NiMo Seeks To Extend Commodity Supply Bill Guarantee For V-TOU Customers

July 17, 2019

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Reporting by Paul Ring • ring@energychoicematters.com

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Niagara Mohawk Power Corporation d/b/a National Grid ('National Grid', 'NiMo', or the 'Company') submitted a petition to the New York PSC seeking a limited waiver to extend the one-time option available to customers with plug-in electric vehicles ('PEVs') at their premises to receive a comparison of 12 months of charges under Service Classification No. 1 ('SC-1') Voluntary Time-of-Use ('VTOU') rate against what they would have paid under the SC-1 standard tariff rate, where such option is currently only available at the end of the customer’s initial one-year term under Special Provision L, entitled 'Residential Optional Time of Use Delivery And Commodity Rate'

The Company is seeking this limited waiver to offer an additional 12-month comparison and corresponding bill guarantee, "due to a National Grid meter programming error that resulted in incorrect pricing for certain time periods for SC-1 VTOU customers which in turn creates an erroneous bill comparison against what these customers would have paid under the SC-1 standard tariff rate," NiMo said

"[G]ranting this limited waiver will prevent an unjust economic burden to those customers who base their energy consumption decisions going forward on incorrectly metered charges for energy usage under Special Provision L of the SC-1 VTOU tariff at the end of the one-year initial term," NiMo said

Special Provision L of the SC-1 VTOU tariff provides a one-time option for those customers who have provided satisfactory verification of a PEV at their premises to receive a comparison from National Grid of 12 months of actual charges under the SC-1 VTOU rate to what they otherwise would have been charged under the SC-1 standard tariff rate, excluding the incremental customer charge and the new hedge adjustment component of the Company’s Electric Supply Reconciliation Mechanism ('ESRM'). If that comparison indicates that the customer would have paid less under the SC-1 standard tariff rate, the customer would receive a refund from National Grid for that difference (i.e., the bill guarantee of Special Provision L). At this same time, the customer may elect to stay on the SC-1 VTOU rate or move back to the SC-1 standard tariff rate as informed by the bill comparison. Customers may also transition back to the SC-1 standard tariff rate any time after their initial 12 months on the SC-1 VTOU rate.

"Regrettably, National Grid was unaware of the metering programming error until most recently when the Company confirmed that metered charges for weekend electric usage for customers taking service under the SC-1 VTOU rate were based entirely on off-peak rates when in fact they should have been based on on-peak rates for the hours of 7:00 a.m. to 11:00 p.m. on each Saturday and Sunday, where off-peak rates are lower than on-peak rates. As such, SC-1 VTOU customers have been underbilled for the duration of their time on this rate," NiMo said

"Through June 30, 2019, there were 192 customers on the SC-1 VTOU rate with 149 of those customers eligible for the bill guarantee provision as a result of having provided verification of a PEV at their premise. Of the 149 customers eligible for the bill guarantee provision, 26 customers have reached their initial one-year anniversary under Special Provision L of the SC-1 VTOU rate and received a bill comparison from National Grid. The bill comparison showed that none of these 26 customers would have paid less under the SC-1 standard tariff rate and therefore no refunds were paid by National Grid. However, as noted above, this bill comparison is not a valid one due to the fact that SC-1 VTOU customers have been underbilled for their duration on this rate," NiMo said

"National Grid’s incorrect programming of the meters deployed to those customers electing participation in Special Provision L of the SC-1 VTOU tariff was an unintentional one and the Company regrets that its actions were not consistent with its Electricity Tariff. This programming error impacts all customers on the SC-1 VTOU rate since inception," NiMo said

"Participating customers in the SC-1 VTOU rate were not negatively impacted by this programming error as they were charged less than they otherwise should have been charged for electric usage during weekend on-peak hours. However, prospectively, and particularly so for those 26 customers that have already received their comparison to what they would have paid under the SC-1 standard tariff rate, participating customers could be making improper decisions on energy usage going forward based on incorrect bill charges for weekend hours energy consumption. Additionally, the customer bill comparison to the SC-1 standard tariff rate was flawed given that the SC-1 VTOU charges were artificially low. National Grid is unable to correct past bills to determine the magnitude of underpayment for weekend on-peak usage as the metered data does not exist for the time-of-use periods in question," NiMo said

"The Company intends to correct the meter programming error by replacing the existing meters at the customers’ premises with new meters upon completion of metering reprogramming and testing. National Grid also proposes to extend the 12-month guarantee for each participating customer in the SC-1 VTOU rate for an additional 12- month period that will commence with the next bill period upon the installation of new meters once metering re-programming and testing are completed," NiMo said

"The Company will notify customers of the metering change-out and the extended bill guarantee provision. National Grid’s initial communication with customers will include notification of the upcoming meter change-out and notice that the Company is seeking Commission approval of a limited tariff waiver to be able to offer an extended bill guarantee. A second communication will be provided to these customers by the Company following Commission action on this limited waiver petition," NiMo said

"Extending the bill guarantee provision will not impose any additional costs on National Grid’s customers as the billing system changes to perform the bill comparisons for the bill guarantee provision are already in place. However, it is possible that with the corrected meters in place, some customers may be eligible for a refund at the end of the extended bill guarantee period," NiMo said

Case 18-E-0206

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