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Utilities Claim Adopted AMI Plans Did Not Include Settling Load At ISO On Hourly Intervals, Seek Cost Allocation To Retail Suppliers
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Massachusetts electric utilities claim that using AMI interval data to settle load at ISO New England was not included in their AMI Implementation Plans approved by the Massachusetts DPU, and argue that competitive retail electric suppliers should pay the cost of EDC system upgrades to implement the use of AMI interval data for ISO-NE load settlement
Retail suppliers and other advocacy groups allege that the EDCs committed to the use of AMI interval data for ISO-NE load settlement under their previously approved AMI Implementation Plans and budgets.
Stakeholders were addressing the Massachusetts DPU's newly opened proceeding to examine necessary systems and system upgrades to allow load settlement with ISO-NE based on customer interval usage data collected by AMI
As first reported by EnergyChoiceMatters.com, the DPU in opening its investigation directed electric utilities, retail suppliers, and non-LSE third-party energy service providers to discuss potential "cost-sharing" methods to implement the use of AMI for load settlement, with the DPU specifically describing such potential "cost-sharing" mechanisms as, "sharing costs between suppliers and ratepayers," in order to minimize ratepayer costs associated with any necessary investments to enable the use of AMI interval usage data to settle load with ISO-NE.
National Grid said in comments to the DPU that, "load settlement of AMI interval data requires additional technology upgrades that are
incremental to the investments approved in D.P.U. 21-81 [its AMI Implementation Plan]".
National Grid said "National Grid was explicit that it was not making a TVR [time varying rate] proposal in its
D.P.U. 21-81 AMI Implementation Plan proposal.
Additionally, there was no reference to load
settlement in the Company’s AMI Implementation Plan."
National Grid said, "The third parties that would make use of this
data should pay to offset these costs that would otherwise be recovered from utility customers."
Concerning its approved AMI plan, National Grid said, "National Grid’s original AMI plan was
approved based on a business case analysis that did not include the costs necessary to use AMI
interval usage data for load settlement. National Grid has estimated these additional costs for its
systems to be approximately $40 million over seven years, including both up-front
implementation costs and run-the-business costs."
Concerning its approved AMI plan, National Grid said, "National Grid testified that its AMI
deployment timeline went through 2027 and that it could use more granular data when reporting
hourly load to ISO-NE 'when we have it and are able to incorporate that into the process,' i.e.,
after deployment of the AMI meters and the supporting network and back-office infrastructure,
and after the Company analyzed its ability to do so. National Grid's evidence also made clear
that additional investments might be needed, beyond those proposed in its AMI Plan, to make
certain products available."
In separately filed comments, Unitil said concerning its approved AMI plan, "Unitil clearly stated, in multiple responses to information requests, that load
settlement was outside the scope of its GMP [grid mod plan] and AMI replacement plans. Specifically, Unitil
explained it 'did not have any plans . . . to use smart meter data for the wholesale settlement of
energy charges with hourly market prices to Municipal Aggregators and retail electric suppliers.'"
Unitil also proposes that third parties who use AMI interval data should pay for upgrades to implement the use of AMI interval data for ISO settlement
Filing joint comments, NRG Energy, Inc., Mission:data, Vistra Corporation, and Base Power Company (Joint Parties) alleged that the EDCs, "have already committed, on the record and under oath, to using actual AMI interval data for ISO-NE load settlement once meters are deployed. "
The Joint Parties alleged, "At the April 7, 2022, evidentiary hearing in D.P.U.
21-80/21-81/21-82 [AMI plans], representatives of each EDC testified that they intended to transition from
load profiles to actual metered hourly data for ISO-NE settlement as AMI deployment
proceeded. The EDCs should be held to that testimony."
The Joint Parties alleged that the EDCs had provided the following testimony in the AMI Plan proceedings:
Eversource’s [witness] testified: "[O]nce the AMI meters are in place and working, we
will use that data, the actual data versus profiles, to provide those updates." D.P.U. 21-80/21-
81/21-82, Tr. 5, at 811. When pressed further, Eversource’s [witness] confirmed: "We did, and I’m pleased
to share that we are ready for customers that have interval data, provide that to ISO New
England, instead of a profile, because of the benefits that you noted." Id., Tr. 5, at 1012-1013.
