Rate Design Testimony and Comments in Maine
Review of Central Maine Power's Proposed TOU Rates and Increased Fixed Charge
On behalf of the Maine Office of the Public Advocate, Synapse testified regarding Central Maine Power's proposed increases to the residential fixed charge and proposed design of time-of-use (TOU) rates. Synapse found that the proposed increase in the fixed charge was not justified on cost causation grounds and would have adverse impacts on low-income customers, would reduce customer control, and would dampen incentives for energy and efficiency. Synapse also found that the company's proposed TOU rates were not cost-reflective, as they lacked seasonal differentiation. Moreover, our analysis demonstrated the need to also offer TOU rates on the supply side in order to accurately reflect the cost of serving load and encourage efficient customer behavior.
Related Publication(s):
Direct Testimony of Melissa Whited and Eric Borden Regarding CMP's Request for Rate Increase
Rate Design for Stranded Cost Recovery in Maine
On behalf of the Maine Office of the Public Advocate, Synapse testified regarding the recovery of stranded costs associated with net energy billing (NEB). Our analysis found that higher fixed charges disproportionately burden the low-usage customers in a rate class and would worsen equity. Thus, Synapse recommended that stranded costs be recovered through a non-bypassable volumetric charge. Alternatively, we recommended including more kWh in the minimum charge for the residential class and implementing a differentiated fixed charge for low- and high-usage customers. Testimony submitted in Docket No. 2023-00230.
Related Publication(s):
Direct Testimony of Melissa Whited and Eric Borden
Direct Testimony of Eric Borden and Caroline Palmer
Designing Time-of-Use Rates for Delivery and Standard Offer Service
On behalf of the Maine Office of the Public Advocate, Synapse prepared comments regarding the Maine Public Utilities Commission’s investigation regarding time-of-use (TOU) rates and demand charges in Docket No. 2024-00231. In our comments, we encouraged the Commission to consider the full suite of rate options, including critical peak pricing (CPP). Further, we recommended that the Commission proceed with implementing TOU rates for residential customers in a measured manner to avoid customer backlash and adverse impacts on vulnerable populations. Specifically, we recommended beginning with actively promoted opt-in TOU rates and other time-varying rates, coupled with a default (opt-out) TOU pilot to assess customer response and impacts on vulnerable customers. This pilot would provide insights into peak reductions from opt-in versus default rates, customer bill impacts (especially for vulnerable customers), customer satisfaction, customer understanding of the rates, and other key factors. These findings would help inform the Commission’s decision on whether to transition to default (opt-out) TOU rates in the future. Authors: Melissa Whited, Caroline Palmer, and Eric Borden
Related Publication(s):
Synapse comments on the Implementation of Time-of-Use Rates for Delivery and Standard Offer Service
Synapse reply comments addressing default (opt-out) versus opt-in TOU implementation