Central Hudson EPOP Letter to PSC

Hon. Garry A. Brown, Chair
New York State Public Service Commission
Three Empire State Plaza
Albany, New York 12223-1350 RE: 09-E-0588 Proceeding on Motion of the Commission as to the Rates,
Charges, Rules and Regulations of Central Hudson Gas & Electric
Corporation for Electric Service. 09-G-0589 Proceeding on Motion of the Commission as to the Rates,
Charges, Rules and Regulations of Central Hudson Gas & Electric
Corporation for Gas Service. Dear Chairman Brown: I write once again to urge the outright rejection of the Joint Proposal agreed to by Central Hudson Gas and Electric, Department of Public Service Staff and Multiple Intervenors to raise gas and electric delivery rates by nearly $40 million over the next three years. The recent developments regarding data used to calculate financing of the arrears forgiveness program, known as the Enhanced Powerful Opportunities Program (EPOP), is deeply troubling. This revelation has led the Consumer Protection Board to join me in opposition to the Joint Proposal as it has raised numerous questions regarding the validity of the process and whether the plan is in the public interest. In the Joint Proposal before the Commission, Central Hudson provided information on per capita costs intended to substantiate the claim that they would increase the number of participants in the company’s EPOP program by 110 households annually over the course of the three year rate plan. However, the funding level calculated by the utility was based on an outdated $1,467 per customer, rather than the more accurate figure of $2,588. Currently, Central Hudson’s EPOP serves roughly 1,000 customers. Under the three year plan that has been put forth, the utility agreed to expand the program to cover 1,330 participants by the expiration of the agreement. In reality, when the actual per customer estimated cost is applied, enrollment in the program will decrease significantly to about 600 customers, or less than half of the 1,330 targeted enrollees assumed in the Joint Proposal. The Joint Proposal is the result of a negotiation that has a broad public impact. The inaccurate calculations used to determine the company’s ability to finance this critically important program raises some serious questions about the plan. I urge the Commission to reject the agreement and require the utility to submit a new filing so that it may be subjected to the full scrutiny only a litigated rate proceeding can provide. Central Hudson’s customers deserve no less. As always, I appreciate your attention to this matter. Sincerely,
Kevin A. Cahill
Member of Assembly