The unions point out that Con Edison's calming reassurances "are not accompanied by the affidavit of any Company or contract employee, let alone one with sufficient knowledge to verify Con Ed’s extensive factual allegations." The union submits that this assertion of unchanged service "is not credible" because later in the same document, Con Edison itself acknowledges significant services have been cut.
In addition,to service shortcomings conceded by Con Edison later on in its papers, the unions' Reply lists numerous additional gaps in operation and maintenance of the gas and electric service systems that may be compromising safety and reliability of service to customers, and the reduction in services available to customers or applicants seeking to obtain or continue service at customer service centers.
The unions emphasize that
the magnitude of the issues at stake — which include the safety and reliability of service to millions of customers — and the rapid and emergent way in which these issues arose merits special consideration to ensure that they are addressed ... and are thereafter evaluated in a Commission-conducted investigation. * * * *There should be no question as to the significance of the matters at issue in this proceeding. Determining whether ConEd is providing safe and adequate service to its customers in these unprecedented circumstances is central to this Commission’s statutory obligations.Citing risks to customers and the public when utility service is off, PULP moved to intervene in the case, urging the PSC to order reopening and immediate restoration of full walk-in service at Con Edison offices where vulnerable people in crisis situations often apply for service or seek its restoration after shutoffs. See PULP Replies to Con Edison Defense of Reducing its Walk-in Customer Services During Lockout of Unionized Employees.