PURA 2023 Annual Report

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PURA 2023

ANNUAL
REPORT
February 14, 2024

Connecticut Public
Utilities Regulatory
Authority
PURA 2023 ANNUAL REPORT

TABLE OF CONENTS
Introduction 1
Purpose of this Report 1
PURA's Mission 2
PURA's Statutory Responsibilities 2
PURA's Organizational Structure 4
PURA’s Public Engagement & Outreach 6
PURA's Docket Database 7

2023 By the Numbers 9

Section 1: Rate Case Updates 10


Revenue Decoupling 11
Rate Cases vs. Electric Rate Adjustment Mechanisms (RAM) 12
Completed Rate Cases 13
2023 Aquarion Rate Case (Docket No. 22-07-01) 13
2023 United Illuminating Rate Case (Docket No. 22-08-08) 14
Active Rate Cases 15
Additional Rate Cases on the Horizon 17
PURA Video Tutorials about Rate Cases 17
Section 2: Performance Based Regulation 19
The Expanding Scope of Utility Regulation 19
PBR Investigations in Connecticut 21
PBR Phase 1 Decision (Docket No. 21-05-15) 22
PBR Phase 2 Topics and Procedural Plan 26
PBR Implementation in Rate Cases 32
Section 3: Grid Modernization 35
Key Grid Modernization Topics in 2023 35
Progress Advancing Energy Affordability 36
Progress Enabling Decarbonization 45
Progress Supporting Resilience and Reliability 49
Progress Growing the Green Economy 58
2023 Clean & Renewable Energy Program Updates 66
PURA 2023 ANNUAL REPORT

Table of 2023 Grid Modernization Decisions 68

Section 4: The Electric Sector 70


Electric Supply Costs 71
Key Electric Sector Topics in 2023 72
Safety: Assessing Accident Response Operations 72
Affordability: Annual Rate Adjustment Mechanisms 75
Reliability: Storm and Emergency Event Planning 78

Section 5: The Natural Gas Sector 85


Key Natural Gas Sector Topics in 2023 86
Updates to Connecticut’s Gas Pipeline Safety Regulations 87
Lost and Unaccounted for Gas Report (LAUF Gas) 87
Table of 2023 Natural Gas Sector Decisions 90

Section 6: The Water Sector 91


Key Water Sector Topics in 2023 92
Water Conservation 92
Water Industry Consolidation 94
Table of 2023 Water Sector Decisions 96

Section 7: The Telecomm. & Utility Pole Sector 97


Key Telecomm. & Utility Pole Topics in 2023 98
Enabling Broadband 98
Utility Pole Safety 99
Ensuring Continuity of Public Telecommunication Resources 100
Table of 2023 Telecomm. & Utility Pole Sector Decisions 105

Section 8: The Office of Education, Outreach & Enforcement


108
(EOE)
EOE Organization 108
Licensing & Certification Unit 108
Mediation & Enforcement Unit 109
Education & Outreach Unit 111
Working Groups 113
PURA 2023 ANNUAL REPORT

Section 9: Legislative Updates 115


Updates on 2023 Legislation 115
PURA 2023 Annual Reports to the General Assembly 116

Section 10: Status of Decisions in Appeal 117


The Decision Appeal Process 117
PURA Decisions in Appeal 118

Appendix 1 - Standard Docket Procedure Guide 122

Appendix 2 - 2023 PURA Decisions - Excel File Attchd.

Appendix 3 - 2023 Clean & Renewable Energy Report Attchd.


PURA 2023 ANNUAL REPORT

INTRODUCTION

PURPOSE OF THIS REPORT


Over the 13 years since the Public Utilities Regulatory
Authority (PURA or the Authority) was established through
Connecticut Public Act 11-80, An Act Concerning the
Establishment of the Department of Energy and
Environmental Protection and Planning for Connecticut’s
Energy Future, PURA's mission continues to evolve. In
addition to its statutory charge to ensure that Connecticut’s
investor-owned utilities, including the state’s electric, natural
2023
gas, and water companies, provide safe, clean, reliable, and
affordable service, PURA also now oversees programs,
policies, and tariff designs that advance the state’s energy,
economic, and climate goals. These responsibilities play a
vital role in ensuring public health and safety and a robust
economy in Connecticut.

Given the growing importance of enhancing utility service


and realizing the state’s climate goals, transparent
communications and accessible stakeholder resources have
become increasingly important, not just for frequent
participants in PURA’s processes, but also for elected officials,
policymakers, and members of the public alike. In recent
years, PURA continues to prioritize improvements to its
communications and engagement opportunities with both
the public and the diverse set of stakeholders that engage in
our proceedings. Notably, in 2020, the Authority established
the Office of Education, Outreach, and Enforcement (EOE),
which is tasked with directly engaging with non-traditional
stakeholders on matters before PURA and fielding important
ratepayer complaints and inquiries. Moreover, the Authority
recently established a program to provide compensation to
underrepresented groups to participate in PURA processes.

PURA also offers a number of public resources available to


stakeholders through the release of its Quarterly Newsletters,

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PURA 2023 ANNUAL REPORT

rate case video series, live-streamed events, PURA 101 Workshops, and this report (Annual
Report or Report). This Annual Report provides a concise summary of the Authority’s
work completed in the previous year, and shares insights into the year ahead. It provides
both quantitative metrics on the Authority’s work, as well as abridged versions of key
decisions across all of the industries regulated by PURA. The Report is organized around
the key public service sectors that PURA regulates, with a section for each sector and
additional sections providing a specific overview of the Authority’s high impact work on
rate cases, performance-based regulation, and PURA’s Equitable Modern Grid Initiative.

The Annual Report also summarizes the reports submitted to the General Assembly in
the previous year, and reports progress on specific PURA investigations required by
recent legislation. The Annual Report also includes an update on the work of EOE and on
all appeals of prior PURA decisions. Finally, the Annual Report addresses major
upcoming topics in the current year, such as new program launches, anticipated rate
proceedings, and the transition to performance-based regulation.

The Authority intends to use this Report to increase stakeholder engagement with and
awareness of ongoing and future proceedings. As a quasi-judicial agency, PURA can only
make decisions based on the record evidence placed before it in any given proceeding.
The Authority’s decisions affect a wide variety of stakeholders both directly and indirectly
and are, therefore, made more robust with increased awareness and participation from
all stakeholders. The Annual Report will evolve year over year, based on feedback
received by the Authority, in order to best communicate with all stakeholders.

PURA'S MISSION

The Public Utilities Regulatory Authority (PURA) is statutorily-charged with ensuring that
Connecticut's investor-owned utilities, including the state’s electric, natural gas, water,
and telecommunications companies, provide safe, clean, reliable, and affordable utility
service and infrastructure. PURA’s mission is essential to advancing the state’s energy,
economic, and environmental goals and is critical to maintaining public health and
safety as well as a robust economy.

PURA'S STATUTORY RESPONSIBILITIES

PURA is a quasi-judicial agency that interprets and applies the statutes and regulations
governing all aspects of Connecticut’s investor-owned utility sector. PURA replaces the
former Department of Public Utility Control (DPUC) and, along with the Bureau of Energy

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PURA 2023 ANNUAL REPORT

and Technology Policy, is part of the Energy Branch of


the Department of Energy and Environmental
Protection (DEEP). DEEP was created in July 2011 and
brings together the state's Department of What does “Quasi-
Environmental Protection (DEP), the DPUC, and an Judicial” mean?
energy policy group that had been based at the This means that PURA’s
Office of Policy and Management.
decisions are legally
Among other things, PURA sets the distribution rates binding on the utilities it
charged by investor-owned utilities, advances the regulates.
modernization of the electric distribution system, sets
rates for customer-owned renewable energy
resources, regulates the retail electric supplier
market, implements federal requirements for natural gas pipeline safety, ensures
adequate water system infrastructure investments, reviews mergers and acquisitions,
provides education and outreach for consumers, and regulates the expansion of certain
telecommunications infrastructure.

The majority of key statutes that govern the work of PURA are found in Title 16 of the
General Statutes of Connecticut (Conn. Gen. Stat.), “Public Service Companies.” Several of
the most referenced statutes are summarized by Table 1 below.

Table 1: PURA's Governing State Statutes

Statutory Section Purpose

§ 16-9 Governs the issuance of orders by PURA.

Requires PURA to regulate the condition of the plant, equipment,


and manner of operation of all public service companies. Enables
§ 16-11 PURA to order reasonable improvements, repairs or alterations to
companies’ plant or equipment, or changes to the manner of
operation as necessary in the public interest.

PURA has jurisdiction over the method and manner of construction


§ 16-18 of wire, poles, conductors, and fixtures for the transmission of
electricity.

§ 16-19 Establishes PURA’s ratemaking authority.

Sets forth the principles PURA must apply when regulating public
§ 16-19e
service companies.

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PURA 2023 ANNUAL REPORT

§ 16-41 Authorizes PURA to issue civil penalties.

Requires public service companies to obtain our approval prior to


§ 16-43
taking certain actions (listed in the statute).

Requires PURA to oversee quality and reliability of electric service.


§ 16-244i Obligates the electric distribution utilities to provide safe and
reliable service to customers, among other things.

§ 16-245 Establishes PURA’s authority to regulate electric suppliers.

PURA'S ORGANIZATIONAL STRUCTURE

All matters and proceedings before the Authority are presented to a panel of PURA’s
three commissioners. Each commissioner is appointed by the Governor, typically to a four
(4) year term, with consent from the legislature.

The Authority's staff assist the Commissioners in reviewing evidence submitted into the
record, issuing information requests like interrogatories, and conducting cross-
examination during hearings, and propose recommended decisions to the commissioner
panel. A decision on a particular proceeding is reached by a majority vote among the
three commissioners.

The Governor, in each odd-numbered year, selects the chairperson of PURA from among
the sitting commissioners. Every June, the commissioners hold a vote to elect a Vice
Chair of the Authority for a one-year term. Per Conn. Gen. Stat. § 16-2(f), appointment as
Chair comes with the responsibilities of coordinating all the activities of the Authority
and organizing staff into divisions to maximize efficiency and effectiveness. The Chair also
approves hiring, contracting, and other administrative resources. Currently, this position
is filled by Marissa P. Gillett, with John “Jack” Betkoski III as Vice Chair, and Michael Caron
as the third Commissioner. PURA staff are currently organized into five distinct offices, as
shown in Figure 1 below:

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PURA 2023 ANNUAL REPORT

Figure 1: PURA's Operational Organization

All docketed work that is primarily related to public policy or that is technical in nature
(i.e., adjudicated investigations) is assigned to the Office of Technical and Regulatory
Analysis (TRA), which supports the technical and substantive elements of each of the
sectors included in this Report. Other docketed work that is primarily legal in nature is
assigned to the Office of Administration and Operations, which houses PURA’s
Adjudications unit. Together, TRA and the Office of Administration and Operations make
up PURA “decisional staff”.[1]

Each docket is assigned technical staff from TRA based on expertise, and at least one
legal advisor (attorney) from the Office of Administration and Operations, with other staff
assisting as necessary and appropriate. Other matters, such as routine licensing, dispute

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PURA 2023 ANNUAL REPORT

mediation, or enforcement, are assigned to the Office of Education, Outreach, and


Enforcement (EOE). As discussed in greater detail in Section 8, EOE staff are separate
from TRA Staff and are subject to ex parte limitations in communicating with other
Authority staff. This allows EOE to also participate in PURA dockets as a separate party,
particularly when a docket is related to rate amendments, performance-based
regulation, or other alternative forms of regulation.[2]

The Office of Legislative & Governmental Affairs serves as PURA’s primary contact for the
Connecticut General Assembly, news media, and other interested stakeholders. The office
handles all inquiries and interview requests from these parties to ensure the Authority’s
goals, services, activities, and programs are communicated in an accurate, transparent,
and timely manner to the benefit of Connecticut ratepayers.

Finally, the Office of Federal, Regional and State Affairs monitors the federal, interstate
and interregional policies that affect the wholesale energy market, and the reliability and
security of energy transmission and distribution. This team is also tasked with matters
related to in-state siting, including representing the PURA chairperson as her designee to
the Connecticut Siting Council and serving as technical staff in reviewing relevant
applications (e.g., construction method and manner applications).

PURA'S PUBLIC ENGAGEMENT & OUTREACH


The Authority’s work impacts all of Connecticut’s businesses and residents, making
outreach to the public essential. Ensuring that the relevant stakeholders are able to
provide input into PURA’s proceedings is critical to preparing robust and equitable
decisions. In 2023, legislation was passed granting PURA with expanded resources to
equitably increase engagement with stakeholders, which PURA has begun to implement.
Most significantly, Section 15 of Public Act 23-102, An Act Strengthening Protections for
Connecticut’s Consumers of Energy (Public Act 23-102), directed PURA to establish a
process for awarding compensation to eligible stakeholder groups for participation in
certain proceedings of the Authority. Specifically, this legislation authorized PURA to
distribute up to $1.2 million per year across proceedings. This important provision will
help stakeholders who otherwise do not have the financial resources or time necessary to
participate in PURA proceedings ensure that their perspectives are represented with the
Authority. Stakeholder groups eligible for this funding include those representing
residential customers who live in environmental justice communities, hardship
customers, small business customers, or nonprofits representing any of those groups.
Through Docket No. 23-09-34, PURA Implementation of the Stakeholder Group
Compensation Provisions of Section 15 of Public Act 23-102 (Stakeholder Compensation
Docket), PURA established the formal process for groups applying for and being awarded
funds. As of January 3, 2024, eligible stakeholder groups may now apply for
compensation in relevant proceedings.

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PURA 2023 ANNUAL REPORT

In addition to the stakeholder compensation provisions, Section 15 of Public Act 23-102


also authorized PURA, in coordination with the Office of Consumer Counsel (OCC), to
distribute up to $1 million per year to allow stakeholder groups to attend trainings
designed to support public understanding of the Authority’s decisions, public service
company regulations and operations, and the roles and functions of PURA and OCC. The
Authority has begun collaborating with OCC to identify such trainings and other
resources and will direct stakeholder groups to them as they are available.

Section 30 of Public Act 23-102 also authorizes PURA to distribute up to $1 million per
year to organizations or individuals providing legal assistance to residential customers
negotiating bill or arrearage payment agreements with their utilities. As discussed in
Section 3 of this report, PURA has heavily focused on ensuring that there are effective and
fair solutions and programs available to customers who have unpaid bills, and/or cannot
afford their utility bills. Nonetheless, these funds will make sure that vulnerable
customers who need further assistance navigating these programs can access these
resources. The Authority is working to establish a program through Docket No. 23-11-04,
PURA Implementation of the Legal Services Funding Provisions of Section 30 of Public
Act 23-102, and expects that the funding distribution process will be operational soon
after completion of the docket.

These efforts are in addition to multiple public outreach and engagement efforts
implemented by the Authority in recent years, including the creation of educational
videos, the publication of quarterly newsletters that highlight recent decisions and
upcoming procedural events, and the PURA 101 Roadshow, which brings live
engagement to public audiences statewide. The Authority is committed to ongoing
education and will continue to modify and enhance its resources so that they can best
serve the needs of the public.

PURA'S DOCKET DATABASE


All documents related to each docket's procedural Access PURA's
record are filed in PURA's online docket database. To Docket Database
search the record of any docket, simply type the docket
number into the search box. To access the database,
click the button to the right.

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PURA 2023 ANNUAL REPORT

[1] Decisional staff work directly with the PURA Commissioners on decisions and, therefore, are
subject to the Authority’s prohibition on ex parte communications (i.e., decisional staff are unable to
discuss substantive matters related to an open investigation with docket Parties, Intervenors, or
Participants).

[2] Conn. Gen. Stat. § 16-19(a) states that the Authority may require a portion of its staff to serve as a
party to any proceeding. Conn. Gen. Stat. § 16-19j(b) mandates that such an assignment shall occur
when the proceedings relate to: (1) a rate amendment proposed pursuant to section 16-19 by a public
service company having more than seventy-five thousand customers; (2) the approval of
performance-based incentives pursuant to subsection (b) of section 16-19a; or (3) the approval of any
alternative form of regulation pursuant to section 16-247k.

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PURA 2023 ANNUAL REPORT

2023 BY THE NUMBERS


Metrics and data tracking are essential tools to understanding trends and progress. The
below are key quantitative statistics related to PURA’s work product and other activities
in 2023, included to help stakeholders better understand PURA’s roles & responsibilities.
Natural
Gas
6% Stakeholder
Grid Engagement Efforts
Modernization
15% Electric 38 Opportunities for Written
31% Comments

100 39 Technical Meetings


55 Hearings
5 Public Comment Hearings
Water
13%
Decisions 20 PURA 101 Workshops
16,969 Customer Complaints
Addressed

Telecom, Poles
& Small Cell
Apps.
35%
72 Issued $15.7M
Total
in Fines
Staff

Contains: 545 | 409 $52.5k


96 Final Decisions EDCs
Dockets Dockets
2 Interim Decisions Opened Closed
1 Supplemental Decision
$199k
1 Declaratory Rulings
1,110 Call
Motion Before
Rulings You Dig

+362
Additional Licensing, Includes: $1.175M
Certification, and
Pipeline
Submetering $1.915M
Safety
Application Decisions in Restitution
+
$1M
in Compliance
+ $2.777M
Over 2,000 $1.48M Electric
Total pages of In payments to Suppliers
analysis across Operation Fuel
decisions

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PURA 2023 ANNUAL REPORT

SECTION 1:
RATE CASE UPDATES
One of the core functions of PURA is regulating the
distribution rates of Connecticut’s investor-owned electric,
natural gas, and water utility companies. These companies
are granted monopoly franchise rights over the distribution
and delivery infrastructure of their respective services because
they are considered to have the characteristics of a natural
monopoly; in other words, it is more efficient and cost-
effective to grant an exclusive retail franchise to one company
rather than many. As a result, the role of the regulator is to
serve as a proxy for the forces of competition to balance this
monopoly control and to ensure that the companies provide
safe, adequate, and reliable service to customers at affordable
rates. Specifically, PURA regulates the rates utilities charge
customers to recover the costs of owning and maintaining
distribution infrastructure only, while the cost of energy
supply is instead a product of the New England regional
wholesale market, which is regulated by the Federal Energy
Regulatory Commission.

In order to change their distribution rates, a utility company


must file a detailed application to amend its rates with the
Authority. PURA is statutorily charged with conducting an
adjudicated proceeding to investigate any rate application.
This investigation is called a “rate case” and is one of the core
functions of the Authority. Connecticut law requires PURA to
conduct a rate case for public service companies at certain
intervals and within a certain amount of time. After receiving
a rate application, PURA has 270 days to complete a rate case
proceeding for water companies, and 350 days for electric
and gas companies, otherwise the rates proposed by a
company automatically take effect.[1]

During each rate case, PURA’s objective is to determine


whether the rates proposed by the utility are just, necessary,
and reasonable, though, by law, it is the company’s
responsibility to prove that its proposed rates are just and

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PURA 2023 ANNUAL REPORT

reasonable.[2] Notably, this responsibility requires the company to provide more than
mere assertions or documentation of expenses. Rather, the company must provide
credible and sufficient evidence and clear explanations that demonstrate that the
proposed rate change is just and reasonable and that the costs arise from prudent and
efficient management of the utility. The Authority is obligated to deny any portion of the
company’s request that is not proven to be just and reasonable or is more than sufficient.
Indeed, it is only in demonstrating that a requested rate is just and reasonable that the
Authority can ensure that the public interest is protected as is required by Conn. Gen.
Stat. § 16-19e.

Authority staff with expertise in accounting, finance, utility regulation, engineering,


economics, and policy scrutinize the evidence provided by the company, starting with its
proposed rate base. A utility’s rate base includes the facilities, infrastructure, and other
capital investments made by the utilities to supply safe, reliable, and cost-effective
service to customers. Utilities finance these investments through a mixture of debt and
equity, and then seek to recover these investments through rates paid by ratepayers. The
Authority conducts a prudency review by analyzing the evidence provided by the utility
and other Parties to the rate case proceeding to ensure that all costs included in the rate
base are reasonable. Specifically, Authority staff carefully review all relevant filings,
conduct public cross-examination of the utilities’ technical experts and other witnesses
in hearings, issue interrogatories (i.e., written questions directed at specific parties) in
advance of those hearings, audit the financial reports filed by the companies, and review
public comment.

In addition to recovering their rate base, utilities are also afforded the opportunity to earn
a specified rate of return (ROE) on prudent investments through rates, as dictated by
centuries-old U.S. Supreme Court precedent.[3] The ROE is set by examining several
factors including current economic and market conditions, analytical models and cost of
equity capital methodologies, ROEs of similar companies in other jurisdictions, and the
company’s financial risk and credit rating.

The Authority then multiplies the rate base by the ROE and adds in any pass-through
operations and maintenance expenses to determine the annual revenue for the utility
(called the revenue requirement). The revenue requirement is what the utility is allowed
to recover through various charges on customer bills. These charges can take various
forms, including fixed customer charges (e.g., $/customer), demand charges (e.g., $/kW
measured in a particular period), and volumetric charges (e.g. $/kWh).

Revenue Decoupling
Any under- or over-collection of a utilities’ approved annual revenue requirement is
subject to reconciliation pursuant to the state’s revenue decoupling law.[4] Decoupling
ensures that the utility receives its annual revenue requirement, regardless of its annual
sales. Ultimately, decoupling is intended to address the disincentive to support

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PURA 2023 ANNUAL REPORT

conservation efforts, such as energy efficiency measures, and other measures that reduce
sales, such as distributed energy resources, that exists for the utilities when their revenue
is tied to their sales.

For electric and gas utilities, the reconciling rate component is known as the revenue
decoupling mechanism (RDM). For water utilities, the reconciling rate component is
known as the revenue adjustment mechanism (RAM). The Authority reviews and
compares a utilities revenue each year with its approved revenue requirement and
authorizes a charge or credit, as appropriate, through the RDM or RAM, as applicable, to
reconcile any difference from the preceding year. The charge or credit is applied for one
year.

Rate Cases vs. Electric Rate Adjustment Mechanisms (RAM)

The Authority also reviews rates through additional mechanisms. For electric and gas
utilities, this includes a review of the charges related to the supply through the standard
service and last resort offer for electric customers and the purchased gas adjustment for
gas customers. For electric utilities, this also includes a review of transmission and
additional distribution-related charges through the annual rate adjustment mechanisms
(RAM). Whereas a rate case is used to determine the expected revenue requirement a
utility needs to recover the cost of providing safe and reliable distribution service, the
electric RAM is used to recover and reconcile any costs not included in base distribution
rates. Included in the electric RAM are any costs or revenues associated with clean
energy programs directed by statute, arrearage management programs, and
transmission costs incurred by the EDC, among other costs. These costs cannot be
charged through base distribution rates and are instead reconciled on an annual basis
and charged to customers through separate rate components that are included on the
delivery side of customers’ monthly bills. Figure 2 below summarizes these distinctions.

Figure 2: Understanding Rate Cases vs. Electric RAM Proceedings

Rate Case Electric RAM


Analysis based on the prudence of
Reviews actual costs and revenues
utility costs, and the the
from the previous year to
reasonableness and sufficiency of
determine if there was an over- or
rates
under-collection of revenues
Reviews core capital expenses and
operating costs
VS. Reviews utility costs not included in
the rate base
Adjusts base distribution rates
Adjusts only specific distribution
Initiated as needed, but typically
rate components and transmission
every 4 years with the statutorily
Initiated annually
required utility review per Conn.
Gen. Stat. §16-19a

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PURA 2023 ANNUAL REPORT

Ultimately, rate cases and rate adjustments are some of the most important tools that
the Authority yields because their outcomes affect all residents, businesses, critical
infrastructure, and industries within a utility’s service territory. For more information on
the EDCs’ 2023 RAM decisions, and how differences in expected and actual revenues are
reconciled each year, see the discussion of the Rate Adjustment Mechanism in Section 4
below in this Report.

COMPLETED RATE CASES

In 2023, the Authority completed full


2023 Rate Case Quick Facts
prudency reviews and issued decisions in
both the Aquarion Water Company Aquarion (Docket No. 22-07-01)
(Aquarion) and The United Illuminating
207,000 Customers
Company (UI) rate cases. Both decisions are
Requested Revenue Requirement:
the result of rigorous discovery and analysis
$236 million annually
described above, which also included
Requested ROE: 10.35%
hundreds of interrogatories, weeks of Approved Revenue Requirement:
hearings including hours of cross $196 million annually
examination and testimony by topical Approved ROE: 8.70%
experts, detailed audits of financial
statements, and multiple public comment
United Illuminating (Docket No.
hearings. The Authority’s decisions present 22-08-08)
the fulfilment of its duties to ensure that
approved rates are sufficient to cover the 341,000 Customers
Requested Revenue Requirement
companies’ prudently incurred costs, plus a
Increase: $332 million over three
reasonable rate of return, while protecting
years
the public interest. Summaries of the
Requested Year 1 Revenue
decision dated March 15, 2023, in Docket No.
Requirement: $460 million
22-07-01, Application of Aquarion Water
Requested ROE: 10.20%
Company of Connecticut to Amend Its Rate Approved Revenue Requirement:
Schedule, (Aquarion Decision), and the $385 million annually (i.e., the
decision dated August 25, 2023, in Docket multi-year rate request was
No 22-08-08, Application of The United denied)
Illuminating Company to Amend Its Rate Approved ROE: 9.1% with a 0.47%
Schedule, (UI Decision) are provided below. conditional reduction

2023 Aquarion Rate Case (Docket No. 22-07-01)


On August 26, 2022, the Aquarion Water Company of Connecticut (Aquarion or
Company) filed a rate application with PURA in accordance with Conn. Gen. Stat. § 16-19
in Docket No. 22-07-01, Application of Aquarion Water Company of Connecticut to
Amend its Rate Schedule (Aquarion Application).[5] Aquarion currently provides water

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PURA 2023 ANNUAL REPORT

service, including fire protection service, to approximately 207,000 customers in 56


Connecticut municipalities. Initially, Aquarion requested an ROE of 10.35%[6] and an
annual revenue requirement of $226 million, but later increased its request to $236
million. The Authority conducted an extensive investigatory process involving four public
comment hearings, several days of field audits and inspections, seven in-person days of
evidentiary hearings, two days of late filed exhibit hearings, oral arguments, and the
issuance of several hundred discovery requests (i.e., requests for further information). At
the conclusion of that process, on March 15, 2023, the Authority issued a Decision
approving an ROE of 8.70% and an annual revenue requirement of $196 million for the
rate year commencing on March 15, 2023. The authorized revenue revenue requirement is
an approximately $40 million reduction from
Aquarion’s request, as the Authority found that
Additional Aquarion Rate Case
the Company failed to meet its burden of
Decision Resources
demonstrating that the requested revenue
requirement and return on equity were just Decision Summary Document
and reasonable. This outcome protects the Final Decision
public interest by preventing customers from Regular Meeting Recording
having to pay for costs that Aquarion did not Aquarion service territory
sufficiently justify. Key components of the map
Aquarion Decision are further summarized
here.

2023 United Illuminating Rate Case (Docket No. 22-08-08)


On September 9, 2022, UI filed an application with PURA to amend its existing rates in
accordance with Conn. Gen. Stat. § 16-19 (UI Application) in PURA Docket No. 22-08-08,
Application of The United Illuminating Company to Amend its Rate Schedule.[7] UI
currently provides electric service to over 341,000 residential, commercial, and industrial
customers in 17 towns and cities in the southwestern part of Connecticut. UI’s application
included a requested ROE of 10.20%, and a base distribution revenue requirement
increase of $131 million over the next three years.[8]

The Authority conducted an extensive investigatory process involving multiple rounds of


pre-filed testimony, several days of field audits and inspections, 13 in-person days of
evidentiary hearings, two days of late filed exhibit hearings, legal briefings and reply
briefs, a draft decision, exceptions to the draft decisions and oral arguments, and the
issuance of several hundred discovery requests (i.e., requests for further information). At
the conclusion of that process, on August 25, 2023, the Authority issued a Final Decision,
approving an ROE of 9.10%, subject to an aggregate forty-seven (47) basis point reduction,
and an annual revenue requirement of $384.87 million for the rate year commencing on
September 1, 2023, including a base distribution increase of $22.96 million. The reduced
ROE and revenue requirement were found to be appropriate as the Authority determined

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PURA 2023 ANNUAL REPORT

that UI did not meet its burden of justifying the


requested revenue requirement and ROE Additional United Illuminating
requested in the company’s application. This Rate Case Decision Resources
outcome protects the public interest by Decision Summary Document
preventing customers from having to pay for Final Decision
costs that United Illuminating did not Regular Meeting Recording
sufficiently justify. Key components of the United Illuminating service
Decision in Docket No. 22-08-08 are further territory map
summarized here.

ACTIVE RATE CASES

In 2023, PURA received rate case applications from Connecticut Water Company (CWC),
as well as from Connecticut Natural Gas Corporation (CNG) and the Southern
Connecticut Gas Company (SCG) (together, Avangrid Gas Companies), jointly. Robust
public engagement and comment have been priorities in both proceedings, as
demonstrated by the multiple opportunities for public comment offered through live
sessions conducted in the communities and held virtually, during lunchtime and evening
hours, and the opportunity to submit comments in writing at any time. Until a decision is
reached in each docket, PURA is unable to comment substantively outside of the formal
noticed proceedings; however, the procedural progress of each case is provided in the
timelines in Figure 3 below. Differences between schedules result from the difference in
the statutory deadlines (270 days for water and 350 for gas), other docket schedule
conflicts, and/or needs of the individual rate case.

