CLP submits comments to PSC on "straw proposal" by DPS staff laying out new regulatory framework for utilities

CLP has submitted two rounds of comments on the NYS Department of Public Service (DPS) Staff “Straw Proposal” — a 107-page document laying out DPS Staff’s recommendations for a new regulatory framework for the utilities that relies on markets, rather than regulation, to achieve a decentralized, distributed energy system. Ironically, Staff proposes putting regulated monopolies at the helm of this market model by giving utilities the new job of  “Distributed System Platform Provider” or “DSP” responsible for managing and running the market for energy products and services (think of Amazon, but for things like roof-top solar, smart thermostats, and energy supply services offered by non-utility companies). Part of the utilities’ new job will be to make sure that these products and services are integrated into the grid in a way that improves grid reliability and reduces the need for new infrastructure investments.

In Initial Comments, submitted last month, CLP calls for establishing an independent statewide DSP rather than relying on the utilities to play this role. We are concerned that the utilities, as private, for-profit companies, will abuse their monopoly position. They also lack the marketing and technical experience to run an online marketplace. And, finally, a single DSP would be far more efficient and far less confusing than seven separate utility-run marketplaces.

In our comments, we also argue against allowing utilities to own renewable generation, which would have unfair market advantages as regulated monopolies that could be used to discourage non-utility-owned investments in renewable resources.  Our comments also emphasize the importance of promoting clean, renewable energy and reducing reliance on natural gas in the electricity sector; addressing the utilities’ high interconnection costs for renewable energy; ensuring that low-income customers are adequately protected under the new regulatory model; and enabling CCA and community renewable energy so that communities have the tools to shift toward a more locally-based clean energy system.

In CLP’s Reply Comments on the Straw Proposal, we respond to the initial comments made by a number of parties to the REV, including the utilities, PULP, the Association for Energy Affordability, and others.