considered and adopted for each utility. The guidelines include considerations of the needs of customers regarding understanding, acceptance, preferences, and other similar factors (at Guideline 9). 2. Customer Impact: CforAT participation at the February Verified CforAT’s focused our participation on 26, 2016 workshop is memorialized in the potential impacts of the Final Decision at page 9. changes to time periods for use Guideline 9 of the adopted policy in future TOU rates on guidelines strongly reflects the concerns vulnerable customers. At the articulated by CforAT regarding TOU workshop held on February 26, periods and rate design, particularly as 2016, CforAT gave a applied to vulnerable customers. The presentation stressing the need decision addresses input on CforAT’s for TOU rate design that is Guideline 9, agreeing with CforAT that simple in order to promote requirements continue various “statutory customer understanding and to apply to and noting that rates,” acceptance. These concerns nothing in the final decision “overrides were accepted by the the protections and rate design Commission and discussed at requirements adopted, or to be adopted, some length in the PD; they in R.12-06-013 for residential were also incorporated into Final Decision at pp. customers.” Guideline 9 of the Policy The final decision also agrees with Guidelines Applicable to the position that residential CforAT’s Design, Implementation and customers will need a simpler rate Modification of Time-of-Use design than larger, more sophisticated (TOU) Periods to be Used in customers. Id. Rate Designs (attached as Appendix 1 to the decision). The final decision also agrees with the significance of concerns, set out in CforAT’s Comments on the Proposed Decision (filed on November 21, 2016), though it found that recommended modifications to the language of the decision were not necessary to reinforce the significance of customer protections.
considered and adopted for each utility. The guidelines include considerations of the needs of customers regarding understanding, acceptance, preferences, and other similar factors (at Guideline 9). 2. Customer Impact: CforAT focused our participation on the potential impacts of changes to time periods for use in future TOU rates on vulnerable customers. At the workshop held on February 26, 2016, CforAT gave a presentation stressing the need for TOU rate design that is simple in order to promote customer understanding and acceptance. These concerns were accepted by the Commission and discussed at some length in the PD; they were also incorporated into Guideline 9 of the Policy Guidelines Applicable to the Design, Implementation and Modification of Time-of-Use (TOU) Periods to be Used in Rate Designs (attached as Appendix 1 to the decision). The final decision also agrees with the significance of CforAT’s concerns, set out in Comments on the Proposed Decision (filed on November 21, 2016), though it found that recommended modifications to the language of the decision were not necessary to reinforce the significance of customer protections. CforAT’s participation at the February 26, 2016 workshop is memorialized in the Final Decision at page 9. Guideline 9 of the adopted policy guidelines strongly reflects the concerns articulated by CforAT regarding TOU periods and rate design, particularly as applied to vulnerable customers. The decision addresses CforAT’s input on Guideline 9, agreeing with CforAT that various “statutory requirements continue to apply to rates,” and noting that nothing in the final decision “overrides the protections and rate design requirements adopted, or to be adopted, in R.12-06-013 for residential customers.” Final Decision at pp. The final decision also agrees with CforAT’s position that residential customers will need a simpler rate design than larger, more sophisticated customers. Id. Verified
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