but we do use our veto when consensus cannot be reached.