Submissions

Daniel

My remarks attached were for the most part initially filed with the Commission on May 12 before the pause in the consideration of the full municipalization of Long Island Power Authority. I have updated the text. Since then, the case for approving read more the municipalization policy is even stronger given the evidence about the savings that could take place. Also, it is clearer the important role a coordinated and accountable LIPA would have in managing the transition of the electric industry to cleaner energy and to continue to strengthen the utility’s resilience in the face of the next weather disaster. For 30 plus years I was lead public power credit analyst for Moody's Investors Service including covering the rating on the Long Island Power Authority. I have evaluated the credit of US municipal electric utilities throughout North America assessing credit position, risks, and strengths and cost recovery process. My opinion from my experience is that what is gained in the full municipalization of electric service on Long Island is the significant cost savings to Long Island ratepayers due to the end of the contract with PSE&G. This change would provide a new locally appointed LIPA board, full control and focus on keeping rates as low as possible as LIPA takes on initiatives to decarbonize the fuel mix; to ensure transmission reliability and preparation for the next major storm; and to continue to be responsive to customers. PSE&G appears to have established a distraction for utility governance and better-quality service for ratepayers. Local control of electric service has been shown throughout the US to have significant value to customers.
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Laurey

I Do Not support the effort to have the government run LIPA. All government run agencies have a proven track record of flaws, restrictions, failures, abuses, and the list goes on. Americans, like our veterans can attest to my claim of incompetence read more of government run programs. Please do not proceed with this effort.
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Ryan

Kiera

My name is Kiera. I am a resident of Rockaway and a Long Island Power Authority ratepayer. I am here to say that I support the work of this Commission. The findings of the draft report only reconfirm what many have pointed out for years: Long Island read more and Rockaway ratepayers will be better off without PSEG. A fully public LIPA will lower rates and provide more transparency and accountability, with more opportunities for local input. Now we must finalize the details to get there. The Commission must introduce legislation in time to pass in the 2024 legislative session.
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Jenna

As a coastal urban peninsula, Rockaway knows all too well the need for reliable, affordable energy that comes from environment-friendly sources. Hurricane Sandy left our peninsula entirely underwater and over 100 homes burned to the ground due to read more electrical fires. But even without a superstorm, our peninsula regularly sees flooding and power outages. A new research paper, of which I am a coauthor, in-press (2023) in the scholarly journal Sustainable Cities and Society, entitled “Local power outages, heat, and community characteristics in New York City” found that across the city, the Rockaway peninsula, particularly Far Rockaway, has among the highest rates of 311-calls for power outages, including during warm days when air conditioning can be an important tool to stay safe and healthy, especially for people with chronic conditions and older adults. Rockaway and Long Island deserve a utility that can provide us with reliable and affordable energy. As discussed in a 2019 report from the Mayor’s Office “Understanding and Alleviating Energy Cost Burden in New York City” low income New Yorkers experiencing energy insecurity, defined by the State as paying no more than 6% of income on energy bills, struggle to afford their bills. This has been shown to have negative health effects, for example: anxiety, stress, extreme temperature-related health impacts. We also need to transition to energy from renewable sources rather than fossil fuels, which are contributing to climate change that will bring more frequent flooding, heatwaves, and more to our area that also impact health. As LIPA is restructured, it is clear that a public power model gives us as ratepayers an opportunity to get some accountability and for the community to be involved in decision-making. This model can also help New York meet our climate goals while at the same time making sure all New Yorkers regardless of income can have reliable and affordable energy. A fully public model provides an opportunity for LIPA’s mission to be expanded to include climate justice, energy democracy, equity, and greater participation by its customers. My name is Jenna Tipaldo, born and raised on the Rockaway peninsula, and my family in Rockaway and on Long Island are Long Island Power Authority ratepayers. I am writing as an individual and in my personal capacity. Professionally, I am a PhD student and researcher studying environmental health and climate-related health impacts. Thank you to the commission for their work thus far and for this second opportunity to provide a public comment.
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Kevin

