In January 2026, the New York Public Service Commission cut Con Edison’s electric rate request by 87 percent.

Not trimmed. Not negotiated down. Cut by nearly nine dollars out of every ten the company asked for.

National Grid had already absorbed a 67 percent cut to its upstate electric request the previous August.

The financial press covered the numbers. The trade press covered the proceedings. Nobody asked the more uncomfortable question: what does it mean when the regulator of the most complex utility market in the country is willing to reduce a $1.6 billion infrastructure request to $234 million in a single rate case order?

It means the old playbook is broken. And the companies that figure that out first will shape the next decade of New York energy policy. The ones that don’t will spend it reacting — to a socialist mayor who has made utility bills a campaign centerpiece, a legislature that is rewriting the state’s climate law in real time, a PSC that has been remade by five new commissioners in five years, and a data center industry that wants 11 gigawatts of new load and is not interested in paying for all of it.

That is not a rate case problem. That is a five-front war.

And most utility government affairs functions in New York are not built for it.

The Five Fronts No Single Strategy Can Manage

For a generation, New York utility government affairs operated on three parallel and largely independent tracks: an Albany team managing the legislative calendar, a regulatory team managing PSC proceedings, and a community and external affairs team managing borough presidents, city councils, and host municipalities. Trade association work ran on a fourth track. The tracks did not need to talk to each other because the threats they managed did not converge.

They converge now. All five of the following forces are cresting simultaneously, in the same 12 to 24 month window, against the same capital plans, the same rate cases, and the same political relationships.

The Rate Case That Should Have Been a Warning

The January 2026 Con Edison rate order is the most under-read government affairs document produced in New York this year.

The headline number — an 87 percent cut to the first-year electric delivery request — is extraordinary enough. But the mechanism that produced it is more instructive than the result. Con Edison entered Case 25-E-0072 in January 2025 asking for an 18 percent base electric delivery increase. By April it had filed updated testimony seeking $1.6 billion. By December a 17-party joint proposal had reduced that to $234 million in year one.

Seventeen parties signed or did not oppose that joint proposal. The New York City Law Department. AMTRAK. Environmental Defense Fund. NY-GEO. Consumer advocates. Municipal governments.

The company filed an ask that the political environment could not sustain. Then it negotiated under maximum public pressure — 20,000 public comments, a White House meeting, a mayoral administration that had already told its constituents that utility affordability was a top priority. The outcome was not shaped by the regulatory record. It was shaped by the political environment that surrounded the regulatory record.

That is not a regulatory strategy. That is a regulatory accident.

National Grid Has a Different Problem and It Is Worse

If Con Edison’s problem is rate case discipline, National Grid’s problem is existential positioning.

National Grid’s New York franchise is, in regulatory terms, a gas utility wrapped around an electric utility. And the gas business is on a statutory glide path toward obsolescence.

The 2019 Brooklyn-Queens-Long Island moratorium remains the defining government affairs case study in modern New York utility history. Imposed after National Grid could not demonstrate adequate gas supply to meet demand, the moratorium was lifted a year later under a settlement that included a $36 million penalty, an independent monitor, and a $7 million customer assistance fund. The independent monitor’s March 2021 report concluded the company had not remedied the organizational weaknesses that produced the problem in the first place.

What came out of that fight was something worse than a penalty: the permanent destruction of the political case for new downstate gas infrastructure. The Williams Pipeline — which would have resolved the supply constraint — is dead. The activist coalitions that killed it are still active.

Layer on the NY HEAT Act — sponsored by Senate Finance Chair Krueger, it would repeal the utility obligation to serve gas and cap residential energy bills at 6 percent of household income — and the Customer Savings and Reliability Act, a narrower successor that passed the Assembly on June 16, 2025. National Grid is being asked to invest billions in gas infrastructure under a statutory regime the legislature is actively dismantling.

