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In a press release the New York State Public Service Commission (PSC) announced the approval of an order making changes to help protect customers to Community Distributed Generation (CDG) billing and crediting performance metrics and Negative Revenue Adjustments or NRAs. 

“Specifically, the Commission adopted two performance metrics with associated NRAs or utility financial penalties related to the timeliness and responsiveness associated with the billing and crediting of CDG programs. Further, the Commission imposed a $10 bill credit for each time a utility fails to provide a CDG subscriber’s bill within 75 days from the end of the CDG host billing period.”

“Community Distributed Generation expands consumer access to affordable, reliable, clean electricity generated from renewable energy facilities,” said Commission Chair Rory M. Christian. “This creative program creates opportunities for low- and moderate-income families and puts customers who do not own homes on an equal footing with traditional single-home customers by providing increased access to electricity generated from renewable resources and lower monthly bills. Getting the utility billing and crediting processes performing accurately and timely for these programs is of the utmost importance to ensure their success.”

“The benefits of CDG development can only be realized if the billing and crediting of CDG members is performed accurately and in a timely manner.”

DPS staff proposed six CDG billing and crediting related metrics in the Staff Proposal, but in this Order, the Commission adopts only two of those six metrics. The two metrics approved by this order are Billing Credit Timeliness  and Utility Response Time to Host Allocation Lists.  At this time the Commission declines to adopt the other four metrics proposed by staff, which include metrics that address accuracy of credit transfers/banked credits and timeliness of utility response to Host or subscriber communications. 

Excerpts from the Order:

{***} “By this Order, the Commission adopts, in part and with modifications, and denies in part, the proposed CDG billing performance metrics and NRAs. This Order adopts two utility CDG billing and crediting performance metrics related to the timely furnishing of CDG credits on customer bills and the utility response times to CDG Host allocation lists and establishes quarterly and annual reporting requirements.” {***}

{***}”the Commission addresses the most important aspects of CDG billing in this Order – billing credit timeliness to customers and host allocation list responsiveness to developers, while continuing to track performance and leaving the door open to impose additional metrics and NRAs in the future.

Metrics and Negative Revenue Adjustments to be Applied 

Billing Credit Timeliness: 

The Commission agrees with the stakeholders that billing and crediting timeliness is critical to the success of the CDG program and contributes to the overall customer experience. In line with these principles, the Commission adopts the Staff Proposal to apply bill credits within 75 days from the end of the Host’s applicable billing period for purposes of applying the NRA. This requirement would apply to both customers that are billed monthly and bi-monthly. Subscribers should be compensated for any billing delays beyond the 75-day period. Subscribers and developers have experienced significant billing errors causing customer confusion and financial impacts for both the developer and subscribers, all of which taints the CDG participation experience. However, the Commission agrees with the Joint Utilities that the NRA percentages proposed in the Staff Proposal are too stringent and should be reasonable and proportional, similar to other Commission-approved utility program NRAs. Therefore, the Commission adopts a billing timeliness NRA with the metric beginning at 95 percent instead of the DPS staff proposed 98 percent. {***}

{***}The Commission adopts the recommendation in the Staff Proposal to apply a $10 credit to the subscriber bill if a utility does not fully allocate the subscriber’s credits within the 75-day period described in the billing timeliness metric previously discussed. As recommended by NYSEIA and CCSA, and to avoid unnecessary credit banking, if the monthly credit is applied to a customer bill in the same billing cycle that CDG credits are applied, the CDG credits shall be applied first, and the monthly credit be applied after the CDG credits to offset any remaining account balance. Finally, this metric and associated monthly credit shall supersede any existing CDG billing and crediting metrics previously adopted by the Commission.{***}

Utility Response Time to Host Allocation Lists

{***} The Commission disagrees that Host allocation lists are outside the scope of the CDG billing issues discussed in the CDG Billing Order. Receipt and proper processing of the Host allocation lists is a critical first step in producing timely and accurate subscriber bills, and if there is a time lag at this juncture, the likelihood of late utility bills being sent to subscribers is increased. The Host allocation list process is a critical intermediary step in providing reasonable billing and crediting performance to consumers and therefore this process does indeed require an NRA to promote overall bill timeliness. Therefore, the Commission adopts the metrics and associated NRAs for the Joint Utilities’ response time to Host allocation lists as shown in Table 2 below. Specifically, this metric will reflect whether, within five business days (inclusive of the 2 business days to provide a confirmation of receipt of the Allocation Form), the utility will review and return the Allocation Form with either an approval of the full allocation list, or by identifying all subscriber allocations that are rejected and the reason (e.g., wrong account number or wrong name) along with list of all accepted subscriber allocations.

The Joint Utilities’ recommendation that this metric only apply to manual processing of Host allocation lists and no longer apply once processes are automated is rejected. Calculation of this metric will include all Host allocation lists communications, regardless of whether the utility has automated its Host allocation list review process, to ensure continued reasonable performance on this critical intermediary process. {***}

Order Approving Community Distributed Generation Billing and Crediting Performance Metrics  (0717/2025)
E-0082
(Proceeding on Motion of the Commission as to the Policies, Requirements and Conditions For Implementing a Community Net Metering Program.)