EDCs outline options for front‑of‑meter charging tariffs; counsel warns exports to utilities risk FERC jurisdiction

Electric distribution companies described the technical and rate‑design considerations for a retail charging tariff for front‑of‑meter (FTM) standalone energy storage and urged stakeholder engagement to define requirements. Ed Davis (Eversource/Avangrid UI presenter) said although existing retail time‑of‑use rates (and UI's SG2) can be applied today, developing a new targeted tariff requires examining all retail components—supply, transmission, distribution and public benefits—and metering/billing capabilities.

Jennifer Key (Steptoe, counsel for Eversource) cautioned stakeholders about jurisdictional limits: the docket’s scope is retail purchases by ESS devices, but any sale of energy or capacity by an FTM storage facility to an EDC is likely a wholesale sale subject to FERC jurisdiction, not PURA. “If a storage device is selling power to an EDC, that is typically a wholesale sale,” Key said, noting exceptions (municipal utilities or QFs) are limited and that paired (hybrid) resources colocated with renewable generation can change qualification.

EDCs recommended a stakeholder working group (modeled on the WDAT process) to design tariff parameters, estimate a stakeholder/design timeline (months to roughly a year for an initial design, longer for full implementation), and emphasized the importance of cost‑causation to avoid cross‑subsidization. They also noted prior studies showed a demand‑response retail compensation construct would likely require subsidies at current prices to be revenue‑neutral, raising affordability and cost‑shift concerns.