CCA (Working Group report, next steps to influence policy changes)

CLP has for several years been advocating for CCA “2.0” in New York—a version of CCA that harnesses the collective buying power and scale of communities to provide energy supply and services aligned with local needs and goals. However, after assessing the possibilities of working within the limits of the state’s regulatory framework, CLP has concluded that changes are needed in state policy and regulations for CCA to deliver meaningful long-term benefits to our communities.

Earlier this year the CEAC state-level working group—of which Jen Metzger was an active participant—filed their CCA policy recommendations report. The report’s recommendations included expanded access to data, opt-out community renewable energy, utility billing changes, and additional financial resources for organizations to administer CCA programs, among other recommendations. If adopted by the PSC and NYSERDA, these recommendations could significantly expand CCA program opportunities.. CLP will continue to work to promote state policies supportive of CCA 2.0.

Meanwhile, the PSC has approved “generic” CCA implementation plans by Joule Assets, Good Energy, and the Municipal Energy and Gas Alliance, Inc. (MEGA)—three CCA administration consultants seeking to sign up municipalities in NYS to aggregate the electricity and gas accounts of communities as these companies sign municipal customers up over time. The MEGA program will consist of “1.0” contracts with ESCOs for supply, at least in the near term, although the implementation plan leaves open the possibility of offering other types of services down the road. Good Energy offers a “1.0” CCA program that focuses on financial savings, which we expect to be quite modest in New York’s retail supply market. The implementation plan filed with the PSC suggests anhe option to include opt-in green products as an alternative to the standard supply; however,Good Energy did not mention a green alternative when presenting its program at the 2018 Association of Towns meeting. Joule's implementation plan includes opt-out community renewable energy. While this option was not approved outright, the PSC did request that Joule “submit a CDG Implementation Plan for Staff review and approval to ensure the program will not produce customer confusion and will comply with Commission requirements before enrolling customers in a CDG program on an opt-out basis. The additional submission should explain the magnitude of participating CDG projects, the target subscription class, the scope and structure of the guaranteed savings, the billing arrangement, and any additional outreach and education the company intends to provide." This leaves open the possibility that opt-out community renewable generation could be part of a CCA program. 

CLP introduced a proposal to the PSC that would enable New York CCA programs to automatically enroll their customers in community renewable projects, which would reduce energy supply costs to customers by reducing developers’ project costs, expand the benefits of renewable energy to low- and moderate-income customers, and incentivize the development of local renewable projects. We believe this is a critical piece and the only way to support local renewables within the current CCA framework in New York. 

As a resource to municipalities being approached by these companies, CLP has compiled a list of questions to ask if they’re considering joining a CCA. We strongly urge any municipality considering CCA to issue an RFP for administrators. It is also very important that the specific goals of the CCA, for example any clean energy or local economic development objectives, are written into the town law and signing documents. 

We need to keep pressing for change at the PSC level. And as we get a more favorable regulatory framework for CCA, we should continue to work towards the ultimate goal of local control.