New York PSC Guidelines on Presenting Solar Savings

Effective December 1, 2017, solar developers in New York are required by the New York Public Service Commission (NYPSC) to meet precise guidelines (PDF Download) when presenting savings estimates.  Genability has reviewed these requirements and we have made some data upgrades for New York so that our solar customers can comply with these new requirements without any change to their API integration.  First, let’s review the new savings requirement:

When marketing materials or information conveyed to mass market customers or potential mass market customers includes savings estimates, CDG and mass market on-site DG providers must include, in addition to any other forecasts used, a forecast using the following baseline: a three-year average of actual historical utility rates for the three most recent calendar years for which data is available, for the customer’s actual utility and service class. The provider may choose to apply an assumed escalation rate of up to 3% per year to this baseline in generating a forecast; if the provider does so, it must disclose the escalation rate used. The forecast generated must estimate savings for the same potential contract term as any other forecast provided. This forecast must be presented with similar prominence to other forecasts and all forecasts must be appropriately labeled to permit customers to understand their source.”.

The New 3 Year Average Tariffs

Genability has created 6 new tariffs that reflect the three-year average of utility rates (listed below) that can be used to calculate solar savings.  To calculate the three year average, we took an approach that incorporates average rates as mandated by the PUC without losing the mechanisms (rates that vary by season, tier and territory) that drive electricity pricing.  Assuming equal usage across all three years we calculate the 3 year, time-weighted average rate for each of the following components:

  1. Fixed Rates
  2. Seasonal and/or Tiered kWh Rates
  3. All-hours kWh Rates by Territory

The resulting PSC compliant rate maintains the seasonal and tiered components that impact the solar savings calculation, while averaging the remaining components equally over three years.  These new tariffs should appear in our customer’s tariff dropdown lists and appear at the bottom of the list (whether it’s sorted by customerLikelihood or alphabetical order).

Utility Tariff Code Tariff Name Master Tariff Id
Consolidated Edison EL1-PSC Residential and Religious – 3 Year Average for 2017 3296036
Orange & Rockland 1-PSC Residential – 3 Year Average for 2017 3296037
New York State Electric & Gas SC1-PSC Residential – 3 Year Average for 2017 3296050
National Grid – New York SC1-PSC Residential and Farm – 3 Year Average for 2017 3296051
Central Hudson Gas & Electric 1-PSC Residential – 3 Year Average for 2017 3296080
Rochester Gas & Electric 1-RSS-PSC Residential – 3 Year Average for 2017 3296079

Impact on Solar Savings

We have performed an analysis of the Avoided Cost of Power (ACP) in each New York utility by using these new 3-year average rates and comparing it to Genability’s comprehensive tariff model (more about our solar savings methodology).  The impact depends on both the specific prices in a utility/region and of Intelligent Baselining on the distribution of usage across the hours in the year.

The 3 Year Average delivers higher ACPs for Consolidated Edison’s Zone J (+5.6%) and National Grid – New York’s Capital Region (+6.5%).  This reflects both the effect of higher prices during the Polar Vortex of 2014 and the application of the average price for each hour (as opposed to the hourly usage and daily prices used by Genability’s model).  Expect that higher ACP to diminish next year as the 2014 prices are replaced by 2017 prices in the 3-year average.

In contrast, the 3 Year Average delivers lower ACPs for New York State Electric & Gas West region (-9.5%) and Rochester Gas & Electric (-4.6%).  For these utilities, the current Genability approach calculates a higher ACP because our climate-specific typical usage profiles assign more usage to days when prices are higher.  In addition, the western part of the state was less impacted by the variable price rises in the winter, like 2014’s Polar Vortex.

If you are interested in the results of our ACP analysis, please email us at support@genability.com and we’re happy to share our findings.

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