Lobbying
Consolidated Edison, Inc. (“Con Edison,” “the company”) and our representatives directly and indirectly lobby policy makers at all levels of government, both in our own name and via trade and other associations. The company typically evaluates how and on what issues to lobby or engage on, based on our 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 our customers throughout our service territory.
This page includes an explanation of Con Edison’s approach to lobbying, access to the company’s public lobbying reports and regulatory comments, and information on our trade association memberships and their lobbying activities. Con Edison continuously reviews its lobbying activities and those of our trade associations to pursue alignment with the company’s corporate policies and values. The Corporate Governance and Nominating Committee of Con Edison’s Board of Directors oversees the company’s approach to political and lobbying activities and receives periodic reports with respect to the company’s political contributions, lobbying and trade association activities. The information here and on succeeding pages will be updated at least annually.
Direct Lobbying
Leading with our Values
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, the company has committed 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 infrastructures. We are also 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.
Con Edison fully supports the Paris Agreement and efforts to implement its goals. While many corporations use the Paris Agreement as the basis for their climate and clean energy principles, Con Edison centers its corporate values and clean energy goals on New York State and the New York City region as the laws and regulations in these jurisdictions have the most impact on our customers and business.
New York State climate change mitigation and clean energy targets are set and governed by the Climate Leadership and Community Protection Act (CLCPA). As such, Con Edison developed its CEC to align with the CLCPA rather than the Paris Agreement because the CLCPA targets are the most relevant and impactful to our customers and stakeholders. Successfully implementing CLCPA and achieving the goals set forth in our CEC will ensure Con Edison and New York State are doing their part to achieve Paris Agreement targets.
Direct Lobbying Categories
Con Edison’s direct lobbying activities can generally be divided into reactive and proactive categories. Reactive activities are those that are done in response to issues advanced by policymakers and/or advocacy groups without consultation with Con Edison. When confronted with a reactive policy issue, the company first evaluates the proposal(s) to determine alignment with our operational responsibilities and corporate values. If the proposed policy would restrict our ability to fulfil our responsibilities or conflicts with the company’s corporate values, we will develop an engagement plan to lobby policymakers, often communicating our concerns directly to those individuals.
Proactive lobbying activities are those that arise at the behest of Con Edison to advance our corporate and customer priorities. Such proactive policy changes are typically sought to support the company’s ability to fulfil our operational responsibilities and/or advance our corporate values. Regarding proactive issues, Con Edison first identifies the enterprise need for potential policy changes, then evaluates 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 these 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. Con Edison does not engage in grassroots lobbying nor independent expenditures.
Indirect Lobbying by Trade Associations
Con Edison and our subsidiaries are members of numerous trade associations and industry groups. Generally, Con Edison maintains membership in these organizations to 1) access additional operational resources and expertise, and/or 2) leverage the power of collective action to lobby for policies that advance the company’s corporate values and/or operational responsibilities. Some of these associations lobby or otherwise work to advance the priorities of their industries and/or respective members, including Con Edison.
In 2023, Con Edison paid membership dues in excess of $25,000 to the following industry groups and trade associations which spent a percentage of those dues on lobbying: American Gas Association (AGA), Coalition for Community Solar Access, Coalition for Renewable Natural Gas, Energy Coalition of New York (ECNY), Edison Electric Institute (EEI), New Jersey Utilities Association (NJUA), Partnership for NYC (PFNYC), and Zero Emissions Transportation Association (ZETA).
View the five-year archive of the percentage of Con Edison’s dues to these groups that went toward lobbying.
Identifying and Addressing Misalignments
While trade associations generally endeavor to lobby only on issues on which there is consensus among their members, situations do arise when an association pursues an action that does not align with Con Edison’s interests and/or values. In these circumstances Con Edison employs multiple methods to identify, assess, and address the misalignment:
Ongoing Monitoring and Engagement
Once a member of a trade association or business group, 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 continual engagement the company works to prevent misalignments from happening by ensuring Con Edison’s perspectives are fully represented and will be shaping the association’s policies as they develop.
Assessing Alignment
Con Edison assesses for alignment primarily through internal discussions with relevant technical, legal, policy, and government affairs subject matter experts (SMEs). Assessing for misalignment is generally a more qualitative than quantitative process because the company’s engagement with its trade associations often is, by its very nature, subjective and imprecise.
