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Parties file initial comments to the Massachusetts DPU proposal regarding the implementation of time of use rates, including for default service supply.

As background on 2014, the Department concluded that implementing TVR is critical to achieving the grid modernization objectives, noting TVR’s potential to: (1) allow customers, assisted by new technologies (e.g., advanced meters, in-home displays, programmable thermostats, load control devices), to respond to the varying costs of electricity; (2) enable individual customers to save money by changing when they use electricity, based on price signals that reflect costs; (3) benefit all customers by reducing peak energy and capacity market costs; (4) increase system efficiencies and support the distribution system by reducing peak demand; and (5) provide appropriate incentives for consumers to install distributed resources such as solar photovoltaic generation, electricity storage, electric vehicles, and targeted energy efficiency and demand response.

Subsequentially on April 2, 2026, the Department of Energy Resources filed a petition recommending that the Department open an investigation regarding the implementation, design, customer experience, and integration of time-varying rates (“TVRs”). On June 30, 2026, the Department issued an order initiating this proceeding to investigate TVR rate design, customer protections, and the electric distribution companies’ (“EDCs”) TVR implementation plans, and marketing, education, and outreach (“MEO”) plans for the TVR transition. To facilitate those efforts, the Department offered an opportunity for interested stakeholders to submit comments.

Highlight of Some Parties Comments Filed:

Attorney General Office (AGO) –  “AGO respectfully requests that the Department provide stakeholders with the opportunity to: (1) issue information requests on the EDCs’ responses to the request for information; (2) submit comments on the EDCs’ Joint MEO Plan, to be filed by September 30, 2026; and (3) provide testimony on specific rate proposals that the Department is considering adopting.

The AGO respectfully requests an opportunity to review estimated bill impacts for income eligible customers and for each usage quartile of each rate class before the Department approves any TVR.”

Elements of TVR – “AGO recommends that the Department establish a default TOU rate for all customers and an opt-in CPP rate. Although DOER’s recommendation is limited to a default TOU rate, the AGO urges the Department to establish both types of rates through this proceeding, in time for full deployment of advanced metering infrastructure (“AMI”), to more effectively support peak load management and to reduce peak-related electric system costs in the near-term. This recommendation is consistent with the Interagency Rates Working Group’s (“IRWG”) recommendations. While well designed TOU rates can incentivize customers to shift load, a CPP rate sends a stronger price signal and can have a more pronounced and targeted impact. More advanced rate design offerings should also be developed and offered to customers in the future.”

City of Cambridge – “The City of Cambridge supports the Department’s investigation into time-varying rates for electricity customers and is supportive of the rollout of the advanced metering infrastructure that will make such rates possible. We believe that thoughtful rate design has significant potential to lower customer energy costs, reduce carbon emissions, help mitigate strain on the grid, and reduce the costs of the grid buildout needed to serve peak loads. These outcomes align closely with Cambridge’s work to reduce emissions, enable a transition off fossil fuels, and reduce energy burdens for our residents.”

“We also believe that the following considerations are important to the successful and equitable implementation of time-varying rates:

A commitment to extensive and accessible communication to ratepayers: The implementation of time-varying rates could represent a significant shift in how most residential ratepayers choose to use electricity. The Electric Distribution Companies (EDCs) need to provide extensive, advance communication to ratepayers of how the time-varying rate will work; provide this communication in multiple languages; and conduct targeted outreach in environmental justice communities.”

Ensuring that municipal aggregations can access, build on, and complement the rate structure: Cambridge operates one of the Commonwealth’s largest municipal aggregation programs. The implementation of time-varying rates could offer municipalities the opportunity to bring further benefits to aggregation participants.

Aligning rate design and its implementation to incentivize electrification: time-varying rates should further enable a shift to electrification, particularly for heating loads. The early success of the heat pump rates provides a foundation on which to build further electrification-oriented rate design.

