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Eversource urges PURA to allow interim RAM rate updates after showing large swings in Millstone PPA benefit projections
Summary
Company witnesses and counsel told the authority that volatility in PPA prices — demonstrated by differences between a March MBFMCC filing and April written exceptions — produced large swings in the net PPA benefit projection and that the company requests PURA consider allowing interim rate adjustments when actual experience materially deviates.
Eversource staff told the Public Utilities Regulatory Authority that volatility in power‑purchase and market price assumptions tied to the Millstone PPA materially changed projected net PPA benefits within a few weeks, and the company asked the commission to consider a process that would permit interim adjustments to RAM/Grama rates if actual experience diverges substantially from assumptions used to set rates.
Nut graf: OCC and PURA questions showed the company’s initial March 3 MBFMCC filing (which relied on prior‑year historicals and limited known‑and‑measurable adjustments) produced a per‑kWh rate forecast materially higher than the company’s April 4 written exceptions. Eversource witnesses and counsel said that a roughly 40% change in the projection between filings reflected market volatility and that the company should be able to update rates when actual PPA outcomes differ significantly from the basis used to set them.
What the record shows: Company testimony explained that the March 3 filing used prior‑year historicals and conservative inputs; subsequent months’ actuals and updated LMP forecasts materially reduced the estimated MBFMCC rate from approximately 3.19¢/kWh (in the March submission) to about 1.82¢/kWh in the April 4 written exceptions. A company witness confirmed the change "included 3 months of actuals that were preliminarily calculated" and that updated projections drove most of the difference.
Company request to regulators: On redirect, counsel quoted the company position in the RRU 10 supplement: the company "requests that PURA update its Grama rate making process to accommodate the latest available information, including actual and forecasted information, and to allow for interim rate adjustments if and when actual experience deviates substantially from that which is put into rates." Counsel said the company was tracking actuals monthly and would notify the commission if materials changes warranted an interim update to rates.
Policy and practical note: Witnesses described the reconciliation mechanics: if a state bond or other outside revenue were received mid‑period, the company said it could be reflected through the monthly rate reconciliation process in the month cash is received; conversely, interim adjustments to MBFMCC rates could avoid rate shock when PPA outcomes swing sharply.
Ending: The exchange places a procedural request on the record: Eversource asked PURA to permit more frequent updates in exceptional circumstances to keep RAM/Grama rates aligned with volatile wholesale market realities.