PURA 2023 ANNUAL REPORT

15
PURA 2023 ANNUAL REPORT

Figure 3: Active Rate Case Progress and Next Steps


Days to
Statutory Deadline
Dkt. No. 23-08-32 Dkt. No. 23-11-02
Connecticut Water Co. Avangrid Gas Companies
October 3, 2023 November 3, 2023
Application Filed & Rolling
270 350 Application Filed & Rolling
Discovery Begins Discovery Begins

January 10, 2024


November 1, 2023
Public Comment Hearing 1
241 275 Public Comment Hearing 1

January 17, 2024


November 27, 2023
Public Comment Hearing 2
215 245 Public Comment Hearing 2

December 14, 2023 February 16, 2024


Public Comment Hearing 3 &
Deadline for Public 198 253 Public Comment Hearing 3 &
Deadline for Public Comment
Comment

April 22 - May 10, 2024


January 23 - January 31, 2024 155
Evidentiary Hearings 150 Evidentiary Hearings

May 24, 2024


February 9, 2024 155 Evidentiary Record Closes
Evidentiary Record Closes 141
June 10, 2024
March 11, 2024 127 Briefs Due
Briefs Due 110
September 4, 2024
May 29, 2024
31 35 Proposed Final Decision (tent.)
Proposed Final Decision (tent.)

June 28, 2024 October 18, 2024


Regular Meeting 1 0 Special Meeting
(Final Decision Adoption) (Final Decision Adoption)

October 18, 2024


June 29, 2024
Statutory Deadline
0 0 Statutory Deadline

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PURA 2023 ANNUAL REPORT

ADDITIONAL RATE CASES ON THE HORIZON


In the next 12 months, there is the potential for PURA to adjudicate additional rate
amendment proceedings, incremental to the CWC and Avangrid Gas Companies’ cases.
As described above, rate cases are a key regulatory mechanism for improving utility
service and affordability. While they may result in rate increases to account for
incremental investment in infrastructure, inflationary pressures, and other cost drivers,
rate cases also remain the best tool that regulators have to ensure utility costs are
contained from a long-term perspective and that the utilities are being managed with
efficiency and care. They provide an opportunity to both regulators and other
stakeholders for careful scrutiny of all parts of a utility’s business operation, which also
helps improve transparency and accountability.

Though formal opportunities for public comment and participation will not be available
until these rate cases are officially filed, PURA continues to emphasize the importance of
proactive and transparent public engagement. Members of the public, legislators,
representatives of various companies or industries, municipalities, and all other interested
stakeholders are encouraged to view the PURA rate case page and to familiarize
themselves with related resources on the various components of a rate case.

PURA Video Tutorials About Rate Cases


Click the links in each circle to learn more.

Overview of The Why and


Ways to Get
Rate Cases & How of
Involved In a
Why They Setting Utility
Rate Case
Matter to You Rates

How is my bill Review of


Parties in a
affected by a Storm Costs in
Rate Case
rate case? a Rate Case

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PURA 2023 ANNUAL REPORT

[1] Conn. Gen. Stat. § 16-19(a).

[2] Conn. Gen. Stat. § 16-22.

[3] The utility is also allowed to recover, without an additional return, certain operation and
maintenance costs, such as labor.

[4] Conn. Gen. Stat. § 16-19tt.

[5] Aquarion’s last rate application was submitted on March 28, 2013, in Docket No. 13-02-20,
Application of Aquarion Water Company of Connecticut to Amend Its Rates.

[6] The September 24, 2013 Decision in Docket No. 13-02-20 previously set Aquarion’s ROE at 9.63%.

[7] UI’s last rate application was submitted on July 1, 2016, in Docket No. 16-06-04, Application of The
United Illuminating Company to Increase its Rates and Charges.

[8] UI proposed $91.055 million in additional revenues in the initial rate year, $20.120 million in rate
year 2, and $19.466 million in rate year 3. In total, this represented an increase over the currently
allowed base distribution revenues of approximately 35%.

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PURA 2023 ANNUAL REPORT

SECTION 2:
PERFORMANCE BASED REGULATION
THE EXPANDING SCOPE OF
UTILITY REGULATION

At both the national and state levels, the scope of utility


regulation has expanded beyond safety, reliability, and
affordability and has evolved to now also include the cost-
effective achievement of certain public policy goals. States
across the country are implementing policies and programs
to reduce greenhouse gas emissions and to modernize
electric distribution systems. In Connecticut, Public Act 08-98,
An Act Concerning Connecticut Global Warming Solutions,
set a goal to reduce economy-wide emissions to 80% below
the 2001 level by 2050. Additionally, the Connecticut General
Assembly has directed PURA and the utilities to develop and
implement multiple programs in pursuit of Connecticut’s
public policy goals that include renewable energy
deployment, energy storage, electric vehicle charging, energy
justice, resiliency, and more. More recently, PURA catalyzed
Connecticut’s grid modernization efforts through the 2019
establishment of the Equitable Modern Grid Framework in
Docket No. 17-12-03, PURA Investigation into Distribution
System Planning of the Electric Distribution Companies, (EMG
Framework), deploying programs and regulatory procedures
across a range of topics from reliability and resilience
standards to zero emissions vehicles, as discussed in Section
3.

However, the legacy business model and operations of the


EDCs are fundamentally at odds with such trends in public
policy. The EDCs’ ability to meet the core requirements of
delivering safe, clean, reliable, and affordable electric service
to customers is becoming increasingly complex and
challenging in the midst of significant industry change and
the present and future impacts of climate change.

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PURA 2023 ANNUAL REPORT

Technology advances and falling costs Figure 4: Historical Evolution of


have accelerated the adoption of Utility Regulation in Connecticut
distributed energy resources (DERs),
1998
giving customers greater control over Public Act 98-28:
their ability to generate and consume CT deregulates its
electricity independently from the grid. electric market 2007
Public Act 07-242:
Additionally, the proliferation of DERs
CT decouples the
requires a more distributed electric grid 2011
Public Act 98-28: electric and gas
that can better accommodate and CT's former utilities’ distribution
manage bidirectional flows of energy Department of revenues from the
volume of sales
and is likely to require additional Environmental
investment to upgrade systems and Protection (DEP),
Department of 2019
infrastructure to optimally integrate Dkt. No. 17-12-03
Public Utility Control
and utilize these resources. Further, (the PUC), and an PURA establishes the
these conditions are all occurring energy policy group EMG Framework and
against a backdrop of increasingly that had been based launches the
at the Office of reopener dockets.
severe and frequent weather events.
Policy and
With every aspect of the economy and Management are 202 0
customers’ daily lives dependent on combined to form Public Act 20-5
reliable access to electricity for power, DEEP. Requires PURA to
heating and cooling, internet service, research and
2021 consider financial,
and so much more, it is essential that Dkt. No. 21-05-15:
performance-based
any electricity outage be minimized to PURA initiates
incentives, penalties,
the greatest extent possible. Such a investigation to
and metrics to use in
establish a
necessarily high bar may be regulating the EDCs
Performance-Based
increasingly difficult to meet in the face Regulation 2023
of an electric grid in transition and the Framework for CT. Dkt. No. 21-05-15
Authority issues
more extreme temperatures and more
2024 Phase 1 PBR Decision
frequent or intense storms associated and officially
Dkt. No. 21-05-15
with climate change. RE01, RE02 & RE03: launches Phase 2
PURA conducting
Against this backdrop and in
ongoing
recognition of these trends, in 2020, the investigations into
General Assembly enacted Public Act PBR Phase 2 topics.
20-5, An Act Concerning Emergency
Response by Electric Distribution Companies, The Regulation of Other Public Utilities
and Nexus Provisions for Certain Disaster-Related or Emergency-Related Work
Performed in The State (Take Back our Grid Act), in 2020. This landmark bipartisan
legislation required PURA to, among other things, initiate a proceeding to research and
consider financial, performance-based incentives, penalties, and metrics to use in
regulating the EDCs. In other words, PURA is required to design a performance-based

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PURA 2023 ANNUAL REPORT

regulatory framework (PBR Framework) that cost-effectively incentivizes the EDCs to


achieve all the outcomes desired from Connecticut’s electric grid, including but not
limited to: reliability, safety, affordability, emergency responsiveness, cost-efficiency,
equity, customer satisfaction, municipal engagement, resilience, and the advancement
of the state’s environmental and climate policy goals. This PBR Framework will provide a
set of tools to reform legacy regulatory structures to enable innovations within modern
power systems.

PBR INVESTIGATIONS IN CONNECTICUT


On May 25, 2021, the Authority initiated Docket No. 21-05-15, PURA Investigation into a
Performance-Based Regulation Framework for the Electric Distribution Companies, to
investigate, develop, and adopt this PBR framework in Connecticut. To help ensure a
successful outcome, the Authority established a two-phase process. The purpose of
Phase 1 was to: (1) consider regulatory goals and (2) desired public outcomes to inform a
PBR framework; (3) evaluate the current regulatory framework in Connecticut to
examine which incentive mechanisms and regulatory components may not be
functioning as intended or are no longer aligned with the public interest, and to identify
specific areas of utility performance that should be targeted for improvement; (4) assess
which regulatory mechanisms can best address the specific areas of interest; and (5)
identify specific performance metrics, where appropriate.

On April 26, 2023, the Authority issued a Decision in Docket No. 21-05-15, summarized
below, concluding Phase 1 and formally launching Phase 2 by initiating three reopener
dockets, each focused on further investigating a distinct element of PBR:

Docket No. 21-05-15RE01: Revenue Adjustment Mechanisms


Docket No. 21-05-15RE02: Performance Mechanisms
Docket No. 21-05-15RE03: Integrated Distribution System Planning

Through these three Phase 2 proceedings, the Authority continues to collaborate with
stakeholders to streamline and/or refine elements of the existing regulatory framework,
develop incentive mechanisms to better address specific objectives or areas of utility
performance, and implement other improvements to the regulatory framework that
meet the goals and outcomes.

The PBR Framework is anticipated to alter the way utilities are regulated in Connecticut.
The legacy regulatory framework used to ensure safe and reliable electricity at
reasonable prices from capital-intensive electricity monopolies is now adjusting to a
wave of disruptive technological advances that impact the way utilities earn revenues
and what value customers expect from their own EDC. Indeed, the Authority views PBR
as a means to revisit the principles of utility regulation and to re-apply these core tenets

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PURA 2023 ANNUAL REPORT

in the context of an increasingly decarbonized, digitized, and distributed electricity


system. The benefits of PBR converge around three main issues shown by Figure 5:

Figure 5: Objectives of PURA’s PBR Proceedings

1. 2. 3.
Establish a Improve EDC Better alignment
comprehensive, performance on between the EDCs'
dynamic framework various financial and rate of return and the
public policy metrics public interest

Identifying regulatory Establishing Tying EDC rate of


goals, outcomes and transparent EDC return to performance
metrics that can performance metrics metrics and outcomes
adapt to a changing tied to financial and in addition to the
energy, technology, public policy outcomes traditional cost of
utility, and social such as GHG reductions service model
environment. and customer
empowerment.

PBR Phase 1 Decision (Docket No. 21-05-15)


As introduced above, Docket No. 21-05-15, PURA Investigation into a Performance-Based
Regulation Framework for the Electric Distribution Companies, was initiated by the
Authority on May 26, 2021, pursuant to Section 1 of the Take Back our Grid Act, with the
purpose of developing a PBR Framework for Connecticut’s electric utilities. After
retaining a consultant to provide additional supporting expertise in PBR framework
development, the Authority announced a two-phase approach to the proceeding, where
Phase 1 would establish a foundation from which to implement modifications and/or
refinements to the current regulatory framework in Phase 2.

Throughout 2022, PURA held two public comment sessions and four stakeholder
workshops, issued five requests for written comments, and published two concept white
papers and a straw proposal in pursuit of the Phase 1 steps. The Authority’s rigorous
analysis and stakeholder input collection during this time culminated in the Authority’s
Phase 1 Final Decision, issued on April 26, 2023. The results of this Decision are discussed
below.

Goals and Outcomes


Identifying and implementing strategies for encouraging and enforcing utility
performance requires a foundation of specific regulatory goals and desired public
outcomes. This base then informs the metrics used to measure the EDCs’ performance.
Figure 6 displays this structure.

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PURA 2023 ANNUAL REPORT

Figure 6: PBR Goals-Outcomes Hierarchy Framework

Through this hierarchy, broad regulatory goals, which are high-level by nature, are
broken down into clear and measurable actions and results, giving PURA a transparent
lens through which to evaluate whether and how the goals are being achieved. While
goals represent the “big picture” objectives for utility regulation, outcomes are a more
specific set of factors that are closely related to utilities’ operations and business
decisions, and metrics are the most specific and fundamental indicators of progress
toward outcomes, and ultimately, goals.

The goals, and outcomes adopted by the Phase 1 PBR proceeding are the product of
significant stakeholder input and are designed with the interest of ratepayers and
benefits to the public in mind. They also have broad applicability to all utility regulatory
matters allowing them to guide current and future utility regulation in Connecticut. The
selected goals are rooted in the longstanding and vital regulatory goals of safety,
reliability, and affordability, as well as the four objectives of the EMG Framework. The
selected goals are described in Table 2 below.

Table 2: PBR Goals and Definitions Established in Phase 1

Goals Definitions

Excellent Operational Achieve the highest standards for EDC performance in terms of
Performance efficiency, reliability, resiliency, and supply.

PUblic Policy Meet state-level GHG emissions, decarbonization and DER deployment
Achievement targets and enhance environmental protection and equity measures.

Beyond traditional customer satisfaction metrics, empower EDC


Customer
customers to take greater control of their energy services (e.g., deploying
Empowerment and
DERs and other grid-edge technology, reducing their carbon footprint,
Satisfaction
etc.) and expenditures (e.g., lowering their monthly utility bill.

Reasonable, Equitable, Ensure customers across all socioeconomic classes receive reasonable
and Affordable Rates rates and equitable access to the same products and services.

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PURA 2023 ANNUAL REPORT

It is important to understand that there is inherent conflict between and within some
legacy regulatory goals and the EMG objectives. For example, the achievement of public
policy goals such as decarbonization may require additional costs that could strain the
achievement of affordable rates in the short term. Such tension between goals cannot be
resolved through pursuit of a “perfect” regulatory goal design; rather, finding an
appropriate balance of such potential conflicts is both the work of the Phase 2
proceedings and the ongoing work of providing, regulating, and advocating for just and
reasonable public utility services. In other words, the apparent tension between the
above goals is a fundamental aspect of utility regulation.

Following the selection of these four regulatory goals, PURA, with input and feedback
from participants and stakeholders, identified a set of priority public outcomes using a
set of five factors:

Participant and stakeholder priorities;


Alignment with EMG objectives and other public policy goals;
How well the proposed outcomes are supported by the existing regulatory
framework;
Magnitude and timing of public benefits; and
Feasibility of outcome success through alternative regulatory mechanisms.

The result is a set of nine stakeholder-supported priority outcomes, shown by Table 3


below, that will facilitate progress and measurable performance toward the regulatory
goals, while ensuring flexibility and a comprehensive approach.

Table 3: PBR Priority Outcomes Established in Phase 1

Goals Definitions

Business Operations and Investment Efficiency


Comprehensive and Transparent System Planning
Excellent Operational Performance
Distribution System Utilization
Reliable and Resilient Electric Service

Social Equity
Public Policy Achievement
GHG Reduction

Customer Empowerment and Customer Empowerment


Satisfaction Quality Customer Service

Reasonable, Equitable, and


Affordable Service
Affordable Rates

Each EMG Framework docket, and all other dockets in the electric sector, can now be
identified to support specific regulatory goals and priority outcomes. Figure 7 below
provides a visualization of the relationship between the regulatory goals and priority
outcomes, the EMG dockets, and other existing mechanisms. As with all of its work, the
Authority will strive to balance competing and, at times, potentially conflicting

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PURA 2023 ANNUAL REPORT

objectives in Phase 2 in pursuit of optimally achievable results for Connecticut


ratepayers.

Figure 7: Visual Map of PBR Goals and Outcomes’ Relationships with EMG

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PURA 2023 ANNUAL REPORT

Ultimately, the regulatory goals and priority


outcomes adopted in the Phase 1 PBR Decision Additional PBR Phase 1
are rooted in, and have broad applicability to, Resources
all utility regulatory matters and, as such, will Final Decision
guide current and future utility regulation in Procedural Record
Connecticut.

PBR Phase 2 Topics and Procedural Plan


Phase 2 of the PBR Framework development focuses on establishing or modifying
mechanisms to ensure the achievements of the established regulatory goals and priority
outcomes and the necessary metrics to track progress towards these goals and
outcomes. The Phase 1 PBR Decision identifies the regulatory mechanisms that PURA is
investigating in Phase 2 and how they map back to the priority outcomes.

Table 4: PBR Phase 2 Regulatory Mechanisms by Topic Area

Regulatory
Regulatory Likely Priority
Mechanism Investigation Description
Mechanism Outcomes Served
Category

Consider a revised MRP design,


Multi-Year Rate including an appropriate control Business Operations
Plan (MRP) and period, and an Externally-Indexed and Investment
Indexed Revenue Cap approach that allows Efficiency
Revenue Cap for interim adjustments pursuant Affordable Service
to a revenue cap index formula.

Examine whether the existing ESM


Revenue Adjustment provides a fair and equitable
Mechanisms: Earnings Business Operations
sharing of earnings between the
Sharing and Investment
EDC and customers when earnings
Regulatory tools Mechanism Efficiency
fall outside an Authority-approved
designed around a (ESM) Affordable Service
range and is consistent with the
utility’s revenue implementation of any PIMs.
requirement aimed at
better aligning the Explore advanced uses of revenue Distribution System
utility’s financial decoupling that both true up Utilization
Revenue
incentives with revenues to an annual revenue Customer
Decoupling
regulatory principles target and protect customers’ Empowerment
or a desired outcome. interests. GHG Reduction

Business Operations
and Investment
Explore development of
Efficiency
Capex / Opex approaches to equalize treatment
Comprehensive and
Equalization of capital expenditures and
Transparent System
operating expenditures.
Planning
Affordable Service

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PURA 2023 ANNUAL REPORT

Regulatory
Regulatory Likely Priority
Mechanism Investigation Description
Mechanism Outcomes Served
Category

Affordable Service
Social Equity
Develop a portfolio of reported Reliable and Resilient
Reported
metrics to highlight activities under Electric Service
Metrics
several priority outcomes. Comprehensive and
Transparent System
Performance Planning
Mechanisms:
Reliable and Resilient
Electric Service
Regulatory tools used
Design and publish scorecards with Business Operations
to track, measure,
targeted performance levels to and Investment
and/or possibly incent Scorecards
track progress against several Efficiency
EDC behavior
priority outcomes. Quality Customer
through achievement
Service
of performance
GHG Reduction
targets.
Reliable and Resilient
Performance Electric Service
Implement a set of PIMs designed
Incentive Customer
to help drive achievement of
Mechanisms Empowerment
several priority outcomes.
(PIMs) Distribution System
Utilization

Establish a comprehensive,
Other Regulatory
transparent, and stakeholder-
Mechanisms:
informed IDSP process that is
Comprehensive and
integrated with considerations
Additional Integrated Transparent System
regarding grid-edge technologies,
mechanisms that do Distribution Planning
DERs, electric vehicles (EVs), and
not qualify as revenue System Distribution System
other beneficial electrification
adjustment Planning (IDSP) Utilization
initiatives. This effort could also
mechanisms or GHG Reduction16F
explore the refinement of data-
performance
sharing mechanisms and
mechanisms.
standards.

As shown above, these various regulatory mechanisms can be grouped into three
distinct categories: revenue adjustment mechanisms; performance mechanisms; and
other regulatory mechanisms. As such, Phase 2 consists of three reopener proceedings,
Docket Nos. 21-05-15RE01, 21-05-15RE02, and 21-05-15RE03, to investigate each of these
categories of regulatory mechanisms. The Authority initiated each of these three
reopener proceedings on May 3, 2023.

PBR Phase 2 Progress


The Authority remains committed to advancing the PBR reopener dockets at an
ambitious but achievable pace. While the timelines are flexible and docket completion

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PURA 2023 ANNUAL REPORT

dates remain tentative, the Authority aims for issuance of a Proposed Final Decision in
both Docket Nos. 21-05-15RE01 and 21-05-15RE02 by the end of 2024 and the completion
of all three proceedings by 2025. These deadlines were designed to ensure ample
opportunity for frequent and detailed stakeholder participation through technical
meetings and opportunities to comment. The following summarizes the substantive
focus and progress in each of the three reopeners through year-end 2023.

21-05-15RE01: Revenue Adjustment Mechanisms

The first PBR reopener is investigating potential modifications and additions to Revenue
Adjustment Mechanisms (RAM). Specifically, these include: Multi-Year Rate Plans (MRP);
Earnings Sharing Mechanisms (ESM); the Revenue Decoupling Mechanism (RDM); and
potential Capex / Opex Equalization Measures. As the MRP is the primary mechanism
governing EDC cost recovery through base rates, it will be the main focus of this
investigation. By necessity, the ESM, RDM, ARM, and Capex / Opex Equalization will also
be reviewed as mechanisms related to the MRP; however, such review may or may not
result in reforms during Phase 2 if none are deemed necessary to advance priority
outcomes. Moreover, the Authority plans to review, consider, and investigate the MRP,
ESM, RDM, ARM, and Capex / Opex Equalization as a group of Revenue Adjustment
Mechanisms in Phase 2 to account for the interrelationships and collective results of such
mechanisms and proposed modifications.

The discovery, analysis, and deliberation of the Revenue Adjustment Mechanisms


reopener will culminate in a Final Decision that provides guidance for subsequent EDC
rate cases. Though this articulated endpoint may evolve over the course of the
proceeding, any material changes will be communicated publicly through Docket No. 21-
05-15RE01.

Table 5 provides a summary of the procedural events that have occurred to date, and the
upcoming events and opportunities for participation.

Table 5: 21-05-15RE01 Procedural Schedule Summary

Event Date

Technical Meeting #1 7/31/23

Technical Meeting #2 8/23/23

Technical Meeting #3 9/05/23

Technical Meeting #4 9/18/23

Written Comments Round 1 9/29/23

Straw Proposal 11/16/23

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PURA 2023 ANNUAL REPORT

Event Date

Written Comments on Straw Proposal 12/21/23

Technical Meeting #5 1/10/24

Technical Meeting #6 2/14/24

3/30/24
Technical Meeting #7*
Register

Written Comments Round 3* 5/31/24

6/7/24
Technical Meeting #8*
Register

9/9/24
Hearing*
Register

Briefs* 10/9/24

Proposed Final Decision* 11/22/24

Final Decision Issued* 1/15/25

*Tentative
21-05-15RE02: Performance Mechanisms

The second PBR reopener is investigating potential modifications and additions to


Performance Mechanisms. These include: Reported Metrics; Scorecards; and
Performance Incentive Mechanisms (PIMs). These elements of the state’s regulatory
structure provide transparency of information with respect to EDC performance and will
help measure achievement of the regulatory goals and priority outcomes adopted in this
Decision. The Authority intends to review this group of performance mechanisms as a
portfolio to account for the interrelationships and collective results of such mechanisms
and proposed modifications. The relationship between an EDC’s revenues and profits
and its performance and financial incentives requires that the substance of Docket Nos.
21-05-15RE01 and 21-05-15RE02 be developed with mutual consideration of each.

The discovery, analysis, and deliberation of the Performance Mechanisms reopener will
culminate in a final Decision to align existing reported metrics within the PBR
Framework and elsewhere and to adopt new metrics effective immediately where
necessary. Additionally, this reopener docket’s final Decision will establish scorecards to
be implemented as soon as practicable and PIMs likely to be implemented in the
subsequent EDC rate cases. The final Decision in Docket No. 21-05-15RE02 will include
the requisite detail for implementation, including but not limited to, metric and
scorecard reporting frequency, the format and venue for reporting, targets and
benchmarks in the case of scorecards, and impact on return on equity in the case of
PIMs. Though this articulated endpoint may evolve over the course of the proceeding,

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PURA 2023 ANNUAL REPORT

any material changes will be communicated publicly through Docket No. 21-05-15RE02.

Table 6 provides a summary of the procedural events that have occurred to date, and the
upcoming events and opportunities for participation.
Table 6: 21-05-15RE02 Procedural Schedule Summary

Event Date

Working Group Meeting #1 6/22/23

Working Group Meeting #2 7/17/23

Working Group Meeting #3 7/27/23

Written Comments Round 1 8/21/23

Working Group Meeting #4 8/29/23

Technical Meeting #1 9/11/23

Written Comments Round 2 10/2/23

Technical Meeting #2 10/12/23

Technical Meeting #3 12/12/23

Written Comments Round 3 12/15/23

Straw Proposal* 3/14/24

3/27/24
Technical Meeting #4*
Register

Straw Proposal Comments* 4/17/24

6/10/24
Technical Meeting #5*
Register

7/16/24
Public Listening Session*
Register

7/18/24
Public Listening Session*
Register

9/13/24
Hearing*
Register

Briefs* 10/16/24

Proposed Final Decision* 11/27/24

Final Decision* 1/22/25

*Tentative

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PURA 2023 ANNUAL REPORT

21-05-15RE03: Integrated Distribution Planning

The third and final PBR reopener will investigate the establishment of an Integrated
Distribution System Plan (IDSP). Such planning among EDCs is a growing industry
standard to anticipate and accommodate the proliferation of DERs and grid-edge
technologies on the distribution system. This investigation is expected to encompass
three key areas: (1) EDC systems and processes that support IDSP, including but not
limited to internal planning, operations, and Information Technology systems; (2)
operations and optimization of the grid; and (3) IDSP structure and process.

Given the interrelationship between these topic areas and various other dockets, the
Authority intends to take a holistic approach that considers elements of IDSP currently in
effect in Connecticut. Various elements of IDSP currently exist in Connecticut, for
example: EDC hosting capacity maps and the Non-wires Solutions (NWS) Process recently
established in Docket No. 17-12-03RE07, PURA Investigation into Distribution System
Planning of the Electric Distribution Companies – Non-Wires Alternatives, (see Section 3
for more information on the NWS Process). Additionally, the EDCs already conduct some
version of load forecasting and assess grid needs to inform capital investments – both of
which are core practices of IDSP.

As a result, this proceeding will focus on documenting the existing components of IDSP,
reviewing and evaluating the systems and processes that support IDSP, making
components of IDSP more transparent and better connected where necessary, and
establishing a public and transparent IDSP process and reporting standard(s).
Furthermore, the Final Decision adopted in Docket No. 21-05-15RE03 will replace the IDSP
requirements in the EMG Decision. Though this articulated endpoint may evolve over the
course of the proceeding, any material changes will be communicated publicly through
Docket No. 21-05-15RE03.

Table 7 provides a summary of the procedural events that have occurred to date, and the
upcoming events and opportunities for participation.

Table 7: 21-05-15RE03 Procedural Schedule Summary

Event Date

Technical Meeting #1 9/20/23

Technical Meeting #2 11/08/23

Technical Meeting #3 1/11/24

Technical Meeting #4 2/6/24

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PURA 2023 ANNUAL REPORT

Event Date

3/6/24
Technical Meeting #5*
Register

4/2/24
Technical Meeting #6*
Register

5/14/25
Technical Meeting #7*
Register

6/11/24
Technical Meeting #8*
Register

Concept Paper* 9/19/24

Written Comments Round 1* 10/9/24

10/22/24
Technical Meeting #9*
Register

12/03/24
Technical Meeting #10*
Register

Straw Proposal* 2/6/25

Written Comments Round 2* 2/27/25

5/13/25
Hearing
Register

Briefs* 6/3/25

Proposed Final Decision* 7/8/25

Final Decision* 8/20/25

*Tentative

PBR Implementation in Rate Cases


A key driver of the Authority’s ambitious timelines for these Phase II proceedings is the
ability to utilize the completed framework for the next set of EDC rate cases. Much of the
PBR reforms outlined in the Final Decisions in Docket Nos. 21-05-15RE01 and 21-05-
15RE02 will be implemented through such rate cases.

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PURA 2023 ANNUAL REPORT

SECTION 3:
GRID MODERNIZATION
The electric sector and its infrastructure are the veins and
arteries that power modern society. Nationally, the electric
sector accounts for approximately 5% of the gross domestic
product (GDP). Indirectly, the electric sector contributes much
more, enabling businesses and industry to create the goods
and services that make up the remaining 95% of the GDP and
improving productivity, health, safety, comfort, and
convenience. However, today’s electric grid faces new and
growing challenges such as rising energy demand, growing
deployment of distributed energy generation resources (DERs)
like rooftop solar, ambitious climate and energy policies, and
increasing storm frequency and intensity. These, and other
challenges, are impacting the affordability, resilience, and
reliability of our electric distribution system.

In response to these challenges, PURA determined that it


needed a distinct strategy for grid modernization, separate
from traditional electric sector regulation. In October 2019,
PURA issued an Interim Decision in Docket No. 17-12-03, PURA
Investigation into Distribution Planning of the Electric
Distribution Companies (EMG Interim Decision) outlining the
Authority’s framework for investigating both near- and long-
term strategies to implement an Equitable Modern Grid (EMG)
for Connecticut. This framework is designed to foster innovative
solutions that address the major challenges and opportunities
facing the electric sector and has four objectives:

Support (or remove barriers to) the growth of Connecticut’s


green economy;
Enable a cost-effective, economy-wide transition to a
decarbonized future;
Enhance customer access to a more resilient, reliable, and
secure commodity; and
Advance the ongoing energy affordability dialogue in the
state, particularly in underserved communities.

