New York Retail Suppliers Seeking Changes in Utility Billing, Load Profiles to Support Time of Use Rates Absent Interval Meters

Consolidated Edison should be required to modify its utility consolidated billing practices and introduce new load profiles to enable the offering of Time of Use (TOU) rates from competitive retail suppliers in the absence of interval meters for all customers, the Retail Energy Supply Association said.

RESA's proposal came in a post-hearing brief in ConEd's current electric and gas rate cases.

RESA was specifically addressing Staff's proposal for ConEd to offer a voluntary TOU generation rate to electric vehicle owners. RESA was particularly concerned with the proposal because it included a hold harmless provision to EV-TOU customers (socialized through other customers), and because, due to certain billing limitations, retail suppliers cannot currently offer a comparable product at ConEd through the utility consolidated bill.

"The potential expansion of TOU rates engenders an important area of concerns among ESCOs that participate in the Company's consolidated utility billing system ('CUBS') program, under which the Company issues one bill for utility and ESCO charges," RESA said. "Although ESCOs may provide time-dependent (TOU) supply products in the Con Edison service territory to larger customers under a dual-bill arrangement; for mass customers where a single bill is vital, they cannot offer TOU products due to the operational limitations that Con Edison places on ESCOs utilizing the consolidated utility billing process."

"The CUBS program utilizes a Rate Ready system which requires the ESCO to provide the applicable rate to be charged to the customer a number of days prior to the end of the billing cycle. This prevents the ESCO from knowing how much and when the customer used energy during the entire billing period. Therefore, the ESCO does not know the total actual volume or time periods of usage during the billing cycle, including the time of use, prior to being required to provide the billing rate under the present Con Edison operational rules," RESA said.

"This places the ESCO at a competitive disadvantage to Con Edison especially with respect to the provision of TOU based commodity service. Essentially, Con Edison can offer and bill customers for TOU service as it will know the customer's entire time differentiated usage for the billing period prior to issuing the bill. In contrast, an ESCO offering a TOU supply price (and wanting to utilize the consolidated utility billing service) will not be in the same position and, in fact, will not know the total billing period time differentiated usage prior to being required to provide its rate under CUBS. As a consequence, ESCOs are unable to pass through TOU based products when utilizing the present Con Edison Rate Ready billing service. Meanwhile, RESA observes that both NYSEG and RG&E enable a 2-day period after the meter read date which does allow index/TOU based products under a consolidated billing arrangement," RESA said.

"To address this growing concern, Con Edison should be directed to develop a mechanism that allows ESCOs participating in CUBS, including those provided with a TOU product, to bill all customers on a level playing field with the Company," RESA recommended.

"Another barrier to providing appropriate commodity service to TOU customers without interval (hourly) metering is that the utility's current use of load shapes does not differentiate between the customers' on-peak and off-peak usage when calculating and reporting to the NYISO each ESCO's hourly settlement data. As a result, the ESCO serving TOU customers that shift their usage to off-peak periods will not realize the commodity savings associated with that shift in usage. Without the properly calculated NYISO settlement, the ESCOs are unable to convey the benefits in their commodity price to individual TOU customers that aggressively shift load as the benefit is effectively socialized among all customers in the lost and unaccounted for energy factor," RESA said.

"In order to be able to provide appropriate commodity products to TOU customers, ESCOs need the utility to report settlement data to the NYISO that is based on the TOU customers' actual on and off-peak usage. This can be accomplished by developing and implementing separate load shapes to map a TOU customer's metered off-peak usage into the corresponding off-peak hours and the on-peak usage into the corresponding on-peak hours," RESA said.

Addressing other retail market issues in the rate case, RESA opposed proposals for an on-bill monthly comparison of the ESCO and default service prices, noting, "The use of a one month time period erroneously focuses attention on a short limited time horizon rather than a longer 12 month period that provides a more accurate picture."

RESA was not opposed, in general, to use of a historical, 12-month ESCO versus default service cost calculator on ConEd's website, but said that it would be logical to await the outcome of the state's generic retail market investigation (which is also addressing the issue) before actually implementing the calculator at Con Edison

To the extent the PSC does not wait, RESA cited recent errors in the calculator offered at Niagara Mohawk, which made default service rates appear cheaper than they actually were, to ensure similar mistakes are not encountered at ConEd.

RESA opposed the Public Utility Law Project's recommendation to end the PowerMove customer referral program.

"All of the costs of the [PowerMove] program are now paid for by participating ESCOs. Thus, the program provides distinct benefits to customers and is paid for by the ESCOs. Under these conditions, there is no rational basis to terminate the program," RESA said.

The state's Utility Intervention Unit supported the elimination of PowerMove, "since the introductory two-month 7% savings gives customers a false sense of savings and does not represent the true value of the ESCO price afterwards."

Case 13-E-0030 et. al.