Requiring “shadow” (parallel) billing during the transition to time-varying rates. As customers move onto time-varying rates, the EDCs should provide “shadow” or parallel billing that shows each customer what their bill would have been under their prior flat rate alongside their actual bill under the new rate.

The Energy Consortium & PowerOptions – “Our principal positions, each developed in the sections that follow, are summarized below:

• TVR reform should be holistic, because a framework that addresses only non-demand accounts leaves the majority of commercial load, and with it a substantial share of the Commonwealth’s near-term load flexibility potential, outside the reform. The demand metered rate classes warrant the same attention as the non-demand classes.
• The analysis described in DOER’s proposal is largely constructed around residential customer profiles, but cost and bill impact analysis should cover all customer segments. The Department should require that commercial, institutional, municipal, and nonprofit customer types be examined with the same rigor.
• The peak period should be four hours, consolidated across supply, transmission, and distribution, and subject to periodic review, which is the correct trade-off even though a single window will not be a perfect price signal for every cost component.
• ISO-NE load settlement and third-party data visibility should be treated as prerequisites rather than parallel workstreams for TVR implementation. Most of our Members do not take basic service, and without settlement-quality interval data flowing to competitive suppliers and authorized third parties, a default basic service TVR will deliver exposure to those Members without any corresponding opportunity. Customer protections and marketing, education, and outreach (MEO) should reach commercial accounts, and particularly the smaller nonprofit and community-serving organizations that take service on the same non-demand rates as residential customers.
• Price signals should be durable, because durable price signals are the only way to effectively promote adoption of distributed energy resources (DER). The Department should coordinate TVR with existing DER programs and long-term contracts and should avoid disrupting the compensation basis for assets already committed under agreements of ten to twenty years.”

GoodEnergy – Consumer Protections – “The Department should ensure that Electric Distribution Companies’ (“EDCs”) schedules to offer TVR for Basic Service supply occur no sooner than the EDCs have completed all necessary improvements to enable third-party suppliers to also offer TVR. Without this fundamental consumer protection, electricity customers of municipal aggregations interested in TVR would have no option but to leave the program. Depending on the aggregation program, leaving the program could mean forfeiting longer-term stability of prices, cleaner energy and potentially additional Low-Income Community Shared Solar discounts.

Importantly, our statement about equal timing of TVR implementation applies to consolidated billing via the rate ready method. Consolidated billing allows the third-party supplier’s charge to appear on the EDC bill, and maintaining a single bill is a very high priority for cities and towns offering municipal aggregation. Consolidated billing also allows the third-party supplier to participate in Purchase of Receivables, which is critical to allowing financial benefits such as budget billing, low-income discounts and net metering credits to be applied to the entire bill (i.e., both delivery and supply). With Rate ready consolidated billing third-party suppliers provide the EDCs the necessary inputs (e.g., per-kWh price) such that the EDCs are able to calculate a supply charge after they have read the meter.”

Additional AMI and Operational Changes Needed for TVR Supply Rates – “We highlight that such response will need to address the EDCs utilizing AMI interval data to conduct load settlement with ISO-New England, a requirement for third-party supplier TVR that we have articulated in comments in Use of Interval Data Collected by Advanced Metering Infrastructure to Settle Load with ISO New England Inc., D.P.U. 26-44.

Additionally, we have not yet seen discussion of changes needed to the Electronic Data Information (EDI) system to accommodate rate ready TVR with consolidated billing. Based on the EDCs’ commitment “to accommodate, as standard rate-ready TVR parameters, up to three daily billing periods with separate options for weekends and holidays” . . . we expect changes to EDI will be needed to allow suppliers to send different prices for different time periods, perhaps to define those time periods, and for EDCs to send to suppliers usage and billed amounts for each of those periods.”

