New York ESCO Files Petition To Continue Offering LED Bulb Bundle To Small C&I Customers Only
January 28, 2021 Email This Story Copyright 2010-21 EnergyChoiceMatters.com
Reporting by Paul Ring • firstname.lastname@example.org
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Atlantic Energy, LLC petitioned the New York PSC for a partial waiver of the Commission’s retail market reset order to continue offering its long-standing energy efficient LED lighting products and services to small commercial customers without being subject to the reset order's price caps or renewable requirement
Although certain specifics of the company's LED program were filed under seal, Atlantic said that it, "does not simply pass on LED products as a token gesture."
"Atlantic’s LED product offerings are diverse and curated to each individual business and come in a variety of shapes, sizes, colors, and finishes," Atlantic said
"Atlantic’s LED Program is properly classified as an energy-related value-added product and services because it provides multiple layers of energy-related value, including but not limited to, reduced on-site electricity consumption, demand reduction value to the distribution grid, as well as enhanced education and awareness of energy usage. Many of those values are expressly listed in the Order as the types of energy-related products and services that ESCOs have been encouraged to develop. Notably, the value provided by the LED Program is unquestionably more directly energy-related than that of EnergyGuard [the only value-added product approved to date]," Atlantic said
Atlantic said that its products and services provide customer-specific value in a wide range of categories, including: Electricity Savings, Merchandise Value, Reduced Replacement Costs, Safety and Environmental Value, Reduced Heating Costs, Qualitative Value, and Business Development Value
"While some of these values are difficult or inherently impossible to quantify, the core economic value of reduced energy savings and bulb replacement cost -- on its own -- is sufficient to demonstrate that the LED Program’s value is commensurate to its cost," Atlantic said
"Atlantic’s LED Program is prudent and appropriate to offer as a bundled product offering with commodity supply. At a basic level, customers are increasingly demanding bundled, seamless services and holistic, integrated energy solutions, particularly small commercial customers that are busy managing complex day-to-day business operations. Furthermore, with respect to lighting, there is a direct connection between the LED products Atlantic provides to a customer and the energy consumption reflected on that customer’s bill. It is natural and efficient for one entity to provide both supply and energy-saving equipment that can reduce consumption of that supply," Atlantic said
"With this market-driven approach, Atlantic is not merely providing “off the shelf” LEDs as a token gesture, but rather, curating customer-specific lighting solutions based on deep customer engagement and understanding of business-specific goals and objectives leveraging Atlantic’s expertise in the LED and supply services sector. This is an area well suited for the competitive marketplace to deliver innovative solutions that complement and align with broader regulatory objectives by capturing a wider range of potential customers with a comprehensive value proposition. Moreover, many of Atlantic’s small commercial LED products are special-order items which are curated and customized to fit the customer’s preferences, or are generally unavailable as an “off the shelf” item in big-box stores," Atlantic said
"Bundling the LED Program with Atlantic’s commodity product also allows Atlantic to achieve economies of scale and deliver LED lighting products at below-market costs. This is a unique advantage that Atlantic has in the marketplace," Atlantic said
Contrasting its program to utility demand management programs, Atlantic said its LED products, "are not token items -- or 'swag' -- these are products and services providing utility-scale benefits by Atlantic -- an independent market actor -- which provide significant load relief and grid benefits commensurate with ConEd’s customer-subsidized programs, the value of which is acknowledged and understood by the Commission."
As first reported by EnergyChoiceMatters.com, the PSC in a recent order cited light bulb bundles, in stating, "we have not been persuaded that ESCOs that have historically bundled commodity with low-cost, widely available consumer retail goods that generally require little or no professional maintenance, such as lightbulbs, have shown that they provided an energy-related value-added service that would justify charging premiums to consumers."
In such order, the PSC also took issue with ESCOs that relied upon the PSC's prior specific "invitation", for ESCOs to file waiver requests for home warranty products, to submit additional waiver requests for other products (in this case, green gas)