National Grid’s [witness] also testified that once AMI meters are deployed, National Grid
"will use the more granular data when we have it and are able to incorporate that into the
process." D.P.U. 21-80/21-81/21-82, Tr. 5, at 810.
Unitil’s [witness] likewise testified that
Unitil would use actual interval data for both energy settlement and capacity tag calculations:
"For both energy settlement and capacity tag. ... Yes." Id., Tr. 5, at 1013.
"The Department should hold the EDCs to their sworn testimony and direct them to develop this
capability without further delay," the Joint Parties said
More specifically, the Joint Parties asked that the DPU direct the EDCs to develop the systems necessary to report hourly supplier load to ISO-NE using AMI interval data, calculate ICAP tags using actual metered data, and enable
competitive suppliers and municipal aggregators so competitive suppliers can monetize the savings from
customer behavior changes resulting from TVR and VPPs, with an implementation
deadline of Q1 2027
The Joint Parties also requested that the DPU reject utilities' efforts to assign implementation costs to retail suppliers or other third parties, "given the preliminarily approved and
largely unspent budgets for customer enablement and systems integration, the sworn
testimony of the EDCs’ own witnesses, and the immense and time-sensitive affordability
benefits at stake."
In separately filed comments, the Retail Energy Supply Association said, "during the evidentiary hearings conducted in 2022 by the
Department regarding the EDCs’ AMI implementation plans, the EDCs each testified
that, once AMI was deployed, they would be able to settle load based on that interval data
(rather than load profiles). Thus, the costs associated with this capability should already
have been included in the EDCs’ AMI implementation plans. Moreover, the cost-benefit analysis used by the EDCs to support the investment in AMI included the benefits
associated with TVRs -- a product offering that [as discussed in RESA's comments] ... requires the use of
interval data for ISO-NE settlements to be effective. Accordingly, any additional costs
associated with enabling the capability to provide interval data for ISO-NE settlements
should be absorbed by the EDCs."
In separately filed comments, the Green Energy Consumers Alliance similarly said that the prior AMI plan orders require the use of interval data for settlement at ISO-NE
Green Energy Consumers Alliance said that, during such AMI plan proceedings, "Department staff directly asked both National Grid and
Eversource whether, after deployment of the new smart meters, they would be reporting actual metered
hourly usage to ISO New England. Both replied affirmatively. Eversource’s witness clarified, 'We use
interval data today, when we have -- customers who are on TVR rates -- to do the settlement.'"
Green Energy Consumers Alliance said, "Nowhere in the entirety of the Grid Mod docket did the utilities disclose that their 'well-planned,'
'comprehensive,' 'cost-effective' AMI Plans (whose benefits included TVR) would not even meet the Department’s longstanding definition of AMI functionality to include 'collection of customers’ interval
usage data, in near real time, usable for settlement in the ISO-NE energy and ancillary services markets.'"
In separately filed comments, Cape Light Compact JPE addressed utility arguments that the AMI plan orders deferred consideration of TVR and associated issues, with the Compact arguing that such deferral only related to basic service TVR, and did not defer the use of AMI interval data for ISO settlement of retail supplier TVRs
The Compact stated, "For their argument, the EDCs relied on footnote 136 of the Track II Order (at 327), which reads, 'The Department
will address TVR for basic service, as well as potential TVR for transmission and distribution, in a separate
proceeding.' Track II Order at 327, n.136. The plain reading of the footnote clearly confirms that it addresses only
TVR offered by the EDCs and was not intended to address third-party TVR".
Docket D.P.U. 26-44
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Retail Suppliers Seek Q1 2027 Start Of ISO Load Settlement Based On AMI, Cite EDCs' Prior Testimony As Requiring Such; Oppose Cost Assignment To Retail Suppliers
April 23, 2026
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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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