Nexamp – Nexamp supports well-designed TVR that gives customers meaningful opportunities to manage their bills and encourages solar, storage, demand response, and other distributed energy resources (“DERs”) to respond to system needs. A successful transition, however, requires more than adopting a peak period and changing tariffs. It requires a complete, predictable, and financeable framework for customer choice, net-metering credits, data access and implementation protections. Nexamp therefore recommends that the Department:

• Reject DOER’s proposal for a monthly minimum reliability contribution (“MMRC”) imposed specifically on NEM customers who decline or leave TVR.
• Confirm that NEM credits will be valued using the applicable time-varying rates, converted to dollars, and usable across the customer’s bill.
• Pair TVR price signals with practical pathways for existing solar and community-solar projects to shift generation into priority periods, including feasible storage-retrofit and flexible-operating options.
• Evaluate TVR together with the related proposals in D.P.U. 25-200 and address their cumulative effects on existing systems and customers.
• Require robust customer-authorized data access, and penalty-free rate switching for customers and the projects serving them.”

NRG Retail Companies – “NRG Retail Companies note their strong support for the following recommendations from DOER:

1. Recommendation: Design a single, consolidated TOU peak period across supply, distribution, and transmission.
2. Recommendation: Differentiate TOU rates by season.
3. Recommendation: TOU rate design should adapt to system conditions.
4. Recommendation: Automatically enroll customers on default TOU rates.
5. Recommendation: Allow all customers to opt out of default TOU rates and provide additional bill protections — including shadow billing for all customers during their first year of enrollment and a bill-stabilization analysis for qualified low-income customers.

Discussion Of The Appropriateness Of CPP For Distribution And Transmission – “The NRG Retail Companies support critical peak pricing (“CPP”) for distribution and transmission on an opt-in basis for customers, as CPP would better align with cost causation.14 Distribution and transmission peaks are largely driven by a handful of peak hours. While a 4:00 p.m. to 8:00 p.m. window every day of the year will likely overlap with the peak, it is a more muted signal than one that correlates to the handful of peak hours of the year that are most responsible for cost causation.

Moreover, for customers served by municipal aggregators and/or retail suppliers, ISO-NE should allocate transmission costs directly to those municipal aggregators and/or retail suppliers that wish to have that option, rather than to the relevant transmission owners for those customers. This is similar to how ISO-NE allocates capacity costs today and how PJM allocates both capacity and transmission costs. If municipal aggregators and retail suppliers were allocated these costs, they would be motivated to provide their customers with the products, tools, and insights that would allow customers to reduce usage during these peak hours. As a result, these customers would reduce the transmission portion of their bills, and reduce the amount of transmission that needs to be built in ISO-NE.

Under the status quo, transmission owners simply pass these costs through to customers. Municipal aggregators and retail suppliers would have additional motivation for enabling customers to manage these costs. While the NRG Retail Companies recognize that neither the Department nor DOER has jurisdiction over such a change, the NRG Retail Companies believe there is value in the Department signaling its support for this approach and collaborating with the Massachusetts Federal and Regional Energy Affairs (“FREA”) office, NECPUC, NESCOE, and other stakeholders to explore what ISO-NE changes would be necessary to effectuate this recommendation.”

RESA –  Consumer Protections For Successful Design And Implementation Of TVRS – “Customers should be provided sufficient information to make informed decisions, including how customers can shift usage, how pricing periods work, and how to understand their bills. Customers should also be able to easily opt-out of or opt-in to the default service TVR rate. In addition, customers should be informed that competitive suppliers and municipal aggregations may have different pricing options available that may be able to better satisfy a customer’s particular needs.

Bill transparency is another key element of ensuring customers understand the impact of their choices. By their nature, TVRs are more complex pricing structures than a single cents per kilowatt hour (“kWh”) price applied to all customer usage. However, current EDC billing formats do not offer options for the billing of supply products on any basis other than a single cents/kWh price. As a consequence, customers choosing competitive suppliers who prefer a single bill have limited options available to them. Furthermore, once default service TVRs are enabled, if the current rate ready billing structure is the only option available, customers who choose a competitive supplier and that prefer a single bill will only be able to adopt TVRs that mirror default service. Conversely, if the EDCs are required to adopt bill ready billing, customers will be able to choose from a variety of competitive supply offers, including TVRs with different billing structures, that best satisfy their needs.”

