More specifically, Staff recommends: (1) the inclusion of all utility account numbers on all New York State Office of Temporary Disability Assistance (OTDA) public assistance program applications as a standard variable to match as a means to identify income eligible customers; (2) working directly with OTDA to effectuate more frequent file matches to capture changes in program participants, with the utilities reporting annually on how many of the participants in the file were not able to be matched, as well as the estimated number of total Home Energy Assistance Program (HEAP) recipients served by the OTDA in their respective service territories; (3) that all future requests for submetering that include affordable housing component should require the building owner to file an application to OTDA for coordinated benefits to low-income customers; (4) that the utilities that receive the OTDA file match develop a uniform statewide approach for customer self-identification, with the utilities and Staff collectively working with OTDA to develop a verification process in their next file match to ensure the self-identified customer was indeed program eligible by OTDA; (5) utilizing the midpoint of each income tier to set income assumptions which represents the least administratively burdensome modification to actual income data provided from OTDA; (6) that the Commission use the regular HEAP renter to develop the low-income energy affordability program discount for Tier 1 electric and gas non-heat customers, with all major utilities conducting an analysis to determine if a more refined calculation has a significant impact to the Tier 1 discount using the actual renter benefits; (7) that the major utilities conduct an analysis to determine if developing distinct tiers for the vulnerable person HEAP add-ons would provide more targeted assistance for their respective low-income customers; (8) that the utilities use a simple three-year average when calculating the average usage for each low-income customer group, and continuation of the current practice of adjusting the calculated average bill by utility upward by ten percent to recognize that some low-income customers’ usage is above the average; (9) that the utilities analyze the potential for stratifying low-income customers into usage groups to determine average bills for those respective groups to determine if further refinements to the discount levels are feasible; (10) that the grandfathering clauses be phased out; (11) that the Commission reiterate that further adjustments will not be considered in individual rate cases, but on a generic basis in this proceeding going forward; (12) that if the Commission adopts Staff’s recommendations, low-income discounts should not be decreased for the next two years (2021-2022 and 2022-2023 program years); (13) that each utility’s two percent total revenue program budget caps be adjusted to factor in scheduled delivery rate increases; (14) that October 1st be the uniform annual filing date established for all utilities and that the updated discounts become effective November 1st to coincide with the beginning of the heating season; (15) that the low-income discounts be moved to tariff statements, which may facilitate faster and more streamlined implementation after the utilities submit their annual EAP filing; (16) that the utility’s energy affordability discounts also be updated for the recommendations herein at the same time as the utility’s tariff compliance filing for its new rate plan; (17) continuation of automatic enrollment of low-income energy affordability participants in utility levelized budget billing programs; (18) that commercial customers be able to self-certify a change in financial circumstance due to the COVID-19 pandemic and be allowed to enter into differed payment agreements (DPSs) with no down payments, have existing DPAs renegotiated due to changes in the commercial customers’ financial circumstances, and late payment charges be waived; (19) residential and commercial late payment fees should continue to be waived for the two-year time period starting on the expiration of the moratorium on terminations and disconnections of residential electricity, gas, steam, telephone, and water customers during the COVID-19 state of emergency; (20) that deferred payment arrangements should not accrue interest on customer residential and commercial arrearages for the two-year time period after the conclusion of the moratorium on terminations and disconnections of residential electricity, gas, steam, telephone, and water customers during the COVID-19 state of emergency; (21) that the Commission adopt an arrears management program at each major utility; (22) that, longer term, if there is room within a utility’s low-income energy affordability program budget, the utility should explore developing a cost-effective arrears forgiveness program; (23) that the utilities leverage their customer data to identify the highest usage low-income customers and coordinate with the New York State Energy Research and Development Authority to administer energy efficiency programs to not only achieve the State’s goals, but to provide meaningful and lasting energy relief to low-income customers; (24) continuing the low-income EAP discounts be only used for purposes of lowering program participant’s utility bills.

Staff also recommends longer term issues be addressed in a subsequent phase of the proceeding, including expansion of eligible low-income customers enrollment, improvement of data sharing between the utilities and OTDA, and a standardized statewide file matching system.

The full text of the Staff whitepaper and the full record of the proceeding may be reviewed online at the Department of Public Service web page: www.dps.ny.gov. The Commission may adopt, reject or modify, in whole or in part, the action proposed and may resolve related matters.

Statements and analyses are not submitted with this notice because the proposed rule is within the definition contained in section 102(2)(a)(ii) of the State Administrative Procedure Act.

(14-M-0565SP15)