New York ESCO "Fundamentally Concerned" About Accuracy Of Estimated Reads, Billing From Utilities For C&I Customers Due To COVID, Asks PSC To Hold Technical Session
July 13, 2020 Email This Story Copyright 2010-20 EnergyChoiceMatters.com
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Direct Energy Services, LLC and several affiliates submitted comments to the New York PSC, in a proceeding concerning COVID-19, stating that Direct Energy is, "fundamentally concerned about the accuracy of ... [utility] estimated reads as well as the potential pricing, billing and general service quality impacts," on commercial and industrial customers resulting from customers' business operation changes due to the pandemic
"During the COVID-19 crisis, leading Energy Service Companies ('ESCOs') like the
Direct Energy companies are attempting to effectively manage the operational challenges related
to the quality and access of customer usage data as provided by the electric distribution
companies ('EDCs'). More specifically, as commercial and industrial enterprises are closed or
operating within a partial work schedule during the pandemic, critical usage information
designed formulate pricing and properly bill these customers may reflect a significant deviation
from their past historical usage, thus, leading to the EDCs providing non-existent or estimated
customer usage readings or 'reads' to ESCOs," Direct Energy said
"Direct Energy is fundamentally concerned about the accuracy of these estimated reads as
well as the potential pricing, billing and general service quality impacts on this segment of
customers," Direct Energy said
"Therefore, within the scope of the Commission’s Case 20-M-0266 - 'COVID-19'
proceeding, Direct Energy recommends the establishment of one or more technical or
informational session(s) with interested stakeholders to fully review and discuss the treatment of
customer usage information," Direct Energy said
Direct Energy said that it has identified "several key utility operational
questions" that should be considered as part of the review process.
Direct Energy said that these questions include but are
not limited to the following areas of concern:
1. Are estimated reads provided by the EDCs being adjusted to account for known customer
outages or industry-segment projected shape changes?
2. Will cancel / rebill transactions be provided by the EDCs to replace the estimated read
period with actual volumes?
3. How will the EDC’s treat cancel / rebill transactions, i.e., a one-for-one match or will the
actual read replace multiple estimated reads?
4. Does the EDC methodology for the addressing estimated readings and the cancel/rebill
transactions change based on customer size or other determinants, i.e., load profile, rate
5. If a customer challenges an estimated read as being 'overstated' or incorrect, what is the
protocol for review and potential resolution?
6. If a customer provides their own meter read, does the EDC treat the information as an
estimated read or and actual read?
7. Will the estimated reads be leveraged as part of the initial ISO settlement process?
8. How will 'corrected' or reconciled actual meter reads be treated by the NYISO? What is
the protocol if corrected reads submitted to the ISO miss the resettlement window?
9. Can the EDCs provide any guidance to ESCOs regarding where a significant number of
estimated bills are expected, i.e., at the municipal, county, etc.?
10. Can the EDCs provide guidance to ESCOs regarding specific load profiles or customer
segments where a significant number of estimated bills are expected?