NY-GEO 100-Foot Rule Testimony May 04 2020

The "100-foot rule" (governed by 16 NYCRR §230.2(c), (d) and (e) of the Public Service Commission's regulations) requires a gas utility to provide an applicant with a minimum length of main and service line extensions at no cost to the applicant.

This has created an unlevel playing field among heating technologies by forcing all gas ratepayers to fund free infrastructure for new gas customers. A lynchpin for gas expansion in NYS, it effectively offers an incentive for customers to choose gas instead of other options. In many cases, they would not opt to install gas if they had to pay the full cost of bringing service to their homes and businesses.

On Monday, April 27, 2020, NY-GEO filed testimony urging the Public Service Commission to require utilities to annually file uniform, complete and accurate data on the cost of complying with the 100-foot rule. In its filing, NY-GEO submitted best guess estimates showing this law costs ratepayers over $960 Million over a 5-year period to fund gas expansion. This number may well be an underestimate.

More importantly, the testimony points to the need for solid data reporting so intelligent decisions can be made about whether the 100-foot rule should remain as the State dials down fossil fueled heating to meet climate goals. The testimony contains extensive data for students of New York's gas utilities.