On Tuesday, November 21, CLP filed testimony with the NYS Public Service Commission (PSC) on Central Hudson's proposed rate plan for 2018-2019—the only community-based organization to do so. The testimony forcefully conveyed CLP's concerns with the proposed plan and made a number of recommendations to the Commission for changes.
The full testimony and accompanying exhibits can be found here. Specifically, the testimony argues that:
- The rate increase will impose an undue burden on our communities, and a number of the proposed utility expenses contributing to that increase are not sufficiently justified.
- Central Hudson's fixed charge of $24.00 a month for residential customers—already the highest in New York and one of the highest in the country—should be lowered, not raised. This high fixed charge unfairly shifts utility costs to lower-usage customers, including low- and moderate-income households, and is incompatible with New York’s clean energy targets and Reforming the Energy Vision (REV) objectives. CLP proposes a step down in this charge over three years to $10, which would be more consistent with regional and national rates.
- The proposed new Service Size Charge should be rejected. Instead the Company should reform its standard residential rate by lowering the fixed charge and tying rates more closely to actual energy consumption.
- Central Hudson’s new voluntary time-of-use (TOU) rate was not designed on the basis of sufficient analysis and could end up costing many customers more than the standard rate.
- The Commission should immediately discontinue Central Hudson’s gas expansion program and channel those resources into energy efficiency and clean heating and cooling programs.
- Central Hudson has proposed to be awarded millions of dollars in additional profits (called “Earnings Impact Mechanisms,” or EAMs) for achieving targets in the areas of energy efficiency, renewable energy, and electric vehicle (EV) adoption that are too weak. CLP proposes more aggressive targets and proposes eliminating the “Customer Engagement” EAM altogether.
- Central Hudson’s EV program is unimaginative and does not take advantage of the utility’s unique position to encourage adoption of EVs. CLP proposes 1) an aggregated purchase program for customers to obtain manufacturer discounts; 2) an incentive program to encourage installation of charging stations at workplaces, and a separate TOU rate specifically designed to incentivize EV adoption and charging during off-peak hours.
- The “rent” for poles charged to municipalities that own their own streetlights has no basis in utility costs, is unreasonable, and should be eliminated.
- The Company’s Main Street Revitalization Program should be retained because of the continuing challenges that many communities in the service territory face with vacant and blighted areas in their downtown business districts—particularly in smaller rural communities. The cost share for communities should be reduced to make the grant program more affordable.
CLP also requested that the Commission hold a second set of public hearings to allow for more meaningful public input, recommending hearings in Newburgh, Poughkeepsie, and Kingston after a Joint Proposal is filed with the Commission in the spring.
Members of the public are strongly encouraged to submit comments on the Central Hudson rate case on the NYS Department of Public Service website here. Click on the “Post Comments” button in the upper right corner.