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PURA 2023 ANNUAL REPORT

All four objectives are inextricably connected and, thus, What is a "reopener docket"?
A docket that is initiated to either
no single objective can be accomplished without the reassess or continue evaluating a
others if an Equitable Modern Grid is to be achieved. specific part of the original
Similarly, the whole of an Equitable Modern Grid is docket's decision. It helps to
maintain continuity between
greater than the sum of its parts, as the realization of each
related dockets. "Reopened"
objective can further the achievement of the others. proceedings use the naming
convention "##-##-##re0#" in
The 2019 EMG Interim Decision introduced 11 sub-topics
PURA's docket database.
for further investigation through a series of “reopened”
proceedings, where PURA has been and, in
one case, continues to evaluate potential solutions for their cost-effectiveness and ability
to meet the objectives of the framework in the long-term. Since 2019, PURA has initiated
decisions or final reports in all 11 reopeners, with several having moved into the annual
program review stage. The reopeners and their progress are as follows:

Figure 8: Progress Across EMG Reopener Dockets

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PURA 2023 ANNUAL REPORT

Though each reopener contributes towards all four EMG objectives, some further more of
the objectives than others. Figure 9 below helps to demonstrate the relationship between
each topic and the EMG objectives, and PURA’s strategy to ensuring all four are
accomplished through this comprehensive approach.

Figure 9: Reopener Alignment with EMG Objectives

KEY GRID MODERNIZATION TOPICS IN 2023


As demonstrated by Figure 9 above, each EMG reopener docket addresses one or more of
the original EMG Interim Decision objectives. As of January 3, 2024, the Authority has now
issued final decisions or reports in all 11 of the EMG reopener dockets and has moved on
to full implementation of the programs and policies designed by these final documents.

In 2023, in addition to its numerous program annual review dockets, the Authority issued
multiple groundbreaking grid modernization decisions, each supporting the EMG
Framework as a whole, and making significant contributions towards the Framework’s
objectives. In Docket No. 23-05-01, Annual Review of Affordability Programs and Offering

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PURA 2023 ANNUAL REPORT

(Energy Affordability Annual Review), PURA’s October 11, 2023, Final Decision assessed the
ongoing residential energy affordability programs offered by the state’s regulated electric
and gas utilities, as well as the 2024 implementation of the residential Low-Income
Discount Rate (LIDR) and changes to the Matching Payment Plan (MPP) program as
directed by Section 30 of Public Act 23-102, An Act Strengthening Protections for
Connecticut’s Consumers of Energy. In Docket No. 22-08-07, Innovative Energy Solutions
Program Cycle 01, the Authority’s December 13, 2023, Decision, formally approved seven
innovative projects for pilot funding beginning in 2024. Additionally, PURA released a
Final Legislative Report on December 13, 2023, in Docket No. 23-08-09, Annual Electric
Distribution Company Reliability and Resilience Framework Review, reporting on the
reliability of each EDC. In Docket No. 22-06-29, PURA Investigation into Distribution
Energy Resource Interconnection Cost Allocation, PURA’s December 20, 2023, Decision
revises the policy regarding how to allocate distribution system upgrade costs that result
from the interconnection of residential DER projects. The Authority also issued a decision
in Docket No. 22-06-05, PURA Implementation of Public Act 22-55, on December 20,
2023, reviewing EDC proposals for front of the meter (FTM) storage resources under the
framework it had previously designed in 2022.

In addition, as a result of significant Authority analysis and stakeholder input throughout


2023, PURA also issued important grid modernization final decisions in early 2024. In
Docket No. 17-12-03RE02, PURA Investigation Into Distribution System Planning Of The
Electric Distribution Companies – Advanced Metering Infrastructure, PURA’s January 3,
2024, Decision establishes a framework that serves as a regulatory roadmap for the EDCs
to invest in advanced metering infrastructure (AMI), while protecting ratepayers and
advancing the state’s policy goals. In Docket No. 17-12-03RE10, PURA Investigation into
Distribution System Planning of the Electric Distribution Companies – Building Blocks of
Resource Adequacy and Clean Electric Supply, PURA issued a Final Legislative Report on
February 1, 2024. This report outlines the Authority’s investigation into the procurement
of Standard Service (SS) for EDC customers in accordance with Section 16 of Public Act
23-102, An Act Strengthening Protections for Connecticut's Consumers of Energy. Further
details on each of these decisions are discussed below.

Progress Advancing Energy Affordability


Each year, PURA conducts a comprehensive review of the energy affordability and
arrearage forgiveness programs (AFP) offered by the EDCs and LDCs through one
consolidated proceeding. The Annual Review process provides the Authority with an
opportunity to assess these programs’ effectiveness at addressing ongoing energy
affordability issues, particularly for low-income or disadvantaged communities, as well as
their impact on reducing overall unpaid utility bills. The programs available to help
customers pay their bills are the result of collaboration between the Authority, the
utilities, the Office of Consumer Counsel, EOE, the Department of Social Services (DSS),
the General Assembly, low-income and community advocates, and other stakeholders

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PURA 2023 ANNUAL REPORT

with a commitment to ensuring these offerings are as helpful to customers as possible.


These programs include the following summarized by Table 8:

Table 8: Connecticut Energy Affordability and Arrearage Forgiveness


Programs

Program or Definition Eligibility Enrollment Process


Policy

A designation that protects Customers who receive Contact your electric


residential customers from public assistance utility, or your local
service shutoff during the benefits from DSS, have Community Action
winter and makes them a household income of Agency (CAA).
eligible for certain energy <60% of State Median
Hardship affordability programs. Income (SMI), or have a
Verification Medical protection status serious or life-
is also available to threatening medical
customers with serious or condition.
life-threatening medical
conditions.

Applies direct funding Customers who also Apply directly at


(typically in the range of receive public your local CAA.
Connecticut $250-$600) towards your assistance benefits from
Energy heating bill. DSS, or have a
Assistance household income of
Program <60% of State Median
Income (SMI).

A payment plan for Customers who qualify Contact your local


hardship customers as medical or financial natural gas or
heating with electricity or hardship through DSS electric utility
Matching gas with past-due or a Community Action company, or CAA
Payment balances. Each payment Agency (CAA) who have directly.
Plan made by the customer is past-due balances.
matched by the utility until
the balance is eliminated.

A payment plan for any Any active electric, Contact your


active electric, residential residential customer of electric utility
Flexible customer with a past-due Eversource or United company directly.
Payment balance. Customers make Illuminating.
Plan monthly payments to
prevent service shutoff.

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PURA 2023 ANNUAL REPORT

These programs are designed to ensure that as many customers and their varying
circumstances can be addressed as possible. The Authority conducted its review of the
2022-2023 Program Year for these programs through Docket No. 23-05-01, Annual Review
of Affordability Programs and Offerings (Energy Affordability Annual Review). Key
findings, issues, and program modifications included in the October 11, 2023, Decision in
this docket are discussed below.

Matching Payment Plan (MPP) Program


Connecticut law provides that residential electric or gas heating customers with unpaid
utility bills who meet either income or medical qualifications are eligible to enter into an
amortization agreement with their utility to reduce their unpaid balance. The Matching
Payment Plan (MPP) program offered by Eversource and UI is the programmatic
implementation of this law. Through the MPP, hardship customers (i.e., customers who
receive public assistance benefits from DSS, have a household income of <60% State
Median Income, or have a serious or life-threatening medical condition) are put on a
payment plan to eliminate past-due utility balances. Each payment made by the
customer is matched by the utility until the balance is eliminated.

Payment Calculation

Historically, a customer’s monthly payment was calculated using the total of the last 12
months of a customer’s bills, less any award from the Connecticut Energy Assistance
Program (CEAP), divided by 12. However, this calculation methodology required
modification due to the launch of LIDR on January 1, 2024. Accordingly, the Authority
modified the monthly payment calculations for the MPP program to use the average of
the past 12 months of kWh usage, multiplied by the average of the past 12 months of
retail rates.

Annual Participation Metrics

In the 2022-2023 MPP Program year, 68,695 customers participated in MPP. The
Authority found that all companies saw an increase in MPP enrollment, up from 60,052 in
the 2021-2022 MPP Program Year. This was likely driven primarily by the implementation
of auto-enrollment for customers who participated the previous year. The Authority will
continue to monitor the auto-enrollment process and its impact on MPP participation to
identify any trends.

The Authority had previously established a goal of 65% of participants successfully


completing payments between November 1 and May 1 of a given program year (Phase 1).
Upon completing Phase 1, they receive their matching payment. During this program
year, 59% of participants across Eversource, Yankee Gas, CNG, SCG, and UI successfully
completed Phase 1. The companies all reported a variety of reasons that customers did
not complete the program.

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PURA 2023 ANNUAL REPORT

In evaluating the MPP and the utilities’ Figure 10: Participation Phases
explanations for a 59% completion rate, the of MPP
Authority reached the conclusion that it may be
necessary to re-examine what is considered
MPP Phase I
success in the program, particularly where
companies are seeing the same customer Phase I of the MPP is the period
participate in MPP year after year. Therefore, the between November 1 and May 1 of
the MPP year. To receive a matching
Authority directed the utilities to propose a
payment, customers must comply
revised definition of success for the MPP that
with the MPP requirements as of
includes, at a minimum, tracking the length of a the time they enroll in the MPP and
customer’s participation in the program to enter into a payment arrangement.
reach a zero past due balance. In advance of
this proposal, the Authority also approved an
expanded set of metrics used to track and
assess participation rates going forward.

Enrollment
MPP Phase II
Customers who participated in the MPP during
the previous year who still have a past-due Phase II is the period between May
balance are automatically re-enrolled. 2 and October 31 of the MPP year.
The customers who successfully
Automatically enrolled customers receive a
complete Phase I are eligible to
letter confirming their re-enrollment,
participate in Phase II. Customers
identifying their monthly payment amount, and participating in Phase II must make
reminding them to apply for CEAP energy payments as scheduled or they are
assistance. For customers that are newly subject to the normal disconnect
enrolling, they need to demonstrate income process. Phase II of the program is
eligibility and to apply for CEAP between much like Phase I. Customers
receive matching payments equal
November 1 and May 1.
to the amount they paid and/or on
In the 2023 Annual Review, PURA examined behalf of the customer through
Eversource and UI’s proposals implementing a CEAP. Lastly, customers have an
rolling 12-month hardship verification opportunity to make up missed
payments by October 31 to
designation, which serves as income eligibility.
successfully complete MPP.
This will help minimize the number of steps
that customers need to take to access the programs and help increase
participation. After reviewing both companies’ proposals and associated costs, the
Authority directed both companies to implement rolling hardship verification by
January 1, 2024, coincident with the launch of LIDR. The Authority did then allow
an extension to Eversource until May 1, 2024.
Modifications to MPP Program by Public Act 23-102
Importantly, the enrollment requirements that have historically been used in the
MPP program were modified, along with multiple other changes to the MPP, by

39
PURA 2023 ANNUAL REPORT

Section 30 of Public Act 23-102. The most significant amendments to MPP were to the
eligibility criteria, the calculation of a customer’s matching payment, and the timing of
the distribution of matching payments. Specifically, the revised MPP is no longer tied to
the heating source on which a residential customer relies. Additionally, residential
customers are no longer required to apply and be eligible for benefits available under
CEAP or a state-appropriated fuel assistance program. Rather, residential customers are
now only required to meet the income eligibility requirements of CEAP or a state-
appropriated fuel assistance program. Residential customers also must be eligible for
financial hardship programs with the gas or electric distribution company. Residential
customers are still required to authorize the gas or electric distribution company to send
a copy of the customer’s monthly bill directly to any energy assistance agency for
payment and to enter into and comply with an amortization agreement that is consistent
with decisions and policies of the Authority.

Throughout the proceeding, the Authority sought information from the utilities regarding
implementation of the authorized changes to MPP, including costs and an associated
timeline, to ensure its timely implementation. Both companies testified that the changes
would take multiple months to implement. As such, the Authority directed the utilities to
make the IT changes necessary to implement the New MPP no later than November 1,
2024, which is the start of next year’s MPP program year, and to provide an update
regarding such changes and the utilities ’ implementation of the New MPP in the 2024–
2025 AFP Plan in next year’s annual affordability proceeding, Docket No. 24-05-01. The
Authority also provided multiple points of clarification regarding the statute to ensure
accurate implementation by November 1, 2024.

Therefore, the Authority permitted the utilities to continue using the eligibility
requirements, the calculation of a customer’s matching payment, and the timing of the
distribution of matching payments (i.e., at the end of each phase) that were in place prior
to the passage of Public Act 23-102, as described above for the 2023-2024 MPP Program
Year. However, all changes directed by Public Act 23-102 must be in place by November 1,
2024. All other modifications made by the 2023 Annual Review to the MPP Program not
affected by Public Act 23-102 will be implemented this winter (i.e., the 2023-2024
Program Year).

Low-Income Discount Rate (LIDR)


In 2022, PURA directed the EDCs to implement a LIDR with an overall eligibility cap at
60% State Median Income (i.e., Tier 1) and eligibility for Tier 2 aligned with existing state
benefit programs (i.e., up to 160% FPG) through its October 19, 2022 Final Decision in
Docket No. 17-12-03RE11, PURA Investigation into Distribution System Planning of the
Electric Distribution Companies – New Rate Designs and Rate Reviews, (LIDR Decision). In
Docket No. 23-05-01, PURA reviewed key LIDR issues including the utilities’ eligibility
verification and enrollment plan and how the LIDR will interact with MPP going forward,
particularly with the implementation of Public Act 23-102.

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PURA 2023 ANNUAL REPORT

Eligibility Verification and Enrollment

The LIDR Decision established multiple avenues for customers to verify eligibility and
enroll on the LIDR. First, the EDCs must automatically enroll all customers designated as
financial hardship and all electric customers receiving CEAP awards into Tier 1 of the
LIDR. Second, each EDCs’ customer service representatives (CSRs) must accept proof of
verification documentation for Tier 1 or Tier 2 eligibility from customers who opt in to
receive a LIDR. Finally, the Authority approved new MOUs between the EDCs and CAAs
and Operation Fuel, Inc. (Operation Fuel) to encourage the enrollment of customers onto
Tier 2 of the LIDR. The Authority further approved the EDC-developed list of eligible low-
income or public assistance benefits to be used by CAAs and Operation Fuel to qualify
eligible customers for Tier 1 or Tier 2.

The October 11, 2023, Decision in Docket No. 23-05-01 discussed ways to ensure that all
eligible customers will be efficiently and correctly enrolled in the LIDR Tier for which they
are eligible. One strategy that will help ensure this is through data-sharing agreements
between DSS and the EDCs, which the utilities were on track to implement by January 1,
2024.

Additional Affordability Modifications


In addition to specific programmatic changes or direction regarding MPP or LIDR, the
Authority also approved or directed changes in Docket No. 23-05-01 that will help
improve energy affordability in Connecticut including changes to the companies’ security
deposit practices, late payment charge policies, and a plan to evaluate affordability for
non-residential customers.
Security Deposits

The collection of security deposits is commonly cited as a strategy for prudently


managing the cost of bad debt for residential customers (i.e., customer non-payment) by
utilities. In Connecticut, the EDCs charge security deposits from non-hardship customers
as a condition for connection. However, in a scenario where a customer is required to pay
a deposit for service restoration after being shut off, given the number of available
programs that should prevent service termination, the customer should instead be
enrolled in those programs for which they are eligible. For new residential customers,
where there may not be enough evidence to determine if the customer qualifies for a
hardship designation (and therefore exempt them from paying a security deposit), the
argument that a security deposit is the best practice for managing the cost of bad debt is
still flawed since the benefit of imposing a security deposit is conditioned on the
customer’s ability to pay.

Accordingly, the Authority directed the utilities to remove the payment of a security
deposit requirement for residential customers as of the date of the Decision, and to
return any security deposits previously charged, plus any accrued interest to residential
non-hardship customers. Additionally, PURA prohibited the utilities from refusing service

41
PURA 2023 ANNUAL REPORT

to a customer based on the customer’s financial inability to pay a security deposit. As


noted by Eversource, security deposits are among the highest dissatisfiers and escalated
complaint types for residential customers. Thus, with a permanent suspension of
residential security deposits, customer interactions are likely to improve and more effort
can be placed on enrolling customers in an appropriate energy affordability program.
Late Payment Charges

The Authority evaluated the utilities’ collection of late payment charges (LPC) from 2018
through 2022. Specifically, the Authority examined: (1) the utilities’ average, maximum,
and minimum LPCs incurred by customers by customer class (i.e., residential, and non-
residential classes) for each year from 2018 through 2022; and (2) the impact LPCs have
on the utilities’ uncollectibles. The submitted data further distinguished the residential
class by hardship and non-hardship customers.

The utilities’ LPC data shows that the EDCs assessed higher LPCs compared to the gas
companies. In addition, the maximum LPC amount charged by UI is the highest of all the
utilities. The Authority review of the LPC data raises multiple concerns, including whether
UI properly screened these customers for hardship eligibility and how many customers
had service terminated because of their inability to pay their bills. The Authority will
continue to monitor LPCs for each company in an effort to address these concerns. As
such, the Authority ordered each of the utilities to submit the average, maximum, and
minimum LPCs incurred by customers, by customer class, in the previous year; and the
impact LPCs have on uncollectibles, no later than January 15, 2024, and annually
thereafter in the relevant annual energy affordability docket.

Non-Residential Programs and General Affordability

In light of the recent significant increase in energy supply rates as of January 2023, PURA
determined that these annual proceedings are an appropriate opportunity to also start
explicitly examining the utilities’ energy affordability offerings for non-residential
programs, in addition to residential initiatives. The Authority requested data regarding
non-residential terminations from each company and solicited comments on the
respective available energy affordability programs. Collectively, the EDCs and LDCs
reported over 7,000 non-residential terminations in 2022, which was nearly double that
of 2021. This is likely primarily due to the end of the COVID-19 shut-off moratorium for
non-residential customers in July 2021.

Both the Eversource and Avangrid companies offer Flexible Payment Arrangements to
assist commercial and industrial customers with delinquent balances. Regardless, the
Authority recognizes the need to investigate further the topic of non-residential
affordability going forward. As such, Authority directed each of the utilities to provide the
total amount of uncollectibles and the amount of uncollectibles attributable to
residential (distinguished between hardship and non-hardship) and non-residential
customers in the next annual affordability review, Docket No. 24-05-01. In addition, the

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PURA 2023 ANNUAL REPORT

Authority directed the utilities to include the


Additional 2023 Affordability
number of service terminations, the number of
Review Resources
active flexible payment arrangements, and the
average, minimum and maximum payments for Final Decision
non-residential customers. The Authority will use Eversource MPP Webpage
this data to examine the portion of uncollectibles UI MPP Webpage
attributable to non-residential customers and
whether the current programs can improve to enhance energy affordability for non-
residential customers.

Standard Service Procurement


Separate from the programs designed to reduce and eliminate overdue bill balances, and
programs designed to lower bills overall for low-income customers, the Authority has also
been investigating mechanisms to improve affordability for ratepayers overall. As
previously discussed, customers’ electric bills are comprised of costs grouped into three
primary categories: generation or supply costs; distribution costs; and transmission costs.
Transmission costs are the costs required to transmit energy on an interstate basis
throughout the regional grid (ISO New England) and are federally regulated. The
Authority regulates distribution costs, or the cost of delivering energy throughout
Connecticut and directly to end-users, through rate cases, RAM proceedings, PBR, or
other tools. The cost of the actual generation of energy is set competitively through the
regional wholesale electricity market. In Connecticut’s de-regulated electricity market,
Eversource and UI do not own electricity generation resources that supply electricity to
customers, but instead purchase electricity from the wholesale electricity market and
pass that cost directly through to customers. These offerings are known as Standard
Service (SS) for residential and small load customers and Last Resort Service (LRS) for
commercial or large-load customers. Customers can choose to source their electricity
supply from a third-party retail supplier[1] or from their EDC’s SS or LRS default option.

Historically, electricity supply prices have been driven by factors such as the weather and
its impact on demand for energy and the infrastructure available to meet energy demand
(i.e., the capacity and fuel mix of available generation resources and the pipelines,
transmission, or other infrastructure to transport fuel). In recent years electricity supply
prices have been volatile due to macroeconomic factors such as the COVID-19 pandemic
and the Russian invasion of Ukraine. Moreover, natural gas comprises approximately 45%
of the New England regional fuel mix, ensuring that the price of natural gas plays an
outsized role in driving the price of electricity in the wholesale markets. In 2022, the price
of natural gas rose sharply, bringing the price of electricity in the ISO New England
wholesale markets along with it. As a result, for the first half of 2023, the price of SS
doubled for Eversource and UI residential customers compared to the prior six-month
period. This significant increase in supply charges adversely impacted EDC customers
with higher-than-expected electricity costs for household budgets and business

43
PURA 2023 ANNUAL REPORT

operations alike.

As a result, Section 16 of Public Act 23-102 directed PURA to evaluate the SS procurement
process and submit a report regarding its findings to the General Assembly. On February
1, 2024, PURA issued a Final Report in Docket No. 17-12-03RE10, PURA Investigation into
Distribution System Planning of the Electric Distribution Companies - Building Blocks of
Resource Adequacy and Clean Electric Supply, and submitted a report to the Energy and
Technology Committee of the Connecticut General Assembly. In this report, PURA
reviewed Connecticut’s existing SS Procurement Process and Objective Pathways
Summary process and compared it with those of peer jurisdictions. Additionally, the
Authority identified and considered potential modifications to the SS procurement
process for consideration by the General Assembly.

By statute, Connecticut’s SS Procurement Objectives are to achieve: (1) relatively low


prices; (2) stable prices; and (3) market-based prices over time.[2] Each must be balanced
with the others to achieve an outcome that optimizes all three. The Procurement
Objectives are not mutually exclusive; however, different potential procurement process
modifications may prioritize or advance one objective more-so than the others, or even at
the expense of the others. As such, through this report, the Authority provided 10
potential SS procurement process modifications in the context of their potential impact
on the three Procurement Objectives. Additionally, the Authority grouped together the
potential procurement process modifications that serve the same SS Procurement
Objectives to demonstrate potential pathways to achieving those objectives. potential SS
procurement process modifications in the context of their potential impact on the three
Procurement Objectives. Additionally, the Authority grouped together the potential
procurement process modifications that serve the same SS Procurement Objectives to
demonstrate potential pathways to achieving those objectives.

Importantly, the Authority is not advocating for specific modifications to the


procurement
outlines someprocess in this
potential nextreport. Instead, byfirst,
steps including taking the approach outlined above, the
Authority
conductingis providing the outreach
additional Energy andtoTechnology
wholesaleCommittee, and the General Assembly
Additional Standard Service
more broadly,
suppliers withconfidential
to solicit a set of potential
input onoptions,
the ten both individual steps and collective
Procurement Resources
pathways, to achieve anddiscussed
potential modifications balance theinSS Procurement
this report. Objectives. The Authority also
Second, where necessary, further investigation of Final Report to Legislature
the potential impacts of high-interest SS
procurement process modifications. Third and
finally, adopting any legislative changes necessary to implement the Energy and
Technology Committee’s priority modifications to the SS procurement process. The
Authority stands ready to continue supporting the Energy and Technology Committee’s
interest in this topic as may be helpful.

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PURA 2023 ANNUAL REPORT

Progress Enabling Decarbonization


Residential DER Interconnection Cost Allocation
A key enabling component of the electric distribution system to ensure deployment of
solar PV systems, battery electric storage systems, and other kinds of distributed energy
resources (DERs) are ability to support two-way flows of energy. DERs are an important
tool to meeting the state’s climate goals, and can be an even more important tool in
providing customers with resiliency solutions and providing demand flexibility, which
provides benefits to both the customer and the grid at large. To unlock the benefits of
DERs, however, they must be interconnected to the grid. While this sounds simple,
without carefully designed standards in place, a new interconnecting resource could
compromise the reliability or safety of the distribution system; conversely, inefficient
interconnection standards and protocols can inhibit the timely deployment of DERs.

The EDCs have had common DER interconnection guidelines in place since 2004 to
ensure and maintain grid reliability after interconnection.[3] To assess whether a new
DER would compromise the grid, the EDCs use a set of four technical screens. These
screens prevent the addition of a new DER when its generation capacity would exceed
the hosting capacity[4] limits of the infrastructure at that point on the distribution grid.
In a situation where the DER does exceed the current hosting capacity, the EDCs offer the
DER applicants two options:

1. Reduce the proposed generation capacity to pass the technical screens;[5] or


2. Pay for distribution system upgrades.

Based on the longstanding policy that allocates all interconnection costs to a new
customer interconnecting to the distribution system for standard electric service, the
interconnection guidelines required that DER applicant that exceeds the hosting
capacity limits to pay for all system upgrade costs required to interconnect to the
distribution system. In other words, the customer that in the moment causes the need for
upgrades, pays for them, even if projects that come afterwards benefit (i.e., freeride).

However, under this cost-causation principle, residential DER applicants can face the
potential for thousands of dollars in distribution upgrade costs. As a result, these
customers will often either downsize their proposed system or withdraw their application
altogether. Currently, the number of customers that find themselves in this situation is
relatively low; 1.24% of all residential DER applicants, as of 2021. However, this number has
nearly tripled since 2019, concurrent with increasing year over year applications tied to
the success of the Residential Renewable Energy Solutions (RRES) Program.[6] It is clear
that the percentage of residential DER projects triggering distribution upgrades is likely
to continue to increase into the future. Manifest in that conclusion is the potential for
distribution upgrades to become an increased barrier to DER deployment, as cost savings
for DER customers and profit for DER developers are a large driver of overall DER
deployment.

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PURA 2023 ANNUAL REPORT

Recognizing this growing issue, the Authority committed to investigating methods to


improve the interconnection standards and upgrade cost allocation frameworks used by
the EDCs to remove barriers to DER deployment. Taking into consideration stakeholder
input and guidance from the PURA-established Distributed Generation Policy and
Technical Working Groups (IX Working Group),[7] the Authority issued revised cost
allocation policies regarding system upgrade costs triggered by the interconnection of
residential DER projects through its December 20, 2023 Decision in Docket No. 22-06-29,
PURA Investigation into Distributed Energy Resource Interconnection Cost Allocation.

The most significant change in this decision is that residential DER applicants that fail the
technical screens and would be required to pay for a new or substantially upgraded
distribution transformer to enable their project are no longer responsible for paying the
cost of the transformer upgrade upfront. Instead, two approaches will be used to cover
the cost of distribution transformer upgrades depending on whether the applicant meets
the Environmental Justice (EJ) eligibility requirements:

1. For applicants meeting the EJ eligibility requirements (EJ applicants), the cost of
upgrading the distribution transformer will be recovered by the EDCs across all
ratepayers through their next rate case proceeding.
2. For applicants not meeting the EJ requirement (non-EJ applicants), the EDCs will
offset a portion, and ideally all, of the costs of non-EJ distribution transformer
upgrades through an adder charged to all non-EJ applicants as part of the
interconnection application fee. Any remaining transformer upgrade costs will be
recovered by the EDCs across all ratepayers through their next rate case proceeding.

Consistent with the other energy programs under PURA’s jurisdiction, EJ eligibility means
the applicant’s income is no more than 60% of the state median income, or the applicant
is deploying the project in a distressed municipality as defined by the Connecticut
Department of Economic and Community Development. The Authority directed the
EDCs to use the existing income verification process already in place for the RRES
program, and to the extent possible, use automatic verification of projects in a distressed
municipality.

The Authority chose to exempt EJ applicants from paying an interconnection application


fee adder for multiple reasons, the primary being that requiring an additional fee for EJ
applicants is counter to the policy objective of supporting residential DER for EJ
communities whose deployment levels already lag the stated policy goals. Further, it
would be inequitable to require EJ applicants to pay for the projects of non-EJ applicants.
Additionally, providing an applicant's EJ status upon application does not introduce a
significant barrier nor any delays to processing applications, and the impact to non-
participating ratepayers for the remaining costs of transformer replacements will be
minimal, especially in the near term.

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PURA 2023 ANNUAL REPORT

For non-EJ applicants, the Authority recognized the need to implement an adder that
fairly distributes the costs relative to the benefits of the upgrade. Therefore, the Decision
establishes a cap on the adder to avoid burdening DER applicants with unreasonable
fees, consistent with stakeholders’ feedback. While determining a precise cap is currently
infeasible as there is no concrete data indicating the price point at which an application
fee adder would begin to negatively impact DER deployment, based on limited historical
data, the Authority found that an adder fee between $3-$150 could cover all or most
anticipated transformer costs. Based on cost analysis in the Decision, the Authority found
that an application fee cap of $50 is sufficient.

Importantly, this new policy applies only to the costs resulting from a new or upgraded
transformer. If a residential DER interconnection requires a new transformer and
additional distribution system upgrades, the customer will be responsible for the costs of
the total upgrade minus the cost of replacing the transformer. This distinction is
necessary because costs of non-transformer upgrades vary significantly and can be much
larger than transformer costs. The Authority does not
currently intend to provide incentives to deploy Additional Residential
residential DERs in locations that require significant DER Interconnection
and costly upgrades. The Authority notes that where Resources
this situation occurs, there may be non-wires
solutions that could be considered through the Non- Final Decision
wires Solutions Process anticipated to launch in 2025.

