Consumer Advocacy on the Cape and Vineyard
Cape Light Compact is known for its services in energy efficiency and its worry-free, renewable power supply option for homes and businesses on Cape Cod and Martha’s Vineyard. But, did you know there’s a third area of focus where the Compact contributes time and efforts? It’s consumer advocacy! Energy issues can be complex and difficult to digest, but the Compact is here to help. Recognizing that electric ratepayers on the Cape and Vineyard often have different interests than customers in other areas of the Commonwealth, the Compact is an advocate working to make Cape and Vineyard positions on energy issues heard at the state level. To learn more about this area of focus, Maggie Downey, the Compact Administrator, and Austin Brandt, the Senior Power Supply Planner, describe the Compact’s history and current efforts regarding consumer advocacy.
What we do and how we do it
“Cape Light Compact’s been advocating for consumers going back almost 20 years, since we were formed in 1997, and the advocacy work has been primarily through our participation in regulatory proceedings in front of the Department of Public Utilities (DPU),” explains Downey.
The advocacy efforts mean the Compact has a seat at the table to provide a voice for Cape and Vineyard residents and businesses that they hadn’t had previously, independent of other organizations that represent the entire state such as the Attorney General.
The Compact is the only municipal aggregator in Massachusetts that advocates for its consumers at the DPU level, which is impressive considering that there are over aggregators across the state, but no other one has been involved or advocated in the same way as the Compact on these issues. While the Attorney General (AG) is the ratepayer advocate at the state level, she represents the interests of electric distribution customers statewide before the DPU. She generally advocates for all Massachusetts customers whereas the Compact’s advocacy efforts are focused specifically on representing customers on the Cape and Vineyard.
“Though the Compact often works in tandem with the Attorney General in areas of mutual interest, sometimes we stand on our own on certain issues and I think it’s fair to say that the Cape Light Compact is the most involved organization in terms of ratepayer consumer advocacy for the Cape and Vineyard at a regional level. There’s no other Cape and Vineyard specific organization that has the same level of activity and focus on DPU proceedings as the Compact,” says Brandt.
“It’s not as sexy as renewable energy or energy efficiency – it’s kind of boring because it’s a lot of reading and legal back-and-forth, but it can have significant impacts,” admits Downey.
The Compact’s participation in consumer advocacy-related proceedings is generally infrequent. There isn’t always a hot ticket item that the Compact is advocating for or against, but when the Compact notices an issue where their ratepayers have a special interest, or where Cape and Vineyard interests may be different than those of other parts of Massachusetts, the Compact’s advocacy team approaches the Compact Governing Board and asks if it’s a proceeding they are interested in participating in. The Governing Board consists of representatives from all fifteen towns on Cape Cod, the six towns on Martha’s Vineyard, and Dukes County. If they vote to participate, then the Compact’s advocacy team moves forward.
“We recommend to the Board the positions that the Compact should take on the relevant issues, and we work with counsel and consultants to put forth the arguments that support our view on different issues,” states Brandt.
So, how does the Compact finance the legal counseling and consulting required to prepare these filings and make arguments? Through the operating fund, which the power supply program customers pay into monthly.
“It’s one of the key items that our power supply customers are supporting by participating in our power supply program,” explains Brandt. “This is one way in which our power supply customers are supporting the operations and mission of the Cape Light Compact.”
Sale of the Canal Plant
The first “foray” into this advocacy role happened in the late 1990’s when Massachusetts restructured the utility industry. This involved the sale of assets owned by the local electric utility provider, including the Canal Generation Plant, and how those proceeds would be allocated or credited to customer bills, raising the question of if they would be allocated more heavily to the legacy Cambridge Electric Company service territory, or to the legacy Commonwealth Electric service territory, which includes the Cape and Vineyard. The DPU sided with the Compact on the allocation of the sale proceeds, resulting in $25 million in savings to Cape and Vineyard customers. Since then, the Compact has worked to continue to keep rates competitive and maintain a watchful eye on proposals that can affect their customers.
In 2012 the DPU issued several orders regarding the modernization of the electric grid. They ordered each electric utility provider to file grid modernization plans to meet certain objectives. In 2015 utilities filed their plans, including the utility that serves the Cape and Vineyard.
“The Compact was heavily involved in the review of that plan,” says Brandt. “There were several elements of their grid modernization plan that the Compact took issue with, and we argued those positions in front of the DPU.”
The grid modernization proceeding was a complex and intricate filing. One of the outcomes of the process was that the DPU did not approve the utility’s proposal to roll out advanced meters on a smaller, opt-in basis, which would require customers to take affirmative action if they want an advanced meter, and would have required them to buy their electricity supply from the utility. The Compact argued against this proposal and advocated for rolling out advanced metering infrastructure on an opt-out basis. Though the DPU did not approve the deployment of advanced metering on an opt-out basis, they did reaffirm their commitment to the widespread deployment of advanced metering. From here, the DPU will start another proceeding specifically to investigate the deployment of advanced metering structure, which the Compact plans to take part in.
Rate Case Intervention
The second major issue came about in 2017 when the regional electric distribution company filed its first fully litigated rate case since 1986.
“They had several problematic proposals in there; they wanted a 10.5% return on equity, they wanted to impose demand charges on solar customers, and they wanted to shift costs from western Massachusetts to eastern Massachusetts. The Compact argued against several aspects of the rate case in that proceeding, which wrapped up at the end of 2017, and we’re following the related proceedings that are still going on”, explains Brandt. The Compact’s participation in the rate case helped save Cape and Vineyard customers approximately $8 million.
These consumer advocacy efforts have saved the Compact’s customers millions of dollars. According to Downey, consumer advocacy is an unsung hero. It can be challenging to get customers engaged on these issues and get the word out, but the Compact continuously posts information to its website, holds public information sessions when possible, and continues to encourage people to get involved.
“It’s not always visible – because these are all regulatory proceedings, we’re not always successful, but our efforts have resulted in significant savings on ratepayers’ bills. We have had a significant impact over the years. For customers who want to learn more about what we’re doing, this information is always discussed at open meetings every month and is posted on our website,” notes Downey, and she adds that they are always looking to improve their engagement strategy.
If you’re interested in learning more about the consumer advocacy efforts at the Compact, subscribe to the Compact’s e-newsletter to stay up to date on current discussions or visit the consumer advocacy page.