Energy Policy Issues

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Entergy Nuclear Fitzpatrick Reorganization
In these comments filed on September 29, 2008, the New York State Department of State Division of Consumer Protection opposes the reorganization of the Company, as it is our position that such reorganization would financially weaken the Company, thereby possibly leading to inadequate maintenance and safety issues.

Comments Regarding Consideration Of Utilities’ Compliance Filings
Pursuant to a notice published in the March 11, 2009 New York State Register, the New York State Department of State Division of Consumer Protection filed comments regarding the proposed plans by New York State electric and gas distribution utilities to provide customers with secure, real-time remote access to their own distribution account number for purposes of procuring service from an energy service company. The Division, in the interest of information privacy and the new State Social Security Act, advises caution regarding the use of Social Security numbers as the sole or primary authentication to access account information by the customer.

Proposed Acquisition of Energy East by Iberdrola: Reply Brief on Exceptions
In this brief submitted July 3, 2008, the New York State Department of State Division of Consumer Protection responds to positions taken by other parties disagreeing with the Judge's June 14, recommended decision. We explain that Iberdrola has overstated the alleged benefit of divestiture of Energy East's fossil-fueled plants, as well as the benefit of its commitment to invest $100 million in New York. We also show why the New York State Public Service Commission should generally require for this acquisition, the same financial protections it required for the National Grid/KeySpan merger.

Proposed Acquisition of Energy East by Iberdrola: Brief on Exceptions
In this brief dated June 26, 2008, the New York State Department of State Division of Consumer Protection identifies our concerns with the June 14, 2008 Recommended Decision by the Administrative Law Judge (ALJ) regarding the proposed acquisition of Energy East by Iberdrola. We continue to explain that the proposed acquisition should be approved by the New York State Public Service Commission subject to several conditions. However, we explain our strong opposition to the ALJ's recommendation that Iberdrola be prohibited from owning wind generation in New York State Energy Generators and Rochester Gas and Electric's service territory, as well as the Judge's requirement that the combined Company divest its existing hydroelectric generation assets. 

Proposed Acquisition of Energy East by Iberdrola: Reply Brief
The New York State Department of State Division of Consumer Protection submitted this brief on April 25, 2008, responding to claims made in the initial briefs of other parties regarding the nature and scope of the conditions that the New York State Public Service Commission should place on its approval of the proposed merger. We explain that the assertion that Iberdrola’s active involvement in the development of wind generation would be a detriment to New York is unfounded and ratepayers should be provided additional monetary benefits to compensate them for the risks posed by the merger.

Proposed Acquisition of Energy East by Iberdrola: Initial Brief
In this brief filed April 11, 2008, the New York State Department of State Division of Consumer Protection demonstrates that the New York State Public Service Commission (PSC) should approve the merger only with the addition of substantial financial benefits to fairly compensate consumers for the substantial risks associated with the acquisition, and with strong financial protection measures similar to those adopted by the PSC in the recent National Grid/KeySpan merger. In addition, we show that no restrictions should be placed on the future development of wind generation that are different from those applicable to any other utility in the State.

Comments Regarding Retail Competition Policies
In a filing dated June 21, 2007, the New York State Department of State Division of Consumer Protection explains that changes are required to the New York State Public Service Commission's (PSC) policies regarding retail energy competition. In particular, several programs to promote or subsidize retail competition should be terminated immediately; while other programs should be modified immediately. We also explain that the PSC must enhance its monitoring and oversight of retail energy markets and tailor its policies to reflect the realities of those markets. 

Comments Regarding Electric Planning and Long-Term Contracts
The New York State Department of State Division of Consumer Protection explains in these June 5, 2007, comments that the New York State Public Service Commission should adopt a statewide integrated resouce planning process to help guide the overall development of electricity infrastructure, since current processes do not properly consider environmental and public policy objectives. We also explain why there should be increased reliance on long-term contracts between electricity generators and utilities to help support new electric generation in New York State.

Comments Regarding Utility Commodity Price Volatility
In these comments filed November 17, 2006, the New York State Department of State Division of Consumer Protection recommends that the New York State Public Service Commission require utilities to reduce the risk of commodity price fluctuations for residential and small business customers. We explain why these customers need protection from extreme price volatility and we provide guidelines to be used to ensure that utilities purchase a balanced portfolio of energy commodities.

 

Last Modified: May 02, 2011