Non-Residential DER Interconnection Cost Allocation Straw Proposal


The issue of interconnection cost allocation is not limited to residential DERs and in fact
results in even more significant costs and time delays for non-residential DER projects.
Under the current application of the cost-causation principle, the EDC assigns the full
cost of the upgrade to the interconnecting customer as that DER project triggered the
needed upgrade. The cost-causation principle results in one non-residential DER project
incurring significant costs for upgrades that other DERs contributed to the need for and
other DERs that will benefit from it. For example, a non-residential DER connecting to the
distribution system may require the installation of additional infrastructure to
accommodate a generators’ power flow and maintain the safety and reliability of the
grid. These upgrades range in cost, though the average upgrade cost for projects greater
than 2 megawatts (MW) reached $4,733,520 in 2018.

If a developer agrees to pay for the upgrade under the cost-causation principle, the result
is an inequitable distribution of infrastructure costs among grid stakeholders. For
example, if a single DER developer finances a distribution system upgrade, additional
hosting capacity is generally created on the circuit. Therefore, any future projects may be
able to interconnect due to the additional hosting capacity created without having to
share the cost of the upgrade. This creates an incentive for DER developers to game the

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PURA 2023 ANNUAL REPORT

the interconnection queue to avoid being the DER that will incur the cost. Moreover,
DERs that interconnect on a circuit with limited hosting capacity that do not trigger a
distribution system upgrade do, however, significantly contribute to the need for a future
upgrade; yet these projects do not financially contribute towards future upgrade costs.

To address this issue, the Authority issued a Straw Proposal on December 22, 2023, in
Docket No. 22-06-29RE01, PURA Investigation into Distributed Energy Resource
Interconnection Cost Allocation – Non-Residential Interconnection Upgrades. In this
proposal, PURA recommends shifting from a cost-causation principle to a “beneficiary
pays” principle. Under this principle, distribution system upgrade costs are assigned to
interconnecting customers in proportion to that customer’s benefits from and
contribution to the need for the upgrade. Specifically, interconnecting customers are
charged on a per-kW basis. This approach is more transparent and equitable because it
recognizes that some interconnecting customers both contribute more to and benefit
more from distribution system upgrades than others and assigns costs proportional to
that attribution.

In order to implement the “beneficiary pays” principle, there must be a method of


evaluating how multiple projects interconnecting at a certain point will impact the grid
and how they will benefit from resulting upgrades. Thus, the Authority proposed the use
of a Group Study Process. Group Studies will allow the EDCs to process applications
simultaneously rather than sequentially, leading to a more efficient use of the EDC’s
resources, lower interconnection costs, and faster interconnection timelines. The
Authority proposes allowing the EDCs to form Group Studies any time they receive more
than one interconnection application on a portion of the distribution system where the
operation of multiple DERs may have cumulative impacts and may require modifications
to the distribution system. Through this process the EDCs can identify the beneficiaries
and contributors to any upgrade cost drivers. Once the EDCs have that information, they
can allocate costs proportionately to the interconnecting projects responsible for the
costs.

The Straw Proposal also outlines several related issues that will need to be resolved. For
example, while the Group Study Process is a needed incremental improvement, it is still a
reactive planning approach. The Group Study Process only occurs when the need for a
distribution system upgrade already exists and DER deployment is already delayed
compared with the upgrade being developed and deployed either when it is identified in
the application review process or through proactive planning. Stated more simply, any
amount of time taken through the Group Study Process extends a pre-existing delay. A
proactive approach to allocating costs could provide price signals correlated with ideal
points of interconnection, and address system upgrades as soon as possible. Further, the
Authority flagged the need to integrate the Non-wires Solutions Process (NWS Process)
and Integrated Distribution System Planning (IDSP) as the means to most strategically
and holistically coordinate the deployment of DERS and necessary grid upgrades.

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PURA 2023 ANNUAL REPORT

The Authority requested written comments on the Straw Proposal from stakeholders by
February 14, 2024. These comments will be used to help determine future stakeholder
input opportunities and to make refinements to the proposed approach.

IX Working Group
As a result of the November 25, 2020, Decision in Docket No. 17-12-03RE06, PURA
Investigation into Distribution System Planning of the Electric Distribution Companies –
Interconnection Standards and Practices, the Authority established the IX Working Group
to consider changes to the current interconnection policies of the EDCs, among other
issues. The IX WG has been consistently meeting since March 2021, with the mission of:
“accelerat[ing] safe, reliable and economical interconnections of distributed energy
resources in Connecticut, through a transparent and informal public forum where
technical and policy stakeholders openly share their experience, knowledge and
challenges, on common ground, where solutions and recommendations to policy makers
strive for consensus, so that renewable energy in Connecticut can flourish, while leading
the nation through an example of mutual respect and collaboration.”

On October 20, 2023, the Authority retained a formal IX Working Group Facilitator to
provide both administrative support and assist with the facilitation of discussion and
development of strategies to improve transparency of the interconnection process,
including but not limited to:

Public distribution system interconnection queues;


Identify best uses of hosting capacity maps;
Establish and make public reporting requirements; and
Review of the Non-Residential Renewable Energy Solutions (NRES) and the Shared
Clean Energy Facility (SCEF) program solicitation documents for consistency with the
interconnection process and to identify possible areas of improvement.

The IX Working Group will continue to meet on Additional Non- Residential DER
a monthly basis and provide important Interconnection Resources
stakeholder information and input to the Straw Proposal
Authority to continue improving IX Working Group Webpage
interconnection policies in Connecticut.

Progress Supporting Resilience & Reliability


Electric Reliability Reporting
By law, the EDCs are required to submit annual reliability data to PURA for the previous 12
months in terms of various power outage metrics that excludes outages caused by major
storms, scheduled outages, or outages caused by customer equipment.[8] Specifically,
the EDCs are required to report System Average Interruption Duration Index (SAIDI) and
System Average Interruption Frequency Index (SAIFI). In turn, the Authority is required to

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PURA 2023 ANNUAL REPORT

report this data to the Energy & Technology Committee of the General Assembly.

In 2022, PURA issued a decision in Docket No. 17-12-03RE08, PURA Investigation into
Distribution System Planning of the Electric Distribution Companies – Resilience and
Reliability Standards and Programs (RE08 Decision), which expanded the reliability data
the EDCs are required to track and report in order to provide more granular, customer-
focused reliability performance data including customer average interruption duration
index (CAIDI), customers experiencing multiple interruptions (CEMI), and customers
experiencing long interruption durations (CELID).

On December 13, 2023, PURA issued its 2023 Report to the General Assembly on Electric
Distribution Company System Reliability through Docket No. 23-08-09, Annual Electric
Distribution Company Reliability and Resilience Framework Review, which incorporated
the new data reporting requirements from the RE08 Decision for the first time. In general,
the Authority found that both EDCs reported 2022 SAIDI and SAIFI values were below the
1995-1998 and 2018-2021 four-year averages.[9] The Authority did, however, find that UI
did not provide the data using the methodology as required in previous reports and
failed to provide other required data related to storms in 2022. As a result, PURA has
directed UI to remedy these issues by February 22, 2024.

Additionally, both EDC’s CAIDI values for 2022 were found to be just above both the four-
year averages. Importantly, this is not necessarily indicative of a decrease in reliability
performance. Since CAIDI is the ratio of SAIDI and SAIFI, a low SAIDI and low SAIFI values
(few outages and short durations) may give the same CAIDI ratio as high SAIDI and high
SAIFI values (many outages and longer durations). Therefore, CAIDI must be interpreted
relative to the underlying SAIDI and SAIFI values. The increase in 2022 CAIDI relative to
the 1995-1998 average here indicates that SAIFI has improved at a faster rate than SAIDI
(since both 2022 SAIDI and SAIFI values are improved from the 1995-1998 averages).

The below graphs, Figures 11 and 12, show the statewide SAIDI and SAIFI values from 1998-
2022, respectively.
Figure 11: Statewide SAIDI Values Since 1998

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PURA 2023 ANNUAL REPORT

Figure 12: Statewide SAIFI Values Since 1998

Non-Wires Solutions Process Additional Electric Reliability


In 2022, PURA issued a Decision in Docket Reporting Resources
No. 17-12-03RE07, PURA Investigation into
2023 Legislative Report
Distribution System Planning of the Electric
Distribution Companies – Non-Wires
Alternatives (NWS Decision), establishing a process to transparently leverage competition
to identify and deploy non-wires solutions (NWS) to meet distribution system needs with
the ultimate objectives of improving grid resilience and reliability, as well as improved
outcomes for customers (NWS Process). As technology has changed over time, new
options are available to lower system costs and improve outcomes, and specifically to
avoid, defer, or reduce the cost of necessary grid investments. In addition, EDCs are now
permitted by statute to own energy storage systems under a wider range of conditions
than previously possible. The NWS Process enables the Authority and stakeholders to
receive the necessary and appropriate information to evaluate the prudence of EDC
investments, including EDC-owned energy storage.

Further, in the NWS Decision, PURA determined that the NWS Process and its policy
objectives would greatly benefit from the expertise and oversight of an official PURA
Process Monitor. Given the role of the EDCs in this process, oversight and transparency is
key to the provision of results in the public interest. The PURA Process Monitor would act
as an extension of lead staff in the annual NWS Process proceedings to supplement
existing staff expertise in its oversight of the NWS Process and will provide expertise in
areas in which Authority staff expertise does not currently exist. Further, given the
importance of the robust stakeholder process called for by many docket participants, the
PURA Process Monitor would assist in the creation of key NWS Process materials and
analytical tools to provide information to stakeholders and facilitate their input.

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PURA 2023 ANNUAL REPORT

Thus, PURA conducted a public solicitation for proposals from consultants to serve as the
NWS Process Monitor in 2023. On May 4, 2023, PURA officially retained Optimal Energy
(formerly identified as NV5) to serve as the NWS Process Monitor. Generally, the Process
Monitor’s responsibilities will include stakeholder engagement, development of NWS
process materials, data review and analysis, oversight of each electric distribution
company’s (EDC) solicitations, and providing feedback to the Authority.

The NWS Process Monitor began the NWS Process Initiation phase identified in the NWS
Decision in the second half of 2023. As part of the phase, the NWS Process Monitor has
organized monthly stakeholder meetings to develop, discuss, and revise several key
deliverables necessary for the NWS Process to begin in 2025. These key deliverables
include, but are not limited to, the following items being developed by the Process
Monitor:

Any additional requirements and format for the annual Grid Needs Filing;
NWS solicitation benefit-cost analysis model and process;
Timelines for competitive NWS solicitation processes;
Applicability of the existing regulations regarding codes of conduct for EDCs and their
affiliates and any additional policies and protections needed to allow EDC affiliates to
submit a competitive NWS bid;
Plans for ongoing market engagement activities and RFI documents; and
A standard set of data to be provided to prospective NWS solicitation bidders, which
shall include, at a minimum, the information listed in Exhibit C and any relevant
information from the EDC Data and Grid Needs Filings.

The NWS Process Initiation Phase also includes review, discussion, and potential
modification to deliverables being developed by the EDCs, including but not limited to:

A standard cybersecurity data access policy and pre-approval process, including non-
disclosure agreements (NDAs) and data security agreements (riders) that specify
vendor security requirements;
The standard RFP to be issued by the EDCs for a NWS solicitation, inclusive of any
processes to screen and qualify bidders, which shall include relevant information from
the cybersecurity data access policy; and
The pro forma contract for NWS bidders to execute with the EDC upon selection,
including performance criteria and EM&V plan.
Additional NWS Process
In 2024, the Process Monitor will continue to
Resources
convene monthly stakeholder meetings to
develop, review, and revise the above Process Monitor Work Plan
deliverables. Ultimately, the above deliverables 24-08-08 Notice of
are required to be submitted to the Authority by Proceeding
June 1, 2024 in Docket No. 24-08-08, Non-Wires

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PURA 2023 ANNUAL REPORT

Solutions Process Initiation Phase. After submission, the Authority will formally review
and request written comments on these deliverables, ultimately issuing a Final Decision
regarding NWS Process implementation in that proceeding in the second half of 2024, in
order to enable the NWS Process to formally begin in January 2025.

Front-of-the-Meter Storage Pilots


Public Act 22-55, An Act Concerning Energy Storage Systems and Electric Distribution
System Reliability, states that the Authority shall direct the EDCs to submit up to three
proposals for energy storage system (ESS) projects with the “purpose of demonstrating
and investigating how energy storage systems can improve resiliency of critical
infrastructure and improve reliability of the electric distribution system.”

On September 14, 2022, the Authority issued an Interim Decision in Docket No. 22-06-05,
PURA Implementation of Public Act 22-55, (Interim Decision) establishing the
requirements for the ESS proposals and directed the EDCs to file such proposals. Because
the term “critical infrastructure” was not defined in Public Act 22-55 or elsewhere in
statute, the Authority ruled that it would consider any facilities included in the EDC’s
emergency response plan, facilities identified by municipalities in conjunction with the
EDC, or facilities that otherwise meet the Connecticut Division of Emergency
Management and Homeland Security (DEMHS) definition. To enable the evaluation of the
resilience benefits of the proposed ESS projects, the Authority required the EDCs to
submit a “Resilience Needs Assessment” of the critical infrastructure and a description of
the ESS’ resilience operational strategy.

In addition to improving the resilience for critical infrastructure, the ESS projects are
required to improve distribution system reliability. To identify the reliability
improvements of a proposed ESS project, the Authority required specific details
regarding the reliability needs of the infrastructure being served, the functionality of the
ESS to address those needs, and how the EDC will dispatch the system to optimize that
functionality under various scenarios.

The final element for assessing a proposed ESS project is determining whether the
project “provides value to ratepayers.” The Authority established certain requisite
technical criteria for a proposed ESS project to be commercially functional. In addition,
the Authority established a Benefit-Cost Analysis model to ensure that ratepayers receive
value from the proposals that exceed the costs.

The EDC’s submitted proposals in December 2022, which ultimately required


supplemental analysis on wholesale energy market participation and possible ESS
operation strategies for PURA to complete its assessment. The EDCs submitted this
supplemental data on June 1, 2023. Following stakeholder and Authority review of the
proposals, PURA issued a Final Decision on the EDCs’ proposed ESS projects on
December 20, 2023.

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PURA 2023 ANNUAL REPORT

United Illuminating‘s Projects

United Illuminating submitted proposals for projects in Bridgeport, North Haven, and
New Haven. The Authority found that the Company’s proposals meet the requirements
set forth in the Interim Decision and are expected to increase the resilience of critical
infrastructure, improve the reliability of the distribution system, and provide value to
ratepayers, if constructed and operated as proposed. Project details are summarized in
Table 9 below.

Table 9: United Illuminating ESS Project Proposals

Critical
Project Project PURA
Infrastructure Features
Location Size Ruling
Served

Bridgeport, CT 2.3 MW/ Three, 9-story Microgrid expansion to Approved


5.5MWh elderly housing provide outage support to
facilities an additional 598 customers
for at least 4 hours

North Haven, CT 1.5MW/ Senior living care Microgrid expansion to Approved


4MWh facility with provide outage support to
outpatient and an additional 166 customers
rehabilitative for at least 4 hours
services

New Haven, CT 2.5MW/ Magnet high school Microgrid expansion to Approved


7MWh that also serves as provide outage support to
the community an additional 166 customers
emergency shelter for at least 4 hours

Additionally, the Authority applauded UI’s extensive engagement with its local
communities in developing their ESS proposals. UI included significant input from
community leaders in its proposals, helping lead to high-value proposals for those
communities. Additionally, the Authority was pleased to find that UI identified key
learning opportunities and demonstration objectives, and exhibited a willingness to
investigate how ESS can improve the reliability and resilience of critical infrastructure
and maximize the ESS’ value through secondary applications. In general, the Authority
appreciates and encourages future application of UI’s approach to tailoring its proposed
solutions to the needs of the communities they serve, as well its adherence to the
statutory intent of Section 2 of Public Act 22-55 and the Authority’s specific direction and
recent guidance on other matters.

Eversource’s Projects

Eversource submitted projects located in Voluntown, Sherman, and Winchester.

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PURA 2023 ANNUAL REPORT

Unfortunately, the Authority’s review of these proposals resulted in denying all three
without prejudice. Eversource did not demonstrate sufficiently that these projects would
provide value to ratepayers. Specifically, Eversource has not adequately justified that the
ESS nameplate capacity is warranted and that the projects will be undertaken at a
reasonable cost. Finally, the Authority found that Eversource’s operational strategy will
not maximize benefits to ratepayers. Therefore, in order to receive Authority approval, the
Authority directed Eversource to resubmit proposals to address the Authority’s findings
by May 31, 2024.

Federal Funding Requirements

The EDCs are permitted to recover prudently incurred costs for approved ESS pilot
projects proposed pursuant to Public Act 22-55 through a fully reconciling component of
electric rates for all customers until the company's next general rate case, when costs
would be incorporated into base distribution rates. The EDCs can, and should, also seek
federal funding for which they are eligible in order to offset ratepayer costs.

In November 14, 2023, the U.S. Department of Energy (DOE) announced up to $3.9 billion
of available grants in the second round of the Grid Resilience and Innovation Partnerships
(GRIP) Program. The ESS proposals may be eligible for federal funding under the GRIP
Program Grid Resilience Utility and Industry Grants. This funding supports grid
modernization efforts by investing in the deployment of advanced technologies
including DERs and storage systems that can mitigate multiple hazards across a region or
within a community.

Thus, PURA directed the EDCs to apply for the second round of funding available through
the DOE’s Grid Resilience Grants program. Concept papers for this funding opportunity
were due at 5:00 p.m. ET on January 12, 2024. The Authority directed the EDCs to report
on progress made seeking the above federal funding opportunities (e.g., the filing of a
concept paper) and any results provided by the U.S. DOE as compliance in the
proceeding within three business days of any submissions or receipt of any
correspondence from U.S. DOE. UI has confirmed, via a compliance filing on January 17,
2024, that it successfully submitted a proposal to DOE for funding of the New Haven ESS
project. The Authority will continue to monitor the deployment of all three UI projects,
and any associated federal funding awards.

Advanced Metering Infrastructure


In 2019, the EMG Interim Decision identified advanced metering infrastructure (AMI) as
essential to achieving the objectives of a modern electric grid for Connecticut. AMI is a
tool available to the EDCs to better understand, plan, and operate their system, but that
same information is also important to customers and market-based opportunities to help
customers better manage their consumption and save money. Specifically, AMI enables a
number of functions that conventional utility meters cannot provide including automatic
measurement of granular energy usage data, remotely identifying and isolating outages,

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PURA 2023 ANNUAL REPORT

and monitoring voltage. These functions unlock a whole host of new customer offerings
such as time-of-use energy rates or advanced rates for EVs, greater control over energy
consumption using smart technology, and load-shifting. For utilities, AMI allows reduced
costs related to metering and billing, better visibility of the grid and power quality, faster
outage restoration, and improved operations efficiency.[10] AMI will accelerate the
modernization of Connecticut’s electric grid in numerous innovative, cost-effective, and
equitable ways.

Today, about 90% of customers in UI’s territory have AMI. The AMI deployment in UI’s
territory has allowed the company to realize many operational benefits such as remote
meter reading, service order automation, proactive outage planning, storm restoration
efficiencies, the validation of resilience/reliability measures, early outage detection,
system planning optimization, energy theft reduction, provision of detailed billing data,
rate design, enhanced online portals, high-bill alerts, outage status, customer targeting
for initiatives, and reduced billing-related calls to the call center. UI expects that the
benefits will continue to accrue for the listed categories and expects the benefits to
increase as the remaining Automatic Meter Reading (AMR) meters are replaced and as
the features of AMI meters and systems are available that can provide load
disaggregation, load balancing, voltage monitoring, and voltage reduction.

In Eversource’s territory, however, more than 75% of Eversource’s customers still have
standard meters (AMR meters) that are 20 or more years old. The other 25% have “bridge
meters” that work with the AMR meters but can be enabled to work with an AMI system.
To support AMI, Eversource would not only need to install meters, but it would also need
to install and integrate the following with meters and existing systems: communications
systems; back-office systems; meter data management; and customer information
systems. Unlike UI, where significant investment has already taken place, Eversource
needs to conduct significant levels of investment to implement AMI.

As such, achieving statewide deployment of AMI and the realization of its associated
benefits will require significant capital investment from ratepayers. After three years of
tremendous public process in Docket No. 17-12-03RE02, PURA Investigation into
Distribution System Planning of the Electric Distribution Companies – Advanced Metering
Infrastructure, including numerous opportunities for stakeholder input, guidance from
industry experts such as federal agencies, peer jurisdiction utilities, and technology
providers, PURA released a framework for the deployment of AMI through a final Decision
on January 3, 2024. This framework provides a regulatory roadmap for the EDCs, protects
ratepayers, and ensures that the investment in AMI will advance the economic, energy,
and environmental policy goals of Connecticut. Importantly, this Decision outlined a
process to assess the prudence of any costs associated with the deployment of AMI in
accordance with the outlined framework during the EDCs’ future, respective contested
rate proceedings.

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PURA 2023 ANNUAL REPORT

The AMI framework implements the regulatory goals and priority outcomes outlined by
the PBR Decision discussed in Section 2. With respect to AMI, the main regulatory goals
are (1) Excellent Operational Performance and (2) Customer Empowerment and
Satisfaction. The AMI-specific priority outcomes for Excellent Operational Performance
and Customer Empowerment and Satisfaction are distribution system utilization and
customer empowerment, respectively. The Decision then identifies numerous metrics to
measure an EDC’s progress in deploying AMI and demonstrating that the infrastructure is
providing service to customers. Additionally, the EDCs are therefore expected to work
towards achieving these regulatory goals and priority outcomes, while taking into
account certain foundational considerations when advancing toward the outcomes,
including, safety, equity, economic opportunity, risk distribution, and transparency.. With
respect to AMI, the main regulatory goals are (1) Excellent Operational Performance and
(2) Customer Empowerment and Satisfaction. The AMI-specific priority outcomes for
Excellent Operational Performance and Customer Empowerment and Satisfaction are
distribution system utilization and customer empowerment, respectively. The Decision
then identifies numerous metrics to measure an EDC’s progress in deploying AMI and
demonstrating that the infrastructure is providing service to customers. Additionally, the
EDCs are therefore expected to work towards achieving these regulatory goals and
priority outcomes, while taking into account certain foundational considerations when
advancing toward the outcomes, including, safety, equity, economic opportunity, risk
distribution, and transparency.

Key components of the framework are a comprehensive list of benefits that AMI can
provide to make business operations more efficient, improve system utilization, and
increase customer engagement with energy usage, all of which help advance the goals of
the Equitable Modern Grid Framework. The framework also identifies investments and
costs necessary to enable the benefits so that the evaluation of the costs and benefits can
be evaluated transparently. For each benefit and cost stream, the Authority has outlined
a set of metrics that the Authority will require the EDCs to report on through the use of
scorecards to monitor both the deployment and implementation of AMI. The goal of the
scorecards is to provide transparency and accountability for the ongoing AMI investment.
Scorecards will be filed semi-annually, starting six months following submission of an
EDC’s final AMI plan.

For next steps, the Decision provides guidance regarding the EDCs’ submission of a Final
AMI plan. Each Final AMI Plan must include required information tied to the identified
AMI benefits and costs outlined in the Decision, implementation and deployment plans, a
benefit-cost analysis using the Authority’s approved design, demonstrated evidence of
competitive procurements for AMI technology components that maximize AMI’s
potential and value to ratepayers, updated proposals for time-of-use rates, and a
customer outreach and engagement plan. The Authority also required that the EDCs
make every effort, both now and in the future, to identify federal funds or other financing
options that can offset the costs associated with implementing AMI.

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PURA 2023 ANNUAL REPORT

AMI Cost Recovery

During the proceeding, Eversource stated that the company requires a clear, reasonable,
and certain cost recovery path to move forward with an AMI investment. In its current
AMI Plan, Eversource proposes approximately $400 million of capital investment over the
first five years of AMI deployment (approximately $80 million per year). Eversource claims
that due to both the level of costs and the short timeline with which they are to be
incurred, it is necessary that cost recovery be granted at defined intervals during the
deployment window outside of a general rate case, such as through the annual RAM
proceedings.
The Authority recognizes that the anticipated capital costs outlined above, while not
entirely incremental, may be significant and incremental relative to the business-as-usual
core business investments. The costs are also largely concentrated in a five-year
deployment period. Taken together, these factors may potentially necessitate
consideration of an extraordinary ratemaking measure, such as the implementation of an
annual cost reconciliation mechanism. Given this, the Authority initiated a docket
simultaneously to releasing the AMI framework decision, titled as Docket No. 17-10-
46RE04, Application of the Connecticut Light and Power company d/b/a Eversource
Energy to Amend its Rate Schedules – AMI Cost
Recovery. This is a contested proceeding that will
consider the development and adoption of an Additional AMI Resources
AMI cost recovery tracker. In the course of that
AMI Final Decision
proceeding, the Authority will consider an
Cost Recovery NOP
appropriate structure of a cost tracker that allows
the company to cover their prudently incurred
costs while providing appropriate protection to the public interest. The schedule for this
proceeding ensures that a ruling will be issued by November 20, 2024, which provides
sufficient time for Eversource to include in its 2025 RAM filing a request for cost recovery
of any applicable 2024 costs, if so authorized.

Progress Growing the Green Economy


Innovative Energy Solutions (IES) Program
Innovation is a natural complement to modernization; one that can, if harnessed, greatly
enhance the benefits and services delivered to ratepayers. With the increase of data
availability, grid-edge visibility, and distributed energy resources comes significant
opportunities to optimize the grid, its resiliency and reliability, and the customer
experience. However, the risk and uncertainty of requiring utilities to conduct traditional
research and development or even to pilot new technologies or applications can often be
too great to consider the expenses prudent. So, conventional strategies often continue to
be implemented, even though novel and emerging options show promise to lower costs
and/or improve service.
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PURA 2023 ANNUAL REPORT

The Authority issued a decision in Docket No. 17-12-03RE05 on March 30, 2022, officially
approving the program design of the Innovative Energy Solutions Program (IES Program).
The goal of this program is to enable the deployment of, on a limited basis, innovative
pilot technologies, products or services, and to evaluate their performance. If satisfactory
ratepayer benefits are demonstrated, the innovation(s) could be scaled up for statewide
deployment by the EDCs.

There are two features of this program that distinguish it from other pilots or test beds.
The first is that it employs guardrails and project “off-ramps” to ensure value and to
minimize ratepayer risk. The IES Program is structured into four phases, where potential
innovations are reviewed with increasing scrutiny to ensure that their product or service
meets the needs of Connecticut’s grid and ratepayers and can deliver their claimed
benefits or value at scale. If a project cannot meet the criteria and thresholds at a certain
phase, the Authority will be able to quickly retire the project, thereby avoiding
unnecessary risk and costs to ratepayers.

The second feature addresses the inverse situation where a pilot project demonstrates
substantial ratepayer and grid benefits. In this case, the IES program provides a clear
pathway by which to move a successful pilot project to full-scale deployment across the
state’s two largest EDCs’ territories, which the traditional approach to EDC pilots have
lacked nation-wide to date. This ensures that successful pilots are brought to scale,
thereby delivering the benefits of innovation to all ratepayers.

The IES Program also places a high value on transparency, which is achieved through the
external Innovation Advisory Council (IAC) comprised of a representative set of
stakeholders, who would have a responsibility for ensuring a balanced perspective in the
IES program.[11] Though the Authority is the primary entity responsible for developing,
administering, and managing the IES Program, and retains ultimate decision-making
authority over aspects of program design and project selection, the IAC provides a forum
where potential participating innovators can engage and discuss the program without
violating the standard communications rules with PURA. Additionally, the IAC will set the
themes and objectives for each annual Program Cycle and will screen projects through
the first two phases.

IES Cycle 1

The first IES Program Cycle officially launched on January 31, 2023, in Docket No. 22-08-
07, Innovative Energy Solutions Program Cycle 01. Each program Cycle focuses on a
selected “theme” around which projects are solicited, but does not exclude proposals that
fall outside that theme. The theme is discussed and voted on by the IAC with
consideration from the EDC’s joint grid and customer needs reports, as well as other
ongoing state policy and priority goals. The Cycle 1 theme focused on Demand-side
Flexibility, which includes, but is not limited to, advanced forecasting, automation,
flexible winter peak technology, and thermal storage.

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PURA 2023 ANNUAL REPORT

Interested innovators were able to submit proposals through one of three distinct
pathways: (1) developer-led projects; (2) EDC-led projects; and (3) collaborative projects.
These pathways are intended to create opportunities for and encourage diverse
participation from the full ecosystem of potential solutions providers and innovators.

Cycle 1 Phase 1

In Phase 1 of the IES Program Cycle 1, interested applicants were required to submit a
concept proposal via the Program website, www.CT-IES.com, providing a high-level
description of the proposed solution and project, by March 1, 2023. The IES Program
received 52 Phase 1 applications.

The Program Administrator (Strategen Consulting), in coordination with IAC, reviewed


the proposals and determined which were eligible to submit a detailed proposal in Phase
2. An IAC meeting was held to determine the final list of Phase 2-eligible projects. To be
determined eligible, applicants were required to demonstrate that their project:

Addresses current gaps in EDC offerings in Connecticut;


Advances decarbonization;
Addresses underserved communities in Connecticut;
Avoids a competitive advantage for EDCs;
Avoids an unreasonable impact to Connecticut ratepayers; and
Will be authorized to practice business in Connecticut.

