NEM submitted comments on the An Act to Implement the Recommendations of the Governor’s Ocean Energy Task Force that requires the Commission to conduct a competitive solicitation for long term contracts for offshore wind and tidal energy demonstration projects. The Commission requested comments on the statutory interpretation of the Act specifically as to whether all customers, or only distribution level customers (medium and small commercial and residential customers), should shoulder the 0.145 cent/kwh rate impact. NEM suggested that an important factor in the Commission’s determination of customer applicability of the rate increase is the concomitant issue of the treatment of customers that have chosen to purchase their energy from a competitive supplier. NEM recommended that the Commission find that the rate impact should be charged to those customers that are receiving utility commodity supply and directly benefitting from the long-term supply contracts. The costs of the long-term supply contracts should be added to the utility commodity rate. As a secondary alternative, the Commission should require that the rate impact be passed through to all customers, utility and shopping customers alike, on a non-discriminatory, competitively neutral basis through a non-bypassable charge. NEM also recommended that any Renewable Energy Credits associated with the long-term contracts should enure to the customers that pay for them, again, to ensure that shopping customers are treated in a competitively neutral manner. The full text of NEM's Comments is available on the NEM Website.

The Board will convene two legislative hearings to take comment on issues pertaining to Basic Generation Service (BGS). The purpose of the first hearing is to examine whether the retail margin currently paid by customers above 750 kw continues to serve its intended purpose and also to examine whether adjustments should be made to the commercial industrial energy pricing (CIEP) threshold. The hearing will take place August 20, 2010, at 10AM in the State House. Final comments on these issues are due September 3, 2010. The full text of the Notice is available on the NEM Website.

An additional hearing will be held on September 21, 2010, to receive comments on the utilities proposals for BGS service beginning on June 1, 2011, as well as alternative proposals. Final comments on the procurement proposals are due September 24, 2010. The full text of the Notice is available on the NEM Website.

NEM filed comments on the Commission’s Tentative Order on draft interim guidelines for Eligible Customer Lists (ECLs). In large part, the draft guidelines reflect the consensus work product of a subgroup of the electric stakeholder CHARGE group overseen by Commission Staff. The draft guidelines recommend that the utilities provide ECLs to marketers with specific minimum data elements and that the ECLs be updated on a monthly basis. NEM supported the Commission’s adoption of the Tentative Order, subject to certain recommended modifications on non-consensus items. NEM agreed with the Commission that telephone number, POLR service indicator, interval meter indicator, capacity and transmission obligations, and one-to-one mapping of accounts in the case of system-wide account number changes be fields included in the ECL. NEM urged the Commission to reconsider its proposal not to include a rate mitigation plan indicator on the ECL. The full text of NEM's Comments is available on the NEM Website.