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Parties File Diverse Reply Comments in MA DPU Investigation into Gas and Electric Delivery and Bill Redesign Including Comments on DER and Net Metering
On May 11-14, 2026 a wide range of reply comments were filed in the Massachusetts investigation by the Department of Public Utilities on its own motion into gas and electric delivery charges and bill redesign.
Excerpts from parties filed reply comments:
DOER – DOER’s initial comments recommended a staggered transition to cost-reflective fixed charges to advance equity, reduce inter-seasonal bill volatility, and support electrification. Specifically, DOER recommended first transitioning the full Energy Efficiency Reconciliation
Factor (EERF) charge to a fixed charge by November 1, 2026, coincident with implementation of tiered discount rates, then transitioning the full Residential Assistance Adjustment Factor (RAAF) charge to a fixed charge by April 1, 2027. DOER supported this recommendation, among other reasons, because it will provide customers with most of the benefits in time for the 2026-2027 winter season while supporting a gradual implementation that allows customers to adapt to higher fixed charges.”
“DOER recognizes the importance of carefully managing changes to rate design but maintains that transitioning EERF and RAAF to fixed charges is an important and reasonable step to improve affordability for customers and advance decarbonization goals. First, transitioning these charges from volumetric to fixed is more cost-reflective and will improve affordability by ensuring that all customers pay their fair share. 13 Second, transitioning volumetric to fixed charges will improve the economics of heat pump and electric vehicle adoption,14 which are central to the Commonwealth’s strategy to decarbonize the building and transportation sectors that account for 74% of Massachusetts emissions. 15 Finally, even with changes to rate design, the Commonwealth’s SMART program provides a sustainable incentive structure for distributed energy resources that will continue to support the expansion of solar. 16 In short, DOER’s recommendation advances, rather than harms, the Commonwealth’s decarbonization and affordability goals.”
“The Department should balance reducing net metering credit values with the long-term cost reduction benefits of Distributed Energy Resources (DER). . . “DOER supports the Department’s approach of “appropriately balanc[ing] the benefits of incentivizing the deployment of distributed generation with the costs borne by ratepayers.” 28 Increasing the state’s renewable energy supply is one of the best long-term strategies for reducing energy costs. In addition, common-sense reforms to electric and gas delivery rates – such as cost reflective fixed charges – may impact the net metering credit value in a manner that will help manage costs to ratepayers. Specifically, transitioning RAAF to a fixed charge will reduce the net metering recovery surcharge in a cost-reflective manner and allocate program costs more equitably to net metering customers.”
Joint Utilities – The utilities who jointly filed the reply comments consisted of Boston Gas Company, Massachusetts Electric Company and Nantucket Electric Company each d/b/a National Grid (“National Grid”), NSTAR Electric Company, NSTAR Gas Company and Eversource Gas Company of Massachusetts each d/b/a Eversource Energy (“Eversource”), Fitchburg Gas and Electric Light Company d/b/a Unitil (“Unitil”), Liberty Utilities (New England Natural Gas Company) Corp. d/b/a Liberty (“Liberty”), and The Berkshire Gas Company (“Berkshire”)
“Given the complexity of potential solutions, the Companies take this opportunity to focus a portion of their joint reply comments on some proposals that could be implemented in the near-term to advance the objectives identified by the Department in opening this proceeding. Specifically, the Companies recommend transitioning the Residential Assistance Adjustment Factor (“RAAF”), the Energy Efficiency Reconciliation Factor (“EERF”) and the Solar Massachusetts Renewable Target (“SMART”) Factor for electric companies, and the RAAF and Energy Efficiency Surcharge (“EES”) for gas companies from volumetric pricing to fixed-charge recovery for at least some portion of the costs recovered through these factors (for purposes of gradualism), as these charges do not scale with individual customer consumption. The proposed phased schedule begins with RAAF, followed by EERF and EES, and SMART thereafter. The Companies recommend that the Department convene a technical session to discuss potential implementation concerns and timelines.”
“In parallel with these near-term actions, the Companies recommend that the Department advance the bill transparency and redesign phase of this proceeding to run in parallel with the rate structure reforms discussed below. As discussed during the April 1st and 3rd technical sessions, advance the bill transparency and redesign phase of this proceeding to run in parallel with the rate structure reforms discussed below. As discussed during the April 1st and 3rd technical sessions, is vital to empowering customers to adapt behavior and control their costs. The Companies support discussing opportunities for enhancements to bill design that benefit customers but are cognizant of cost and timelines to modify billing systems to incorporate such enhancements. Accordingly, as discussed below, the Companies recommend commencing this process in the near term.”
The Energy Consortium – “several stakeholders expressed support for key principles advanced by TEC in its initial comments regarding the core questions posed by the Department in its Inquiry. These principles include increased transparency, reducing bill volatility, and evaluating whether certain reconciling mechanisms should be incorporated into base distribution rates. An underrepresented issue has risen to the top of this proceeding: the need for utilities to achieve cost control and reduction to promote ratepayer affordability. TEC aligns with and supports the Attorney General’s recommendation that costs associated with the “core business of providing distribution service” be recovered through base distribution rates rather than through proliferating reconciling mechanisms. Under this approach, all distribution-related operations and maintenance expenses and capital investment costs recovered through capital trackers and reconciling mechanisms would be folded into base rates.1 Moving such costs into base rates would create regulatory lag that incentivizes utilities to control costs while providing greater regulatory scrutiny and transparency over certain utility expenditures.”
Massachusetts Institute Technology – “We want to be clear, we support the Governor’s ambitious goals that advance clean and renewable energy resources in Massachusetts, including incentives for DERs. The present net-metering program has been a sustained driver of distributed solar growth in Massachusetts, but it would not sufficiently incentivize the adoption of other DERs such as demand response, storage, and virtual power plants (Governor Maura Healey 2026); and, perhaps more importantly, it has led to a cost shift from those installing rooftop solar to those who have not, or not able to such as renters and low-income households. To design incentives that effectively compensate a diversity of DERs, we join the Attorney General’s Office and the Environmental Advocates in recommending that the D.P.U. lead a value-of-distributed-energy study that includes benefits to both network and societal benefits (such as a reduction in power sector emissions). This would build upon a previous effort undertaken in a 2015 by a “Net-Metering Task Force” whose 17-members included those from regulatory agencies, the solar industry, and utility companies. The report included a comprehensive cost-benefit analysis of various solar incentive programs in Massachusetts and explicitly recommended a “Value of Solar” study to further “inform compensation and incentives for solar” (Massachusetts Legislature 2015, pg. 15). The value of additional supply or reduced demand in the electricity system has always been time-dependent, as reflected in the wholesale electricity markets and locational marginal pricing. Supporting a diverse landscape of DERs requires that future incentives are more reflective of the time-varying value they provide to the network and the environment. If done carefully, updating the net-metering program to a time varying, cost-reflective, incentive structure would both support the future development of a diverse DER landscape in Massachusetts while improving ratepayer affordability and equity.”
Read all reply comments here.

