DPU 19-55 Investigation into DG Interconnection

Monitored proceeding due to TEC member interests regarding interconnection of DERs

DPU 18-152 (GAS) Investigation into Gas Special Contracts

TEC participated in the proceeding and submitted a detailed comment letter into the record in support of special contracts for natural gas distribution service

DPU 18-76 (ELEC) Long Term Contracts - Offshore Wind

TEC wrote a Brief and Replay Brief related to rate-payer protections and ways to reduce costs for consumers.

DPU 18-64 (ELEC) Long Term Contracts - Large Hydro

TEC wrote a Brief and Replay Brief related to flaws in the proposed contract related to firm capacity and winter deliverability of hydropower, excessive utility remuneration, and post term renewal provisions

DPU 18-50 (ELEC) Eversource Electric PBR Metrics

TEC wrote a Brief regarding necessary changes to Eversource’s proposed PBR Metrics report to better align them with the need to contain retail costs and meet the Commonwealth’s energy goals

DPU 17-05 (ELEC) Eversource Electric Rate Case

Submitted expert testimony, participated in hearings, and wrote Briefs advocating for: rate design changes, changes to the methods used to determine maximum rate increases for any customer class; rejection of a proposed property tax tracker, more capital spending to address momentary outages, and grandfathering of certain solar rates.

The DPU Order adopted TEC’s position on the formula used to set maximum allowable rate increases which serves as a precedent for future electric rate cases. DPU also denied the requested property tax rider and granted grandfathering of certain solar rates. Despite denying the Stipulation between TEC and Eversource to address momentary outages, this resulted in the beginning of a multi-year process for the Company to address this issue.

DPU 13-05 January 2013 Retail Rate Filing of Massachusetts Electric Company and Nantucket Electric Company

If the Company’s proposed rate adjustments, including the RAAF, PAF, RDM, CapEx, and solar cost adjustment factor are approved as proposed: (1) the bill of an average Massachusetts Electric Company residential customer using 600 kWh of electricity per month will increase by $3.48 per month or 4.2%. By TEC’s calculation, the impact on C&I delivery charge will be 10%. Bill impacts for commercial and industrial customers will vary, and these customers should contact the Company at 781-907-1833 for additional information on rate impacts.

DPU 12 -126

Section 51 of An Act Relative to Competitively Priced Electricity in the Commonwealth requires the Department of Public Utilities on or before January 1, 2013, to commence a proceeding for each gas and electric distribution company to establish a cost-based rate design for costs that are currently recovered from distribution customers though a reconciling factor. Section 51 provides that the Department shall approve the redesigned reconciliation factors, after a public hearing comment period, not later than January 1, 2014. TEC among others will participate. This is a long standing issue for C&I customers. Moving to a cost based rate design may save members between 5 -15 % in delivery charges.

DPU 12-87 Petition of NSTAR Electric Company

Pursuant to NSTAR/Northeast Utilities Merger, D.P.U. 10-170, for approval by the Department of Public Utilities of the following standby rate tariffs. TEC is an active participant and filed comments in January 2013. A condition to the NSTAR/NEU merger required an investigation into standby rates. The driving force behind this condition was the general sense that the existing standby rates were discriminatory against DG customers. This investigation should have as its ultimate goal a determination of just and reasonable rates for DG/CHP, recognizing the obvious fact that partial requirements customers impose fewer costs on the utility than full requirements customers. The end result should be lower rates for partial requirements customers.

NGrid Gas case, DPU 12-65

TEC intervened in October 2012 along with the Attorney General. As proposed the Boston Gas winter peak delivery charge for G44B and G54B customers increased by 4.76 and 5.14 % respectively. The DPU order is pending although the rate was affective 11/1/2012. TEC questioned the timing of the filing, the significant increase over the previous year, the application of the 3% cap and the Revenue Decoupling Adjustment Factor, RDAF, sensitivity to weather abnormalities.

NGrid Gas case: DPU 10-55

Joining with A.I.M. and Power Options and support from the AGO, TEC (as a member of the The Energy Network, TEN) was successful in pushing back on NGrid’s proposal , DPU 10-55, to increase natural gas distribution rates and reduce potential cost impact of Targeted Infrastructure Replacements Factor, TIRF. saving customers about $70 million annually. With the recent DPU order peak/off-peak C&I distribution rates were pushed back to pre-10-55 filing ratios saving Boston Gas customers hundreds of thousands of dollars effective 11/1/11.

FERC order 1000 for Regional Transmission Planning

TEC is following this FERC order as it will impact customers. Recapping the order, it will provide the states proposing renewable generation access to the grid and allocate cost among participating NE states. Also, it gives the RTOs first refusal to build transmission in stressed areas for five years. TEC and others are recommending a three year RTO time frame vs. five. This change will allow non transmission alternatives, NTA, to participate in the solution earlier.

FERC docket EL 11-66-000

A complaint by MA Attorney General on high RTO return on equity of 11.14 %. AG recommends 9.2 % which is more in line with industry returns. TEC has signed on to the complaint noting that customers would save $110M annually now and potentially $206M in 2015 with today’s transmission build-out schedule. FERC in their comments support the AG recommendation; however the time has lapsed to a point that a second filing other than the AG’s was needed to keep open the docket. TEC filed comments supporting FERC docket 13-33-000.

Massachusetts Legislation Issues

• TEC is following and continues to support CHP policy changes
• Decoupling reform that eliminates the weather component
• More transparency and itemization of state-mandated costs

Electricity

As member of the Customer Coalition, successfully defeated use of Standby Charges for on-site generation for Massachusetts Electric Co. and advocated successfully for standby tariffs to be excluded from NGrid’s decoupling filing.

As a full intervener on NStar’s Standby Rate Filing, D.P.U. 12-87, TEC and others successfully pushed back on interim rate changes that would be a barrier for C&Is to expand and build new on-site generation

As a NEPOOL end user member, TEC continues to monitor the Forward Capacity Market, FCM, to insure that the auction clearing price reflects the real need for new generation. Through this joint effort with other NEPOOL end users, the result is the region saves over a billion dollars annually through 2017.

Joining A.I.M. and CLF, TEC proposed that RGGI be established via a competitive market and that 80% of the proceeds be used for energy efficiency programs

As a voting member of the NEPOOL reliability committee, TEC continues to question the regional Installed Capacity Requirement, ICR. The ICR and North American Electric Reliability Council, NERC, drive the need for new and updated transmission service. For each billion dollars spent, increases the retail transmission charge by one half cent.

Electric – Natural Gas communication and supply concerns

Beginning last summer with the FERC meeting in Boston, the need to assess the natural gas supply to the NE Region has become an important issue for the ISO, NEPOOL and End Users. In simple terms, the pipelines are at capacity in both summer and winter seasons and the needed for an additional line is being seriously considered. With the retirement of coal fired generation and the continued conversion of residential heating, the capacity squeeze will only get worse in the foreseeable future. TEC is very concerned with the cost impact to consumers and the best approach to minimize it.

Consumer Liaison Group, CLG, Summary

TEC continues to attend the meetings; however, the content and participation has room to improve. TEC has a current interest in discussing with other consumers: electrical – natural gas capacity, cost impact of Salem power plant and cost impact of change from single zone to 4 and 8 zones. These along with transmission expansion and upgrade costs will consume the CLG’s time.