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Utilities: Retail Suppliers, "May Be Motivated To Develop New TOU Product Offerings With The Goal Of Optimizing Product Profitability Rather Than Faithfully Reflecting Wholesale Market Dynamics"

May 19, 2026

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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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In reply comments in the Massachusetts DPU's inquiry on electric delivery rates (which has, as previously reported, included consideration of policies concerning electricity supply), the state's investor-owned utilities said that the goals of time of use pricing may not be realized because the utilities alleged that, "retailers may be motivated to develop new TOU product offerings with the goal of optimizing product profitability rather than faithfully reflecting wholesale market dynamics."

As first reported by ECM, Eversource earlier in the proceeding had alleged that, "reductions in wholesale market prices may lead to higher profits for retail suppliers instead of lower costs for their customer."

In the newly filed reply comments, the utilities said that any change to TOU pricing for electricity basic service will have limited impact since most of the state's load is served on competitive supply (largely through municipal aggregation)

The utilities further said, "current full requirements procurement structures also present an obstacle to economically efficient TOU rates."

The utilities said, "The current [basic service] supply practice is procurement based and suppliers cannot be compelled to offer TOU pricing to EDCs without a statutory mandate."

"While the EDCs could also shape flat rate pricing into a TOU rate structure, these costs would be based on historic pricing, rather than current market conditions, and given reconciliation of Basic Service costs, savings achieved by individual customers would redistribute costs," the utilities said

"Moreover, such pricing [real-time pricing], if offered by retail suppliers, may not reflect real time pricing but rather reflect supplier risk premiums," the utilities alleged

The utilities who jointly filed the reply comments consisted of Boston Gas Company, Massachusetts Electric Company and Nantucket Electric Company each d/b/a National Grid (“National Grid”), NSTAR Electric Company, NSTAR Gas Company and Eversource Gas Company of Massachusetts each d/b/a Eversource Energy (“Eversource”), Fitchburg Gas and Electric Light Company d/b/a Unitil (“Unitil”), Liberty Utilities (New England Natural Gas Company) Corp. d/b/a Liberty (“Liberty”), and The Berkshire Gas Company (“Berkshire”)

Docket 25-200

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