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Comments on Scope of Bill Impact Study to New York

New York State is carefully considering rate design reforms that could be adopted by utilities to provide efficient incentives for adoption of distributed energy resources. Studies on customer bill impacts of such rate design changes are necessarily going to be an important factor in moving forward. Our comments on the scope of bill impact studies emphasize that the effect on consumer bills is just one of the aspects to be considered when looking at rate design changes. In addition, we suggest that DPS give more guidance on the types of rate designs it’s considering, parameters used to model consumer behavior, and the time horizon that the studies cover.