New York ESCO "Fundamentally Concerned" About Accuracy Of Estimated Reads, Billing From Utilities For C&I Customers Due To COVID, Asks PSC To Hold Technical Session

Direct Energy Services, LLC and several affiliates submitted comments to the New York PSC, in a proceeding concerning COVID-19, stating that Direct Energy is, "fundamentally concerned about the accuracy of ... [utility] estimated reads as well as the potential pricing, billing and general service quality impacts," on commercial and industrial customers resulting from customers' business operation changes due to the pandemic

"During the COVID-19 crisis, leading Energy Service Companies ('ESCOs') like the Direct Energy companies are attempting to effectively manage the operational challenges related to the quality and access of customer usage data as provided by the electric distribution companies ('EDCs'). More specifically, as commercial and industrial enterprises are closed or operating within a partial work schedule during the pandemic, critical usage information designed formulate pricing and properly bill these customers may reflect a significant deviation from their past historical usage, thus, leading to the EDCs providing non-existent or estimated customer usage readings or 'reads' to ESCOs," Direct Energy said

"Direct Energy is fundamentally concerned about the accuracy of these estimated reads as well as the potential pricing, billing and general service quality impacts on this segment of customers," Direct Energy said

"Therefore, within the scope of the Commission’s Case 20-M-0266 - 'COVID-19' proceeding, Direct Energy recommends the establishment of one or more technical or informational session(s) with interested stakeholders to fully review and discuss the treatment of customer usage information," Direct Energy said

Direct Energy said that it has identified "several key utility operational questions" that should be considered as part of the review process.

Direct Energy said that these questions include but are not limited to the following areas of concern:

1. Are estimated reads provided by the EDCs being adjusted to account for known customer outages or industry-segment projected shape changes?

2. Will cancel / rebill transactions be provided by the EDCs to replace the estimated read period with actual volumes?

3. How will the EDC’s treat cancel / rebill transactions, i.e., a one-for-one match or will the actual read replace multiple estimated reads?

4. Does the EDC methodology for the addressing estimated readings and the cancel/rebill transactions change based on customer size or other determinants, i.e., load profile, rate code, etc.

5. If a customer challenges an estimated read as being 'overstated' or incorrect, what is the protocol for review and potential resolution?

6. If a customer provides their own meter read, does the EDC treat the information as an estimated read or and actual read?

7. Will the estimated reads be leveraged as part of the initial ISO settlement process?

8. How will 'corrected' or reconciled actual meter reads be treated by the NYISO? What is the protocol if corrected reads submitted to the ISO miss the resettlement window?

9. Can the EDCs provide any guidance to ESCOs regarding where a significant number of estimated bills are expected, i.e., at the municipal, county, etc.?

10. Can the EDCs provide guidance to ESCOs regarding specific load profiles or customer segments where a significant number of estimated bills are expected?

Case 20-M-0266