STATE OF CONNECTICUT

PUBLIC UTILITIES REGULATORY AUTHORITY

February 18, 2020
In reply, please refer to:
Docket No. 19-07-01
Christopher R. Bernard
Manager, Regulatory Policy & Strategy, CT
Eversource Energy
P.O. Box 270
Hartford, CT 06141
Mark P. Colca, P.E.
Manager, Pricing
United Illuminating Company
180 March Hill Road
Orange, CT 06477
Re:

Docket No. 19-07-01– Review of Statewide Shared Clean Energy Facility
Program Requirements

Dear Messrs. Bernard and Colca:
The Public Utilities Regulatory Authority (PURA) is in receipt of the January 17,
2020 compliance filings from the Connecticut Light and Power Company d/b/a
Eversource Energy (Eversource) and United Illuminating Company (UI; collectively,
Companies) filed in response to Order No. 1 in the Decision dated December 18, 2019
(Decision) in the above-referenced proceeding.
Order No. 1 required the Companies to submit within thirty (30) days 1) a SCEF
Rider for both Subscribers and Subscriber Organizations based upon the Modified
SCEF Program Requirements, and 2) a filing requesting any clarifications needed to
begin billing system modifications to implement the SCEF Rider. The Authority finds
that the submissions by the Companies did not meet the requirements of Order No. 1,
as discussed below.
During the proceeding, the Participants, including Eversource and UI, had ample
opportunity to present information on any program design concerns and/or
implementation challenges expected, and to discuss their opinions and suggestions
regarding the SCEF program, including: technical meetings on September 26, October
22 and October 29, 2019; numerous written comments and interrogatories; written
exceptions to the draft decision; and, finally oral arguments on December 12, 2019. 1 At
1 Notably, Interrogatory EL-37 specifically afforded Eversource the opportunity to propose their own
SCEF Program Requirements.
10 Franklin Square, New Britain, CT 06051
An Equal Opportunity Employer
www.ct.gov/pura

 no point did the Companies raise a concern with meeting the Order No. 1 requirements.
Further, the time to make changes to this program has since passed, including the time
to make a request for reconsideration and the time to appeal the Authority’s Decision.
After reviewing the Order No. 1 compliance filings, the Authority finds that neither
of the Companies’ SCEF Subscriber Riders were up to the quality standards we would
expect from the Companies. The only SCEF Subscriber Rider Terms and Conditions
submitted in the Companies’ compliance filing were those already contained in the first
twenty pages of the Modified SCEF Program Requirements, of which only a small
portion is relevant to Subscribers. The Companies shall revise the SCEF Subscriber
Rider Terms and Conditions to include only such information relevant to the SCEF
Subscriber tariff rider.
Additionally, UI explicitly acknowledged its failure to meet the Authority’s
requirements regarding the submission of a Subscriber Organization Rider, stating: “UI
did not include a draft Subscriber Organization Rider with this filing.” Further, instead of
filing the requested clarifications, UI suggested that each of the Companies will be
requesting “numerous program changes” and therefore “does not have any clarifying
questions regarding the on-bill crediting process at this time.” The Authority reiterates
that “…the Modified SCEF Program Requirements provide sufficient information for the
EDCs to begin any billing system modifications necessary to provide Subscriber credits
under the program.” Decision, p. 11. The Authority has afforded the Companies the
opportunity, through Order No. 1, to identify additional clarifying information the
Companies need to begin the necessary billing system modifications to provide
Subscriber Credits by July 1, 2021. The Companies shall begin the billing system
changes necessary to implement an on-bill Subscriber Credit upon receiving the
necessary clarifications in response to the Companies’ Compliance Filing for Order No.
1. All required clarifications regarding billing and Information Technology (IT) systems
related to the SCEF program shall be addressed in the above referenced docket, not in
Docket No. 19-07-01EE01.
As for Eversource’s submission for Order No. 1, the Authority appreciates
Eversource’s effort to identify points of clarification. Ultimately, however, Eversource
also did not meet the requirements because it did not provide appropriate SCEF
Subscriber Rider Terms and Conditions, as described above. Furthermore, Eversource
indicated in its compliance filing that aspects of the SCEF program should be
reconsidered for various reasons that could have been and were discussed during the
original proceeding. Eversource further suggests that the work groups should discuss
alternative structures for the SCEF program. The Authority reiterates, in no uncertain
terms, that the topics for consideration in Docket No. 19-07-01RE01, and the associated
working groups, shall be limited to the topics listed in the Notice of Proceeding dated
January 17, 2020 in that docket. The Authority considers all other matters related to this
program, unless specified in the Modified SCEF Program Requirement, to be closed.
The Authority’s response to the clarifications sought by Eversource are appended as
“Attachment A”.