Its August 2025 upstate rate plan allowed $1 billion in gas capital expenditure. That money sits on a regulatory faultline.

The PSC Nobody Is Lobbying

Five of the seven New York PSC commissioners have joined the bench since 2021. Most utility government affairs teams have not materially adjusted their approach to the commission since the appointments began.

That is a significant oversight.

Chair Rory Christian is a former engineer who went on to lead NRDC’s New York office and chair the board of WE ACT for Environmental Justice. Commissioner Uchenna Bright spent 13 years at NRDC before joining E2 as Northeast Lead. Commissioner Denise Sheehan was the DEC Commissioner who designed the Regional Greenhouse Gas Initiative. Commissioner Radina Valova is a national authority on interconnection process design who came from the Pace Energy and Climate Center and the Interstate Renewable Energy Council. Commissioner John Maggiore is a career Cuomo policy hand who understands Albany political dynamics.

This is not a commission that is philosophically hostile to utilities. It is a commission that is structurally skeptical of cost-of-service maximalism and structurally sympathetic to environmental justice framing — because three of its seven members built careers in organizations that have been counterparties to Con Edison and National Grid in contested proceedings.

A government affairs strategy built around explaining reliability needs to the Commission is misreading the room.

A strategy built around demonstrating how the capital plan affirmatively delivers CLCPA compliance, environmental justice benefits, and large-load cost insulation for residential customers is the only credible path. Those are different arguments. They require different preparation. They require different coalition support. And they cannot be assembled in the 90 days before a rate case filing.

The Most Underpriced Political Risk in Con Edison’s Portfolio

In November 2025, President Trump sat across from then-mayoral candidate Zohran Mamdani at a White House meeting and said, publicly, that Con Edison “has to start lowering the rates.”

That sentence deserves more attention than it received.

A Democratic-socialist mayoral candidate and a Republican president found common ground on utility rate relief in the same room. Mamdani’s chief of staff had already told the Queens Daily Eagle that roughly a quarter of constituent calls to the office were about Con Edison utility bills. The Westchester Municipal Consortium was coordinating with municipal Democrats across the region. Senator Shelley Mayer’s office had covered the rate case as a political mobilization campaign.

The 2026 New York City Hall is not a customer service problem for Con Edison. It is a coordinated political adversary with a municipal franchise relationship — meaning the franchise agreement itself becomes a negotiating lever if the political pressure intensifies.

That is not hyperbole. That is the trajectory of a 2019-style moratorium situation before it becomes a moratorium.

The utility that treats City Hall as a stakeholder management problem rather than a political risk management problem will be six months behind when the risk materializes.

The Data Center Cost-Allocation Fight Is Already Half-Lost

On February 12, 2026, the PSC instituted Case 26-E-0045 — “In the Matter to Address Interconnection Reforms for Large Loads” — under Governor Hochul’s Energize NY Development initiative. Chair Christian framed it with six words that should be required reading for every utility government affairs director in New York: “data centers pay their fair share.”

The proceeding will determine three things that matter enormously for utility revenue strategy: whether large loads must commit to firm capacity through long-term contracts, whether they pay directly for system upgrades or socialize the costs across the customer base, and whether utilities can offer differentiated tariff structures.

The template already exists. Virginia’s State Corporation Commission approved a GS-5 rate class for data centers requiring 14-year contracts with 85 percent minimum demand charges, effective January 1, 2027. The NY PSC is studying it. NRDC and Sierra Club cited it in joint comments. The New York version will be adapted, not invented from scratch.

Here is the strategic problem: Con Edison and National Grid have built their entire downstate growth narrative on the promise of data center, electrification, and reindustrialization load. If large loads are tariffed off with 14-year commitments and 85 percent minimums, some of that pipeline does not sign. If they are not tariffed correctly, the residential customer base absorbs the infrastructure cost — and the political coalition that produced 20,000 public comments in a rate case will produce 200,000 in the next one.

