offset tariff Q&A
- What does the tariff mean by the term "premises"?
- Under proposed General Rule 20.2.1(B)(8), premises is defined as:
“A parcel of land; or more than one building and/or parcel of land proximate to each other if there is common use, whether or not such buildings or parcels are separated by public or private roads.”
This tariff is intended to apply to campus-style settings with accounts in a single customer’s name. This is consistent with the definition applicable to line extensions in General Rule 5.1 of PSC No. 10 tariff (Leaf 33).
- When in the interconnection process will the customer know whether or not they are considered a “premises”?
- This will happen fairly early in the interconnection application process. In preliminary meetings between Con Edison and the Customer and after Con Edison’s receipt of the customer’s load letter, the parties will establish how the service will be utilized.
- Why is the proposed General Rule 20.2.1(B)(8) limited to a single person or entity?
- Allowing multiple customers to share allocations of a generator’s output could involve Con Edison in disputes among different customers regarding the appropriate allocation of credits. Under the new tariff, Standby Service accounts and the account associated with the generating facility must be established in a single Customer’s name, which creates a uniformity of interest on the customer side.
- What’s the rationale behind the over-2 MW lower bound?
- We designed this tariff to address the family of customers that we knew might be interested in taking advantage of this tariff (i.e., connecting a generator to the high-tension system and supplying multiple on-premises accounts).
- What if there is a mixture of high-tension and low-tension accounts?
- This is fine so long as at least one of the accounts is low-tension. Each account will be separately metered, so you may have a mix of different kinds of accounts - high- and low-tension accounts and accounts formerly billed under time-of-day and non-time-of-day rates. However, each of the accounts that are to be credited for the generator’s output will be billed under the standby service rate applicable to that individual account and must have interval metering.
- Would the new tariff allow me to provide generation to commercial buildings in my vicinity? By “vicinity,” I mean buildings across a city street or on the same block.
- There are some campus environments within the city that do cross public streets; typically they will also have physical interconnections, such as tunnels below the street and have agreements in place with City agencies to utilize that space for services such as steam lines or chilled-water lines - such interconnections would fall under “common use” and would thus make connected buildings eligible for this tariff.
- Am I eligible for NYSERDA incentives if I take service under this tariff?
- NYSERDA currently requires CHP projects to be able to provide emergency back-up supply, so please check with NYSERDA regarding your particular interconnection arrangement.
- How will the Company’s approval of Contract Demand be executed for these arrangements?
- We expect to handle this through the interconnection application process. As the project is being designed, we will work closely with the customer to determine the appropriate Contract Demand for each of their accounts.
- Will I get a credit towards my Contract Demand associated with the generator output?
- No, the Contract Demand on each Standby Service account will be based on the Customer’s maximum potential demand on the Company’s system inclusive of the delivery of the generator’s output to that account. Because the generator’s output does not reduce the Customer’s use of local facilities, such output will not be netted against the Customer’s peak demand as registered by the Customer’s standby service meters. However, the generator output will be allocated and netted against the As-used Demand of each account, as explained below.
- Can the Contract Demand be reduced if the load at one of the buildings is reduced?
- A Standby customer’s right to request reduction of its Contract Demand is not altered by the proposed tariff change. As described in General Rule 20.4.3 of the tariff, a customer can reset its Contract Demand downward once every 12 months if the customer demonstrates a permanent load reduction. See tariff leaves 164 and 165 for further detail.
- Why can’t I get credit for excess generation through SC11?
- The new tariff provision has been designed consistent with the design of General Rule 20.2.1(B)(7) (originally Special Provision E of PSC No. 9), where export is expected to be equal to or less than the aggregate demand at the premises. This tariff assumes that generation would meet only the customer’s local campus load. If a customer does not elect to take service under General Rule 20.2.1(B)(8) and interconnects its generator to Con Edison’s high-tension system, the customer has the option of taking service under SC11 and selling its export to the Company or directly to the NYISO.
- Must As-Used Demand be coincident with the DG output?
- Since each account is a Standby Service account, Daily As-Used Demand is handled on a per-account basis. That is, the highest relevant daily demand for each account will determine its Daily As-Used Demand, regardless of the other Standby accounts and DG output.
- Please explain As-Used demand.
- For an account that is billed under Standby Service rates, As-used Daily Demand charges are determined for each weekday in the billing period when service is taken from Con Edison to supplement or replace generator output. As-used Daily Demand charges are based on applying a daily demand delivery charge to the daily peak demand during each time period, net of the kW allocated generator demand (M-F 8 am-6pm and 8am-10pm during the months of June through Sept. and M-F 8am-10pm during all other months). As-used Daily Demand charges for the billing period are equal to the sum of the As-Used Daily Demand charges for the time periods.
- How would the As-Used Daily Demand be calculated if all of the accounts on a premises are not time-of-day?
- Interval metering is required for all accounts billed under Standby Service. Each account is then billed separately for daily As-used demand charges based on each account’s specific daily peak demand during the time periods specified above. as defined above. Each account will be allocated a share of the generator demand based on the account‘s registered demand multiplied by the ratio of the generator demand to the sum of demands registered on the meters of all accounts supplied by the generator. Allocated As-used Generator Demand will be determined for each 15-minute interval.
- Why is the billing charge based on the number of offsetting accounts rather than a fixed customer charge?
- Billing under this tariff will have to be manually prepared, rather than going through the existing billing engine, and billing complexity increases with the number of offsetting accounts associated with a generator. The billing charge reflects the higher cost to bill because of the added allocation billing and checks and balances required under this arrangement. A time may come when a larger number of customers have adopted the tariff, and development of an automated billing process is appropriate. Until such time, undertaking the creation of an automated billing system at the expense of the early adopters would impose a large cost burden on them.
- How will transformer losses between the generator and offsetting accounts be calculated?
- Transformer losses are either programmed into the meter or are part of the billing calculation, depending on each individual configuration. Each configuration will vary based on the voltage level of the connection with the generator and the voltage level of the offsetting accounts, so these will be handled on a per-project basis. We will be working closely with customers to make sure that we’re correctly calculating losses taking into account the specific configuration and voltage levels.
- Where did Special Provision E go?
- Special Provision E is now contained in General Rule 20.2.1(B)(7) of PSC No. 10 tariff (Leaf 157).
- There will be a power-factor charge on the generator account and on the accounts that receive the generator’s output. If the DG could contribute VARS would there be any credit for or sale of VARs to Con Edison?
- Currently, there’s no mechanism for Con Edison to purchase VARs. Customers with on-site generation may qualify to sell VARs to the NYISO. Customers with on-site synchronous generation are able to control the generator’s VAR output.
- Why is the customer responsible for meter communications?
- The customer is in the best position to assure equipment under its control is operating properly. And delays in meter-data collection can result in estimated bills, which are unworkable for allocating generator output across multiple accounts.
- Would Con Edison consider using customer owned monitoring equipment to obtain consumption data needed for billing if there is insufficient interval data available from its own equipment?
- Metering used for billing purposes must be revenue-grade per New York State Public Service Commission requirements. Meters contain interval data for approximately two months, so we would be able to retrieve data directly from meters once communications have been re-established or by having a Con Edison employee obtain a reading at the premises (at a cost to the customer).