Implementable Strategies For Guiding Customer Behavior- “There are several ways in which the Department can provide the appropriate signals to guide customer behavior to mitigate against creating new peaks. First, the Department could require the EDCs to establish multi-period TVRs with graduated pricing that sets the lowest price for the period in which the Department wishes to encourage the highest reductions in usage. Second, the Department could require the EDCs to stagger peak times by customer segments either by establishing different windows for different rate classes and/or for customers within a given rate class. The Department could also require the EDCs to use demand charges as a financial incentive to spread out or stagger increased usage.”

Additional Changes To Enable Customer Choice – “The Department also requested that stakeholders “identify any additional changes to AMI functionalities, billing systems, or other operational functions required by the EDCs to enable TVR supply rates for non-demand customers who receive supply from competitive suppliers or municipal aggregation providers.”12 Any innovative solution that involves shaping consumer behavior by having them respond to immediate price signals and receive appropriate credit for actions taken to reduce or avoid consumption in response to those signals will depend on suppliers having real-time access to actual customer usage data.

Supplier access to and load settlement based on the interval data available from advanced metering infrastructure (“AMI”) will revolutionize the ability of retail suppliers to offer and Massachusetts customers to adopt more innovative products. The ability of customers to choose the innovative solutions available from the competitive market will also facilitate the Commonwealth’s public policy goals by supporting further development of “energy efficiency, renewable energy resources, demand response, electricity storage, microgrids, and EVs.”13 Thus, RESA urges the Department to require the EDCs to provide: (a) electric suppliers with customer interval usage data collected by AMI in near real time; and (b) interval data for use in settlements in the ISO New England, Inc. (“ISO-NE”) markets. In addition, to allow smaller consumers to take advantage of these innovative product offerings, the Department should also adopt certain billing enhancements.”

Key Elements Of The EDCs Implementation And MEO Plans – “The EDCs’ implementation plans should be competitively neutral and ensure that they do not impede the ability of customers to choose from a wide range of TVRs and other products available from competitive suppliers and municipal aggregations. Those plans should include, at minimum, AMI deployment status, customer information system and meter data management system readiness, interval data load settlement, and billing enhancements.

In addition to the items noted above, the MEO plans should not be solely focused on the TVRs available from the EDCs. Instead, the MEO plans should provide information about TVRs generally and ensure that consumers are aware that competitive suppliers and municipal aggregations may have different product offerings available that may better suit a particular customer’s needs. To ensure the EDCs’ implementation and MEO plans take into account the interests of all stakeholders, the Department should offer an opportunity for comment on those plans.

In addition, RESA urges the Department to take a comprehensive approach and coordinate its efforts in its various related proceedings to appropriately sequence the timing of its decisions and maximize efficiencies in implementation.”

Information And Analysis – “The Department further asked stakeholders to provide information and analysis regarding serval items, including “the appropriateness of a single four-hour peak window from 4:00 p.m. to 8:00 p.m. for each day” and demand elasticity across customers groups.23 RESA does not have empirical information or analysis to offer regarding the proposed four-hour peak window. However, whatever rate design limitations the Department adopts should only be applied to EDC-administered TVR offerings. A uniform default-service peak period may be appropriate for an EDC-administered TVR framework but applying that same window to competitive suppliers would limit product innovation and customer choice in contraction of the Restructuring Act. Competitive suppliers and municipal aggregations should be free to design product offerings that work best for their customers, including non-TVR products and TVR products based on different or additional peak periods, pricing periods, seasonality, and product structures.”

See docket link 26-92 for all comments filed.