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Consolidated Edison Reports Consensus Items from Rate Ready Work Group, Changes Delayed Until All Issues Resolved

May 3, 2011
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Consolidated Edison and ESCOs were not able to reach complete consensus on 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).

A joint proposal in ConEd's most recent electric case required a collaborative to review modifications to the rate ready utility consolidated billing model to enable ESCOs to offer and bill for products which reflect time of use, interval, and real time pricing, as well as to offer multiple rate components, such as demand, on peak, and off peak usage.

Though consensus was reached on some changes, ESCOs have sought additional changes ConEd is not willing to implement. Cost recovery, and whether ESCOs or distribution customers should pay for any enhancements, was also not agreed upon.

ConEd conditionally agreed with ESCOs that the following modifications should be made to rate ready billing:

- Reduce from four days the minimum period for Con Edison's acceptance of ESCO retrospective submission of commodity prices.

- Provide an adjustment line on the ESCO portion of the consolidated bill

- Allow ESCOs to provide customer-specific messages on the ESCO portion of the consolidated bill

- Allow ESCOs to supply 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

- Permit Con Edison to calculate ESCO commodity rates using a dollar or percentage factor submitted by the ESCO that would be applied against current Con Edison commodity charges

- Permit Con Edison to calculate an ESCO loss factor charge

ConEd's assent to such changes, however, was conditioned on an agreement regarding cost recovery. Furthermore, ConEd said that it would not pursue such consensus changes until an agreement was reached regarding the full scope of changes to the rate ready model, or ConEd otherwise knew the full extent of any other changes to the rate ready model (should the PSC order changes outside of a consensus). ConEd said that it did not wish to make modifications in a piecemeal fashion 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.

Specifically, ESCOs have proposed several additional rate ready changes which ConEd does not support, including:

- Allowing ESCOs to supply kWh and peak demand commodity rates for Small Commercial & Large Commercial Customers under Service Classification Nos. 4 [since eliminated], 8, 9, and 12

- Permitting ESCOs to supply on-peak and off-peak commodity rates and multiple demand rates under Mandatory Time-of-Use Service Classification Nos. 4, 5, 8, 9, 12, and 13 that typically have demands in excess of 1500 kW per month

- Allowing ESCOs to supply multiple kWh and kW rates for Mandatory Hourly Pricing under Service Classification Nos. 4, 5, 8, 9, and 12 that typically have demands between 1000 kW and 1500 kW

- Allowing billing for rate plans that have different rates based on volumes consumed (e.g., a rate of $0.100 for the first 100 kWh, with a rate of $0.150 for any consumption above 100 kWh); and

- Allowing billing for rate plans with a minimum bill amount

ConEd said that it could not make several of these changes without extending its Purchase of Receivables program to large demand-billed customers that are not currently participating in the consolidated billing program. ConEd further said that, "it is not reasonable for the Company and its customers to assume the additional and substantial financial risk associated with purchasing the receivables of these large customers."

ConEd said that it remains open to pursuing the changes upon which consensus was reached, but will not proceed until any other potential changes to the rate ready system are locked down, for the earlier stated reason.

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