Consolidated Edison Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Consolidated Edison discloses a detailed governance system that seeks to keep both its direct and indirect lobbying consistent with its climate-related “Clean Energy Commitment” (CEC). The company has adopted a “Policy Regarding Evaluation of Direct and Indirect Lobbying Related to the Clean Energy Commitment,” stating that “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.” For direct advocacy, it notes that “when lobbying in our own name, the Company … first evaluates the proposal(s) to determine if it is in alignment with our operational responsibilities and corporate values,” while for trade bodies it performs an upfront and ongoing check whereby “Con Edison performs an initial review of the organization’s public statements, policy documents, membership lists, and other relevant materials to assess alignment,” then “designates specific employees to serve on committees, attend meetings, and generally monitor and engage with the association’s policy development and lobbying.” If misalignment emerges, employees “will attempt to remedy the misalignment … and, if necessary, escalate the issue … and determine next steps,” and “if new significant conflicts with an association arise that cannot be addressed to Con Edison’s satisfaction the Company may end its affiliation with the group.” The company therefore describes concrete mechanisms to influence, correct or ultimately exit associations and also uses the leverage of senior executives who “serve on the Board of Directors and other governing bodies” of EEI and AGA to “further enhance its influence over association policies to ensure they align with the Company’s values.” Oversight is clearly assigned: “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,” while “Con Edison’s Corporate Affairs department holds primary responsibility for all the company’s lobbying and other external communications.” Furthermore, the company reports that “We continuously review our lobbying activities and those of our trade associations to pursue alignment with our corporate policies and values.” However, the disclosures do not include a publicly available climate-lobbying alignment audit nor do they set out how often the Board committee reviews alignment, and the company confirms that it has “No” public commitment to conduct engagement in line with the Paris Agreement. These gaps mean that, while governance of lobbying is clearly defined and covers both direct and indirect channels with Board-level oversight, transparency on formal audit results and Paris-based criteria has not yet been provided. View Sources	B

Overall Assessment

Analysis

Score

Strong

Consolidated Edison discloses a detailed governance system that seeks to keep both its direct and indirect lobbying consistent with its climate-related “Clean Energy Commitment” (CEC). The company has adopted a “Policy Regarding Evaluation of Direct and Indirect Lobbying Related to the Clean Energy Commitment,” stating that “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.” For direct advocacy, it notes that “when lobbying in our own name, the Company … first evaluates the proposal(s) to determine if it is in alignment with our operational responsibilities and corporate values,” while for trade bodies it performs an upfront and ongoing check whereby “Con Edison performs an initial review of the organization’s public statements, policy documents, membership lists, and other relevant materials to assess alignment,” then “designates specific employees to serve on committees, attend meetings, and generally monitor and engage with the association’s policy development and lobbying.” If misalignment emerges, employees “will attempt to remedy the misalignment … and, if necessary, escalate the issue … and determine next steps,” and “if new significant conflicts with an association arise that cannot be addressed to Con Edison’s satisfaction the Company may end its affiliation with the group.” The company therefore describes concrete mechanisms to influence, correct or ultimately exit associations and also uses the leverage of senior executives who “serve on the Board of Directors and other governing bodies” of EEI and AGA to “further enhance its influence over association policies to ensure they align with the Company’s values.” Oversight is clearly assigned: “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,” while “Con Edison’s Corporate Affairs department holds primary responsibility for all the company’s lobbying and other external communications.” Furthermore, the company reports that “We continuously review our lobbying activities and those of our trade associations to pursue alignment with our corporate policies and values.” However, the disclosures do not include a publicly available climate-lobbying alignment audit nor do they set out how often the Board committee reviews alignment, and the company confirms that it has “No” public commitment to conduct engagement in line with the Paris Agreement. These gaps mean that, while governance of lobbying is clearly defined and covers both direct and indirect channels with Board-level oversight, transparency on formal audit results and Paris-based criteria has not yet been provided.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Consolidated Edison Inc. offers an extensive and detailed picture of its climate-policy lobbying. It identifies several concrete measures it is working on, including New York State’s Climate Leadership and Community Protection Act (CLCPA), New York City’s Local Law 97 and the related Public Policy Transmission Need (NYC PPTN), and federal actions such as FERC Order 2222. The company explains how it seeks to influence these measures: “Con Edison and its representatives directly and indirectly lobby policy makers at all levels of government both in our own name and via trade and other associations,” with additional detail that employees serve on trade-association committees and senior executives sit on the boards of the Edison Electric Institute and the American Gas Association, and that the Corporate Affairs department coordinates proactive and reactive lobbying strategies. It also names specific regulatory targets such as the New York State Public Service Commission and the New York Independent System Operator and provides links to the federal, state and city lobbying filings in which meetings, letters and submissions are recorded. Finally, the company is explicit about the policy changes it is seeking: it advocates “the ability to own large-scale renewable generation,” supports amendments needed to meet CLCPA timelines, and pursues policies that “expand energy efficiency, develop offshore wind, and grow the electric-vehicle sector,” while its NYC PPTN proposals aim to bring offshore-wind power into the city’s grid by 2033. By clearly naming the policies, describing the mechanisms and targets of engagement, and spelling out the desired outcomes, Con Edison demonstrates a high level of transparency around its climate-related lobbying activities.	A