LIPA should be dismantled and sent to the scrap heap. What we need is a privately owned utility robustly regulated by NYS DPS. ( Like LILCO was). As a stand alone entity there is NO oversight of LIPA, and it will become another MTA or NYCHA. A read more perfect example is the new time-of-day rates. Nobody wants them yet the Board cooks up this scheme and with negative public input approves them anyway. At least with the current model PSEG has to answer to the Authority when problems arise. Government fails miserably when it tries to take on an enterprise better left to private industry. Why has LIPA's debt doubled ,with nothing to show for it when the original mission was to assume the debt from Shoreham and pay it down. I believe it should have been paid off by this time. 'Public Power' (socialized power) becomes reality it will be the detriment of LI and one more step in NY's march to socialism and I will not be here to witness it.
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Fred

Submitted by Fred Harrison, Independent ratepayer advocate Notes on LIPA’s “Hybrid” Model of Operation I thought it might be helpful in your deliberations and discussions regarding the future of LIPA to have some background on the read more “hybrid” model of management which has existed since LIPA took over from LILCO. The hybrid model refers to the dual-management structure created by LIPA "outsourcing" the operation and management of the electrical transmission and distribution system. LIPA owns the transmission and distribution system but has hired Keyspan/National Grid, followed by PSEG, to run the system. No other utility in the country operates as does LIPA. The LIPA/PSEG model has had two well-documented problems. It has been very expensive ($80 million/yr.), and its dual-management structure has been problematic from the outset. The failure of this model has little to do with PSEG managers being incompetent or evil. There are no demonic forces at work. Smart, talented people work for PSEG. As has been well understood for quite some time, the hybrid model- the institutional arrangement- is the problem. In 2013, the NYS Department of Public Service concluded that "A traditional utility functions with an organizational hierarchy where decisions made at the top of the structure are communicated down the chain of command and implemented in a direct line. Communication and discussion occur across the organization and up and down the hierarchy so that decisions based on analysis, current information, and past experience are all focused on the mission of one entity. In contrast, LIPA exists as a nucleus, separated from the realities of daily operations, information, and experience by a commercial contract barrier…Fundamentally it is not possible to outsource leadership for an enterprise.” Management experts sometimes identify this as the “Principal-Agent Problem.” The Harvard Business School identifies the problem as “intractable.” What follows are excerpts from reports and studies going back to before Superstorm Sandy outlining this fundamental weakness in LIPA’s operation. LIPA in its new Operating Services Agreement (OSA) with PSEG has tried to address the ingrained contradictions of the hybrid model through elaborate metrics and performance-based compensation. This very time-consuming process of "micro-management on steroids" has not solved the predicament of a dual-management structure. The time and attention devoted to basic Call Center deficiencies is a case in point. LIPA Board members have been rightly frustrated for months. An unintended consequence of this duplicative and expensive oversight is that the LIPA staff is getting good training in the “nitty-gritty” of managing the power system. They will be well prepared for full municipalization under a much needed unified-management structure. A. In 2012, Governor A. Cuomo appointed a Commission to Investigate New York Utilities’ Response to Hurricane Sandy. The Moreland Act (1907) empowers the governor to appoint a commission to investigate agencies, bureaus, and departments of NYS. The Commission published two reports. The Interim Report was issued January, 2013. The final report was released June, 2013. THE REPORT CONCLUDED THAT THE HYBRID MODEL MAKES IT VIRTUALLY IMPOSSIBLE TO MANAGE THE POWER SYSTEM EFFECTIVELY. “The Interim Report provides sufficient evidence that LIPA’s outsourcing of most of the day-to-day management and operations of its system