Dominion Energy solved this problem by proposing the large-load tariff itself before the SCC mandated one. The company owned the framework, shaped the terms, and emerged from the 2025 rate case with an approved cost-allocation structure that protected the residential customer base while keeping the data center pipeline intact.

New York utilities can do the same thing. But the window to move first is closing. A DPS staff white paper is due February 12, 2027. The utility that files a proactive large-load tariff proposal before that white paper lands will have shaped the conversation. The utility that waits will be responding to staff recommendations.

What Best-in-Class Utility Government Affairs Actually Looks Like

What Other Jurisdictions Are Doing That New York Is Not

The most useful frame for understanding where New York utility government affairs is falling short is to look at what comparable jurisdictions are doing that New York is not.

Dominion Energy in Virginia prosecuted a 12-month strategic narrative campaign before its 2025 biennial rate case. Rate increase requests were paired with a publicly proposed large-load rate class and a 14-year contract framework. The company socialized the bad news — load growth costs money, data centers should pay for their share — on its own terms. The result was an SCC order that gave Dominion much of what it needed on cost allocation while protecting residential customers. Dominion did not wait for the commission to propose a framework. It proposed one and defended it.

Pacific Gas and Electric and Southern California Edison maintain dedicated local public affairs structures embedded in geographic territory teams, with explicit responsibility for community intelligence and political risk validation. External affairs is not a function that assembles a coalition when a project faces opposition. It is a function that has already built the coalition before the project is announced. The difference is 18 months of relationship capital that shows up at a critical hearing as support instead of opposition.

Georgia Power has executed explicit contractual frameworks allocating cost responsibility to large loads. As of Q3 2025, 18 of 28 committed data center projects had broken ground. The utility built the load growth pipeline by building the cost-allocation framework first, not after the legislature asked.

What New York utilities are not doing:

Owning the affordability narrative. The NYSERDA cost memo — warning that full CLCPA compliance could impose $4,100 per year on upstate gas households — became the central document of the 2026 budget debate. Liz Krueger, Pete Harckham, the Business Council, NRDC, and Governor Hochul are all defining the affordability story. Con Edison and National Grid are not.

Building environmental justice political infrastructure. WE ACT, NY Renews, and Public Power NY collectively shape every CLCPA implementation decision. Utility participation is largely transactional — project-by-project mitigation payments — rather than structural. The utilities that will fare best in the next five years are the ones that have genuine co-design relationships with EJ communities before the next round of capital projects goes into the rate case record.

Integrating federal and state risk. Trump’s offshore wind halt, IRA repeal risk, and FERC’s large-load interconnection rulemaking all directly affect NYISO and the New York utilities. There is no visible utility government affairs structure in New York dedicated to federal-state policy integration at the level of sophistication this moment requires.

What the New Playbook Actually Looks Like

The Closing Practitioner Observation on Utility Government Affairs in New York

The three-stage framework above is not complicated. None of it is novel. Dominion figured out pieces of it. PG&E figured out other pieces. Georgia Power figured out the rest.

The complicated part in New York is organizational. A function that has been built around separate Albany, PSC, and community tracks does not naturally produce integrated responses to integrated threats. The incentive structure rewards managing your lane. The five-front environment punishes it.

The most underappreciated regulatory risk facing New York utilities in the next 18 months is not any single proceeding. It is the convergence: the Energize NY Development proceeding cresting in early 2027, the CLCPA amendment fight running through consecutive budget cycles, the Mamdani administration building its utility affordability agenda, and the next rate case filing already under preparation — all hitting simultaneously, all requiring coordinated responses, all making demands on the same relationships and the same political capital.

The utility government affairs function that is still organized for 2015 will not survive 2027 intact.

The one that restructures now — around the five fronts, around the commission as it actually is, around a political environment that includes both Mamdani and Trump as actors — has a real chance to shape the decade.

That is not a guarantee. But it is the only available path to something better than reacting.