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Comments to New York PSC on Gas Planning Procedures

The New York Public Service Commission requested input on its Staff Gas System Planning Process Proposal. We submitted comments encouraging the Commission to add several minor requirements and directly address the legal tensions and ambigious policies that make planning decisions more challenging. Our comments also suggest that the Commission consider taking certain steps, which go beyond the scope of the proposal, to improve the alignment of its approach to gas with the Climate Leadership and Community Protection Act's overarching mandate.