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New York PSC Directs Utilities To Develop Plans To Improve Community Solar Billing, Address Errors

September 15, 2022

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Copyright 2010-21
Reporting by Paul Ring •

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The New York State Public Service Commission said today that it directed utilities to file implementation plans regarding the automation of Community Distributed Generation (CDG) billing and initiated a process for the development of CDG billing performance metrics.

In an order, the PSC noted that an earlier Staff filing, "recognized numerous ongoing billing issues related to utility billing of CDG impacting thousands of customers and generating confusion surrounding energy costs and CDG program benefits."

Such Staff filling reported that, "instances have occurred, and are still occurring, where customers do not receive a utility bill for several months and later received multiple bills within a short period, or a single very high bill for that extended period. There have also been many reports of CDG members not receiving appropriate credits on their bills, fueling skepticism of the program itself. These billing deficiencies have also impacted the CDG Sponsor’s ability to bill and collect payments from the utilities and/or customers for the generation that has been produced by these CDG projects. This has led to CDG Sponsor capital issues and, in some instances, the potential for default on their contractual obligations to their customers and project funding sources."

The Staff filing also highlighted the "significant delay", the PSC said, on the part of the utilities in implementing an efficient and automated billing process, particularly for CDG Net-Crediting.

The PSC said, "the original timelines for utility automation of Net-Crediting have been exceeded by more than a year in some instances, with only one utility, Orange and Rockland Utilities, Inc., having achieved automation at the time the Straw Proposal was filed."

The PSC specifically directed the investor-owned utilities who have filed tariffs related to CDG to file implementation plans associated with automated CDG billing. These implementation plans shall, at a minimum, include: (1) the current billing system constraints preventing full CDG billing automation; (2) the billing system changes necessary to effectuate automated CDG billing; and (3) the steps and timeline to achieve full automation of CDG billing. These implementation plans shall be filed with the Secretary within 30 days and updated quarterly until automation efforts are complete.

"Understanding the utility billing system capabilities and constraints is the first step in addressing these delays," the PSC said

The PSC said that the future processes established by its order, "are intended to address and resolve ongoing CDG billing issues originating with the utilities, improve the industry’s visibility into the utilities’ transition to an automated Net- Crediting billing process, and incentivize more accurate and timely utility performance in billing for CDG."

The PSC also initiated a process focused on developing CDG billing performance metrics, including a potential financial penalty tied directly to the utilities’ CDG crediting and billing performances.

"The Commission sees potential benefits in establishing CDG billing metrics to track and evaluate utilities’ performance in billing for CDG," the PSC said

The details of such metrics shall be developed in consultation with industry stakeholders as part of a collaborative process to establish minimum standards for utility billing of CDG, the PSC said

The PSC directed that the Secretary shall, within 30 days, issue a notice convening an initial stakeholder conference focused on developing CDG billing performance metrics. As part of this process, stakeholders shall also propose a negative revenue adjustment mechanism to be tied directly to the utilities’ CDG crediting and billing performances, the PSC said

The utility implementation plans, and any proposed metrics, will come back before the Commission for consideration and approval.

While a Straw Proposal filed by Staff also proposed establishment of quarterly utility CDG billing and crediting reports, "the Commission sees this step as premature at this time, and instead will take up the issue of reporting requirements in the future as part of its consideration of any CDG billing and crediting metrics developed through the collaborative process," the PSC said

"Getting the utility billing and crediting processes performing accurately and timely for [community solar] programs is of the utmost importance to ensure their success," said Commission Chair Rory M. Christian

"The benefits of CDG development can only be realized if the billing and crediting of CDG members is performed accurately and in a timely manner. The process initiated today is necessary to address the ongoing CDG billing issues originating with the distribution utilities," the PSC said

The PSC said that today’s order focused only on the future process necessary to ensure customers participating in a CDG program receive accurate and timely bills from their utility, and does not address issues related to opt-out CDG under municipal aggregation, which had been raised in concert with the billing issues

Cases 19-M-0463, 15-E-0082, 14-M-0224


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