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State Energy Agency "Revisiting" Position On Keeping Default Service Reconciliations Bypassable
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The New Hampshire Department of Energy (DOE) is "revisiting" its previously stated position regarding the appropriate mechanism to collect under-recoveries in large customer default service costs at Public Service of New Hampshire
As previously reported, the New Hampshire PUC had directed PSNH to propose to recover a $6.5 million under-recovery of default service costs, for large non-residential customers, through the nonbypassable stranded cost charge. PSNH has made such a proposal, with PSNH specifically proposing to make default service reconciliations nonbypassable for all customer classes. See background here
In June 2024, the DOE had expressed support for addressing the large C&I default service under-recovery on a bypassable basis, but with the reconciliation applied to all default service customers, not only large SOS customers. DOE had, at such time, stressed that its position favoring such shared cost recovery among customer classes was limited to the specific under-recovery balance accrued at such time
In light of PSNH's Nov. 2024 proposal on reconciliations, DOE said that it is "revisiting" its position on default service reconciliations
While retail suppliers have broadly argued that nonbypassable default service reconciliations contravene statute, which requires in the restructured market the "unbundling of prices" and "appropriate price signals", DOE cited, as retail suppliers also did, a more specific statutory provision which may be violated by nonbypassable SOS reconciliations
Specifically, RSA 374-F:3, V(c) provides that, "any prudently incurred costs arising from compliance with
the renewable portfolio standards of RSA 362-F for default service [...] shall
be recovered through the default service charge."
DOE questioned whether the default service reconciliations contain reconciliations related to RPS compliance costs. If so, "those costs should not be
transferred to the [nonbypassable] SCRC [stranded cost recovery charge]," DOE said
Notwithstanding its observation concerning this RPS statutory provision, DOE developed an "alternative proposal" to address the large customer default service under-recovery (now standing at about $6.87 million) which would nevertheless rely on nonbypassable cost recovery
Specifically, DOE's alternative proposal would include the $6.87 million in the nonbypassable SCRC for large customers only, and would not collect this cost from the mass market SCRC (in contrast to PSNH's SCRC proposal)
The DOE noted that its position is not final, as DOE will develop a final position in response to filings and testimony from PSNH and other stakeholders
DE 24-112
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January 20, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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