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Program administrators recommend discretion, not universal clawback, for ESS enrollment incentives
Summary
Program administrators said enrollment incentives in Construct 5 are small relative to long‑term performance payments and recommended keeping the ability to claw back payments only in high‑abuse cases (for example, third‑party owners bulk‑unenrolling customers), citing administrative cost and customer hardship concerns.
Program administrators and the Connecticut Green Bank urged the Public Utilities Regulatory Authority to avoid a blanket clawback for enrollment incentives in the Energy Storage Solutions (ESS) program, recommending instead case‑by‑case discretion for high‑risk situations.
“Keeping a customer enrolled is the best option,” said Ed Kranich of the Connecticut Green Bank, explaining the rationale for a clawback is to protect ratepayers from nonperformance and early unenrollment, but warning that universal enforcement would be costly and could impose undue burdens on homeowners who sell their homes, suffer a death or bankruptcy, or otherwise face circumstances beyond their control. Kranich said the administrative cost of pursuing small repayments (for example, recovering a prorated ~$400 from a residential non‑grid‑edge participant) could outweigh the dollars recovered.
Logan Terakani of United Illuminating reinforced that construct‑5 is deliberately performance‑oriented: the enrollment incentive is an upfront, modest payment while the majority of customer value accrues through performance payments paid over a 10‑year commitment. “The long term financial position is overwhelmingly tied to continued participation in the program,” Terakani said, describing a hypothetical 20 kW/30 kWh home system where performance incentives are worth many times the upfront payment.
Green Bank and program administrators listed scenarios where a clawback could be appropriate, notably when a third‑party owner or aggregator enrolls large numbers of customers, collects enrollment incentives, and then bulk‑unenrolls—an outcome they said is unlikely but plausible enough to warrant discretionary authority. They recommended retaining the ability to pursue callbacks in those high‑abuse cases while preserving the simplified, performance‑based structure of Construct 5 for typical participants.
The Authority's stakeholder questioners asked for ballpark estimates of administrative costs and the program administrators committed to follow up with interrogatory responses and further correspondence. The meeting record shows the Authority will consider those quantitative follow‑ups as part of the docket's IR schedule.
