New York DPS Staff Support Short Delay In Mandatory Hourly Pricing Expansion At ConEd -- EnergyChoiceMatters.com

New York DPS Staff Supports Short Delay In Mandatory Hourly Pricing Expansion At ConEd

Staff Recommends Denial Of ConEd's Retail Access System Replacement Proposal, Would Direct Stakeholder Engagement

ESCOs Seek Relief From Alleged ConEd Usage, Data Errors

Staff Would Deny ConEd's Proposal To Own Renewable Generation To Benefit Low-Income Customers

May 23, 2022

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In testimony filed in Consolidated Edison's current electric and natural gas rate cases, New York Department of Public Service Staff recommended a short delay in the expansion of mandatory hourly pricing (MHP), but not the specific delay sought by ConEd

The expansion of MHP from the current 500 kW demand threshold level down to the 300 kW demand level threshold had previously been set to occur once AMI meter installation is complete. ConEd plans to finish installing AMI meters in the first quarter of 2023

ConEd has proposed to defer expanding the MHP threshold to its next filing for revenue requirement relief due to the transition to a new customer service system (CSS). The new CSS is scheduled to be implemented in May 2023, after which there is a six-month stabilization period.

Staff recommended that the expansion of MHP to 300 kW be delayed until 2024, when the CSS is "stable."

"The recommended delay provides the Company needed time to 'stabilize' the CSS, finish installing AMI meters to customers, and develop O&E [outreach] to educate customers about MHP," Staff said

There are 1,150 commercial and industrial customers with demand between 300 kW and 500 kW representing 436 MW of load in the Company’s service territory. Only 189 of these customers are full-service customers, with 70 MW of load.

Staff recommended that the PSC deny ConEd's proposed plan to replace its retail access legacy applications and backoffice systems, in favor of directing ConEd to develop a business plan that accounts for engagement and feedback from stakeholders

Con Edison proposed to replace its retail access legacy applications beginning in 2024, after the implementation of the new CSS. The Company proposes to focus on eight key areas: 1) account enrollments, de-enrollments, reinstatements, billing option selections, and supply price changes; 2) requests and responses for customer historical and monthly usage; 3) exchange of customer billing cycle usage; 4) exchange of customer profile usage; 5) processing transactions to effect changes to customer accounts required by ESCOs; 6) notifications to ESCOs of customer/account information changes; 7) management of ESCOs’ account information, including the total number of customers per entity, pending enrollment and de-enrollments, and rejected transactions; and, 8) Purchase of Receivables, referred to as POR.

Staff, "acknowledges that there may be a need for an upgraded retail access system in the future, however, [Staff] is concerned that Company has not engaged with ESCOs, DER Providers, EDI Providers, and other interested stakeholders to provide important feedback in the development of the project and the associated costs."

"We recommend the Commission deny the Company’s proposed replacement plan and direct the Company to develop a business plan that accounts for engagement and feedback from stakeholders to fully understand the needs of those impacted and identifies, among other things, cost avoidance and reductions gained from efficiencies and automation of certain areas of the Company operations," Staff said

Retail suppliers submitted testimony alleging various billing and data issues at ConEd

The Retail Energy Supply Association filed testimony alleging that its members have experienced the following issues at ConEd:

• "Usage is missing and ConEd is not estimating usage so no bill is generated. Once ConEd finally gets an actual meter read, the customer receives a bill for three to four months of usage at once."
• "When ConEd sends data to ESCOs, there are missing usage files. In some cases, ESCOs still have not received usage data from as long as two (2) years ago."
• "ConEd is reconciling missing or inaccurate usage with customers outside of the Electronic Data Interchange ('EDI') system."
• "When change orders are submitted, it takes months for ConEd to implement the changes."
• "Canceled meter reads/reduced meter volumes fall outside the New York Independent System Operator’s ('NYISO') version 3 (i.e., final bill closeout period) settlement window."
• "When customers transition between service providers, at times, ConEd sends the data to the wrong load-serving entity ('LSE') and reports that incorrect data to NYISO."
• "There is lack of transparency in Unaccounted for Electricity ('UFE') values reported by ConEd."
• "ESCOs are frequently unable to obtain interval data for extended periods of time."

RESA said that the Commission should only approve funding for ConEd to maintain and repair its 'existing' customer data systems. RESA said that the Commission should re-allocate the funding that ConEd requested for new and/or improved systems to fixing the issues with those existing systems.

RESA said that ConEd should be directed to hold, within thirty (30) days of the Commission’s order in the proceeding, a meeting with ESCOs to compile a complete list of the current problems those ESCOs are experiencing

RESA recommended that the PSC establish Customer Service Performance Mechanisms (CSPMs) for ConEd which include negative revenue adjustments (NRAs) for failure to issue accurate bills and for failure to issue bills at all.

NRG Energy separately filed testimony seeking more accurate data from ConEd and the provision of additional information to ESCOs

DPS Staff recommended denying ConEd's plan to own renewable generation to provide benefits to low-income customers, stating that programs such as these are being addressed in a generic statewide proceeding.

ConEd had proposed a 10-year project to incrementally purchase, own, and operate a total of one GW of solar capacity with the energy and capacity output of these solar projects sold into the wholesale markets, with net market revenues to be provided as bill credits to customers participating in the Company’s Low-Income Energy Affordability Program.

Cases 22-E-0064 & 22-G-0065

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