The IAC ultimately found 33 of the 52 applications to be eligible to apply to Phase 2, and
were simultaneously invited to present at Pitch Fest on April 18, 2023, a live pitch event
co-hosted by PURA and Connecticut Innovations. At Pitch Fest, attendees including non-
decisional PURA Staff, EDC Staff, and IAC members, heard elevator pitches from
applicants, had the opportunity to speak directly with applicants to learn more about
their projects, and then voted for the projects they were most interested in hearing
longer pitches from. Regardless of whether an applicant was selected to present a longer
pitch at Pitch Fest, all Phase 2 eligible applicants were invited to submit Phase 2
applications. Phase 2 applications were provided to applicants on May 1, 2023.

Cycle 1 Phase 2

Projects invited to submit proposals in Phase 2 were required to provide detailed


information regarding the project’s value proposition, business and financial model,
strategic alignment with the IES Program objectives, equity provisions, scalability, and
project team qualifications.

The Program Administrator and the IAC then evaluated these proposals and their ability
to address key criteria such as Innovation Potential, Measurable Benefits, and Focus on
Underserved Communities and Equity. Descriptions of these criteria are included in Table
10 below:

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PURA 2023 ANNUAL REPORT

Table 10: IES Phase 2 Evaluation Criteria

Category Description

Innovation Potential Examines whether the Proposed Project involves “testing a new
product, program, tariff, service, or business model that is not widely
used in Connecticut and is conducive to scaling, replication, or serving
as a potential model for others to adopt or deploy.”

Project Examines whether the Proposed Project’s implementation tracking


Implementation plan is reasonably achievable and outlines performance metrics, data
Tracking Plan (PITP) collection specifics, a timeline with stages, and milestones that are tied
to cost recovery, and the frequency and detail required for progress
reporting.

Project Benefits Examines whether the Proposed Project provides measurable and
sustainable benefits to society or the community, to customers, and to
the EDC and electric grid.

Focus on Examines whether the Proposed Project provides measurable benefits


Underserved for Connecticut’s underserved communities, as that term is defined by
Communities the Connecticut Department of Economic and Community
Development’s (DECD) Environmental Communities and Distressed
Municipalities.

Advances Examines whether the Proposed Project provides measurable and


Decarbonization sustainable benefits to support Connecticut’s goals to decarbonize its
electric grid by delivering zero-carbon electricity to customers by 2040
and reducing greenhouse gas emissions.

Women and Examines whether the Proposed Project has a Connecticut or Federal
Minority-Owned certification as a women-owned business, minority-owned business, or
Business both. This is not a requirement, but considered a benefit.

Priority Theme Examines whether the Proposed Project fits within the Cycle 1 theme of
Demand-side Flexibility. According to the Program Administrator, the
Proposed Project’s alignment with the Cycle 1 theme is not a
requirement, but rather a benefit.

During the Phase 2 process, all IAC members were provided an opportunity to discuss
applications amongst council members and highlight follow-up questions to ask
applicants. To that end, and to host a general open-forum discussion on Phase 2
applications, the IAC met on June 27, 2023, and again on July 11, 2023. The Program
Administrator, on behalf of PURA Staff and IAC members, issued follow-up requests to
applicants.

On July 31, 2023, the Program Administrator filed a portfolio of 8 recommended projects

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PURA 2023 ANNUAL REPORT

totaling $14 million on behalf of the IAC to the Authority for final review and approval.
The Authority issued rounds of interrogatories and hosted a technical meeting where
representatives of the IAC-recommended projects gave presentations and answered
further questions from Authority staff.

On December 13, 2023, the Authority issued an Interim Decision in Docket 22-08-07
approving seven of the eight recommended projects for pilot deployment in Phase 3 of
Cycle 1 along with the supporting justification for each project. Below are descriptions of
each of the seven innovative pilot projects.

AmpUp
AmpUp proposed a project for managed EV charging by integrating its existing
charging management software with utility demand response programs. This
project will allow grid operators to decrease load at EV charging stations during
periods of grid stress through automated participation and incentives that
compensate charging station owners for decreasing charging during peak
periods. The platform will also offer real-time reporting on station status and
energy management controls, such as time-of-use rate setting. Additionally,
AmpUp’s project can further demonstrate economic benefit by managing EV
charging to shift loads, which can help defer or avoid distribution infrastructure
investments, resulting in savings for ratepayers.

Edo
Edo proposed an 18-month project that demonstrates how commercial
buildings can provide both temporary, flexible demand management and
longer-term, geographically specific load reduction. Edo aims to target 25
commercial buildings served by a single substation in a distressed municipality
in Eversource’s service territory. The project offers energy and non-energy
benefits including energy savings, load shifting, improved health, job creation,
and reduced greenhouse gas emissions.

GridEdge Networks
GridEdge Networks proposed integrating an Area Cooperative Educational
Services (ACES) electric school bus in New Haven, CT, with the electric grid
using Vehicle to Grid (V2G) technology and bidirectional V2G direct current fast
charging (DCFC). V2G capability is an emerging technology with particularly
high potential benefits given the characteristics and use patterns of electric
school buses. GridEdge anticipates that the project would provide additional
revenue streams to the EV fleet owner through participation in utility demand
response programs, allow the EDCs to manage the bus’s charging and
discharging cycles, and benefit the local community by reducing air pollution
and serving as a back-up power source in case of outages.

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PURA 2023 ANNUAL REPORT

KrakenFlex
KrakenFlex proposed to use its Kraken technology platform to enroll residential
customers with DERs in a new demand-side flexibility tariff program that
optimizes those DERs for customer and EDC objectives. KrakenFlex’s proposal is
designed to automate customer and EDC participation and remove gaps in
Connecticut’s electric distribution system by giving UI the ability to utilize
residential demand flexibility to control and optimize network connected
residential DERs. This model can help further promote the sales and installation
of clean technologies such as EV chargers and heat pumps by improving the
cost-effectiveness of these investments. Participating customers are expected
to see an estimated $100-$120 in annual bill reductions per asset.

Piclo
Piclo proposed creating a statewide flexibility market in Connecticut that can
help mitigate grid constraints. The project aims to be the “eBay” of
decarbonized grid flexibility by introducing a cloud-based, competitive
marketplace to connect buyers of demand-side flexibility (i.e., the EDCs) with
sellers of demand-side flexibility (Flexibility Service Providers or FSPs, e.g., DER
owners and aggregators).Piclo’s pilot will expand the portfolio of DER types and
companies available to provide flexibility services and consolidate them onto a
single platform, which will enable flexibility procurement transactions and
provide supporting services. The pilot phase involves customizing the existing
Piclo Flex product to Connecticut’s grid, identifying use cases, recruiting FSPs,
and determining dispatch and communication protocols with FSPs and the
EDCs.Piclo has identified two FSPs prepared to enroll DERs on the platform and
plans to pursue partnerships with additional FSPs.

Smarter Grid Solutions


Smarter Grid Solutions (SGS) proposed the use of Strata Grid Active Network
Management Platform (Strata Grid) to integrate flexible load, energy storage
solutions, and EV chargers to help UI dynamically manage grid constraints. As
the use of the grid is approaching pre-set limits, Strata Grid will ensure that
network limits are not violated. Strata Grid will help optimize system capacity,
including increased capacity as well as expedited interconnection. Previous
applications of the Strata Grid have seen 50-100% capacity improvement.
Greater hosting capacity and faster interconnection could lead to increased
deployment of DERs and the creation of additional in-state jobs.

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PURA 2023 ANNUAL REPORT

Tantalus
Tantalus proposed an initiative to deploy smart computing devices, known as
the TRUSense gateway, to access and control behind-the-meter DERs. The
devices would provide power quality data to analyze the impact of DERs and
identify vulnerable transformers. The demonstration would target about 200
homes located in an underserved community in UI service territory, of which
about 100 homes would receive smart devices and behind-the-meter DERs,
such as smart thermostats, smart circuit breakers, and thermal energy storage
water heaters. Tantalus’ project will test a strategic combination of new
products to enhance benefits associated with existing demand response
programs and dynamic rate performance.

Cycle 1 Phase 3

Following the Authority’s December 13, 2023 Interim Decision, each project began the
contracting phase with the EDCs to begin pilot deployment in Phase 3. Upon contract
execution, the projects can begin deploying their technology. Using pre-determined
milestones set during Phase 2, the projects will recover costs concurrent with each
milestone’s achievement. Each Phase 2 Applicant with a Proposed Project selected for
deployment in Phase 3 is required to track and report on their metrics and milestones on
a bi-monthly basis. At the conclusion of each project’s pilot phase (approximately 12-18
months), the Program Administrator will prepare a final recommendation to PURA
regarding whether the technology should be deployed at scale statewide. Projects that
are not yet ready to scale but display promise and economic viability will have an
opportunity to cycle back though the IES program with modifications in place, but this
will be assessed on a case-by-case basis. Projects that do not display further potential to
scale up upon assessment during Phase 4 will exit the IES program.

IES Cycle 2

The Cycle 2 proceeding will be conducted through Docket No. 23-08-07, Innovative
Energy Solutions Program Cycle 2. On January 1, 2024, the IES Program began accepting
proposals for Cycle 2 under the theme, “Empowering Electrification.” Electrification refers
to replacing direct fossil fuel use (e.g., propane, heating oil, gasoline) with electricity in a
way that reduces overall emissions and energy costs. Transportation, electricity, and
residential heating account for almost three quarters of Connecticut’s greenhouse gas
(GHG) emissions, which by 2030, must be reduced by 45% from 2001 levels.

The IES program is looking for innovative projects that can reduce barriers to clean
technology adoption, electrify energy consumption, and/or develop ways to integrate and
manage new and flexible loads to the electric grid.Projects that fit within the Cycle 2
Theme of “Empowering Electrification” can reduce emissions across all sectors by
electrifying equipment as electricity generation simultaneously shifts towards cleaner

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PURA 2023 ANNUAL REPORT

alternatives, creating a “win-win-win” for EDCs, customers, and the environment.


Examples of eligible technologies under this theme could include but are not limited to:

Figure 13: IES Cycle 2 “Empowering Electrification” Potential Projects

Pathway 1 Pathway 2

New rates for heat pump


Lowering barriers to fleet
and/or electric vehicle
electrification adoption.
customers.
Platform development to
Recommended modifications
facilitate transactions for
to support fuel switching
customers that want to
(including cures to loss of
electrify homes.
customer if they switch from
Novel behind-the-meter
natural gas to electric
electrification technology.
equipment).

Pathway 3

Integration of a holistic solution that enables active management of EV


chargers and other customer-sited DERs to increase dynamic hosting
capacity through continuous monitoring of network load and active
management of flexible resources.
Integration of smart grid technology that can improve user understanding
and control of their building energy usage, and provides them with
pathways towards reducing their energy usage or pivoting towards
electrification.
Location-based incentives/rates for interconnection and/or energy use,
depending on grid constraints.

Importantly, the IES Program will also accept proposals that address the priorities
identified in the EMG Framework. Concept proposals were due by February 1, 2024.
Interested parties should visit www.ct-ies.com or contact [email protected] with any
questions.

Click to visit the IES


Additional IES Program Portal
Resources
IES Program Design
Cycle 1 Interim Decision

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PURA 2023 ANNUAL REPORT

2023 CLEAN & RENEWABLE ENERGY


PROGRAM UPDATES
Since 2021, the Authority has prepared and released an annual report summarizing the
most up-to-date and comprehensive data available regarding ratepayer-funded clean
energy programs in Connecticut. This Annual Clean and Renewable Energy Report (CRE
Annual Report) is designed to provide transparency and insight into the state’s CRE
programs and procurements for all stakeholders and state policymakers. The CRE Annual
Report is also intended to be a resource for state policymakers and stakeholders when
considering potential modifications to state energy policy goals. In sum, the Authority’s
primary objective in the CRE Annual Report is to provide open access to the data from
the CRE programs that are funded by Connecticut ratepayers.

Specifically, this report provides data regarding the following CRE programs and market
segments:

Residential solar photovoltaic (PV) systems


Non-Residential solar PV systems
Shared Clean Energy Facilities (SCEF) Program
Public Policy Contracts and Power Purchase Agreements (PPAs) selected through
Department of Energy and Environmental Protection (DEEP) procurements
Clean Energy Options Program (CEOP) / Voluntary Renewable Option (VRO) Program
Renewable Portfolio Standards (RPS) Compliance
Electric Vehicle (EV) Charging Program
Energy Storage Solutions (ESS) Program

Beginning with the 2023 CRE Annual Report, PURA will release this report concurrently
with the release of each PURA Annual Report both in its standard docket and as an
appendix to the PURA Annual Report. The 2023 CRE Annual Report was released on
February 14, 2024, in Docket No. 23-08-01, 2023 Clean and Renewable Energy Program
Data and Report. The Authority remains committed to expanding and improving the
type, quality, and presentation of the data included in the CRE Annual Report, and will
seek to make incremental improvements each year, to the extent possible.

2023 Clean and Renewable Energy Report


See Appendix 3
Report in Docket

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PURA 2023 ANNUAL REPORT

[1] Retail suppliers are licensed by the Authority to provide electricity generation services. See Conn.
Gen. Stat. § 16-245(b).Retail suppliers’ rates are posted on the EnergizeCT rate board at
https://energizect.com. See Conn. Gen. Stat. § 16-244d(b); Decision, May 6, 2020, Docket No. 14-
0720RE01, PURA Development and Implementation of Marketing Standards and Sales Practices by
Electric Suppliers – Revised Standards, Ex. B, p. 5 (“[A]ll of a [retail supplier’s] generally available rates
must be posted to [energizect.com].”).

[2] Conn. Gen. Stat. §§ 16-244c(a)(3) and 16244m(a).

[3] Decision, Apr. 21, 2004, Docket No. 03-01-15, DPUC Investigation into the Need for Interconnection
Standards for Distributed Generation.

[4] Hosting capacity is the estimated maximum amount of energy from a distributed resource (such
as solar panels) that can be accommodated on the distribution system at a given location. This
capacity is under existing grid conditions and operations without requiring significant infrastructure
upgrades. This capacity takes into consideration safety, power quality, reliability, or other operational
criteria.

[5] Additional, specific options exist, including smart inverter setting, that can generally be
categorized other reducing the project’s capacity.

[6] See Appendix 3 for more information on the RRES program and its deployment data.

[7] The make-up of the working group includes the EDCs, various distributed energy resource
developers, OCC, BETP, the Connecticut Industrial Energy Consumers (CIEC), and PURA EOE staff.

[8] Excluding these categories of outages helps evaluate the long-term, blue-sky reliability of the
distribution system. Major storms in particular can create large variations in reliability data making
year-to-year comparisons difficult and potentially misleading.

[9] The Authority includes the four-year average ending 1998 in conjunction with Conn. Gen. Stat. §
16-244i.

[10] U.S. Department of Energy, Advanced Metering Infrastructure and Customer Systems, September
2016, available at:
https://www.energy.gov/sites/prod/files/2016/12/f34/AMI%20Summary%20Report_09-26-16.pdf

[11] In 2023, the IAC membership composition included PURA, the Connecticut Green Bank, DEEP,
OCC, United Illuminating, Eversource, Connecticut Innovations, CTNext and the Yale Carbon
Containment Lab.

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PURA 2023 ANNUAL REPORT

2023 GRID MODERNIZATION DECISIONS

Docket Decision
Title
Number Date

Annual Residential Renewable Energy Solutions Program


22-08-02 2/8/2023
Review – Year 2

2023 PURA Report to the General Assembly Regarding the


23-02-02 2/8/2023
Electric Efficiency Partners Program

22-08-01 2022 Clean and Renewable Energy Program Data and Report 2/22/2023

Application of The Connecticut Light and Power Company


and Yankee Gas Services Company, each individually d/b/a
Eversource Energy, The United Illuminating Company,
21-07-01 9/6/2023
Connecticut Natural Gas Corporation, and The Southern
Connecticut Gas Company for Approval of Arrearage
Forgiveness Program 2021-2022

Annual Review Of Affordability Programs And Offerings


23-05-01 10/11/2023
(Energy Affordability Annual Review)

Annual Residential Renewable Energy Solutions Program


23-08-02 11/1/2023
Review - Year 3

Annual Non-Residential Renewable Energy Solutions Program


23-08-03 11/82023
Review - Year 3

23-08-05 Annual Energy Storage Solutions Program Review - Year 3 11/29/2023

23-08-06 Annual EV Charging Program Review - Year 3 11/29/2023

23-08-04 Annual Shared Clean Energy Facility Program Review - Year 5 12/6/2023

22-08-07 Innovative Energy Solutions Program Cycle 01 12/13/2023

Annual Electric Distribution Company Reliability And


23-08-09 12/13/2023
Resilience Framework Review

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PURA 2023 ANNUAL REPORT

Docket Decision
Title
Number Date

22-06-05 PURA Implementation Of Public Act 22-55 12/20/2023

PURA Investigation Into Distributed Energy Resource


22-06-29 12/20/2023
Interconnection Cost Allocation

23-07-02 PURA Implementation Of The Provisions Of Public Act 23-199 12/20/2023

PURA Investigation Into Distribution System Planning Of The


17-12-03
Electric Distribution Companies -Advanced Metering 1/3/2024
RE02
Infrastructure

A comprehensive list of PURA 2023 decisions is available in Appendix 2,


attached to this Report.

PURA 2023 ANNUAL REPORT

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PURA 2023 ANNUAL REPORT

SECTION 4:
THE ELECTRIC SECTOR
1.5 M Customers
The Electric Sector is the largest industry regulated by PURA
with over $2.88 billion annually in distribution revenue under
PURA’s jurisdiction. The Authority is responsible for regulating
the rates, services, and distribution infrastructure of
Connecticut’s two investor-owned electric distribution
companies (EDCs), The Connecticut Light and Power Company
d/b/a Eversource Energy (Eversource) and The United
Illuminating Company (UI), in a manner that leads to just and
reasonable rates. Together, Eversource and UI serve over 1.5
million customers (also called “ratepayers”), which represents
over 90% of the state’s electric customers.

The Authority’s oversight of the EDCs, which is detailed in


Conn. Gen. Stat. Title 16, covers a broad range of topics,
including but not limited to:

Electric distribution rates and other bill charges;


The provision of safe, adequate, and reliable service;
The wholesale procurement of electricity;
The administration of renewable power contracts;
Emergency performance and incident response procedures;
The administration of utility poles;
Vegetation management practices (i.e., tree trimming);
Metering and billing accuracy;
Customer service, education, and outreach; and
The oversight of renewable energy tariff structures.

In addition to its regulation of the EDCs, the Authority also has


purview over other aspects of electric sector regulation,
including but not limited to:

Third party electric supplier licensing;


Registration of electric aggregators;[1] and
Monitoring compliance with the renewable portfolio
standards.

When a docket concerning any of the above topics is brought

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PURA 2023 ANNUAL REPORT

before the Authority, staff must follow the docket process to build a record of evidence
that enables a well-founded decision that supports the agency’s overall mission of just
and reasonable rates. A detailed explanation of this process is included in Appendix 1 –
Standard Docket Procedure Guide, attached to this report.

Electric Supply Costs

While many components of the Electric Sector are under PURA’s jurisdiction, PURA does
not regulate wholesale energy costs. When Connecticut deregulated its energy supply in
1998, the intent was to let market competition reduce both supply costs and risk to
ratepayers, while PURA would oversee the safe, reliable, and affordable distribution of
electricity throughout the state.[2] The cost of electricity supply is now dictated by the
regional wholesale energy markets overseen by the Independent System Operator of
New England (ISO-NE or ISO New England). Although ratepayers are authorized to shop
for an alternate supplier, most ratepayers elect to remain on standard default service,
whereby Eversource and UI purchase electricity through the wholesale energy markets
and pass that cost directly through to ratepayers. The EDCs do not earn a return on the
cost of electricity supply.

On January 1, 2023, the EDCs’ procured supply rates effectively doubled, reflecting
increased wholesale electricity prices due to a variety of factors, but most significantly,
the cost of natural gas. As shown by Figure 14, natural gas fuels approximately 53% of
New England’s electricity generation. With ongoing global conflicts, high demand, and
natural gas transmission constraints, the price for electricity generated by natural gas
plants increased dramatically. Since natural gas is the “marginal resource”, or the resource
that sets the price in the wholesale energy markets in most hours, this means that
electricity generation overall in New England became more expensive in early 2023 when
natural gas prices rose.[3]

Connecticut, and many other states in New England, have committed to decarbonizing
their electric sectors and reducing their reliance on natural gas for electricity generation.
[4] ISO New England has reported that it currently has over 35,000MW of new generating
capacity proposals in its interconnection queue, the majority of which is wind or battery
storage.[5] Over time, as the region shifts to renewable resources powered by low- or
zero-cost energy inputs, wholesale electric supply costs should decline.

In the meantime, the Authority recognizes that in a state with already high utility rates,
any increase is alarming, frustrating, and harmful for many ratepayers. Though the
Authority unfortunately does not regulate the price of wholesale electric supply, it has
designed and implemented multiple affordability and shut-off protection programs,

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PURA 2023 ANNUAL REPORT

particularly for customers with past-due


Figure 14: New England
balances, and renewable energy tariffs that Regional Generation Mix
facilitate a ratepayer’s decision to install, lease,
or subscribe to solar facilities in the state to
gain some control over their electric supply
costs. See Section 3 for further details on these
programs.

While the Authority does not have oversight


over the regional wholesale energy markets, it
does have the ability to review and modify, as
necessary, the manner in which the EDCs
procure electricity supply for their customers.
On January 12, 2024, PURA issued a Legislative
Report that reviewed the current Standard
Service (SS) electric procurement practices, i.e.,
the process by which the EDCs’ supply offer is
determined, and conducted an initial analysis
of potential modifications to the process that
could result in more reasonable rates, more
stable rates, or outcomes more reflective of
market prices. Further discussion on this
report is available in Section 3.
Source: ISO New England

KEY ELECTRIC SECTOR TOPICS IN 2023


Safety: Assessing Accident Response Operations
Maintaining the safety of the electric grid, for both the public and utility employees, is
paramount for the provision of reliable and cost-effective electric service. As such, the
Authority takes accidents involving grid infrastructure and the enforcement of safety
standards and regulations very seriously. Electric distribution companies are legally
required to notify PURA of any accident resulting in personal injury or involving public
safety, which was or may have been connected with or due to the operation of the grid as
soon as reasonably possible, and to update the Authority at regular intervals thereafter.
Should the Authority find that a company has failed to comply with these laws and
regulations, it can issue fines to regulated entities.[6]

In 2023, the Authority conducted investigations related to accidents impacting the


distribution grid that involved both civilians and contractors used by Eversource.[7]

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PURA 2023 ANNUAL REPORT

Docket No. 23-01-32, Investigation into Eversource’s Manner of Operation and Safety
Regarding its Underground Electric Distribution System, focused on accidents related to
Eversource’s underground infrastructure, while Docket No. 23-01-39, Investigation into the
Response of The Connecticut Light and Power d/b/a Eversource Energy to the Accident
on January 17, 2023, at 602 Greenwoods Road, Norfolk, CT, investigated Eversource’s
response to an accident involving a civilian vehicle. The Authority’s investigations of these
events are summarized below.

Eversource’s Response to Operations and Maintenance Accidents


Connecticut regulations define major accidents for utilities as “[a]ny explosions, major
fires or other cases of serious damage at any utility facility . . . .”[8] Between April 2022 and
February 2023, Eversource filed at least six major accident reports related to its
underground electric distribution infrastructure:

1. Electrical fault in manhole No. 27 at 310 Main Street in Middletown at 11:48 a.m. on
April 22, 2022 (Middletown Incident);
2. Fire in network vault at 29 Main Street in Waterbury at 11:49 a.m. on June 9, 2022
(Waterbury Incident);
3. Failed splice in or around manhole No. 719 at 128 Black Rock Avenue in New Britain at
11:14 p.m. on August 3, 2022 (New Britain Incident);
4. Damaged cable that resulted in dislodged cover at manhole No. 20 at 44 Harwinton
Avenue in Torrington at 8:06 a.m. on August 23, 2022 (Torrington Incident);
5. Electrical fault at a pad-mounted transformer near 627 Churchill Drive in Newington
at 7:44 p.m. on September 8, 2022 (Newington Incident); and
6. Fire occurred where rubber insulation on the secondary cable ignited at manhole No.
1029 on Laurel Street in Hartford prior to 3:02 p.m. on February 2, 2023 (Hartford
Incident).

In its November 22, 2023 decision in Docket No. 23-01-32, the Authority found that all of
the above incidents, with the exception of the Newington Incident, met the definition of
major accident and therefore were subject to the regulatory reporting requirements.
Nonetheless, multiple of the required reports were submitted outside the required
timeframes and all contained reporting deficiencies, including leaving some sections of
the reporting forms blank. The regulations provide clear requirements for accident
reports. For example, Eversource is required to include the “total number of injured
employees” but elected to leave this value blank in several reports.

The Authority also observed during its investigation that Eversource is required to file a
maintenance plan to the Authority on an annual basis. Under the Eversource Electric
Utility Line Maintenance Plan – 2022 (Maintenance Plan), the Company is to inspect
manholes every five years. The objectives of such inspections are to prevent or mitigate
service interruptions, extend the useful life of equipment, avoid future, more costly
maintenance and repairs, and ensure compliance with safety rules, regulations, legal

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PURA 2023 ANNUAL REPORT

requirements, and contractual agreements. However, through this proceeding, the


Authority found that inspections at four of the six incident locations were significantly
overdue.

Eversource’s failure to comply with both regulatory accident reporting requirements, and
with its own Maintenance Plan, raised concerns regarding the Company’s managerial
oversight and whether the Company is prudently and efficiently operating its franchise.
Therefore, the Authority directed Eversource to submit a report to PURA identifying any
non-compliance with the Maintenance Plan on an annual basis until its next rate
proceeding. The report shall state the cause of the non-compliance and any corrective or
remedial action taken by the Company to address the non-compliance.

Eversource’s Response to a Civilian Accident


Docket No. 23-01-39, Investigation into the Response of The Connecticut Light and Power
d/b/a Eversource Energy to the Accident on January 17, 2023, at 602 Greenwoods Road,
Norfolk, CT, investigated Eversource’s response to an accident that occurred on January
17, 2023, at 2:23 p.m. A motor vehicle collided with a utility pole on Greenwoods Road
East in Norfolk, CT causing electrical wires to fall on the car, entrapping the two people
inside the vehicle. This incident was considered a “Priority 1” in that it was a life-
threatening situation where live wires prevented emergency responders from performing
rescue efforts and first aid.

PURA is responsible for determining whether Eversource’s response to this accident was
prudent and reasonable. To make this determination, the Authority assembled the
sequence of events following the accident and assessed whether the actions taken were
completed in the order prescribed by the Company’s protocols. The sequence of events
includes the time that the Company’s System Operation Center (SOC) received
notification of the accident, the time a Response Specialist was assigned to address the
incident, the time the area was deenergized, and the time that the individuals were
rescued from the vehicle. Importantly, it is Eversource’s policy to assign the “fastest”
available Response Specialist to address a Priority 1 event as this type of event requires
immediate attention and is of the highest priority relative to other lower-level events.

In reviewing the sequence of events, PURA found that rather than immediately assigning
a Response Specialist after receiving the notice of a Priority 1 event, it took 17 minutes for
Eversource’s SOC to do so. Further, the SOC did not assign the fastest available Response
Specialist, further delaying Eversource’s response to the accident by a total of 25 minutes.
Notably, as first responders are directed to treat electrical lines as energized under
Priority 1 events until Eversource personnel arrive and can confirm the area is safe, any
delay in Eversource’s response has impacts on timely aid to the entrapped individuals.
Given the life-threatening nature of this accident, this could have had serious
consequences for the individuals in the vehicle, who were trapped for nearly an hour.
Accordingly, the Authority found that the Company’s procedures and actions in response
to the Accident were imprudent.
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PURA 2023 ANNUAL REPORT

As a result of PURA’s finding of Eversource’s imprudent response, the Authority


developed a prospective Priority 1 response target. To do so, PURA first evaluated
Eversource’s response to the nearly 2,000 previous Priority 1 calls that did not occur
during a major storm (also known as “Blue Sky Priority 1 Calls”) between January 2, 2018,
and March 16, 2023. Based on the evaluation, the Authority found that Eversource’s
average response time, i.e., the period between the time the Company received the
Blue-Sky Priority 1 Call and the time the Company arrived at the scene of the Priority 1
event, is 29 minutes and 43 seconds. The Authority also found that Eversource’s
response time for 92.05% of the Blue-Sky Priority 1 Calls is 45 minutes or less and is 30
minutes or less on 68.52% of the calls. Based on the evidence in the record, including
the Company’s response time data and the timeline of its response to the Accident, the
Authority determined that a response time target of 30 minutes (30-Minute Target) for
Blue-Sky Priority 1 Calls is reasonable and appropriate to better protect public safety.

Importantly, the Decision recognizes that extenuating circumstances may exist for
exceeding the 30-Minute Target for a given event. Thus, the Decision specifies
information requirements that Eversource must provide in its accident reports to the
Authority explaining the circumstances that prevented the target from being met
should Eversource fail to meet this new 30-Minute Target. The Authority will review this
information as part of future accident investigations to determine if delays were caused
by factors out of the Company’s control, such as weather or traffic conditions.
Following the completion of the Authority’s
investigation in Docket No. 23-01-39, the Authority
Additional Safety
issued a Notice of Violation and Assessment of
Investigation Resources
Civil Penalty (NOV) in Docket No. 23-01-39RE01,
PURA Consideration Of Civil Penalty And Dkt. No 23-01-32 Final
Enforcement Action Against The Connecticut Decision
Light And Power D/B/A Eversource Energy After Dkt. No. 23-01-39 Final
Investigation Of The Accident, against Eversource Decision
for violations of Title 16 of the General Statutes of Dkt. No. 23-01-39RE01 Final
Connecticut and orders or regulations adopted by Decision
the Authority. In this decision, the Authority found Dkt. No. 23-05-87 UI Final
that Eversource violated Conn. Gen. Stat. § 16-16 Decision
and Conn. Agencies Regs. § 16-163 and
consequently, fined Eversource $12,500.

