Letter Regarding Energy Efficiency Program
In this letter dated June 3, 2008, the New York State Department of State Division of Consumer Protection recommends that the New York State Public Service Commission (PSC) take action to ensure that an expanded gas energy efficiency program is available for Consolidated Edison’s customers by October 1, 2008. We propose that the PSC expand funding for this initiative by approximately 20% to $17 million, maintain New York State Energy Research and Development Authority's responsibility for administering the current gas efficiency programs in Consolidated Edison’s territory, and preserve its flexibility to modify this effort for consistency with its upcoming decision in the generic energy efficiency case. We also encourage Consolidated Edison to submit a detailed proposal for a gas energy efficiency program that it would administer beginning October 1, 2008.
Statement Regarding Joint Proposal
Consolidated Edison and other parties submitted a Joint Proposal on June 1, 2007, to resolve all matters in the Company's pending rate case and to establish a three-year rate plan. The New York State Department of State Division of Consumer Protection is not a signatory of that document. In this filing dated June 19, 2007, we explain that the proposal reflects many of the Division's recommendations, including rate increases that are much lower than proposed, a new gas energy efficiency program, elimination of subsidies for competitive energy suppliers and an enhanced low-income program.
Testimony Regarding Policy Issues
The New York State Department of State Division of Consumer Protection submitted this testimony on regulatory policy issues applicable to Consolidated Edison's gas operations on March 16, 2007. It explains that a new gas efficiency program should be established to provide the benefits of energy efficiency to Consolidated Edison's gas customers. The testimony also demonstrates that new regulatory policies should be established to eliminate utilities' disincentive to promote conservation, eliminate ratepayer subsidies of competitive energy companies and encourage appropriate infrastructure investment.
Testimony Regarding Accounting Issues
Consolidated Edison proposed to increase delivery rates by approximately $200 million. In this testimony, the New York State Department of State Division of Consumer Protection explained that numerous adjustments to the Company's proposals are required to accurately measure its need for rate relief. In particular, substantial adjustments are necessary to the Company's projections of pension expense, capital expenditures, and operations and maintenance expense. Overall, no more than one-half of the Company's rate increase proposal should be approved.
Testimony Regarding Profit Rate
In testimony filed March 16, 2007, the New York State Department of State Division of Consumer Protection demonstrates that Consoldiated Edison's proposed return on equity of 11.25% is excessive. We show that a fair return on equity for the Company is 9.05%.
Testimony on Low-Income Assistance Programs
Consolidated Edison proposed to maintain its low-income assistance programs and to impose a reconnection fee of approximately $200. In this testimony, dated March 16, 2007, the New York State Department of State Division of Consumer Protection explains that the Company's low-income assistance programs should be enhanced and that a reconnection fee should not be applicable to Consolidated Edison's low-income customers.
Comments Regarding Gas Efficiency Program
In these comments submitted April 20, 2007, the New York State Department of State Division of Consumer Protection explains that a gas efficiency program should be available in Consolidated Edison's service territory in the 2007 - 2008 heating season. We propose that the New York State Public Service Commission approve a cost-effective gas efficiency program with target expenditures of $14 million, to provide low-income, residential and commercial customers access to services to help reduce their gas usage. We also recommend several reporting requirements to ensure that the program is providing anticipated benefits to consumers.