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Default Service Supplies Sourced From ISO Spot Market Set To Increase
From the Order:
“This order approves the Liberty Utilities (Granite State Electric) Corp. d/b/a Liberty (Liberty or the Company) proposal to continue its ISO-New England market based procurement tranche of 50 percent of the load for the Small Customer Group, and 100 percent of the load for Liberty’s large Default Service Customer group (Large Customer Group), which includes commercial and industrial (C&I) customers, with some technical changes. The changes regarding market-based procurement are to be implemented for the August 1, 2025 to January 31, 2026 Default Service period and are expected to provide continued cost savings for residential and C&I Default Service customers.
This order also approves the Company’s proposal to accommodate two potential future scenarios. These potential scenarios would be (1) if the Company’s solicitation process seeking a full-service third-party contract to serve 50 percent of the Small Customer Group load results in no bids; or (2) if the Commission does not approve the winning bid to serve this load in the upcoming Default Service procurement review by the Commission.”
“II. COMMISSION ANALYSIS
In assessing the Liberty proposal to modify its Default Service procurement process, the Commission is required to consider whether the proposal is consistent with: the principles elucidated in the relevant prior Commission orders (see Order No. 24,577 (January 13, 2006); Order No 24,922 (December 19, 2008); Order No. 25,601 (November 27, 2013); Order No. 25,806 (September 2, 2015); Order No. 26,758 (January 13, 2023); Order No. 26,643 (June 20, 2022); Order No. 26,752 (December 22, 2022); Order No. 26,854 (June 30, 2023); Order No. 26,984 (March 29, 2024); Order No. 27,027 (June 27, 2024); Order No. 27,058 (October 1, 2024); Order No. 27,091 (December 27, 2024); the Electric Utility Restructuring Policy Principles governing default service in RSA 374-F:3, V(c)-(e); and the goal of cost-effectively meeting the state’s energy needs and reducing the burden on ratepayers, in RSA 378:37 and RSA 12-P:7-a. The Commission must also assess whether the resulting rates would be just and reasonable as required by RSA 374:2, RSA 378:5, and RSA 378:7.
Having reviewed the Liberty proposal, we find that the proposal meets the above-listed standards, and will produce market-based, just and reasonable, and cost-effective rates for Liberty Small and Large Customer Group residential and C&I customers. Given the ongoing broad differential between the ISO-New England prevailing monthly market prices, including all components, and the requirements contract prices being paid by Liberty, we expect that ongoing maintenance of the ISO New England market-based procurement component will offer savings for Liberty default service customers, and offer a valuable process for a market-based procurement approach. We find the Company-proposed technical adjustments related to the futures component for proxy-price development and scenario planning for failed RFPs or rejected RFPs, to be just, reasonable, and well-considered. We do not agree with RESA’s comments to the effect that the market-based procurement approach is a violation of the Restructuring Act, RSA 374-F; we point to our analysis presented in the Orders listed above as showing that this approach is just, reasonable, in the public interest, and within our authority, pursuant to the Restructuring Act and all allied statutes, to approve.
We therefore APPROVE the Liberty proposal for these reasons, for implementation in the August 1, 2025 through January 31, 2026 Default Service rate period, and for future Default Service rate periods, unless further modified by the Commission. If interested parties wish to discuss hedging-related matters with the Company over the upcoming Summer, they may make arrangements to do so and report the results of their discussions into a future Liberty Default Service proceeding.”
