At oral argument, investor-owned utilities asked PURA for a clear path to recover incremental implementation costs associated with standing up Performance-Based Ratemaking (PBR) — including new staff, contractors and IT systems for Integrated Distribution System Planning (IDSP) and PIM tracking — while consumer advocates urged caution and said such costs belong in base-rate proceedings.
Eversource and UI said the IDSP and PBR obligations will require ‘‘incremental headcount, new IT systems and contractors’’ before those costs can be included in base rates. Counsel asked PURA to allow recovery of such near-term, but potentially material, costs through the revenue adjustment mechanism (RAM) or a similar timely process rather than making companies wait until the next litigated rate case. ‘‘If we can demonstrate they truly are incremental and if we meet our burden of proof, we should have an opportunity to present to you a request for cost recovery,’’ Vincent Pace said.
Nut graf: The utilities framed these costs as ‘‘but for’’ compliance expenses: costs driven by new regulatory obligations rather than by ordinary run-the-business decisions. OCC and intervenors strongly disagreed, arguing that hiring staff and building reporting systems is part of a utility’s normal operations and therefore appropriately belongs in base distribution rates. OCC told the authority it opposes RAM recovery for these costs; CIEC and other intervenors urged PURA to require utilities to file estimates so the authority and stakeholders understand potential rate impacts before implementation begins.
OCC attorney Tom Wheel said that while utilities will incur new costs, those costs are typically base-rate items and should be vetted in a rate case. ‘‘The appropriate treatment would be for the company to come in during its rate case and demonstrate the incremental costs it has incurred or will incur in the rate year and ask for an adjustment to base rate O&M,’’ he said. CIEC asked that PURA require utilities to submit implementation-cost estimates promptly; counsel said the record contains no comprehensive estimate of PBR implementation cost and urged the agency to request one.
Utilities replied that the magnitude is likely material and that waiting for a rate case could create cash-flow pressure and slow implementation of the regulatory framework PURA is ordering. Eversource and UI offered to provide estimates if ordered by PURA.
Ending: PURA will consider the competing proposals. Utilities asked for RAM or similar interim recovery for demonstrably incremental compliance costs; consumer advocates said those costs should be proven in a rate case, and they asked PURA to require early estimates of implementation cost so stakeholders can assess rate impacts before the framework is implemented.