Affordability: Annual Rate Adjustment Mechanisms


In 2007, the General Assembly enacted Public Act 07-242, An Act Concerning Electricity
and Energy Efficiency, which ordered Connecticut’s electric and gas utilities to decouple
their distribution revenues from the volume of sales. Essentially, this means that if a utility
collects revenue higher than the amount previously established through a full rate case, it
is returned in the next year’s rates as a credit to customers, and if there is an under-

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PURA 2023 ANNUAL REPORT

collection, then the utility can recover that shortfall through an additional charge
instead. Additionally, other costs for programs such as the EDCs’ arrearage forgiveness
programs and several clean energy project contracts entered into by the State of
Connecticut are not included in base distribution rates. While distribution rates are set
through a rate case, the other costs and revenues associated with clean energy
programs, arrearage management programs, etc., are reconciled and charged to
customers through separate rate components that are delineated as additional line
items on the delivery side of a customer’s monthly bill as explained in Section 1.

To ensure a fair and accurate accounting of all rate components charged to customers
and to address any associated under- or over-collections, the Authority annually
performs a full prudency review of actual revenues and approved expenses from the
prior calendar year for all rates, apart from base distribution rates, charged to retail
electric customers.[9] Areas of review include, but are not limited to: the collection
timeline of each rate component, including transmission; program costs (e.g., the
Residential Renewable Energy Solutions program); state-led renewable energy
procurements; resilience and reliability measures; and revenue decoupling. The
Authority initially reviews these filings in March and April to allow for changes to be
provisionally made to the reconciling components starting May 1 of each year.
Subsequently, the Authority conducts a full prudency review of the underlying costs
expended through the associated programs during the previous calendar year and
approves the final rate adjustments associated with such prudency review; any
differences between the May 1 rates and the findings of the Authority’s prudency review
go into effect September 1 of the current year.

In accordance with Conn. Gen. Stat. § 16-19e(a), PURA reviews these rate components to
ensure that:

1. The level and structure of rates [are] sufficient, but no more than sufficient, to allow
public service companies to cover their operating costs including, but not limited to,
appropriate staffing levels, and capital costs, to attract needed capital and to
maintain their financial integrity, and yet provide appropriate protection to the
relevant public interests, both existing and foreseeable…; and
2. The level and structure of rates charged customers shall reflect prudent and
efficient management of the franchise operation.

This process is known as the Annual Review of the Rate Adjustment Mechanisms, or
RAM, and is conducted for both Eversource and UI. Like a rate case, this is an essential
tool that PURA uses to regularly ensure that costs being recovered from ratepayers are
only those that are prudent and necessary.

Every year on March 1, Eversource and UI each submit their RAM filings for the previous
year, detailing the Company’s calculated over- or under-recoveries for the period of
January 1 through December 31 of the previous calendar year. A standardized docket

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PURA 2023 ANNUAL REPORT

numbering system is used for each company’s


annual RAM proceeding: XX-01-03 for Eversource Additional 2023 RAM
and XX-01-04 for UI, with the “XX” representing the Resources
last two digits of the current calendar year. The
Eversource RAM Interim
Authority typically issues an interim decision in
mid-April authorizing the provisional May 1 rates
Decision
and a final decision in mid-August approving the Eversource RAM Final
final revenues and expenses and any rate Decision
adjustments for September 1. UI RAM Interim Decision
UI RAM Final Decision
Table 11 below provides an illustrative example
UI RAM TAC
from the final decision in Docket No. 23-01-03
Reconsideration
issued on August 16, 2023, of PURA’s determination
of whether Eversource under- or over-collected
revenue for each rate component in 2022. Based on the below under- or over-
collection, the Authority made appropriate adjustments to rates in 2023, while also
taking into account the revenues and expenses Eversource was likely to incur through
each rate component in 2023.

Table 11: 2023 Eversource RAM Determination by Rate Component

Rate Component Determination Amount

Generation Services Charge (GSC) Under-Collection ($29,290,269)

Bypassable Federally Mandated Congestion


Over-Collection $8,562,783
Charges (BFMCC)

Non-bypassable Federally Mandated Congestion


Over-Collection $234,482,565
Charges (NBFMCC)

Transmission Adjustment Clause (TAC) Over-Collection $4,603,708

Systems Benefit Charge (SBC) Over-Collection $16,981,906

Electric Systems Improvements (ESI) Under-collection ($26,947,289)

Competitive Transition Assessment Under-Collection ($2,773,134)

Revenue Decoupling Mechanism Under-Collection ($10,422,833)

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PURA 2023 ANNUAL REPORT

Reliability: Storm and Emergency Event Planning


ESF-12
The increase in major storms that have impacted Connecticut over the past decade,
including those at the beginning of the 2010s, as well as 2020’s Tropical Storm Isaias, and
the increased frequency and severity of extreme weather events in recent years, including
the fires and heat waves in the Southwest U.S., Hurricane Ian in Florida, and the flash
flooding events across the Eastern U.S., demonstrate the necessity of diligent and
continuous emergency response planning.

Following the severe storms that hit Connecticut in 2011, the Department of Emergency
Services and Public Protection’s (DESPP) Division of Emergency Management and
Homeland Security was directed to establish an Emergency Planning and Preparedness
Initiative to prepare the State’s response in advance of future events. One component of
this initiative was the creation of an Energy and Utilities Work Group that would prepare
an “All-Hazards Energy and Utilities Annex” to the State Response Framework that
established a process to coordinate with state and local emergency operations and to
restore power and utility service to critical public facilities during disasters. This Annex is
often referred to as Emergency Support Function 12, or ESF-12.[10] The official ESF-12
Annex was released in August of 2013 and continues to be maintained by Working Group
members. The ESF-12 Annex defines the operational processes used to coordinate energy
and utility-related emergency response actions. The annex covers all utility sectors (gas,
water, electric) and defines the emergency preparedness, response, and recovery actions.

PURA serves as the lead agency of the ESF-12 Working Group, which is responsible for
conducting emergency preparedness activities. Emergency preparedness responsibilities
include ensuring that operating procedures are in place in advance of emergencies,
coordinating with utility and State and local emergency services to ensure emergency
planning measures are in place, planning and participating in emergency exercises and
training, identifying critical facilities, and helping identify road clearing priorities.

The ESF-12 Working Group meets on a quarterly basis, or as needed, to address potential
or active threats. In 2023, PURA organized and held non-emergency ESF-12 Working
Group meetings on March 21, June 14, September 13, and December 20. The focus of those
meetings was to continue the ongoing work to plan and address load shedding during
winter energy emergencies, improve coordination among different utility sectors for
service restoration during outage events, and provide cybersecurity expertise to group
members.

Following lessons-learned from the Tropical Storm Isaias investigation, the Authority
identified that additional planning and coordination was needed between the electric
sector and telecommunications and water/wastewater sectors. The Authority’s
investigation yielded the finding that better communication and coordination between

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PURA 2023 ANNUAL REPORT

these sectors is necessary to improve the restoration of key telecommunication and


water/wastewater infrastructure. Consequently, the Authority established two
subgroups to the ESF-12 Working Group, one to aid coordination between EDCs and
telecommunication providers to ensure that critical telecommunication infrastructure
has been identified in advance of storms. The other subgroup is designed to aid
coordination between the EDCs and the water/wastewater providers to likewise ensure
their critical facilities are identified prior to storms so that they can be properly
prioritized for restoration during an event.

The two subgroups made notable progress in 2023, developing and sharing critical
facility lists for water, wastewater, and telecommunications critical infrastructure
sectors. Progress included defining critical facilities for each industry, developing lists of
priority restorations, and incorporating those facilities into electric distribution
company restoration planning. Ongoing work will continue to incorporate more
industry providers (especially smaller water and wastewater utilities) into the
coordination to ensure statewide participation.

The ESF-12 Working Group also focused on addressing the potential for rolling
blackouts throughout New England in future winters. This included refining rolling
load-shedding plans, incorporating low-pressure gas systems into electric outage
planning, and thinking through communication protocols for such an event.

The ESF-12 Working Group will continue to focus on inter-utility coordination and
winter reliability planning in 2024. Upcoming ESF-12 meetings are scheduled for March
15, June 18, September 11, and December 11, 2024.

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PURA 2023 ANNUAL REPORT

[1] An electric aggregator is an entity that brings customers together to buy electricity in bulk in
order to increase customers’ buying power.

[2] Public Act 98-28, An Act Concerning Electric Restructuring.

[3] Throughout New England, wholesale electric prices are set by the sum of the cost of energy, a
local congestion component, and a measurement of local loss component, together constituting the
Locational Marginal Price (LMP). The Day-ahead LMP is set using scheduled energy bids for each hour
in the next day. Because natural gas is the largest fuel source for the region, it therefore has a
significant effect on wholesale electric prices by setting the cost of energy.For more information, see
ISO New England’s 2022 Annual Markets Report, issued June 1, 2023, available at: https://www.iso-
ne.com/static-assets/documents/2023/06/2022-annual-markets-report.pdf

[4] Public Act 22-5, An Act Concerning Climate Change Mitigation.

[5] See ISO New England’s 2023 Regional System Plan, p. 98, issued November 1, 2023, available at:
https://www.iso-ne.com/static-assets/documents/100005/20231114_rsp_final.pdf

[6] See Conn. Agencies Regs. §§ 16-16-1 through 16-16-4.

[7] The Authority also completed an investigation of a fatal accident involving a UI contractor
through Docket No. 23-05-87,PURA Investigation into the Fatal Accident that Occurred on May 17,
2023 at 2150 Post Road, Fairfield, CT, on January 24, 2024.

[8] See Conn. Agencies Regs. § 16-16-2(a)(9) and § 16-16-3(e)

[9] This review is inclusive of all reconciling component rates, regardless of whether the Authority
has jurisdiction over the underlying costs. For example, electric transmission is overseen by the
Federal Energy Regulatory Commission; however, transmission costs are recovered from retail
electric customers. Thus, the Authority has purview over the timing and manner in which the
transmission costs are passed on to Eversource and UI ratepayers, but not the amount due.

[10] Connecticut Emergency Support Function 12 – All Hazards and Utilities Annex, August 2013,
https://portal.ct.gov/-/media/DEMHS/_docs/Plans-and-Publications/EHSP0061-SRF-ESF12--
EnergyandUtilitiesAnnex.pdf

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PURA 2023 ANNUAL REPORT

2023 ELECTRIC SECTOR DECISIONS

Docket Number Title Decision Date

PURA Review of the Combined Heat and Power


18-08-14RE01 Project Solicitation Pursuant to Conn. Gen. Stat. 1/4/2023
§16-258e – Request to Modify Order No. 4

Petition for Approval of the Manner and Method


of Construction and Permission to Energize the
22-12-14 1/11/2023
Milvon to West River Railroad Transmission Line
115-kV Rebuild Project

22-06-01 2021 Annual RPS Compliance Review (Errata) 1/18/2023

Petition for Approval of Method and Manner of


23-01-17 Construction and Permission to Energize the 2/8/2023
Pootatuck to Stevenson Line Rebuild Project

Petition For Approval of Method and Manner of


Construction and Permission: to Energize the
23-01-18 1280 Line from Whipple Junction to the Groton 2/22/2023
Town line as part of the Ledyard Junction to
Mystic Substation Upgrade Project

Petition of Sunnova for a Declaratory Ruling


Regarding Ownership of Capacity Rights
22-10-05 Regarding Class I Renewable Energy Sources 3/22/2023
Participating in the Resi. Renewable Energy
Solutions Program

2022 PURA Report to the General Assembly


22-11-01 3/29/2023
Regarding the State of Electric Competition

Application to Approve and Install a Single


22-12-12 4/5/2023
Meter at 359 Hazard Ave., Enfield, CT 06083

PURA Investigation into the Establishment of


21-05-15 Integrated Distribution System Planning within 4/26/2023
a Performance-Based Regulation Framework

Petition For Approval Of Method And Manner Of


Construction And Permission To Energize The
23-04-50 3754 And 3041 Lines For The 3754/3041 5/31/2023
Transmission Lines Structure Replacement
Project
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PURA 2023 ANNUAL REPORT

2023 ELECTRIC SECTOR DECISIONS

Docket Number Title Decision Date

PURA Annual Reconciliation of the Conservation


Adjustment Mechanisms filed by The
Connecticut Light and Power Company, The
23-02-01 United Illuminating Company, Connecticut 6/21/2023
Natural Gas Corporation, The Southern
Connecticut Gas Company, and Yankee Gas
Services Company

Petition For Approval Of The Manner And


Method Of Construction And Permission To
23-05-32 6/28/2023
Energize The Derby Junction To Ansonia 115-Kv
Transmission Rebuild Project

Petition For Approval Of Method And Manner Of


Construction And Permission To Energize The
23-05-69 7/12/2023
1222/1637/1714/1720 Weston Substation To Old
Town Substation Lines Rebuild Project

PURA Investigation Into Redesign of the


Residential Electric Billing Format – Cost
14-07-19RE07 7/26/2023
Allocation Among Suppliers for System
Redesign and Associated Costs

Investigation into the Response of The


Connecticut Light and Power d/b/a Eversource
23-01-39 8/9/2023
Energy to the Accident on January 17, 2023, at
602 Greenwoods Road, Norfolk, CT

PURA Annual Review of the Rate Adjustment


23-01-03 Mechanisms of The Connecticut Light and 8/16/2023
Power Company

PURA Annual Review of the Rate Adjustment


23-01-04 Mechanisms of The United Illuminating 8/16/2023
Company

Petition For Approval Of Method And Manner Of


23-07-23 Construction And Permission To Energize The 8/16/2023
1637 And 1720 Lines Rebuild Project

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PURA 2023 ANNUAL REPORT

Docket Number Title Decision Date

Application For Temporary Master Meter


23-06-33 8/23/2023
Approval At 2155 Main Street, Hartford, Ct

Application of The United Illuminating


22-08-08 8/25/2023
Company to Amend Its Rate Schedule

23-07-19 Application Of UI To Issue Debt 9/20/2023

Petition For Approval Of Method And Manner Of


Construction And Permission To Energize The
Norwalk Bridge 115-KV Transmission Relocation
23-08-26 9/27/2023
Project From Darien Substation To Fitch
Substation (Line 1028) And Sono Substation To
Sherwood Substation (Line 1146)

Petition For Approval Of Method And Manner Of


Construction And Permission To Energize The
23-09-10 10/11/2023
1610/1355/1690 Southington To Cook Hill Rebuild
Project

Petition For Approval Of Method And Manner Of


Construction And Permission: To Energize The
23-09-16 1268, 1485, 1622, And 1887 Lines As Part Of The 10/25/2023
Brookfield Junction To Bates Rock Substation
Upgrade Project

PURA Annual Review of the Rate Adjustment


23-01-04 Mechanisms of The United Illuminating 10/25/2023
Company

23-09-26 Petition Requesting Reconsideration 11/1/2023

Genconn Energy LLC Application To Establish


23-06-02 11/8/2023
2024 Revenue Requirements

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PURA 2023 ANNUAL REPORT

Docket Number Title Decision Date

Application For Temporary Master Meter


23-08-27 Approval At 9 Covered Bridge Road, Newtown, 11/22/2023
CT

Investigation Into Eversource’s Manner of


23-01-32 Operation and Safety Regarding its 11/22/2023
Underground Electric Distribution System

Petition For Approval Of Method And Manner


Of Construction And Permission To Energize
23-10-13 11/22/2023
The Pootatuck Substation To West Devon
Junction Rebuild Project

GB II New Haven LLC Application To Establish


23-06-03 12/6/2023
2024 Revenue Requirements

A comprehensive list of PURA 2023 decisions is available in Appendix 2,


attached to this Report.

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PURA 2023 ANNUAL REPORT

SECTION 5:
THE NATURAL GAS SECTOR
600K CUSTOMERS

PURA is responsible for the regulation and oversight of all in-


state natural gas pipelines, both as they relate to the operation
and management by the owners and operators of such
pipelines and regarding public safety.[1] These owners and
operators of in-state natural gas pipelines are commonly
referred to as the local distribution companies (LDCs). The LDCs
receive gas from interstate transmission pipelines and
distribute the gas to retail customers. Pipelines, called mains,
run down streets to distribute the gas throughout the area.
Smaller service lines run from the mains to the individual
customers.

LDCs are required to meet both Minimum Federal Safety


Standards and the laws and regulations of Connecticut, which
together address most areas of gas operator activities. Detailed
requirements apply to the materials that may be used for
constructing new gas pipelines. The requirements also address
permitted pressure levels for the systems, design standards for
the facilities, construction requirements, and initial testing of
the facilities to ensure safety. There are extensive requirements
for welding steel and other forms of joining materials.
Corrosion control, operation and maintenance, emergency
response, and qualification of employees to perform safety-
related activities are also covered.

PURA’s gas pipeline inspection program uses a combination of


field inspections and reviews of company plans, procedures,
and records to ensure compliance with applicable safety
requirements. When a safety incident occurs, PURA staff will
perform an investigation of the cause, and may levy fines or
penalties depending on who or what was responsible for the
incident. Any member of the public may file a complaint
reporting defects or state or federal safety violations of any part
of the natural gas pipeline infrastructure in the state to the
Authority.

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PURA 2023 ANNUAL REPORT

Submit a Safety
Sometimes, damage to a gas pipeline is caused by improper
Complaint
or unauthorized digging during construction projects.
or
Excavation damage to underground utility facilities can
cause fires and explosions, injuries, deaths, and significant
Contact CBYD:
disruptions to public utility service. To prevent this, PURA Call 811 or 1-800-922-4455
administers the Call Before You Dig (CBYD) program. The
CBYD Program was established to protect the public safety
with regard to excavations near underground facilities by
providing a communications link between excavators, public agencies, and public
utilities. Excavators must call CBYD prior to digging, and then CBYD will notify all utilities
that might be in the area. Utilities will then locate their pipes and cables using paint and
stakes so excavators can conduct their work without causing damage to existing
underground utilities. The Authority assesses significant civil penalties to any party who
violates the statutes and regulations, which are not recoverable in rates.

In 2023, PURA conducted robust inspection processes, and found and corrected multiple
violations. Additionally, PURA issued multiple civil penalties designed to deter further
noncompliance.

484 828 80 $1.4 M


Pipeline CBYD Total Civil
Safety Inspections Violations Penalties
Inspection Found Issued
Person-days

KEY NATURAL GAS TOPICS IN 2023


The Authority’s foremost responsibility related to natural gas is ensuring the safe and
affordable delivery of service throughout the state. In addition to inspections,
documentation review, and civil penalties, the Authority can monitor and enforce safety
compliance through the adoption of regulations and measurement of leak metrics. In
2023, PURA revised its regulations for the first time since the 1960’s, and completed its

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PURA 2023 ANNUAL REPORT

annual Lost and Unaccounted for Gas Report, which will both support continued high
standards of safety and affordable service in Connecticut.

Updates to Connecticut’s Gas Pipeline Safety Regulations


On July 25, 2023, the Authority initiated Docket No. 23-07-21, Regulations for Gas Pipeline
Safety, to repeal, amend, and adopt new gas pipeline safety regulations for Connecticut.
Before this date, the existing regulations had not been revised since the 1960’s.[2] Since
that time there have been significant changes in the gas industry including the materials
and equipment used and the processes for installing and maintaining gas distribution
systems. Additionally, there is now increased prioritization on the enhanced public safety
and reduced environmental impact of gas distribution systems.

The Authority issued draft proposed regulations on August 21, 2023, and held a public
hearing on October 11, 2023, accompanied by an opportunity to submit written
comments through October 20, 2023. The Authority received comments from CNG and
SCG, Yankee Gas, and Norwich Public Utilities. Importantly, though PURA does not
regulate the rates of municipal utilities such as Norwich Public Utilities, all state gas safety
regulations apply to all gas companies in Connecticut, regardless of their ownership
structure. The Authority reviewed all comments and issued final proposed regulations
with appropriate revisions on January 3, 2024. Key amendments in the final proposed
regulations include, for example, strengthening the qualification and training
requirements for pipeline operators and codifying enhanced leakage reduction
procedures, as well as leak severity level criteria as set by the October 7, 2020 Decision in
PURA Docket No. 20-02-19, PURA Investigation into a Uniform Natural Gas Leak
Classification.

These regulations will be considered final


only after review and approval by the Office Additional Gas Pipeline
of the Attorney General and the Legislative Safety Regulation Resources
Regulation Review Committee (LRRC). Upon PURA Final Proposed
approval by the Office of the Attorney Regulation Amendments
General and the LRRC, these modern eRegulations System
regulations that benefit public safety, Tracking Number:
employee safety, and the environment will PR2023-019
take effect.

Lost and Unaccounted for Gas Report (LAUF Gas)


The Authority is required to submit a report to the General Assembly each year reporting
on LAUF gas in Connecticut. LAUF gas is an accounting concept and ratemaking tool
developed to balance the receipts and deliveries of natural gas. During a 12-month period,
a difference may arise between the amount of gas injected into a distribution system and
the gas measured at customers’ meters; this difference is accounted for using the concept

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PURA 2023 ANNUAL REPORT

of LAUF gas. The LAUF gas metric is comprised of various sources, such as measurement
and accounting errors, estimates for unbilled gas, stolen gas, and pipe leaks. Thus, LAUF
gas encompasses both a physical (e.g., from leaky pipes) and a nominal component. LAUF
gas must be kept to a reasonable and prudent level because uncontrolled LAUF gas can
indicate that there are excessive leaks, or utility mismanagement in repairing leaks,
resulting in customers paying too much for gas.

In 2023, PURA opened Docket No. 23-03-02, 2023 PURA Report to the General Assembly
Concerning Lost and Unaccounted for Gas, to review the 2022 LAUF reports submitted by
CNG, SCG, and Yankee Gas. If the LDCs reported LAUF gas for the previous year exceeds
3%, PURA is obligated to undertake further investigations. The Authority requires the
LDCs to submit LAUF data on both a calendar year and a summer-to-summer basis
because Connecticut’s LDCs experience peak sales and delivery of natural gas during the
winter months. Therefore, a 12-month period from summer-to-summer provides a more
accurate LAUF calculation because it encompasses a full winter heating season. The
associated loss of revenue attributable to LAUF gas calculated from summer-to-summer
is then recovered by the LDCs through the purchased gas adjustment (PGA) mechanism.
Table 12 displays the historical summer-to-summer LAUF Gas over the past five years.

Table 12: Historical LAUF Gas During Summer-to-Summer Period

Based on the data in Table 12, the Authority found that the LAUF gas percentages for the
LDCs in 2022 are below the 3% threshold and therefore do not require further
investigation. Nonetheless, gas leak reduction continues to be a major priority for both
the Authority and the LDCs. Indeed, two major threats to an LDC’s system integrity are
aging infrastructure and third-party damage during excavation work. At the direction of
the Authority, the LDCs have implemented a variety of methods to address these threats
and reduce gas leaks. These methods include but are not limited to: replacing older leak-
prone infrastructure; implementing distribution integrity management programs; and
executing aggressive damage prevention programs and enforcement such as CBYD. The
Authority recommended that the LDCs continue their efforts to implement the programs
listed above to further reduce gas leaks.

In addition to reporting LAUF Gas, the LDCs provide the number of leaks that they
repaired, broken down by the cause of leak, as well as the remaining leaks. Leaks are
categorized on a series of grades that reflect the hazard level. A Grade 1 Leak represents
an existing or probable hazard to persons or property.[3] A Grade 2 Leak is a leak that is

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PURA 2023 ANNUAL REPORT

recognized as nonhazardous to persons or property at the time of detection, but justifies


a scheduled repair based on probable future hazard.[4] A Grade 3 Leak is a leak that is
recognized as nonhazardous to persons or property at the time of detection and can be
reasonably expected to remain nonhazardous. All Grade 1 leaks must be repaired
immediately; however, Grade 2 leaks are not always repaired immediately, but are still
considered important. The Authority limits the
number of Grade 2 leak backlogs at the end of each
calendar year based on the number of miles of gas Additional LAUF GAs
mains in a company’s territory. For CNG and SCG, the Resources
limit is no more than 30 outstanding leaks at the
end of each calendar year; for Yankee Gas, the limit
2023 LAUF Gas Report
is 45. As of the end of 2022, CNG and SCG each had
11 Grade 2 leaks remaining, while Yankee Gas had 5.

[1] See Conn. Gen. Stat. § 16-272.

[2] See Conn. Agencies Regs. §§ 16-11-22, 16-11-31, 1611-41, and 16-16-2.

[3] A Grade 1 Leak is present if any of the eight conditions listed in Appendix A of the Leak
Classification Decision occurs.

[4] A Grade 2 Leak is present if any of the six conditions listed in Appendix A of the Leak Classification
Decision occurs.

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PURA 2023 ANNUAL REPORT

2023 NATURAL GAS SECTOR DECISIONS

Docket Number Title Decision Date

PURA Annual Review of the Purchased Gas


22-10-01 Adjustment Clause Charges or Credits Filed by 5/17/2023
Connecticut Local Distribution Companies

Application Of Yankee Gas Services Company


23-04-15 Dba Eversource Energy For Approval Of The 6/7/2023
Issuance Of Long-Term Debt

2023 PURA Report to the General Assembly


23-03-02 6/21/2023
Concerning Lost and Unaccounted for Gas

23-07-18 Application Of CNG To Issue Debt 9/13/2023

Call Before You Dig, Inc. - Proposed Budget For


23-09-01 12/20/2023
2024

Annual Review of the System Expansion


23-03-01 10/4/2023
Reconciliation Mechanisms

A comprehensive list of PURA 2023 decisions is available in Appendix 2,


attached to this Report.

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PURA 2023 ANNUAL REPORT

SECTION 6:
THE WATER SECTOR
1.1 M CUSTOMERS
Connecticut’s water is an essential natural resource that must
be carefully maintained and distributed in order to ensure
long-term, safe, available, and affordable water service. Within
the state boundaries are over 6,000 miles of rivers and streams,
at least 2,000 lakes and reservoirs, and groundwater resources
that supply Connecticut residents with water.[1] These public
water systems and resources are jointly regulated by PURA,
DEEP, and the Department of Public Health (DPH). DEEP is
responsible for administering the Aquifer Protection Area
Program, establishing land use regulations and standards, and
monitoring, assessing, and reporting water quality. DPH
oversees the safe and adequate supply of drinking water for
Connecticut’s population by regulating the purity of all public
water systems, while PURA regulates the costs, rates,
infrastructure, conservation mechanisms, and business
operations of Connecticut’s investor-owned water utilities.

Together, PURA, DEEP, and DPH coordinate their roles in


protecting Connecticut’s water resources through their
membership on the Connecticut Water Planning Council
(WPC), which is chaired by PURA Vice Chairman Jack Betkoski.
The WPC was founded in 2001 through Public Act 01-177, An
Act Establishing a Water Planning Council, with the purpose of
“address[ing] issues involving the water companies, water
resources, and state policies regarding the future of the state’s
drinking water supply.” The WPC jointly prepared the State
Water Plan in 2018 with a goal of balancing public water supply
needs, economic development, recreation, and ecological
health. The WPC is now used to guide Connecticut’s water
strategy, policies, and actions.

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PURA 2023 ANNUAL REPORT

KEY WATER SECTOR TOPICS IN 2023

Water Conservation
Despite typically receiving plentiful precipitation, Connecticut is not exempt from
experiencing drought conditions. Though Connecticut is not currently experiencing
drought conditions, PURA continuously works to ensure that utility rate designs
encourage conservation and responsible water use, particularly through a regulatory tool
called the Water Infrastructure Conservation Adjustment (WICA) surcharge. The WICA
process enables the Authority, in consultation with OCC, to administer a rate adjustment
mechanism for the purpose of funding eligible water infrastructure improvement
projects completed by PURA-regulated water companies between rate cases. Under the
WICA program, ratepayers pay the rate-case-approved rates, plus an additional WICA
surcharge to recover the costs of approved improvements. Pursuant to Conn. Gen. Stat. §
16-262w(i), the amount of WICA charged between general rate case filings cannot exceed
10% of the water company's approved annual revenue requirement.

When companies propose new WICA projects, the Authority analyzes the proposals
against the following criteria:

It is eligible for WICA Program treatment under Conn. Gen. Stat. § 16-262v(1).
Specifically, the project is eligible if it:
Improves or protects the quality and reliability of service to customers including:
renewal or replacement of existing infrastructure … [that has] either reached the
end of its useful life, are worn out, are in deteriorated condition, are or will be
contributing to unacceptable levels of unaccounted for water, or are negatively
impacting water quality or reliability of service if not replaced;
covers main cleaning and relining projects;
relocation of facilities as a result of government actions, the capital costs of which
are not otherwise eligible for reimbursement; [and]
purchase of leak detection equipment or installation of production meters, and
pressure reducing valves;
Benefits customers by improving water quality, system integrity, or service reliability;
Adheres to the criteria established for determining priority of infrastructure projects;
and
There is a sufficient level of investment in infrastructure.

