RESA Seeks Additional Rate Ready Options at ConEd

July 19, 2011
Email This Story

The Retail Energy Supply Association has submitted a response to a working group report from Consolidated Edison regarding an evaluation of modifications to ConEd's rate ready billing system to permit ESCOs to use rate ready billing for dynamic and demand-based rates (09-E-0428).

RESA agreed with ConEd's summary of the working group's lack of consensus, as previously reported in Matters (see 5/3).

However, RESA sought to emphasize the need for the desired changes regarding rate ready billing capability at ConEd.

"A critical goal of the Collaborative, especially from the perspective of the ESCO community, was to enable ESCOs to provide the general customer base with hourly or real time pricing. However, in this crucial area Con Edison merely proposed to consider enabling ESCOs, 'to supply non-demand billed customers with on-peak and off-peak commodity rates for customers taking service under Rate II (voluntary time-of-day ('TOD') rates) of Service Classification Nos. 1, 2, and 7,'" RESA said.

This "limited" proposal from ConEd suffers from, "a number of material deficiencies," RESA added.

First, ConEd's proposal "entirely ignores" the concept of allowing ESCOs to bill customers on an hourly or real-time basis, and would instead limit ESCOs to offering only a single on-peak/off-peak rate without any reflection of more time sensitive pricing, RESA noted. RESA called the proposal, "inconsistent with the on-going efforts to provide a larger swath of customers with hourly pricing."

Furthermore, RESA noted that the ConEd proposal would exclude the entire body of demand-billed customers and only apply to a small subset of customers that take voluntary Time of Use service under SC 1, 2, and 7.

Finally, RESA reported that ConEd's proposal would not address the "fundamental systemic issue" that, under the rate ready model, the ESCO cannot view the customer's actual usage during the billing cycle prior to the submission of a rate. While ConEd is amendable to reducing from four days to two days the minimum period for ConEd's acceptance of the ESCO's submission of commodity prices, RESA found this scenario lacking since it still requires the ESCO to submit the commodity rate prior to receiving and reviewing the actual billing data for the period.

Additionally, RESA opposed ConEd's insistence for an "all or nothing" approach to billing system changes. ConEd does not wish to make any changes until all such changes are locked down, in order to preserve the integrity of its billing system and avoid the development of system changes that may prove to be unnecessary or in conflict with other changes being addressed. Practically, this means until there is either agreement on all rate ready issues (e.g. ESCOs agree to forego contested modifications), or until litigation of all proposed changes is extinguished, no improvements will be made.

"This in effect held simple measures like changing the due date for submission of pricing hostage to agreement on how real time pricing would be implemented," RESA said.

ConEd does not offer bill ready utility consolidated billing. ESCOs may elect to dual bill any dynamic rates.

Email This Story

HOME

Copyright 2010-11 Energy Choice Matters.  If you wish to share this story, please email or post the website link; unauthorized copying, retransmission, or republication prohibited.

 

Be Seen By Energy Professionals in Retail and Wholesale Marketing

Run Ads with Energy Choice Matters

Call Paul Ring

954-205-1738

 

 

 

 

 

Energy Choice
                            

Matters