to National Grid simply does not work. In short, the bifurcated LIPA-National Grid structure lends itself to mismanagement, a lack of appropriate investment in infrastructure, a lack of accountability to customers and excessive rates… The Commission has reached a clear consensus that fundamental structural change in Long Island’s electric utility is necessary. The existing management contract structure is unique in the U.S. retail power supply industry and is rarely used elsewhere in the world, save as an interim approach to restoring poorly managed utility systems( my highlighting).” https://moreland.ny.gov/sites/default/files/MAC-Interim-Report1-7-2013.pdf B. Later that same year, the PSC issued its own “Comprehensive Management and Operations Audit of LIPA” (Sept. 2013) “LIPA is unlike any typical utility. Its unique organizational structure is a product of State Law, and it has had to operate its utility business, providing electric power to Long Island ratepayers, within the confines and constraints of its enabling statute. Core functions that are normally central to a utility, such as operations, maintenance, and construction work, are executed by National Grid and LIPA has minimal direct involvement in the day-to-day activities…Fundamentally it is not possible to outsource leadership for an enterprise.” https://www.lipower.org/wp-content/uploads/2018/06/DPS-2013-Management-and-Operations-Audit.pdf C. The Moreland Commission and the Public Service Commission were not the first to study these issues. There were studies in 2005, 2010 and 2011. “In May 2010, Navigant Consulting ( the management company employed by LIPA to manage National Grid) …concluded that full municipal would be the best deal for ratepayers. In August 2011, there was another review and Brattle was tasked with providing the cost data comparisons…Brattle found that privatization would immediately increase rates by 10-20% but that the rate impact of both the Servco option and full municipal options would be comparable. The Servco option was a new option to improve upon the existing public/private hybrid. It is sort of training wheels approach for LIPA to allow its employees time to develop expertise and institutional memory necessary to be able to one day run the utility outright. The conclusion of the Brattle Group was that privatizing would cost a fortune and immediate full municipalization might result in LIPA personnel not being able to manage the system. The training wheels Servco won out by default.” Ms Cynthia Kouril, who reported on the Navigant and Brattle studies, noted: “There were lots of good ideas offered, including from the unions about how to manage the workforce and how to deal with the pension issue if the utility went full municipal. In fact, the electrician’s union has an elegantly simple idea which was for LIPA to contract directly with the union and the union is a contract labor provider and the workers stay in the union pension plan.” https://shadowproof.com/2013/01/27/about-privatizing-long-island-power-authority-part-ii/ Ms Kouril is a former Special Assistant United States Attorney in the Southern District of New York under several different U.S. Attorneys; former counsel to the Inspector General for the NYC Department of Environmental Protection where she investigated threats to the NYC water supply and other environmental crimes, as well as public corruption and fraud against the government; former Examining Attorney at the NYC Department of Investigation; and, former Capital Construction Counsel at NYC Parks and Recreation D. in December 2020, following Hurricane Isaias, and after public hearings, a DPS investigation, and its own internal study, LIPA staff professionals issued an Options Analysis for the Board. What follows is an excerpt from Page 14 of that report. "The promise of LIPA’s business partnership with PSEG Long Island was scale—that operating LIPA’s assets jointly with a neighboring utility would deliver best practices and cost savings that more than made up for the PSEG profits built into the agreement. The thought was that it was worth paying a premium to a neighboring utility for outstanding management. However, divorcing control from ownership also creates problems. The agent makes business decisions on behalf of the asset owner but does not ultimately own the outcomes. ‘Nobody ever washed a rental car,’ as the saying goes.”
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Allison

