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New York Power Authority Seeks Utility Consolidated Billing For All DER And Clean Energy Solutions

September 4, 2019

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Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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In comments supporting the expansion of utility consolidated billing to include community distributed generation (CDG), the New York Power Authority said that the New York PSC should, "adopt and implement consolidated billing for all DER [distributed energy resources] and CS [Clean Energy Solutions]."

"In addition to CDG, the Commission should adopt and implement Consolidated Billing for all DER and CS to allow customers to benefit from uniform treatment of billing and accounting practices for an expanded suite of energy products and services. Consolidated billing will streamline a customer’s utility bill and costs incurred in CS, further decreasing soft costs associated with accounting, billing, and bill collection," NYPA said

"The Commission should permit VDER credits to offset any costs consolidated onto a utility bill to encourage wider adoption of Customer Clean Energy Solutions," NYPA said

NYPA said that utility charges for consolidated billing should be flat per-customer fees

In contrast, Sustainable Westchester favors a percentage-of-the-bill method for consolidated billing cost recovery

Sustainable Westchester said that consolidated billing for CDG should use the purchase of receivables model and that, "The POR transaction should likely best be without recourse for highest efficiency."

Sustainable Westchester said that utility consolidated billing for CDG would enable the offering of community solar on an opt-out basis

Opt-out community solar would, in turn, "[m]ak[e] possible guaranteed savings offerings to LMI [low and moderate income] customers," Sustainable Westchester said

"CCAs are constrained from enrolling this group without such a product offering. Consolidated billing does not of itself solve the LMI guaranteed savings requirement to CCAs, but it makes it possible," Sustainable Westchester said

The joint utilities favored an alternative model in lieu of consolidated billing

"The Joint Utilities support a billing model that splits the Value Stack credit between the CDG Host and CDG Subscriber, with a portion of the CDG Host’s credit retained by the utility, as a simpler alternative to consolidated billing. The CDG Host would designate a portion of the Value Stack credit to be allocated to the CDG Subscriber as a net credit, with the remaining portion of the Value Stack credit, less the utility billing fee, to be retained by the CDG Host as a payment from the utility. This payment to the CDG Host would take the place of the, subscription fee that is traditionally billed to the CDG Subscriber. If the Commission adopts such a Net Crediting Model, the Commission should require that the credit to the CDG Subscriber always be zero or greater. In other words, the Net Crediting Model must be implemented in a way that the sum of the monthly Value Stack credit amounts retained by the CDG Host, CDG Subscriber, and utility can never exceed 100 percent of the Value Stack credit for that month," the joint utilities said

"A Net Crediting Model, whereby a fixed percentage (not to exceed 100%) of the CDG Subscriber’s Value Stack credit would be provided directly from the utility to the CDG Host, less any applicable utility billing fee, with the remainder of the credit appearing on the customer bill, would be a simpler and preferred alternative to consolidated billing for all stakeholders – CDG Subscribers, CDG Hosts, and utilities. This approach avoids many of the policy and implementation complexities and concerns associated with putting CDG subscription fees onto the customer bill under a consolidated billing approach and would result in the amount applied to the bill always being a credit and the bill being lower than it would be absent the CDG participation. Under the Net Crediting Model, collection and partial bill concerns associated with consolidated billing no longer apply. It represents an alternative to the existing Value of Distributed Energy Resources ('VDER') structure for CDG projects and simplifies the CDG Host-Subscriber relationship as there would be no need for CDG Hosts to generate customer bills and collect payments, or for participating customers to reconcile and pay an additional bill each month. That said, there remain policy and implementation issues, some of which are yet to be identified, with the Net Crediting Model, including potential inconsistencies with the contract-based subscription model now in place for certain CDG projects, and customer protection concerns because customers may not be able to withhold a payment in the case of a billing dispute," the utilities said

Eligo Energy NY, LLC encouraged the adoption of consolidated billing for CDG projects, and stated, "We also believe that some those entities participating in consolidated billing should undergo any necessary EDI and other interconnection testing with NY utilities, as well as maintain any utility-mandated security procedures and cyber insurance. This is already presently required of energy suppliers working in the State of New York."

Case 19-M-0463

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