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As reported previously the Massachusetts Department of Public Utilities (DPU) when it initiated the Advanced Meter Infrastructure (AMI) investigation directed the electric utilities, retail suppliers, and non-LSE third-party energy service providers to discuss potential “cost-sharing” methods to implement the use of AMI for load settlement, with the DPU specifically describing such potential “cost-sharing” mechanisms as, “sharing costs between suppliers and ratepayers,” in order to minimize ratepayer costs associated with any necessary investments to enable the use of AMI interval usage data to settle load with ISO-NE.

Surprisingly the electric utilities written comments contend that using AMI interval data to settle load at ISO New England was never included in their AMI Implementation Plans approved by the DPU.  Even more surprisingly they argue that competitive retail electric suppliers should pay the cost of EDC system upgrades associated with the AMI implementation and load settlements.

National Grid – “National Grid’s original AMI plan was approved based on a business case analysis that did not include the costs necessary to use AMI interval usage data for load settlement. National Grid has estimated these additional costs for its systems to be approximately $40 million over seven years, including both up-front implementation costs and run-the-business costs.”

“National Grid testified that its AMI deployment timeline went through 2027 and that it could use more granular data when reporting hourly load to ISO-NE ‘when we have it and are able to incorporate that into the process,’ i.e., after deployment of the AMI meters and the supporting network and back-office infrastructure, and after the Company analyzed its ability to do so. National Grid’s evidence also made clear that additional investments might be needed, beyond those proposed in its AMI Plan, to make certain products available.”

Unitil – “Unitil clearly stated, in multiple responses to information requests, that load settlement was outside the scope of its GMP [grid mod plan] and AMI replacement plans. Specifically, Unitil explained it ‘did not have any plans . . . to use smart meter data for the wholesale settlement of energy charges with hourly market prices to Municipal Aggregators and retail electric suppliers.’”

Green Energy Consumers respectfully requests that the Department to:

• Swiftly apply its large body of prior precedents and record evidence regarding benefits of time varying rates (TVR) in lieu of repeating the decades of proceedings spent on this question;
• Decline to revise the 2022 Grid Mod Order to authorize additional expenditures on AMI functionalities that had been ordered to be included in AMI Plans since 20142 and expressly formed the basis for the that order’s approval of the AMI proposals3 ;
• Order the utilities to make a compliance filing within the next month’s showing how they will ensure that their AMI Plans, as authorized for the costs identified in the Grid Mod Order, will include “AMI deployment strategies that may expedite the ability for competitive suppliers to offer TVR products” prior to additional proceedings concerning TVR for basic service and potentially transmission and distribution4 and meet the Department’s longstanding definition of AMI to include “collection of customers’ interval usage data, in near real time, usable for settlement in the ISO-NE energy and ancillary services markets” and facilitate supplier TVR programs.

NRG Energy, Mission:data, Vistra Corporation, and Base Power Company – “The question before the Department in this proceeding is whether that $1.1 billion AMI investment will be the linchpin for achieving the $950 million in projected annual savings by 2030 — or further exacerbate the affordability crisis.

To capitalize on the benefits of AMI and realize the $950 million in projected annual savings, the Department must direct the electric distribution companies (“EDCs”) to develop the back-office capability to report hourly supplier load and customer interval usage data to ISO-NE for load settlement. Without this foundational capability, municipal aggregators, default suppliers (including the EDCs), and retail suppliers, will not be able to offer TVR, and customers will not be able to earn the financial rewards that would flow from reducing peak demand or VPPs.

ISO-NE load settlement using AMI interval data is not merely a technical back-office upgrade — it is the foundational infrastructure that makes the Governor’s demand management objectives and DOER’s $950 million in savings achievable.

The need for urgency in this proceeding is underscored by two additional facts. First, the EDCs have already committed, on the record and under oath, to using actual AMI interval data for ISONE load settlement once meters are deployed. At the April 7, 2022, evidentiary hearing in D.P.U. 21-80/21-81/21-82, representatives of each EDC testified that they intended to transition from load profiles to actual metered hourly data for ISO-NE settlement as AMI deployment proceeded. The EDCs should be held to that testimony. Second, based on publicly available data, it appears that the EDCs have spent only a small fraction of the budgets preliminarily approved by the Department for customer enablement and system integration — two categories that are applicable to enabling ISO-NE settlement capabilities. Customers will not be able to control their energy costs without the EDCs developing ISO-NE settlement capabilities.

For these reasons, we respectfully urge the Department to:

• Direct the EDCs to develop the systems necessary to report hourly supplier load to ISONE using AMI interval data, calculate ICAP tags using actual metered data, and enable competitive suppliers and municipal aggregators so they can monetize the savings from customer behavior changes resulting from TVR and VPPs, with an implementation deadline of Q1 2027; and
• Reject any effort to saddle suppliers or any third party with the cost to develop the utility systems necessary to deliver the benefits of AMI, given the preliminarily approved and largely unspent budgets for customer enablement and systems integration, the sworn testimony of the EDCs’ own witnesses, and the immense and time-sensitive affordability benefits at stake.

RESA – “When it passed the Electric Restructuring Act, the Massachusetts legislature found, among other things, that “the introduction of competition in the electric generation market will encourage innovation, efficiency, and improved service . . . .”5 The General Court also declared that competitive electric markets “should open markets for new and improved technologies” and “provide electricity buyers and sellers with appropriate price signals.”

“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 more innovative products to Massachusetts customers. The ability of suppliers to offer these innovative solutions will provide substantial benefits not only to the customers adopting those solutions, but to all customers and to the transmission and distribution systems by reducing costs and increasing reliability, and will facilitate the Commonwealth’s public policy goals to support further development of “energy efficiency, renewable energy resources, demand response, electricity storage, microgrids, and EVs.”7 Thus, RESA urges the Department to require the electric distribution companies (“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-NE markets. In addition, to allow consumers and the Commonwealth to begin to realize the benefits available as soon as possible, the Department should require the EDCs to make interval data available to suppliers and for ISO-NE settlements once a customer’s AMI meter has been installed and not wait until the entire AMI deployment is complete.”