As New York regulators consider a proposal from Consolidated Edison Co. of New York Inc. to spend $1 billion over four years to better protect utility infrastructure from storms, some say the company should do more work to make sure that infrastructure can withstand threats posed by climate change.

The Consolidated Edison Inc. subsidiary in January asked the state Public Service Commission to sign off on the plan that involves new electric, gas and steam delivery rates for 2014. The proposal followed the company's experience with Hurricane Sandy, which hit the area with 90-mph wind gusts and a 14-foot storm surge, causing significant damage to Con Edison's equipment and a multiday power outage to customers in New York City and Westchester County, N.Y.

Con Edison proposed strategic undergrounding and flood protection projects, including building flood walls for certain electric and steam equipment, raising critical equipment, upgrading gas system equipment and accelerating installation of submersible equipment.

The company framed the proposal as one that will strengthen critical infrastructure and reduce the impact of future major storms. But representatives from New York City, the state Attorney General's Office and some Con Edison employees on May 31 said Con Edison needs to better plan for climate change.

While New York City supports parts of the proposal, Con Edison did not go far enough or relied partly on outdated information for other aspects, representatives for the city said.

"In many cases, the company's proposed projects are not supported by any publicly available studies or analyses, and it is unclear whether the projects constitute the most appropriate and most cost-effective alternatives," the three-member New York City Policy Panel said in testimony.

In general, the panel recommended that the commission put more emphasis on resiliency of utility infrastructure in New York City. That includes a "holistic shift" in utility design, planning, construction and operations to reflect changing factors that affect the company's ability to provide safe and adequate service.

"Con Edison must factor in potential changes in the frequency, intensity, and duration of major storms and heat waves and other similar events that can have catastrophic impacts on its ability to continuously provide utility services," the panel said.

The panel said Con Edison must expand the way in which it plans and designs its equipment to consider the potential loss of entire substations and other facilities, rather than the loss of one or two feeders or other components. For example, the company's proposal seems to design storm barriers to the highest of three levels: flooding experienced during Sandy; the 2010 sea, lake and overland surges from hurricanes, or SLOSH, model data; or Federal Emergency Management Agency flood insurance rate maps data from 2007.

"This proposal is inadequate and must be revised by the PSC," the panel said.

Claim: Climate-related risks not properly identified

Picking up a similar argument, Klaus Jacob, a geophysical consultant testifying on behalf of the New York State Office of the Attorney General, said in developing its proposed storm hardening plan, Con Edison did not properly identify climate-related risks to its system.

Jacob said the company did not consider recent data and reports about rising sea levels and their potential to increase coastal flooding and did not provide a cost-benefit analysis of its storm hardening proposals.

In a report included with his testimony, Jacob said although Con Edison's list of hardening proposals is extensive, the design basis for the proposals does not appear to take into consideration increased coastal flooding risk from rising sea levels. Relying on the observed flood levels during Sandy, together with FEMA and SLOSH maps, for establishing flood design standards is a risk, he said.

"Using Sandy flood levels as a benchmark for system enhancements reflects a deterministic approach which relies exclusively on past experience," he said. "However, if anything, Sandy has shown that history is a poor predictor of the future."

Aside from rising sea levels, climate change is expected to bring weather extremes like higher temperatures, which overburden parts of the Con Edison system as demand for power increases during heat waves, he said.

Jacob said the commission should require Con Edison to develop and use a risk management strategy that sufficiently takes into account current and forecast climate change impacts for the New York City metropolitan area, including increased coastal flooding due to rising sea levels.

Radley Horton, an associate research scientist at the Center for Climate Systems Research testifying on behalf of the Center for Climate Change Law at Columbia University, encouraged Con Edison to work with scientists to learn more about scenario predictions and then evaluate its current and projected vulnerability to higher temperatures and extreme weather.

"Long-term infrastructure investments should be guided by an understanding of climate factors that the infrastructure will have to operate in," Horton said.

Union wants more 'human infrastructure'

Con Edison's unionized workers said an important element is missing from the plan: "human infrastructure." The Utility Workers Union of America, Local 1-2, said the most important storm hardening proposal Con Edison could put in place would be to hire more in-house staff.

The union, which represents nearly 8,000 field and operations employees of Con Edison, said the company is understaffed and unable to keep up with operations and maintenance or to adequately address emergency situations.

"With sufficient staff, the company can operate and maintain its existing physical infrastructure properly, and thus keep the system in a state of readiness when emergencies arise," the union said in its testimony. "Likewise, with sufficient staff, the company will be more able to restore service in a timely manner after a storm hits."

In its testimony, the union reiterated arguments about the state of the system prior to Sandy, saying the system was weakened because of a lockout months before the storm and that mutual aid workers, inexperienced with a system like Con Edison's, complicated restoration efforts.

The union offered several conditions it said ought to be put in place if the commission approves the rate increase. They include starting a generic proceeding to establish minimum in-house employee levels for Con Edison's electric, gas and steam utilities. Whether the rate request is granted, the union asked that the commission formally ask Gov. Andrew Cuomo to designate utility workers as first responders during power emergencies.

Con Edison gave notice on May 31 that an initial meeting to discuss possible settlement is scheduled for June 10. (Case Nos. 13-E-0030, 13-G-0031, 13-S-0032)