In 2023, PURA issued WICA decisions on Semi-Annual Filing Reports (SAFR) filed by the
Connecticut Water Company (Docket Nos. 20-12-30WI05 and 20-12-30WI06), the
Hazardville Water Company (Docket No. 12-07-07WI19), the Jewett City Water Company
(Docket No. 20-10-31WI01), and the Torrington Water Company (Docket No. 10-05-
01WI26). These decisions authorized one or more of the following: new projects as WICA-
eligible; modifications to projects previously identified as WICA-eligible; and/or an

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PURA 2023 ANNUAL REPORT

increase in the WICA surcharge (up to 10% of the approved revenue requirement in
total) to recover costs associated with completed WICA projects. A summary of
these decisions is in Table 13 below:

Table 13: 2023 WICA Decisions by Company

Docket Company Decision New Approved Cumulative Current


Number Date WICA Project Completed Surcharge
Types WICA
Investments

20-12-30WI05 Connecticut 3/22/2023 Water Mains, $70,762,974 7.38%


20-12-30WI04 Water Company 3/29/2023 pressure
20-12-30WI06 9/25/2023 reduction
valves,
customer-side
service line
replacement

12-07-07WI19 Hazardville Water 12/20/2023 Water Mains $2,699,624 9.98%


Company

20-10-31WI01 Jewett City Water 9/20/2023 Water Mains $616,092 3.4%


Company

10-05-21WI26 Torrington Water 3/29/23 Water Mains, $5,161,380 9.96%


Company relocation /
replacement of
fire
hydrants and
service lines
owned by the
Company

The Authority also reconciled any under- or -over-collection of the previously-


authorized WICA surcharge, resulting in either an additional surcharge to
customers in the event of an under-collection and a credit to customers in the
event of an over-collection, through the following decisions: Aquarion Water
Company (Docket No. 13-02-20WI24); Connecticut Water Company (Docket No. 20-
12-30WI04); the Hazardville Water Company (Docket No. 12-07-07WI19); and the
Torrington Water Company (Docket No. 10-05-01WI25).

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PURA 2023 ANNUAL REPORT

Water Industry Consolidation


As part of PURA’s responsibility overseeing the provision of safe, clean, reliable, and
affordable utility service, the Authority must evaluate and consent to any water
company’s application to cease operations. Specifically, PURA will consider how the
water company plans to ensure that there is a continuous supply of clean water at
adequate pressure and volume, regardless of whether they are the operating company.
[2]

On September 30, 2022, PURA received a joint application from Aquarion and the town
of New Hartford in Docket No. 22-09-18, Joint Application of the Town of New Hartford
and Aquarion Water Company of Connecticut for Approval of the Transfer of Water and
Wastewater System Assets, requesting consent and approval for Aquarion to acquire
New Hartford’s Water System and Wastewater System, and for New Hartford to cease
operations as a water company. Aquarion stated it would pay New Hartford $8 million to
acquire all the assets related to those systems. The New Hartford Water System, which is
regulated by DPH as a community public water system, serves 404 residential users, 40
commercial users, 8 industrial users, and 6 New Hartford-owned buildings in New
Hartford. The Wastewater System, which is classified as a Municipal Sewerage System
and is regulated by DEEP, serves a population of approximately 900, with 218 customers,
213 of which are also customers of the Water System. Following acquisition, Aquarion
stated that it planned to spend $358,500 on improvements to the Wastewater System to
protect existing wells and the drinking water aquifer.

PURA’s consent in acquisitions is dependent on findings, in consultation with DPH,


regarding the suitability of Aquarion to acquire the Water Systems and the expenditures
required to reasonably operate the system. The Authority considers a number of factors
for a Water System acquisition, identified by statute, that include: (1) the geographic
proximity of the plant of the acquiring entity to the water company; (2) whether the
acquiring entity has the financial, managerial, and technical resources to operate the
water company in a reliable and efficient manner and to provide continuous, adequate
service to the persons served by the company; (3) the current rates that the acquiring
entity charges its customers; (4) public health concerns, including, but not limited to, any
closed or active consent decrees or deficiencies identified by DPH relating to the water
company; and (5) any other factors the Authority deems relevant.

In conducting their analysis, the Authority and DPH found that Aquarion was suitable to
acquire the assets of the Water System. Further, in evaluating whether the acquisition of
the New Hartford Water System will impact existing ratepayers, PURA found that
anticipated revenues will exceed the estimated cost of service for the Water System by
$408,252. Consequently, the acquisition did not indicate a financial deficiency, and no
surcharge was required by existing ratepayers.

Conversely, Connecticut law limits PURA’s jurisdiction over the transfer of Wastewater

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PURA 2023 ANNUAL REPORT

Systems to evaluating the necessity and


reasonableness of an acquiring entity’s proposed Additional Water
expenses and directing any reasonable Acquisition Resources
improvements to the plant infrastructure such that
New Hartford
it is in the public interest.[3] In other words, the
Acquisition Decision
Authority’s approval is not required for Aquarion
and New Hartford to complete the Wastewater
System transfer. In this proceeding, Aquarion instead requested PURA’s approval of an
initial rate for existing Wastewater System customers set equal to the rate they had been
paying as customers of New Hartford. Importantly, Aquarion did not file this request as a
rate application or an interim rate increase.[4] Without one of these applications, PURA
has no statutory authority under which to establish the rates for Aquarion for this set of
customers. Instead, the Authority will review the acquisition of the Wastewater System,
the expansion of plant, and proposed rates in accordance with all relevant statutes in a
future rate proceeding.

[1] DEEP, Connecticut’s Water Resources, https://portal.ct.gov/DEEP/Water/Connecticuts-Water-Resources

[2] See Conn. Gen. Stat. § 16-262n(c).

[3] See Conn. Gen. Stat. § 16-11

[3] See Conn. Gen. Stat. § 16-19(a); Conn. Gen. Stat. § 16-19(d)

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PURA 2023 ANNUAL REPORT

2023 WATER SECTOR DECISIONS

Docket Number Title Decision Date

Application of Aquarion Water Company of


22-07-01 3/15/2023
Connecticut to Amend Its Rate Schedule

Application of The Connecticut Water Company


20-12-30WI05 for a Water Infrastructure Conservation 3/22/2023
Adjustment Semi-Annual Filing

Application of The Connecticut Water Company


20-12-30WI04 for its Annual Reconciliation of its Water 3/29/2023
Infrastructure and Conservation Adjustment

Application of Torrington Water Company for a


10-05-01WI26 Water Infrastructure & Conservation 3/29/2023
Adjustment

Joint Application of the Town of New Hartford


and Aquarion Water Company of Connecticut
22-09-18 8/9/2023
for Approval of the Transfer of Water and
Wastewater System Assets

Application of Jewett City Water Company for


Approval of Water Infrastructure and
20-10-31WI01 9/20/2023
Conservation Adjustment and Semi-Annual
Filing Report

Application of The Connecticut Water Company


20-12-30WI06 for its Water Infrastructure Conservation 9/25/2023
Adjustment Semi Annual Filing Report

Application of Hazardville Water Company for a


12-07-07WI19 Water Infrastructure Conservation Adjustment 12/20/2023
Semi Annual Filing Report

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PURA 2023 ANNUAL REPORT

SECTION 7: THE TELECOMM. &


UTILITY POLE SECTOR
4.7M COMMUNICATIONS LINES
Since the mid-1990s, both wireless and wireline
telecommunications in Connecticut have been largely
deregulated under state and federal law. Most
telecommunications services, including cellular service, local
and long-distance calling, “800” services, and voice over
internet protocol (VOIP), are not subject to rate or quality
regulations.

Connecticut customers can obtain telecommunication services


from The Southern New England Telephone Company (Frontier
Communications of Connecticut), which is the primary
incumbent local exchange carrier, or from any number of
Competitive Local Exchange Carriers (CLECs), or even from
cable companies.

PURA continues to provide regulatory oversight of what is


referred to as Plain Old Telephone Service (POTS), which is the
traditional, analog voice transmission over copper wires. This
service, however, has been largely replaced as customers have
migrated towards more sophisticated competitive services.

PURA also plays an important role in promoting a competitive


telecommunications market through its regulation of public
rights-of-way and utility poles, which support a substantial
portion of the state’s telecommunications infrastructure. With
rapid advances in communications technology, PURA
endeavors to maintain a regulatory scheme that facilitates
equitable and timely access to these critical assets. Further, the
CBYD program, discussed in Section 5 and overseen by the
Authority, ensures that excavations related to underground
telecommunications facilities are done safely and in
coordination with other relevant utilities.

Finally, PURA is also responsible for determining and approving


funding for public and community technology and
telecommunications resources such as Connecticut’s

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PURA 2023 ANNUAL REPORT

Enhanced Emergency 911 (E-911) program and community access television. These
services are critical elements of Connecticut’s infrastructure, providing education,
and emergency support, and enhancing First Amendment rights for Connecticut’s
citizens.

KEY TELECOMM & UTILITY POLE TOPICS IN


2023
Enabling Broadband
In 2021, Public Act 21-159, An Act Concerning Equitable Access to Broadband, directed
the state to begin promoting the build out of highspeed broadband internet service,
particularly in underserved communities, such as rural communities, urban centers, or
low-income areas. This Act also specifically directed PURA to develop a process and set of
requirements for broadband providers that want to deploy certain underground
telecommunications infrastructure in the public rights-of-way. Such requirements
include:

1. The size of such conduit shall be consistent with industry best practices and sufficient
to accommodate potential demand;
2. Any handholes and manholes for fiber optic cable access and pulling with respect to
each such practice shall be placed at intervals consistent with industry best practices;
3. Such conduit shall be installed with a pull tape and capabilities of supporting
additional fiber optic cable;
4. The applicant shall notify telecommunications service providers and broadband
Internet access service providers of the proposed excavation to reduce the potential
for future street excavations in the same location;
5. Any requesting telecommunications service provider or broadband Internet access
service provider shall be able to access such conduit on a competitively neutral and
nondiscriminatory basis and for a charge not to exceed a cost-based rate;
6. The applicant shall report to the Authority upon completion of any approved
construction verifying that it has complied with the provisions of this subsection; and
7. Any other condition deemed prudent and reasonable by the Authority.

On January 14, 2022, PURA issued a notice of proceeding in Docket No. 21-12-21, PURA
Implementation of Process and Procedures for Conduit Excavations for
Telecommunications Service Providers and Broadband Internet Access Service Providers,
pursuant to the requirements of Public Act 21-159. On February 8, 2023, PURA issued a
Decision establishing a formal application and approval process for the coordination of
construction of conduit excavations in the public rights-of-way by telecommunications
and broadband providers. This process, as was intended by Public Act 21-159, will ensure
that underground telecommunications and broadband facilities are deployed with

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PURA 2023 ANNUAL REPORT

efficiency and care, both minimizing deployment costs and disturbances in the
public right-of-way (i.e., fewer instances of streets and sidewalks being dug up).
Additionally, this application process will help ensure a competitively neutral and
nondiscriminatory process that promotes timely construction of underground
excavation while reducing the potential for future excavations.
Specific components that help to achieve these outcomes include a five-year
moratorium on underground excavations on certain CTDOT-noticed construction
and maintenance projects to ensure the viability of new construction, and a
notification deadline to ensure that all broadband providers have the opportunity
to review proposed excavations so as to minimize future excavations.
This process formally took effect as of the date of
the Final Decision. Applications submitted in Additional Conduit
compliance with this process have been filed in Excavation Resources
Docket No. 23-02-03, Application of Conduit
Final Decision
Excavation and Notification Process for
Conduit Excavations
Telecommunications Service Providers and
Broadband Internet Access Service Providers, Applications
since that date. In 2023, PURA reviewed and
approved 118 applications for conduit excavations statewide, helping to support
the deployment of broadband infrastructure.

Utility Pole Safety


Utility poles support many services required by modern society including broadband
attachments, telephone service, and electric distribution wires. Their common placement
throughout communities helps to make these services accessible for millions of residents
and businesses. However, given utility poles’ proximity to where people live and work,
structurally compromised poles can present a significant risk to public safety. Proper and
regular maintenance procedures are therefore essential to ensuring safety for all.

An ongoing issue related to poles in Connecticut are the existence of “double poles” that
result from inefficient pole maintenance and replacement. The term “double poles” refers
to instances when a replacement pole is installed next to an existing pole, but the
existing pole removal is not completed. Not only are double poles an aesthetic issue, but
they can present public safety hazards. The most common cause of this condition is that
all the attachments on the existing pole have not been transferred, which can be
hindered by the fact that they must be transferred to the new pole sequentially before
the original pole can be removed. If all the attachments are not transferred in a timely
manner, the new and old pole may exist together for an extended period of time.

Previous requirements placed the responsibility of transferring a pole attachment on the


attachers themselves, but authorized the pole custodian to transfer the facilities if the
attachers did not meet the required deadline. If the pole custodian did not comply with
the deadlines, they would be subject to fines. Notwithstanding this rule, the number of

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PURA 2023 ANNUAL REPORT

double poles throughout the state swelled to 24,672 by June 1, 2022, with over
15,000 of those in delayed status.
In December 2022, the Authority approved a pilot program through its Final
Decision in Docket No. 21-07-29, Single Visit Transfer Process for Double Poles, (SVT
Decision) to test a “single visit transfer” process (SVT Pilot Program) over a six-
month period in six communities around the state (three in Eversource territory
and three in UI territory). This pilot was implemented by a mutually selected
contractor to make all simple transfers on double poles in those six communities,
while collecting data on the status and cause of delays related to poles.
EOE filed its report on progress made, lessons learned, and any modifications
during the pilot phase on August 22, 2023. EOE surveyed stakeholders involved in
the SVT Pilot Program including Eversource, UI, Frontier Communications of
Connecticut, New England Cable and Telecommunications Association, Inc.
(NECTA), Rocky Mountain Fiber Plus (Rocky Mountain), Charter Communications
Entertainment I, LLC (Charter), Comcast of Connecticut (Comcast), NetSpeed, LLC
(NetSpeed), Crown Castle Fiber, LLC (Crown Castle), and Lumen Technologies, Inc.
(Lumen). The survey revealed that the SVT Pilot Program was largely successful
over the six-month test period. There were no safety issues, no unscheduled
customer interruptions, no traffic control issues, and most importantly, double
poles had been significantly reduced in the six pilot communities. Further, the
contractor retained to implement the pilot was able to address both simple and
complex transfers, and successfully coordinated with pole attachers and the EDCs.
An additional concern is the cost and responsibility of ensuring that all pole
transfer data, both pre- and post-work, is accurately documented. Both EDCs have
indicated that while it is reasonable for them to be responsible for updating the
database, an SVT Program at scale would be a significant undertaking and could
harm ratepayers. Ideally, the contractor conducting pole transfers would be able
to perform this data recording. Unfortunately, the
Additional SVT Program
database currently in use does not support this
kind of user interface; and EOE therefore Resources
recommended that the Pole Attachment Working SVT Decision
Group continue to discuss what modifications to SVT Pilot Program
the database are achievable to facilitate efficient Report
updates and allow contractors to engage with it.
In compliance with the direction in the Authority’s SVT Decision, EOE will submit
another update on the SVT Pilot Program no later than February 22, 2024.

Ensuring Continuity of Public Telecommunication Resources


In addition to supporting the deployment of broadband and ensuring the structural
safety of the poles throughout the State, the Authority determines and approves funding
for important public services each year including State-directed technology education
grants, Connecticut’s Enhanced Emergency 911 (E-911) program, and community access
television.
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PURA 2023 ANNUAL REPORT

PEGPETIA
In 2007, the General Assembly established the Public, Educational and
Governmental Programming and Education Technology Investment Account
(PEGPETIA) program to promote and improve public, educational, and
governmental programming and to support education technology initiatives
through the enactment of Public Act 07-253, An Act Concerning Competitive
Video Services. This account is funded by a quarterly tax on the gross earnings of
video service providers, while the Authority is responsible for determining the
allocation of accumulated funds into the account and administering grants to
eligible entities.
Each year, PURA opens a proceeding where it accepts applications for funding.
The Authority opened Docket No. 22-10-02, Allocation of Public Educational and
Governmental Programming and Education Technology Investment Account
Pursuant to Conn. Gen. Stat. Sec. 16-331cc, to distribute $7,741,331 in available
funding. This amount represents an unusually significant increase over prior
annual funding, which generally ranges from $2 - $3 million. Given the
magnitude of deviation, the Authority opted to distribute $7,200,000 in grants
and to reserve the remainder for potential accounting or funding variances.
Fifty percent (50%) of this amount, or $3,600,000, is allocated to local
community television councils, the state-wide video advisory council, public,
educational, and governmental programmers and public, educational, and
governmental studio operators; the other 50% is allocated to boards of education
or other entities offering education technology initiatives. In the event that the
total amount requested by eligible applications for one category is less than 50%,
and the other is greater, PURA may reallocate excess funds to the other category.

The Authority received a total of 92 applications.


The Authority delegated the review of the Additional PEGPETIA
applications to EOE and directed that office to file Resources
a motion with a draft proposed decision. EOE filed
the motion on May 11, 2023, finding 89 of the 92 2023 PEGPETIA Final
applicants to be eligible with 31 seeking a total of Decision
$3,055,535 for “public, educational and
governmental” programming (PEG Grants) and 58
seeking a total of $6,647,582 for “education technology initiatives” (ETI Grants).
Because the requests for PEG Grants were less than the $3,600,000 available for
PEG Grants, the Authority used the residual for ETI Grants. Table 14 below
summarizes the allocation of funding. A complete list of awardees and the
amount of funding received is available in the decision.

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PURA 2023 ANNUAL REPORT

Table 14: 2023 PEGPETIA Requests, Funding, and Awards

Grant Type Total Request Funding Available Awarded

PEG $3,055,535 $3,055,535 $3,055,535

ETI $6,647,582 $4,144,465 $4,061,070

Total $9,703,117 $7,200,000 $7,116,605

E911 Program
The Authority is statutorily responsible for determining the amount of the
monthly fee to be assessed on each telephone service, commercial mobile radio
service (CMRS or wireless), customer-owned coin operated telephone (COCOT)
service, and Voice over Internet Protocol (VoIP) subscriber to fund the
administration of the E-911 program. PURA bases this fee on:
1. The operating budget established by Department of Emergency Services and
Public Protection (DESPP), taking into consideration any existing moneys
available in the Enhanced 9-1-1 Telecommunications Fund;
2. A progressive wire line inclusion schedule (excluding CMRS) that considers
“the final report of the task force to study enhanced 9-1-1 telecommunications
services established by public act 95-318;” and
3. A maximum fee of $0.75 per month per access line.
The Authority calculates the E-911 monthly assessment fees for non-CMRS
customer accounts with multiple lines using a progressive schedule. In other
words, the more lines on an account, the less the account pays per line.
Telecommunications companies report the total number of accounts based on
number of lines to PURA, while DESPP reports the annual operating budget for
the E-911 program. Examples of expenses comprising this budget include
database services, network management and maintenance, translation services,
regional telecommunications centers, and training. Using these values, PURA can
calculate a per-line monthly fee necessary to fund the program.
In Docket No. 23-01-05, Annual Assessment Proceeding to Fund the Development
and Administration of the Enhanced Emergency 911 Program – 2023, using the
telecommunications companies’ provided line numbers and the 2024 E-911
budget of $36,246,091 provided by DESPP, PURA calculated a single-line fee of
$0.68 per month. Accounts with more than one line pay a lower rate per line on a
progressive scale, as low as $0.14 per line. The $0.68 per line fee is a two cent
decrease over the previous year.
Additional E911 Program
Annual Community Access Support Review
Resources
Public access television programming provides
2023 E911 Decision
benefits that are not necessarily easily quantified
but are nonetheless important public services, such

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PURA 2023 ANNUAL REPORT

as enhancing a sense of community and First Amendment rights. Connecticut law


requires multichannel television companies (e.g., cable or satellite television), referred to
as “multichannel video programming distributors” (MVPDs) to fund public community
access programming (CAP) by assessing a baseline $5 per year charge on each of their
customers. The Authority is responsible for determining whether this charge should be
adjusted each year to reflect any increase or decrease in the consumer price index (CPI)
in the previous year.[1]

Further, the Authority can adjust the community access subscriber fee amount for each
MVPD within a range of 40% above or below the statutory benchmark, as adjusted for
inflation, based on the following criteria:

The level of public interest in community access operations in the franchise area;
The level of community need for educational access programming;
The level and breadth of participation in community access operations;
The adequacy of existing facilities, equipment and training programs to meet the
current and future needs of the franchise area; and
Any other factors determined to be relevant by the Authority.

Through Docket No. 23-01-06, Annual Community Access Support Review, PURA
conducted this analysis of the subscriber fee amount for each MVPD that took effect on
July 1, 2023. Using data from the Bureau of Labor Statistics, PURA found that the 2022
rate of inflation as measured by the CPI for the Northeast Urban Region is 6.11%. To
determine the +/-40% range within which the per subscriber amount can be set, the
Authority adjusts the original statutory $5 per subscriber amount for inflation. In the
Decision in Docket No. 21-07-26, The Public Utilities Regulatory Authority Annual
Community Access Support Review (2022 Decision), the Authority found that the
statutory amount as adjusted for inflation was $8.95. To this amount, an additional $1.25
was added by the 2022 Decision making the total $10.20.[2]

Applying 6.11% for 2022 CPI inflation to the prior year statutory amount of $10.20 equates
to a subscriber fee of $10.82 for 2023. Forty percent of $10.82 is $4.33. Consequently, the
community access support per subscriber for each MVPD must be between $6.49 ($10.82
– $4.33) and $15.15 ($10.82 + $4.33). The Final Decision in Docket No. 23-01-06 calculates
the 2023 subscriber fee for each MVPD, applying an increase of 6.11% for inflation. The
subscriber fees for each MVPD are within the statutory range identified above.
PURA Study of Community Access Operations

In 2022, PURA initiated a study at the legislature’s direction in Docket No. 22-06-26, PURA
Study of the Operations of Certified Third-Party Nonprofit Community Access
Programming Providers, (CAP Study) to examine community access operations and
current funding structures and to provide analysis and recommendations related to the
state-wide consolidation of community access operations. The Authority considered,

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PURA 2023 ANNUAL REPORT

among other things, the degree of financial support provided by the communities served
by the community access organizations, the appropriateness of community access
organization personnel salaries, and the degree of support provided to the community
access organizations through moneys made available pursuant to Conn. Gen. Stat. § 16-
331cc.

On December 15, 2023, PURA submitted its final report to the Energy & Technology
Committee of the Connecticut General Assembly. Key findings include that declining
cable subscribership numbers are impacting funding for non-profit CAPs, but also that
existing MVPD subscriber viewership of PEG programming provided by CAPs is
significantly lower relative to for-profit broadcasters such as NBC, CBS, ABC, and Fox.
Therefore, if CAPs are to continue to exist in their current form, the funding mechanism
will need to be revised.

As a result of these findings, the CAPs Study outlines


Additional Community
various potential solutions to reduce the operating
costs of CAPs including the consolidation of CAPs,
Access Provider Review
replacing CAPs with internet-based sharing platforms, Resources
and the elimination of cable-run CAPs in favor of non- 2023 Community
profit CAPs. The CAP study also considered alternative Access Final Decision
funding sources such as applying the subscriber fee to 2023 Study of
both streaming internet television services and cable Community Access
subscriptions. These options all require statutory Operations
changes and will require the careful evaluation and
consideration by the General Assembly.

[1] Conn. Gen. Stat § 16-331a(k).

[2] The 2022 Decision allowed MVPDs to opt out of this additional fee.

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PURA 2023 ANNUAL REPORT

2023 TELECOMM. & UTILITY POLE SECTOR


DECISIONS

Docket Number Title Decision Date

Application of Cellco Partnership d/b/a Verizon


Wireless for Approval of a Construction Plan to
22-11-02 1/11/2023
Install Wireless Facilities Within Certain Public
Rights-of-Way – MERRITT PKWY

1/25/2023
3/29/2023
4/19/2023
Application of Crown Castle Fiber, LLC for
5/17/2023
19-02-28 Approval to Install Facilities Under and Over
6/07/2023
Certain Public Rights-of-Way
8/09/2023
9/13/2023
10/25/2023

PURA Implementation of Process and


Procedures for Conduit Excavations for
21-12-21 2/8/2023
Telecommunications Service Providers and
Broadband Internet Access Service Providers

3/08/2023
Application of New Cingular Wireless Pcs, LLC
4/26/2023
For Approval of a Construction Plan to Install
18-06-13 7/12/2023
Wireless Facilities Within The Public Rights-Of-
8/02/2023
Way
9/06/2023

Application of New Cingular Wireless PCS, LLC


for Approval of a Construction Plan to Install
23-01-09 3/22/2023
Facilities Under and Over Certain Public Rights-
of-Way - Waterbury 325

Application of Cellco Partnership d/b/a Verizon


Wireless for Approval of a Construction Plan to
22-10-20 4/5/2023
Install Wireless Facilities Within Certain Public
Rights-of-Way – SHELTON SC 14 CT

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2022 ANNUAL REPORT-
PURA
THE TELECOMM + POLES SECTOR

Docket Number Title Decision Date

Application of TIME CLOCK SOLUTIONS, LLC for


Certificate of Public Convenience and Necessity
23-02-10 4/5/2023
to Provide Resold Local Exchange
Interexchange Telecommunications Services

Application of Cellco Partnership d/b/a Verizon


Wireless for Approval of a Construction Plan to
22-12-03 4/19/2023
Install Wireless Facilities Within Certain Public
Rights-of-Way – BERLIN SC 4 CT

Application of Cellco Partnership d/b/a Verizon


Wireless for Approval of a Construction Plan to
23-02-04 4/19/2023
Install Wireless Facilities Within Certain Public
Rights-of-Way – WILTON SC13 CT

Application of Cellco Partnership d/b/a Verizon


Wireless for Approval of a Construction Plan to
23-02-13 4/19/2023
Install Wireless Facilities Within Certain Public
Rights-of-Way – NEW CANAAN SC27 CT

Application of Cellco Partnership d/b/a Verizon


Wireless for Approval of a Construction Plan to
23-02-14 4/19/2023
Install Wireless Facilities Within Certain Public
Rights-of-Way – GLASTONBURY SC12 CT

Application of Cellco Partnership d/b/a Verizon


Wireless for Approval of a Construction Plan to
23-02-16 4/19/2023
Install Wireless Facilities Within Certain Public
Rights-of-Way – WETHERSFIELD SC6 CT

Application of Cellco Partnership D/B/A Verizon


Wireless for Approval of a Construction Plan To
23-03-04 4/19/2023
Install Wireless Facilities Within Certain Public
Rights-Of-Way – Cromwell SC10 CT

Annual Allocation of Public Educational and


Governmental Programming and Education
22-10-02 5/31/2023
Technology Investment Account Pursuant to
Conn. Gen. Stat. § 16-331cc

Annual Assessment to Fund the Development


23-01-05 and Administration of Enhanced Emergency 911 5/31/2023
Program

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PURA 2023 ANNUAL REPORT

Docket Number Title Decision Date

Application of Cellco Partnership d/b/a


Verizon Wireless for Approval of a
23-02-06 Construction Plan to Install Wireless Facilities 5/31/2023
Within Certain Public Rights-of-Way – NEW
CANAAN SC23 CT

Application of Cellco Partnership D/B/A


Verizon Wireless For Approval of a
23-05-74 Construction Plan To Install Wireless Facilities 5/31/2023
Within Certain Public Rights-Of-Way –
Greenwich CT Sc36

Application of Cellco Partnership D/B/A


Verizon Wireless For Approval of a
23-06-54 Construction Plan To Install Wireless Facilities 5/31/2023
Within Certain Public Rights-Of-Way – Enfield
Sc3 CT

Application Of Cellco Partnership D/B/A


Verizon Wireless For Approval Of A
23-04-23 Construction Plan To Install Wireless Facilities 6/7/2023
Within Certain Public Rights-Of-Way – Darien
Sc21 CT

Application Of Cellco Partnership D/B/A


Verizon Wireless For Approval Of A
23-05-75 Construction Plan To Install Wireless Facilities 10/25/2023
Within Certain Public Rights-Of-Way –
Greenwich Ct Sc33

PURA Study Of The Operations Of Certified


22-06-26 Third-Party Nonprofit Community Access 12/15/2023
Programming Providers

A comprehensive list of PURA 2023 decisions is available in Appendix 2,


attached to this Report.

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PURA 2023 ANNUAL REPORT

SECTION 8:
THE OFFICE OF EDUCATION,
OUTREACH, & ENFORCEMENT (EOE)
Due to PURA’s quasi-judicial structure, there are limitations on the communications PURA
staff may have with stakeholders and members of the public, particularly during active
proceedings. These rules, referred to as a prohibition on “ex parte communications,”
prevent any individual participant from gaining an unfair advantage in terms of additional
knowledge over other participants in a docket. However, many of the dockets before
PURA, and even the docket process itself, are complex and sometimes challenging to
navigate, particularly for stakeholders that do not often engage in Authority proceedings.
Additionally, there are certain topics before the Authority that would benefit from less
formal engagement structures such as working groups or are more routine in nature and
could be processed more efficiently.

Recognizing these needs, PURA established the Office of Education, Outreach, and
Enforcement (EOE) in July of 2020. The key objective of EOE is to provide ratepayers and
non-traditional stakeholders that interact with PURA an improved customer service
experience. The "ex parte" rules that apply to PURA's decisional staff do not apply to staff
assigned to EOE, meaning ratepayers and other parties may pose questions and concerns
to EOE staff. Importantly, however, EOE staff are not able to discuss active substantive
matters with PURA’s decisional staff and commissioners, nor are EOE staff permitted to
speak on behalf of the Authority.

