Evaluation of National Grid's Proposed Rate Design, Performance Incentives, and Cost Recovery Mechanisms
In D.P.U. 23-150, Melissa Whited provided expert testimony evaluating National Grid’s proposed electrification pricing, performance incentive mechanisms (PIMs), and capital cost recovery framework. Her testimony concluded that the National Grid’s proposed fixed-charge electrification rate would undermine efficient price signals, increase system costs, exacerbate inequities for low-income customers, and hinder the Commonwealth’s climate goals. Ms. Whited recommended rejecting the proposal in favor of more cost-reflective alternatives that support beneficial electrification without eroding conservation incentives. She also evaluated National Grid’s proposed PIMs, recommending rejection of financial rewards tied to core reliability obligations, conversion of several investment-based PIMs to scorecard metrics, and continuation of penalty-only reliability mechanisms. Finally, Ms. Whited advised against adoption of the proposed ISRE capital tracker, recommending instead that capital costs be recovered through mechanisms that better preserve cost-containment incentives.