PULP Files Testimony in Con Edison Rate Case, Seeking Improved Low Income Rates, Reduced Service Interruption to Collect Bills, Improved Storm Cost Recovery Measures

Con Edison filed new rates in January 2013 which were suspended by the Public Service Commission for an 11-month review and likely modification.  Con Edison requested an electric rate increase of approximately $375 million and updated the request in March to $411.9 million.  The total “delivery rate” increase requested is about 7.9%.  (Con Edison sometimes describes the increase as lower, based on total bills which include the estimated cost of “supply” service, which is handled separately for rate purposes.)

On May 31, 2013, New York’s Utility Project filed testimony of expert witness Nancy Brockway in the pending Con Edison rate cases.  The Project is seeking improved low income rates, reduced use of service interruption as a bill collection measure, and improvement in allocation of risks and incentives in storm outages and storm cost recovery.  See As Poverty Continues its Tight Grip on New York State, Utilities Increase Interruptions of Electric and Natural Gas Service to Collect Bills (New York’s Utility Project, April 1, 2010).

Referencing an AARP report, The Quiet Blackout, New York’s Utility Termination Storm, the testimony makes the point that for many customers, Con Edison bills are not affordable, and that each month more than 200,000 households are threatened with interruption of service due to unpaid bills.  The Utility Project proposes improved coverage of low income rates to reach more low income customers, and reform of collection practices to move toward reduced reliance on interruption of service. The Project urges review of low income customer participation and benefits from existing utility ratepayer funded energy efficiency programs, and reforms necessary to assure a fair measure of participation and direct benefits for low-income customers.  In addition, the Project urges review and reform of the “Revenue Decoupling Mechanism” which, ceteris paribus, gives Con Edison the same revenue through upward rate adjustments when service is interrupted and no electricity is delivered, for example, during storm outages or during periods when service is deliberately interrupted for collection purposes.  The Project also seeks reforms to decrease ratepayer subsidy of ESCO services and improved information for customers considering ESCO service, or who for any reason, want to know what Con Edison would charge for a specific amount of service during a particular time period.

Department of Public Service (DPS) Staff and other intervenors also filed testimony, which is available at the PSC website page for Case 13-E-0030 et al.

Notably, DPS Staff recommended electric and gas  rate decreases, as opposed to the increases requested by Con Edison.  The largest proposed DPS Staff adjustment to the Con Edison request is a return on equity (ROE) of 8.7%, in contrast to Con Edison’s request for an ROE of 10.35.  The Department of State’s utility Intervention Unit proposed a lower ROE, and improved low income rates.

Rebuttal testimony is due June 21, and hearings are currently scheduled to begin July 22.

Gerald A. Norlander

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