Order No. 28,127 Approving Modifications to Default Service Procurement (04/08/2025)
DE 24-061
(Liberty Utilities (Granite State Electric) Corp. d/b/a Liberty 2024 Default Service Solicitations)
From the Unitil Order:
“This order approves the Unitil Energy Systems, Inc. (Unitil or the Company) expansion of its ISO-New England market-based procurement tranche to 50 percent of the load for its small and medium Default Service customer groups, which includes residential and certain commercial and industrial (C&I) Default Service customers, and the implementation of a 100 percent market-based procurement tranche for its large, G1, C&I Default Service customer supply. The changes regarding market-based procurement are to be implemented for the August 1, 2025 to January 31, 2026 Default Service period, and are expected to provide cost savings for residential and C&I Default Service customers>”
“II. COMMISSION ANALYSIS”
In assessing the Unitil proposal to modify its Default Service procurement process, the Commission is required to consider whether the proposal is consistent with: the principles elucidated in the relevant prior Commission orders (see Order No. 24,511 (September 9, 2005), Order No. 24,921 (December 12, 2008), Order No. 25,397 (July 31, 2012), Order No. 26,679 (September 9, 2022), Order No. 26,694 (September 20, 2022), Order No. 26,910 (December 8, 2023); Order No. 26,973 (March 15, 2024); Order No. 27,020 (June 14, 2024), Order No. 27,059 (October 7, 2024); Order No. 27,086 (December 12, 2024); the Electric Utility Restructuring Policy Principles governing default service in RSA 374-F:3, V(c)-(e); and the goal of cost-effectively meeting the state’s energy needs and reducing the burden on ratepayers, in RSA 378:37 and RSA 12-P:7-a. The Commission must also assess whether the resulting rates would be just and reasonable as required by RSA 374:2, RSA 378:5, and RSA 378:7.
Having reviewed the Unitil proposal and the supporting data presented by Unitil, including its monthly pricing-comparison reports filed in this docket, we find that the proposal meets the above-listed standards, and will produce market-based, just and reasonable, and cost-effective rates for Unitil residential and C&I Default Service customers. Given the ongoing broad differential between the ISO-New England prevailing monthly market prices, including all components, and the requirements contract\RFP prices being paid by Unitil, we expect that the proposed expansion of the ISO-New England market-based procurement component will offer savings for Unitil default service customers, and offer a valuable process for a market-based procurement approach.
The Commission finds Mr. Pentz’s support for a 100-percent third-party procurement due to protection for market spikes unconvincing. Third party 100 percent RFP procurements come with substantial risk premiums, exacerbated by market volatility, that is costly when compared to the six-monthly average based default service offering using self-supply, which of course includes exposure to wholesale market spikes. We also do not agree with RESA’s, and the NRG Retail Companies’ comments to the effect that the market-based procurement approach is a violation of the Restructuring Act, RSA 374-F; we point to our analysis presented in the Orders listed above as showing that this approach is just, reasonable, in the public interest, and within our authority, pursuant to the Restructuring Act and all allied statutes, to approve. Importantly, we expect that this proposal will support more competitive energy market outcomes in line with the Restructuring Policy Principles incorporated by statute. See also Order No. 27,059 at 6. We find that Unitil’s market based rate projections, including proxy price development, embedded in its proposal are also just and reasonable, and will produce rates that are predictable, transparent, and reflective of energy market conditions.
We therefore APPROVE the Unitil proposal for these reasons, for implementation in the August 1, 2025 through January 31, 2026 Default Service rate period, and for future Default Service rate periods, unless further modified by the Commission. We would expect that any necessary Tariff or other modifications would be presented to the Commission, in final form, by Unitil as part of its upcoming Default Service rate proposal for the August 2025-January 2026 rate period. We also hereby ORDER Unitil to continue filing its monthly summary comparison of the monthly average ISO-New England market electricity prices with the power supply charge components for Unitil’s small and medium customer groups, pursuant to the current timing and format for these reports, in the instant DE 24-065 docket.
Regarding the OCA requests for notes used by Mr. Pentz in the Company’s oral testimony provided at the April 2, 2025 public hearing in this matter, the Commission notes that such material may be subject to trial-preparation privilege, but the OCA and the Company are free to bilaterally discuss the potential provision of this material into this Docket, if appropriate.
Order No. 28,128 Approving Modifications to Default Service Procurement (04/09/2025)
DE 24-065
(Unitil Energy Systems, Inc. – 2024 Default Service Solicitations)

