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New York Utility's Charge To ESCOs For Billing Modifications Increases By Nearly 5x, Nearly $10 per Customer
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Orange and Rockland has filed an updated cost to be charged to ESCOs to implement shadow billing information, to be included in utility bills, and other aspects of General Business Law sections 349-d(9) and (10)
As previously reported by ECM, the new law requires that: (1) the "billing party" provide residential and small commercial customers with billing statements which include a side-by-side comparison of prices charged by ESCOs versus the "price" the customer would have paid had the customer been on default service, and (2) ESCOs provide an annual statement to the customer comparing the ESCO’s prices with the utility’s over the prior 12-month period.
Statute provides that ESCOs shall be responsible for any costs incurred to implement the comparisons. As first reported by EnergyChoiceMatters.com, the utilities seek to recover from ESCOs "all" costs to comply with GBL §§ 349-d(9) and (10)
See full background here
For implementation costs, Con Edison and Orange and Rockland had both provided an initial estimate of a per-customer charge of $1.76, charged to ESCOs
O&R has now filed an updated cost estimate of $9.76
ConEd has filed an updated cost estimate of $3.84
"Revised cost estimates now also include costs for calculation and bill presentment of hypothetical delivery
charges, bill history export, and small non-residential gas customer account characteristic," and well as, "the cost associated with the new export function on the RAIS and TCIS web
portals," ConEd and O&R said
For Con Edison and Orange and Rockland, the utilities propose a new charge code under EDI that will will allow the utility to communicate with ESCOs to fulfill ESCOs' 12-month reporting obligations. This information will be added as new charge codes in the existing “810 URR-Invoice Transaction – Utility Rate Ready” implementation guide.
Con Edison and Orange and Rockland will also update the RAIS and TCIS web portals to allow ESCOs to view and export information for the side-by-side billing and 12-
month billing statement
National Grid, for NiMo, KEDNY, and KEDLI, also reported a higher per-customer charge applicable to ESCOs, now at $6.16 per customer, versus the earlier estimate of $3.62
National Grid said that revised per-customer charges reflect, in part, a refinement of the accounts to which the charge will apply, as National Grid has now conducted a process to examine a customer's historical annual usage to determine whether the customer is a small nonresidential customer and should be included in the count of customers to whom the new billing comparison will be provided. National Grid's earlier estimate was prepared before this process was concluded and thus included some large nonresidential customers, which have now been removed from the count, thus raising the per-customer fee as there are less customers over which to spread the fee charged to ESCOs
National Grid intends to implement the changes required by GBL § 349-d through its existing
Energy Market Web (“EMW”) platform
For rate ready, bill ready, and dual-billed arrangements, National Grid intends to use EMW to
provide ESCOs with the monthly comparison data needed to support ESCO bill presentation under
GBL § 349-d(9). Where National Grid does not present the supply charges, such as in dual-billed
arrangements, the ESCO remains responsible for presenting any required comparison on its bill.
EMW will include a dedicated comparison-data view or tab from which ESCOs can retrieve
current-period comparison data for inclusion on their bills.
"Where National Grid presents the
ESCO charge on a consolidated bill, the bill would compare the customer’s actual billed charges
(utility delivery plus ESCO supply, inclusive of applicable taxes) against the corresponding full-service
utility charges the customer would have incurred for the same period. Consistent with the
Companies’ billing systems, the comparison would be shown as total billed amounts rather than
price-per-unit figures. The bill comparison will reflect both commodity and delivery components,
presented in a manner consistent with National Grid’s bill format," National Grid said
For the 12-month price data that ESCOs must report, National Grid will configure the EMW comparison-data view to retain a rolling fourteen (14) months of data
per ESCO customer, refreshed monthly, providing a two-month buffer for delayed ESCO
retrieval while ensuring at least twelve consecutive months of data remain available at any
point during a billing cycle
In an updated implementation plan, National Fuel Gas Distribution Corporation maintained its estimated cost of $0.86 per UCB customer initially, and then an ongoing $0.0616 per page charge for the cost of the new page that is to be added to the bill
Central Hudson is also maintaining its prior estimated cost of $1.09 per ESCO customer
NYSEG's and RGE's updated costs were first reported by ECM last week
NYSEG now approximates the per-customer charge to ESCOs as $14.14 per NYSEG residential or small non-residential ESCO account
RGE now approximates the per-customer charge to ESCOs as $12.63 per comparable RG&E account.
Cases 98-M-1343, 15-M-0127, et al.
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October 1, 2026
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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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