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New York DPS Staff Proposes Requiring Utility To Verify That ESCOs Serving Non-Core Customers Have Firm Primary Point Capacity To The City Gates
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Staff of the New York Department of Public Service have recommended in testimony in a Niagara Mohawk (NiMo, NMPC, or National Grid) rate case that NiMo, "be required to
implement a process to verify that direct non-core customers or the ESCO’s or marketers
serving non-core customers have firm primary
point capacity to the city gates so that non-core customer requirements are properly being
met."
Staff was responding to a NiMo proposal, exclusively first reported by EnergyChoiceMatters.com, to close its non-core daily balancing transportation service to new customers, and to offer a new core daily balancing transportation service, which will require that ESCOs take released capacity associated with such core daily balancing customers
Staff opposed NiMo's proposal on several grounds, noting that the NiMo's proposal tacitly redefines non-core customers as core and does not comply with the existing Commission policy (which defines core customers as being residential and small commercial customers, which at NiMo are full service sales and monthly-balanced transportation customers).
Staff further said that NiMo's proposal would, as previously reported in our prior story, allow the Company to allocate and release capacity assets held on behalf of core customers to the ESCOs serving any new non-core
customer participating in the proposed core
daily balancing transportation service.
"This
would reduce the capacity assets that are
available for the needs of demand growth of both
existing and new core customers," Staff said
Staff instead said that NiMo should be required to
implement a process to verify that direct non-core customers or the ESCO’s or marketers
serving non-core customers have firm primary
point capacity to the city gates so that non-core customer requirements are properly being
met.
"Specifically, the Company should require
all direct firm non-core customers or their
agent and all marketers serving firm non-core
customers to submit to the Company, by July 1st
of every year, capacity contracts, redacted as
appropriate, showing firm primary point capacity
to the Company’s city gates for the firm non-core customers’ supply requirements for the
upcoming heating period. In lieu of a redacted
contract, the customer, agent or marketer may
file an affidavit stating that they have the
required firm primary point capacity to their
required city gates for their specific customer
supply requirements," Staff said
"This verification process
has been successfully used by other utilities in
the State such as NFG [sic]. It is described in NFG’s publicly available Gas Transportation Operating
Procedures Manual," Staff said
"Implementing a verification process would allow
NMPC to identify any bad actors on its system
improperly using resources held on behalf of
core customers," Staff said
Cases 20-E-0380 & 20-G-0381
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Would Identify "Bad Actors" Improperly Using Resources Held For Core Customers, Staff Says
November 30, 2020
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Copyright 2010-20 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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