Each situation is different and Con Edison must retain the flexibility to assess and address each situation as it arises. Setting research priorities and technical standards, for example, is very different than litigating a new law or regulation. As such, Con Edison does not use a specific scoring metric to assess specific instances of or general alignment with its trade associations.
Escalation
If/when a misalignment is identified, the employees will attempt to remedy the misalignment at the committee level through voicing the company’s position during discussions, editing proposed language, and voting against or otherwise opposing the proposed action. If these steps do not fully address the misalignment, the employees will typically escalate the issue internally by engaging their managers, other relevant departments (e.g. Law, Government Affairs, Media Relations), and executives to discuss the matter and determine next steps.
Actions to Address Misalignment
If a misalignment is identified, Con Edison takes actions to address it. The company’s actions to address misalignments typically include, but are not limited to:
- Clearly communicating our position directly to the association staff and/or leadership.
- Insisting on edits to proposed language.
- Voting against or otherwise opposing proposed actions; and/or
- Acting independently of the association to clearly state Con Edison’s position, such as filing separate comments, including a footnote clearly stating Con Edison’s position, making a public statement, or lobbying independently on the issue.
If significant and/or repeated misalignments with an association arise that cannot be addressed to Con Edison’s satisfaction the company may choose to end its affiliation with the group, once all the appropriate factors are weighed by company leadership.
Executive Engagement
In addition to the specific actions described above, Con Edison also utilizes the company executives’ engagement in the associations’ leadership to further enhance our influence over association policies in pursuit of alignment with the company’s values, priorities, and responsibilities. Serving in executive leadership of these organizations empowers Con Edison to influence the associations’ policies and push them to align more closely with Con Edison’s values and goals than they would be without the company’s engagement.
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. These trade associations are aware of Con Edison’s CEC and that we seek alignment of their policy positions and lobbying activities with the CEC.
Con Edison is also 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.
Lobbying Reports, Regulatory Comments, and Policy Statements
Lobbying Reports
Con Edison's lobbying activities are publicly available and are reported and properly disclosed in accordance with federal, state, and local laws.
How to obtain Con Edison’s federal, state, and city lobbying reports:
Federal
U.S. Senate Lobbying Disclosure Database
For Con Edison:
- Enter “Consolidated Edison” or “Consolidated Edison Company of New York” as the Registrant.
- Click Search Reports.
For Trade Associations:
- Enter the trade association’s full name (not acronym) as the “Registrant”.
- Click “Search Reports”.
State
New York State Commission on Ethics and Lobbying in Government (CELG)
- Ensure the “Global Search” box is highlighted.
- Click the “Client” option (second from left).
- Enter “Consolidated Edison Company of New York, Inc.” as the client name.
- Select a registration year.
- Click View Results.
Note: to view specific bills and issues lobbied, click "Consolidated Edison Company of New York, Inc." and then click "Bi-Monthlies".
City
- Choose “Lobbyist” from the “Search By” menu.
- Enter “Consolidated Edison” as the “Entity Name”.
- Click “Submit”.
- Click “View Details” link on far right of the search results then scroll down to view additional information.
Regulatory Comments
Con Edison frequently files comments and other public statements with federal, state, and city agencies. Below are instructions and links to locate these documents.
Federal
- Enter the full company name (e.g. "Consolidated Edison Company of New York” or “Orange and Rockland Utilities”) into the search box.
- Click the search icon.
- Use the filter options on the left to narrow the search results by publication date, document type, agency, or others.
State
New York State Department of Public Service
- On click the “Case Related Documents” button under “Search Type”.
- Click the “Advanced Search for Commission Case Related Documents” hyperlink.
- Under “Search” select the “Documents” button.
- Click the “Add” hyperlink under “Company Name”.
- Type “Consolidated Edison” or “Orange and Rockland” in the pop-up window, then click “Search”.
- Select “Consolidated Edison Company of New York, Inc.” or “Orange and Rockland Utilities, Inc.” from the list below and click “Select”.
- Fill out the other boxes if you wish to narrow your search.
- Click “Search”.
Note: You may need to define a period of time to limit the load time of the search results
Policy Statements
Con Edison sometimes issues a public statement regarding key legislation or provides testimony at public hearings. Below are copies/links to those statements and all company press releases.