EOE Organization

EOE is comprised of three units including the Licensing & Certification Unit, the
Mediation & Enforcement Unit, and the Education & Outreach Unit.

Licensing and Certification Unit

The Licensing & Certification Unit is responsible for analyzing and processing routine
licensing and certification matters filed with PURA under the Authority’s jurisdiction and
oversees reporting and other administrative matters related to the State and utility
stakeholders.

In 2023, staff reviewed nearly 18,000 licenses and certifications statewide, including but
not limited to electric and water submetering applications, renewable generator
certification (Class I), and electric supplier licensing applications and natural gas seller
registrations:

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PURA 2023 ANNUAL REPORT

17,614 Class I Renewable Energy Certifications


6 Electric Submetering Applications
10 Water Submetering Applications
21 Natural Gas Seller Registrations
29 Wireless Facilities Within the Public Rights-of-Way (1 closed without approval)
Applications
30 Installation of Wireline Facilities Under and Over the Public Rights-of-Way
Applications
2 Telcom Certificates of Public Convenience and Necessity
5 Electric Supplier License Application
119 Electric Aggregator Certifications

Additionally, this unit supports oversight and engagement with the EnergizeCT Rate
board. The EnergizeCT Rate Board is Connecticut’s official site for alternative electric
supplier rates. EOE staff maintain the public facing Rate Board as well as the back-end
functionality known as Rate Manager, and works with licensed electric suppliers to create
public offers.

In 2023, EOE staff also supported thousands of customers in how to access the Rate
Board, explain utility standard service pricing, view alternate generation offers, and
understand the enrollment process specific to their needs.

Mediation & Enforcement

The Mediation & Enforcement Unit mediates disputes concerning matters related to
regulated companies whenever possible or appropriate, enforces applicable regulations
and statutes in matters delegated to EOE, and independently investigates issues related
to PURA-regulated or licensed entities as directed or delegated. Consistent with the
objectives of the Authority and EOE, this unit dedicated significant focus to vulnerable
and low-income customers (hardship) in 2023.

Over the past year, the Mediation and Enforcement unit monitored the activities of
electric suppliers in Connecticut and initiated investigations regarding the customer
service practices of suppliers to determine whether they are in compliance with state
statutes, state regulations, and PURA’s orders.

As part of this work, EOE settled two supplier enforcement actions, amounting to over $2
million in settlement and customer restitution. The Authority directed the entirety of
these settlement amounts to be used as a donation to reduce EDC hardship customer
arrearages. Table 15 summarizes EOE's settlements through 2023.

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PURA 2023 ANNUAL REPORT

Table 15: 2022 EOE-Facilitated Settlements

Settlement/
Entity Docket No. Docket Title
Restitution

Xoom Energy Application of Xoom Energy CT LLC for


$1,624,725 11-06-05
Connecticut LLC an Electric Supplier License

Application of Community Power &


Town Square Utility, LLC for an Electric Supplier
$450,000 10-03-11RE01
Energy, LLC License – Transfer of License to Town
Square Energy, LLC

As part of continued efforts to monitor supplier actions, in 2023, EOE:

Streamlined and provided inputs to the Annual Renewable Portfolio Standards (RPS)
program, among other efforts, through Docket No. 23-06-01, Annual Review of
Connecticut’s Electric Suppliers’ and Electric Distribution Companies’ Compliance
with Connecticut’s Renewable Energy Portfolio Standards in the Year 2022.
Drafted the report to the legislature on suppliers and supplier licensing applications
for 2023 in Docket No. 22-11-01, Annual Report to the Legislature – The State of Electric
Competition, and began work on the next report in Docket No. 23-11-01, 2023 PURA
Report to the General Assembly Regarding the State of Electric Competition. This
report summarizes the state of electric competition by analyzing a variety of
indicators, including the average generation service charge and the Standard Service
generation rates for residential and business customers, to show the market’s impact
on customers who participate in the third party electric supplier market.

EOE also participated in several dockets in 2023 focused on helping vulnerable and low-
income customers reduce outstanding arrearages. These efforts include but are not
limited to contributions to Docket No. 17-12-03RE11, PURA Investigation into Distribution
System Planning of Electric Distribution Companies – New Rate Designs and Rates
Review, Docket No. 23-05-01, Annual Review of Affordability Programs and Offerings, and
18-06-02RE01, Two Year Review Required Pursuant to Conn. Gen. Stat § 16-245 O(M). This
work included research, analysis, and investigation for the implementation of a Low-
Income Discount Rate (LIDR) in Connecticut, and related oversight of practices by
suppliers that have historically had disparate impact on low-income customers.

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PURA 2023 ANNUAL REPORT

Efforts to support customer education and experience included support for the
implementation of utility bill redesign via Docket No. 14-07-19RE06, PURA Investigation
into Redesign of the Residential Electrical Billing Format – Five Year Review, and Docket
No. 14-07-19RE07, PURA Investigation into Redesign of the Residential Electrical Billing
Format – Cost Allocation Among Suppliers for System Redesign and Associated Costs. In
these dockets, EOE supported efforts to provide greater transparency and accessibility of
billing information for customers.

EOE facilitated the work product provided in Docket No, 22-10-12, PURA Proceeding to
Investigate Alternative Risk Transfer Programs. As part of the docket, EOE worked with
the Connecticut Insurance Department (CID) and Connecticut’s electric distribution
companies (EDCs) to explore, analyze, and advance a risk transfer advisory study, captive
insurance feasibility study, and the analysis of government backstop mechanism. As part
of the State of Connecticut’s ongoing risk management strategy, PURA directed the
investigation into the value/cost efficiencies and viability of using a captive insurance
company (captive) to provide alternative risk financing for certain Transmission and
Distribution (T&D) exposures and vulnerabilities faced by EDCs under its regulatory
supervision. This docket originated with Order No. 11 of the Final Decision dated August
31, 2022, in Docket No. 17-1203RE08, PURA Investigation into Distribution System
Planning of the Electric Distribution Companies – Resilience and Reliability Standards
and Programs, pursuant to a recommendation by several state agencies made in Docket
No. 20-08-03, Investigation into Electric Distribution Companies’ Preparation for and
Response to Tropical Storm Isaias. It was also related to PURA’s final decision in Docket
No. 20-08-03 regarding the performance of Eversource and UI in preparing for, and
responding to, Tropical Storm Isaias, in which the EDCs were directed to explore the
potential for obtaining storm-related insurance policies aimed at reducing the post-
disaster financial impact to customers.

EOE also supported the Aquarion and United Illuminating rate cases (Docket No.22-07-01
and Docket No. 22-08-08, respectively). EOE also supported efforts in the Connecticut
Water Company (Docket No. 23-08-01) and SCG and CNG (combined Docket No. 23-11-02)
rate cases with a focus on customer service, engagement, and return on equity.

Education & Outreach


The Education & Outreach Unit (also referred to as Consumer Affairs) receives complaints
and inquiries from Connecticut utility ratepayers and works to provide resolution and
relevant educational resources to assist the complainant. This unit also produces,
distributes, and presents educational materials about Connecticut’s utilities and their
regulation through public forums.

Since 1995, PURA has maintained records of customer complaints and inquiries.
Customers have numerous ways to contact the Authority’s call center and submit a

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PURA 2023 ANNUAL REPORT

complaint directly or indirectly to EOE:

Telephone, 8:30-4:30PM, Monday – Friday (except for state holidays)


Toll Free: 1-800-382-4586
Email: [email protected]
Web Portal

In addition to these direct-to-agency methods,


PURA also receives complaints that have been
referred to it via the state legislature, the
governor’s office, U.S. Representative and Senator Billing
offices, the OCC, the AG, municipal officials, and General Complaint/Quality
not-for-profit organizations and advocates. PURA Utility Complaint
of Interaction
Scorecard
Installation Data Types
The Education and Outreach team also manages Meter Test
the “Utility Scorecard” report. The Scorecard is a Outage
collection of 10 specific complaint types filed by Payment Arrangement
Connecticut utility customers; data can also be Quality of Service
viewed by time frames, location, intake specialist, Deposit
status, reasons for call, and more. Slamming
Termination
In 2023, the Education & Outreach Unit responded
to nearly 17,000 complaints and inquiries. As a
result of complaint resolution, EOE was able to secure the return of over $164,000 to
customers, demonstrated by Tables 15 and 16 below:

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PURA 2023 ANNUAL REPORT

Table 15: 2023 Customer Complaints and Inquiries by Industry

Table 16: 2023 Customer Complaint Resolution Amount by Industry

Working Groups
Representatives from EOE support PURA’s roles in dozens of state-mandated working
groups and subgroups, including but not limited to the Water Planning Advisory Group
(WPAG), Interagency Work Group (IWG), the WPCAG Watershed Lands Work Group,
Interagency Drought Workgroup, Water Utility Coordinating Committees, State Water
Plan Outreach and Education Workgroup, as well as the Low Income Energy Advisory
Board (LIEAB), which supports the planning, development, implementation, and
coordination of energy-assistance-related programs and policies and low-income
weatherization assistance programs and policies.

EOE further participated in a newly-formed working group mandated in Docket No. 22-
03-16RE02, Petition of the Office of the Consumer Council for and Investigation into the
United Illuminating Company and Eversource Energy Regarding Collections Practices
During the COVID-19 Moratorium – Wage Garnishment Working Group and related
Matters. The working group is looking to review the practice and impact of wage

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PURA 2023 ANNUAL REPORT

garnishment on customers for the purpose of reducing uncollectible and


outstanding debts.
EOE continues to lead the Vegetation Management Standing Working Group created by
the Authority in Docket No. 17-12-03RE08, PURA investigation into Distribution System
Planning of the Electric Distribution System Planning of the Electric Companies -
Resilience and Reliability Standards and Program. This Working Group works to establish
programmatic improvements and emerging issues regarding utility vegetation
management for the maintenance of distribution lines. The Working Group evaluates
current practices and makes recommendations as needed for legislative, regulatory, or
other improvements, and produces annual reports for PURA.

EOE also serves as the facilitator of several Distributed Generation Working Groups. The
working group members consist of solar developers, electric distribution companies, and
various state agencies. These groups have implemented numerous changes over the past
year to improve the process for the interconnection of distributed generation resources,
such as solar photovoltaics (PV), to the electric distribution system, and have improved
hosting capacity maps, updated interconnection guidelines, and created a public
interconnection queue, among other accomplishments.

EOE also serves as the facilitator for the Pole Attachment Working Group with members
consisting of the SPAs, ILECS, 3rd party attachers, and other state and municipal
stakeholders. The working group was tasked with implementing the Single Visit Transfer
Pilot program. Currently, the Working Group is discussing open issues with the current
phase of the program.

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PURA 2023 ANNUAL REPORT

SECTION 9:
LEGISLATIVE UPDATES
Updates on 2023 Legislation

In 2023, multiple pieces of legislation were enacted directing PURA to participate in or complete a number of tasks by
certain dates. Table 11 below summarizes each of these bill’s requirement(s) of PURA, and the progress made since their
passage.

Table 15: 2023 Legislation Relevant to PURA

Act Title Tasks Assigned to PURA Effective Date Progress

Public Act An Act Concerning PURA shall prescribe a form and 1/1/2024 PURA opened Docket No. 23-07-
23-199 Notification of Utility Service implementation date for the notification 02, which was voted on favorably
Terminations at Certain of utility service terminations following an in December, outlining the
Rental Properties uncontested proceeding with electric and processes and procedures related
gas companies, as well as other interested to the Public Act.
parties.

Public Act An Act Strengthening Requires PURA to investigate and create 10/1/2023 PURA opened Docket No. 23-09-
23-102 Protections for Connecticut’s an approval process for stakeholder 34. The Final Decision was released
Consumers of Energy compensation for traditionally in January 2024 and provides the
underrepresented groups, including small documents and instructions for
businesses, environmental justice applicants seeking compensation
communities, or those receiving through the program.
protection as hardship cases.

Public Act An Act Implementing Tasked PURA and DEEP with 7/1/2023 PURA provided informational
23-156 Recommendations of the implementing the regulations of the testimony on this bill, HB 6851.
Hydrogen Task Force Hydrogen Task Force.

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PURA 2023 ANNUAL REPORT

PURA Annual Reports to the General Assembly

Over the years, the State legislature has tasked PURA with providing annual reports to the General Assembly on various
topics. Links to the final reports for 2023 are available in Table 12 below.

Table 16: 2023 PURA Reports to the State Legislature


Submission
Report Title Codifying Act Docket Number Due Date
Date

2023 PURA Report to the General Assembly Regarding the Public Act 07- 23-02-02 2/8/2023 2/15/2023
Electric Efficiency Partners Program 242

2022 PURA Report to the General Assembly Regarding the State Public Act 17-64 22-11-01 3/29/2023 4/1/2023
of Electric Competition

2023 PURA Report to the General Assembly Concerning Lost and Public Act 14- 23-03-02 6/21/2023 7/1/2023
Unaccounted for Gas 152

Annual Electric Distribution Company Reliability and Resilience Public Act 12- 23-08-09 12/13/2023 9/1/2023
Framework Review 148

The Public Utilities Regulatory Authority’s Study of the Special Act 22- 22-06-26 12/15/2023 12/15/2023
Operations of Certified Third-Party Nonprofit Community Access 23
Programming Providers

PURA Investigation into Distribution System Planning of the Public Act 23- 17-12-03RE10 2/1/2024 1/1/2024
Electric Distribution Companies – Building Blocks of Resource 102
Adequacy and Clean Electric Supply: Legislative Report

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PURA 2023 ANNUAL REPORT

SECTION 10:
STATUS OF DECISIONS IN APPEAL
The Decision Appeal Process

All Authority decisions are based upon robust evidence gathered through the docket process, which includes discovery,
hearings, written and verbal comments and testimony, interrogatories, and more. Authority staff with technical expertise
in finance, accounting, engineering, economics, policy, and law are assigned to each docket to ensure that the record of
that docket is substantial and sufficient to issue sound decisions. However, on occasion, a party to a PURA docket will
disagree with a finding or statutory interpretation of the Authority; in these cases, the party may choose to appeal the
decision to the Superior Court, pursuant to the limitations of the Uniform Administrative Procedure Act. Importantly,
parties filing an appeal of a decision issued by PURA are only allowed to appeal on issues that were raised during the
proceeding or were addressed in the final decision.[1] This must be completed within forty-five days after issuance of the
final decision.

Once an appeal is filed, it is the Superior Court’s responsibility to review the record used to issue the decision and
determine whether the party appealing the decision’s rights have been violated because the decision:

1. Is in violation of constitutional or statutory provisions;


2. Is in excess of the statutory authority of the agency;
3. Was made through unlawful procedure;
4. Was affected by other error of law;
5. Is clearly incorrect in the view of the reliable, probative, and substantial evidence on the whole record; or
6. Is arbitrary or characterized by the unwarranted exercise of discretion.[2]

Should the Superior Court find any of the above to be true, it may issue a judgement that modifies the original decision or
orders a particular agency action.[3] If the Superior Court rules in favor of the Authority, the original appealing party may
attempt to appeal that decision through the Appellate Court and/or Supreme Court if appropriate.

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PURA 2023 ANNUAL REPORT

PURA Decisions in Appeal

The below table provides a status update of PURA’s decisions that were in some stage of an appellate process in 2023.

Table
YOUR 17: StatusTEXT
PARAGRAPH of PURA Decisions in Appeal during 2023

Appellant Docket No. Summary Status

Direct Energy Services, LLC 16-12-29 Certain electric suppliers appealed a 2020 The Superior Court affirmed PURA
et al. SC 20643 PURA decision that imposes restrictions on the on all counts.
Voluntary Renewable Offers (VRO) market to The CT Supreme Court sustained
minimize customer confusion and to align the the lower court’s determination in
VRO program with the state's energy and favor of PURA.
environmental goals.

Northland Investment 19-12-25 Northland challenged PURA’s determination The Superior Court affirmed PURA’s
Corporation SC 20769 that ratio utility billing methodology (RUB) is determination. The CT Supreme
not permitted under state law. Court heard arguments on the
matter. A decision is pending.

Retail Energy Advancement 18-06-02RE01 REAL appealed motion ruling declining to REAL withdrew the appeal.
League (REAL, assoc. of retail CV23-6077829 strike evidence.
electric suppliers)

Retail Energy Advancement 18-06-02re02 REAL is seeking a declaratory judgment Schedule pending.
League (REAL, assoc. of retail CV23-6082579 relating to provisions of Senate Bill 7 and
electric suppliers) PURA’s pending docket No. 18-06-02RE02.

Yankee Gas (Eversource) 21-08-24 Eversource appealed a 2022 PURA decision After full briefing, Eversource
CV22-6073770 ordering LDCs to apply surplus non-firm withdrew the appeal.
margin (NFM) revenues to capital infrastructure
investments at their next rate case.

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PURA 2023 ANNUAL REPORT

Appellant Docket No. Summary Status

CL&P (Eversource) 21-01-03 Eversource appealed a 2021 Rate Adjustment The Superior Court affirmed PURA
CV21-6069473 Mechanism (RAM) decision in which PURA on the storm cost issue and
disallowed $17.2M of catastrophic storm costs remanded the interest rate matter
in the Electric System Improvement (ESI) for clarification by PURA. PURA
tracker. Eversource also challenged the issued a clarification decision, and
interest rate applicable to carrying charges. the matter is pending before the
Superior Court.

CL&P (Eversource) 21-01-03 See CV21-6069473 above. Eversource separately PURA is reviewing the complaint
CV23-6078865 appealed the clarification decision issued on and considering legal options,
remand by PURA. including a motion to dismiss.

CL&P (Eversource) 23-01-39 Eversource appealed a decision resulting from PURA is reviewing the complaint
CV23-6081727 PURA’s investigation into Eversource’s response and considering legal options,
(exceeding 1 hour) to an entrapment incident including a motion to dismiss.
involving injured persons in Norfolk. PURA
directed Eversource to reduce its target
response time to 30-minutes for “blue sky”
conditions and to improve its accident
reporting.

CL&P (Eversource) 23-01-39 In addition to the direct appeal of the PURA is reviewing the complaint
CV24-6083548 accident/entrapment investigation, Eversource and considering legal options,
also filed a request for a declaratory judgment including a motion to dismiss.
challenging the entrapment investigation.

CL&P (Eversource) 23-01-32 Eversource appealed a decision resulting from PURA is reviewing the complaint
CV24-6083754 PURA’s investigation into a series of explosions and considering legal options,
and fires in Eversource’s underground facilities. including a motion to dismiss.

CL&P (Eversource) 22-09-08 PURA identified a transcription error in a PURA has filed a motion to dismiss.
CV23-6078868 decision that consolidated existing PURA
orders related to RAM proceedings. PURA
issued an errata decision correcting the error.
Eversource appealed the correction.

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PURA 2023 ANNUAL REPORT

Appellant Docket No. Summary Status

Aquarion (Eversource) 22-07-01 Aquarion/Eversource appealed the 2023 rate The appeal has been fully briefed
CV23-6078177 case decision denying a $35M rate increase. and argued in Superior Court. A
Aquarion/Eversource is challenging approx. decision is pending.
$15M in disallowances.

United Illuminating (UI) 23-01-04 UI appealed the 2023 RAM decision in which PURA is reviewing the complaint
CV24-6083218 PURA made adjustments related to RDM and considering legal options.
revenue, fuel cell project accounting, and
incentive compensation

United Illuminating (UI) 22-08-08 UI appealed the 2023 rate case decision PURA filed a request for UI to revise
CV23-6081616 granting a $22M increase. the complaint to remove extra-
CV23-6082032 record documents. Briefing is
scheduled through Fall 2024.

United Illuminating (UI) 22-01-04 UI appealed the 2022 RAM decision in which The appeal has been fully briefed
CV22-6075751 PURA reduced the RDM revenue requirement and argued in Superior Court. A
by $5.2M and indicated that UI may have been decision is pending.
imprudent in failing to implement an
accounting change that would have saved
ratepayers millions of dollars annually. PURA
subsequently issued the 2023 rate case
decision, which adjudicated the accounting
change issue, resulting in a 5 basis point
reduction in ROE.

United Illuminating (UI) 20-08-03 and After finding UI's storm response was deficient The Superior Court affirmed PURA’s
20-08-03RE01 in several areas, PURA imposed a civil penalty decision on all counts. UI appealed
SC 20795 of $1.3M for non-compliance with performance the affirmation. The CT Supreme
CV21- standards and accident reporting Court heard arguments on the
6067807S requirements and ordered a 15 basis point ROE matter. A decision is pending.
CV21- reduction penalty in UI's next rate case to
6066639S incentivize improved storm response
performance by UI. In the subsequent rate
case, PURA determined that the 15 basis point
reduction was no longer warranted.

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PURA 2023 ANNUAL REPORT

Appellant Docket No. Summary Status

GenConn Energy LLC(a joint 20-06-14 GenConn has appealed the decisions issued in The Superior Court affirmed PURA’s
venture between UI and 21-06-28 these annual rate proceedings for 2021 to 2024. initial decision on all counts
NRG Energy, Inc.) 22-06-02 The primary issue on appeal is GenConn’s debt- (subsequent appeals have been
23-06-02 to-equity ratio used to calculate the ROE. stayed). The CT Supreme Court
CV21-6064030 heard arguments on the matter. A
CV22-6070555 decision is pending.
CV23-6077103
CV24-6083506
SC 20716

Vistra Corp. et al. 23-06-01 Several electric suppliers that had previously PURA is reviewing the complaint
CV24-6083505 entered into a settlement agreement to resolve and considering legal options,
a PURA investigation appealed this decision, including a motion to dismiss.
which requires the suppliers to pay their actual
Renewable Portfolio Standard (RPS)
obligations, rather than have these costs
shifted to ratepayers.

Sunnova Energy Corp. 22-10-05 Sunnova appealed PURA’s determination PURA has filed a motion to dismiss,
CV23-6078852 regarding the transfer of RECs under the RRES which is pending before the
program. Superior Court.

Clearview Electric, Inc. 07-08-17 Clearview appealed PURA’s denial of PURA will file a motion to dismiss.
CV23-6082224 Clearview’s request to withdraw its electric
supplier license until Clearview pays the
amount it owes under the supplier cost
allocation decision (14-07-19re07).

[1] Conn. Gen. Stat. § 16-35(b)

[2] Conn. Gen. Stat. § 4-183(j)

[3] Conn. Gen. Stat. § 4-183(k)

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PURA 2023 ANNUAL REPORT

APPENDIX 1:
STANDARD DOCKET
PROCEDURE GUIDE
The Public Utilities Regulatory Authority (PURA or the Authority) is a quasi-judicial state
agency, which means that, similar to a court, all matters before PURA must go through a
standardized procedural process, also known as a “docket”. Though each docket is
unique, nearly all follow a five-step framework outlined by Figure A1. A more detailed
description of each step is provided below.

Figure A1: The Standard PURA Docket Process


Receive pre-filed
testimony
Technical Written
meetings or comments,
Hearings exceptions, or
Written comments briefs
Interrogatories Oral
Briefs arguments

Step 3: Step 4:
Step 1: Step 2: Step 5:
Issue Make
Docket Build the Issue Final
Draft Changes,
Initiation Record Decision
Decision If Any

Receive application Summarize Finalize decision at


or initiate on own proceeding Regular Meeting
motion Standard of Issue compliance
Issue Notice of review requirements
Proceeding PURA analysis
Identify docket Conclusions &
objectives orders
Identify participants
Review application

Step 1: Docket Initiation

Dockets are initiated for a variety of matters in response to external stakeholder petitions
or applications. The Authority may also initiate dockets of its own accord, either on a
voluntary basis or as required by law. External stakeholders file their application through
PURA’s online docket system. Upon receipt of an application, PURA’s Docket Control staff
will assign the application a docket number and title.

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The Authority will then issue, through the docket, a Notice of Proceeding (NOP), which is
a legal document that reflects the type (i.e., contested or uncontested) and scope of the
proceeding. The NOP is also an important communication device, used by the Authority
to set appropriate stakeholder expectations for the proceeding. This includes citing to
relevant statutes, providing an initial list of docket participants, and outlining potential
areas of exploration or investigation.

At the same time as the NOP is distributed, or shortly thereafter, PURA will also publish
an external docket schedule whenever possible, particularly if the docket is governed by
a statutory timeline. The external schedule is used to communicate the planned
procedural steps in a docket, to facilitate the PURA discovery and decision drafting
process, and to make sure that external procedural steps do not conflict with other
scheduled events.

At this point, any docket participant in an uncontested case or a party or intervenor in a


contested case may submit docket correspondence. Correspondence provides a
stakeholder’s perspective outside of the procedural steps identified in the external
schedule. Correspondence need not be as structured as the other forms of comments or
testimony discussed. The Authority gives docket correspondence its due weight based on
the nature of the comments provided, and the evidence presented. The Authority may
use correspondence to help guide the discovery process in Step 2: Build the Record.

Step 2: Build the Record

In order for the Authority to issue a decision, it must have a robust record of evidence that
supports it. During Step 2, PURA establishes this record evidence through discovery.
Discovery entails a variety of tools and events that allow the Authority to investigate the
components of the issue(s) in the proceeding. These include:

Pre-Filed Testimony: Pre-filed testimony provides participants, parties and/or


intervenors an opportunity to introduce expert witnesses and to present their main
position at the outset of the proceeding.
Written Comments: Written comments allow participants, parties, and/or intervenors,
and other stakeholders, the opportunity to share their support, concerns, and
thoughts regarding the docket. A Request for Written Comments will be separately
noticed by PURA and will specify the topics for comment.
Interrogatories: Interrogatories are questions the Authority issues to specific
participants, parties, and/or intervenors. These questions are based on the Authority’s
review of written comments, testimony, or other filed evidence. Interrogatories may
also be propounded by other participants, parties, and/or intervenors, as governed by

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the Notice of Proceeding and any associated rulings on a request for status as a
participant, party or intervenor.
Hearings & Late Filed Exhibits: Hearings allow the Authority to question the
participants, parties, and intervenors, as well as their expert witnesses. Exhibits are
entered into the evidentiary record during the Hearing for use in the Decision.
Answers submitted at a later date to questions asked during cross examination are
considered Late Filed Exhibits. The Authority may seek additional explanation or
clarity on Late Filed Exhibits during a Late Filed Exhibit Hearing.
Technical Meetings: Technical Meetings are informational meetings that allow the
Authority to question the participants while also providing the opportunity for the
participants to discuss issues with the Authority. Technical Meetings may be held in
addition to, or in lieu of, a formal hearing, depending on the type of docket under
consideration.
Briefs: Following the conclusion of the final hearing and/or close of the formal record,
the Authority may issue briefing prompts for parties and participants to submit final
arguments into the record. The Authority may also issue briefs at other times in the
proceeding prior to the close of the evidentiary record to better ascertain the legal or
other positions of participants, parties, and/or intervenors. Briefs are not an
opportunity to enter new evidence into the record.

The Authority may employ one, many, or all of these tools, and may use them more than
once throughout a proceeding. Contested proceedings are guided by the Uniform
Administrative Procedure Act and Title 16 of the Regulations of Connecticut State
Agencies, and often involve a hearing. Any of these tools that are relied on by the
Authority will be listed in the external docket schedule for a proceeding.

Step 3: Issue the Proposed Final Decision

Decisions are authoritative rulings or determinations made by the Authority through its
adjudicatory powers over certain matters, as dictated and delegated by state statute. A
Decision is written based on evidence entered into the evidentiary record. In most
dockets, the Authority may elect to issue a Proposed Final Decision. Virtually all of
PURA’s decisions follow a standardized outline and inventory of information that
includes:

A summary of the decision;


Background and conduct of the proceeding;
A list of the parties, intervenors, and/or participants;
A list of relevant statutes, regulations, case law, or PURA precedent that governs the
application and PURA’s review;

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A summary of the standard of review, including specific findings or conclusions made


by PURA;
A description of the burden of proof, or other statutory limits;
The Authority’s analysis of the proceeding, organized by each subtopic, which may
include a synopsis of stakeholder comments in general or by subtopic;
Conclusions;
Orders that direct subsequent action related to the topic from specific parties; and
Any appendices.

Step 4: Revise the Proposed Final Decision (Optional)

Proposed Final Decisions are published for stakeholders to review, along with a Notice for
Written Exceptions. Exceptions are provided by stakeholders that disagree with or take
issue with specific components of a Proposed Final Decision, and must be structured to
identify errors of fact or errors of law; importantly, written exceptions cannot introduce or
rely on evidence not already in the official record. Parties, intervenors, and/or participants
to the docket are provided the opportunity to file exceptions to portions of the Proposed
Final Decision. Additionally, the Notice for Written Exceptions may, but is not required to,
offer parties and participants the opportunity to request that the Authority hold Oral
Arguments so that they may present their argument directly before the Authority. The
Proposed Final Decision may be revised as a result of Written Exceptions and/or Oral
Arguments.

Step 5: Issue the Final Decision

Following any changes made in response to Written Exceptions and Oral Arguments,
PURA staff will present a Final Decision before a panel of the three Commissioners at a
Regular or Special Meeting. The PURA Commissioners hold a Regular Meeting most
Wednesdays at 10:00a.m. to vote on the adoption of Final Decisions. A Decision is not
considered final until it is placed on a Regular or Special Meeting agenda and receives a
vote of adoption by a majority of the Commissioners. All Regular and Special Meeting
agendas are published on the Secretary of the State’s Connecticut State Agency Public
Meeting Calendar on the Thursday prior to the Regular Meeting, as well as on PURA’s
Calendar of Events.

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