My name is Allison Tipaldo, a resident of Rockaway Park, a social worker, and a Long Island Power Authority ratepayer. I am here to say that I support the work of this Commission. The findings of the draft report only reconfirm what many have read more pointed out for years: Long Island and Rockaway ratepayers will be better off without PSEG. A fully public LIPA will lower rates and provide more transparency and accountability, with more opportunities for local input. Now we must finalize the details to get there. The Commission must introduce legislation in time to pass in the 2024 legislative session. This Commission is the opportunity to reimagine, reinvent, and restructure LIPA so that it is led by those most impacted by decisions concerning our energy system: ratepayers, union workers, municipalities, community organizations, low-income households, and environmental justice communities. We must ensure that those who use, pay for, and work for the system have a say in how it runs. In order to do that, many things must happen. We need to transform the Board of Trustees to make it more accountable and diverse. This means restructuring the Board to have more expertise and to better represent ratepayers and their communities. We need to establish an accountable and representative multi-stakeholder Board of Trustees where local voices help determine the composition by appointment. Appointees need to be from the LIPA service territory. Right now all appointments to the LIPA Board are made by the governor and elected state officials with no meaningful input from local communities. The Board must be multi-stakeholder in terms of both constituencies and expertise. It should be composed of traditional members skilled in management, policy, law, science, engineering, technology, and cybersecurity. It should also consist of workers, customers, and community-based organizations, as well as experts in justice, resilience, and engagement. LIPA’s mission should be expanded to include climate justice, energy democracy, equity, and greater participation by its customers. This is necessary to change the underlying purpose of the utility, which does not currently prioritize these issues. Across the US, publicly owned utilities employ a range of mechanisms for public engagement, which we can learn from. Some such as the Sacramento Municipal Utility District (SMUD) have citizen review boards that allow ratepayers to be actively involved in giving feedback on specific policy proposals and/or rate increases. SMUD also has a business advisory board with a focus on racial justice. Seattle’s public utility has a public advisory council that advises on rates and strategic plans. Austin Energy sponsors a regional science festival to invite diverse youth to learn about the energy sector. And one of the most impressive recent examples of engagement occurred in Los Angeles where the Department of Water and Power, as a part of developing its plan to transition to renewables by 2035, did a two-year-long engagement process that had an advisory group dedicated to environmental justice. With this in mind, a new Community Board must be established to replace the existing Advisory Board so that communities are centered in decision-making for the energy system and that sustained public participation is a function of the utility. LIPA has struggled to engage the public across the many different Towns, Villages, and Cities of Long Island and in the Rockaways. This has fostered disengagement and distrust while perpetuating inequities and vulnerabilities. The Community Board should be made up of representatives from diverse sectors and backgrounds with proper geographic representation, all from the LIPA service territory, including social justice, environmental, Indigenous Nations, business, labor, local government, economic development, energy, low and fixed income, consumer, civic, and education. These representatives should include those in Disadvantaged Communities in the LIPA service territory as defined by the Climate Leadership and Community Protection Act. It should also have appropriate regional representation to account for the particular geographic scope of LIPA’s service territory. All this must be codified in statute. The Community Board must play a leading role in engaging communities across the LIPA service territory in determining rate structure, accessing energy programs, implementing renewable energy projects, providing support during outrages and other emergencies, and developing initiatives to help the utility realize its mission. It must be resourced with research support, technical assistance, and a budget to carry out its work. In order for the Community Board to be properly resourced, it must be supported by an independent Energy Observatory which would be funded by half of the current DPS-LI budget. Every self-directed public utility needs an independent partner institution to help monitor and advise the utility, engage ratepayers, conduct independent research, and support communities in their own efforts for resilience and energy justice. This is a body, independent from both the utility and the government, that would coordinate the needs of the utility with the needs of the community. Partnered with universities and community-based organizations, it would be a place to meaningfully involve communities within the LIPA service territory and has the potential to empower ratepayers, enhance social justice, and improve the quality of decision-making. A restructured LIPA must spend more of its revenues for the benefit of our communities. Rather than continue the decades-long habit of spending money on expensive management fees for private corporations, which diverts funds from public use, LIPA can double down on its commitment to invest in Long Island and the Rockaways. Instead of providing bonuses to unaccountable management and dividends to distant stockholders, LIPA should lower utility rates, especially for low-income households, seniors on fixed incomes, and small businesses; reinvest revenues to enhance resiliency; improve identification of and service to customers with special needs such as those requiring electricity for medical equipment and municipal sewage treatment plants and other services that would otherwise create environmental disasters; support community solar, thermal energy networks, and more wide ranging conservation programs; and seek out public-public partnerships that improve service delivery and community resilience. LIPA also has the right and ability to fund, build, own, and operate its own renewable energy systems via bond issuances, which should be explored as a part of the democratic buildout of public renewables. A more equitable rate structure is really vital and a restructured LIPA must do more to uphold NYs goal of tackling the energy burden on LMI customers by ensuring they don’t spend more than 6% of their monthly income on their energy bills. We should also explore the recent decision by the Los Angeles Department of Water and Power to end power shut offs for low-income customers who can’t pay. Some things should stay the same, however, unless otherwise requested by the workers. There should be no change to the jobs, salaries, or benefits for the 2,500 ServCo employees. LIPA made, and kept, the same promise when it transitioned from National Grid to PSEG Long Island management in 2014. This dedicated workforce is integral to LIPA’s success under any management structure. IBEW Local 1049 has made it clear they do not want to be a public sector union. There are a few pathways to ensuring this outcome that they will determine for themselves. We must support IBEW’s position in the transition and stand with the workers who have kept this system running. This commission was set up to steer Long Island and the Rockaways back on course to the electric utility we need. I urge this commission to stay strong on this path and incorporate the above suggestions to truly reimagine LIPA. These are the reforms needed to build a truly accountable, democratic, renewable and affordable energy system.
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Geraldine