 Due to the above, the Authority is ordering a technical meeting on Friday,
February 28, 2020, at 1p.m., at the Agencies’ offices, Ten Franklin Square, New Britain,
Connecticut, which cannot be postponed, to discuss any further clarifications needed
regarding the direction provided by the Authority in this correspondence and to reiterate
the Authority’s orders. On or before March 17, 2020, 2 the Companies will re-submit all
items ordered in Order No. 1 of the Decision meeting all of the requirements. If the
EDCs do not comply with Order No. 1, on or before March 17, 2020, the Authority will
issue a Notice of Violation (NOV), pursuant to General Statutes of Connecticut § 16-41,
to impose daily fines in-line or above previous fines for similar violations. If the
Companies do not put a good faith effort into the re-filed documents, the Authority will
issue an NOV proposing to impose daily fines after March 17, 2020 until documents
compliant with Order No. 1 have been submitted.
The Authority reiterates that the time for seeking further changes to items
addressed in the Decision has passed. The Authority is attempting to give the
Companies as much guidance as possible, but progress cannot be made if the
Authority’s orders are not followed. For all future submissions related to the SCEF
program, if the documents are not filed timely and with a good faith effort at compliance,
the Authority will issue a NOV to impose daily fines on the Companies until the
documents are submitted meeting all of the Orders’ requirements. Order No. 2 – 4 are
also due on or before March 17, 2020, i.e. within ninety (90) days after the issuance of
the Decision.
The Authority reminds the Companies that this program and docket exists to
cost-effectively allocate up to 25 megawatts to SCEFs and to “provide savings to
specific categories of customers, particularly customers with low- to moderateincome (LMI), low-income serve organizations, and customers who reside in
environmental justice communities.” (Decision, section III(B), emphasis added).
Sincerely,
PUBLIC UTILITIES REGULATORY AUTHORITY

Jeffrey R. Gaudiosi, Esq.
Executive Secretary
cc:

Service List

2 This date is 90 days from the date of the December 18, 2019 Decision. This date provides a 60-day
extension of time from the compliance date set for Order No. 1.

 Attachment A
Requested Clarifications of SCEF Program Requirements
SCEF Output
The Companies shall calculate the “estimated annual output from the SCEF” 3 using the average
estimated annual output from the SCEF over the term of the tariff with the Subscriber
Organization, i.e. 20 years. The Authority will evaluate any mismatch between SCEF production
and Subscriber credits annually through Compliance Filings No. 9.
SCEF-Related IT System Modifications
The Companies have testified at length in the above referenced proceeding, Docket Nos. 17-1203, 18-08-33, and 18-06-15, among other proceedings, to the administrative burden and cost
associated with both the LREC/ZREC and Virtual Net Metering (VNM) programs, in particular
the current manual billing process used for both programs. Tr. 10/22/19, pp. 77-81. The
Companies also testified to the complex administration and manual billing process of the current
SCEF Pilot. Tr. 10/22/19, pp. 87-88. The Authority heavily weighed these comments in
modifying the SCEF Program Requirements.
The Authority ordered a simple on-bill Subscriber Credit that requires one calculation of the
Companies per Subscriber and requires the Subscriber Credit to remain on the Subscriber’s
account in perpetuity, subject to Appendix A, A1.1 of the Modified SCEF Program Requirements.
The Authority recognizes that the Decision also directs the Companies to make payments to the
Subscriber Organizations, which were not originally included in DEEP’s proposed SCEF
Program Requirements. The Authority expects the Companies to leverage their existing billing,
data management, and other IT systems pertaining to the LREC/ZREC program for the
payment of the SCEF Subscriber Organizations under the Modified SCEF Program
Requirements.
As stated in the body of this correspondence, the time has passed for reconsideration of the
Authority’s Decision. However, the Authority will answer clarifying questions in response to the
re-submitted Compliance Filings No. 1 to provide the necessary information to enact PURA’s
Decision.
“The Authority expects implementation costs related to these billing system changes to be
significantly below the previous cost estimates provided in response to EL-10 related to the
proposed SCEF Program Requirements: $4 million for Eversource and $900,000 for UI.”
Decision, p. 19. Simply put, the Authority is unlikely to approve cost recovery for the IT
modifications needed for the SCEF program, for either Eversource or UI, at or above their
original cost estimates provided in response to EL-10. In Eversource’s case, the Authority is
unlikely to approve cost recovery anywhere near $4 million. The Authority will consider
approving cost recovery for the addition of staff member(s) to administer the SCEF program.
Lastly, the Authority appreciates Eversource’s concern for administrative efficiency and interest
in comprehensively evaluating the Company’s billing, data management, and IT systems. The
Authority plans to take a comprehensive look at the future of the Companies’ billing, data
management, and IT systems in Docket No. 17-12-03RE02. The Authority looks forward to
Eversource’s active participation on this topic in that docket.

3 Exhibit B – Modified SCEF Program Requirements, dated December 18, 2019, p. 15.

 Eversource’s Fixed Credit Clarifications
a. Yes. See Section 7.1 of the Modified SCEF Program Requirements. See Section 3.2
and 6.1 for direction on calculating the “annual Subscription kWhs.”
b. Yes. See Appendix A, A2.1(b) of the Modified SCEF Program Requirements.
c. The Subscriber Credit will be a fixed monthly amount, specific to the individual customer,
“…for the duration of the contract term of the associated SCEF unless or until the
Subscriber’s service is terminated or the Subscriber choses to end the Subscription.”
Modified SCEF Program Requirements, Appendix A, A1.1.
d. Subscribers enrolled as part of the “EDC-administered identification and enrollment
process” (i.e. opt-out Subscribers) shall continue to receive the fixed monthly Subscriber
Credit as outlined in Appendix A, A1.1 of the Modified SCEF Program Requirements
regardless of whether they continue to meet the qualifying criteria of the program. The
Companies may recommend how best to ensure continued qualification of voluntarilyenrolled Subscribers in Compliance Filings No. 5.
e. Cost recovery is subject to the conditions laid out in Section Q of the Decision.
Section 6.1
The Companies may provide recommendations regarding the specific concerns Eversource
identified in its January 17, 2020 correspondence regarding Section 6.1 of the Modified SCEF
Program Requirements through Compliance Filings No. 5. Eversource Correspondence
1/17/20, p. 3. The Companies must detail how any proposed solutions to these concerns
comply with the relevant statutes.
On-Site Load
SCEFs are not eligible to serve on-site load.