My husband and I are residents and taxpayers of Long Island living in Sag Harbor since 1993. I am writing to say we wholeheartedly support the work of this commission. That we ratepayers of Long Island and Rockaway would be better off without PSEG read more is supported by the findings of the draft report and that a fully public LIPA will serve to lower our rates and provide us with more transparency and accountability as well as more opportunities for our local input. The task is now for us to finalize the details to get there. Time is of the essence and the Commission must introduce legislation in time to pass in the 2024 legislative session. We care about this issue because we pay too much for our electric bill. Along with so many others, we were also negatively impacted by both Superstorm Sandy and Tropical Storm Isaias. Our utility should do more to protect ratepayers, invest in resilient infrastructure, and expand renewable energy. It must also be more democratic and provide meaningful opportunities for community participation. We need to transform the Board of Trustees to make it more accountable and diverse. This means restructuring it to have more expertise and to better represent ratepayers and their communities. We need to establish an accountable and representative multi-stakeholder Board where local voices help determine the composition by appointment. A new Community Board must be established to replace the existing Advisory Board. The Community Board should be made up of representatives from diverse sectors and backgrounds with proper geographic representation, all from within the LIPA service territory. It must play a leading role in engaging communities across the service territory in determining rate structure, accessing energy programs, implementing renewable energy projects, providing support during outages and other emergencies, and developing initiatives to help the utility realize its mission. It must be resourced with research support, technical assistance, and a budget. In order for the Community Board to be properly resourced, it must be supported by an independent Energy Observatory which would be funded by half of the current DPS-LI budget. Every self-directed public utility needs an independent partner institution to help monitor and advise the utility, engage ratepayers, conduct independent research, and support communities in their own efforts for resilience and energy justice. A restructured LIPA must spend more of its revenues for the benefit of our communities. LIPA should lower utility rates, especially for low-income households, seniors on fixed incomes, and small businesses. It should reinvest revenues to enhance resiliency, like burying our lines. And it should improve identification of and service to customers with special needs. We also need a more equitable rate structure and to explore ending power shutoffs for low-income customers who can’t pay. Finally, unless requested by the workers, there must be no change to jobs, salaries, or benefits for the 2,500 ServCo employees under LIPA. IBEW Local 1049 has made it clear they do not want to be a public sector union. There are a few pathways to ensuring this outcome that they will help determine. We must support IBEW’s position in the transition and stand with the workers who have kept this system running. Thank you for your time and consideration.
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Billii

Mike

LIPA Commission Hearing: East End Meeting - Sep 20, 2023

Ronald

LIPA Commission Hearing: East End Meeting - Sep 20, 2023

Ronald

LIPA Commission Hearing: East End Meeting - Sep 20, 2023

Ron

LIPA Commission Hearing: East End Meeting - Sep 20, 2023

Jennifer

LIPA Commission Hearing: East End Meeting - Sep 20, 2023

Stacey

LIPA Commission Hearing: East End Meeting - Sep 20, 2023

DPS

LIPA Commission Hearing: The Rockaways Meeting - Sep 18, 2023

Eugene

LIPA Commission Hearing: The Rockaways Meeting - Sep 18, 2023