DE 25-017

The main stakeholders in New Hampshire Public Utilities Commission docket DE 25-017 are:

- Public Service Company of New Hampshire (d/b/a Eversource Energy)
- New Hampshire Department of Energy (DOE)
- Community Power Coalition of New Hampshire (CPCNH)
- Office of the Consumer Advocate (OCA)
- Municipal aggregations/community power programs
- The Commission itself (as adjudicator)

Stakeholder positions on current proposals:

- Eversource: Proposing new energy service rates for August 2025–January 2026, based on RFP results and proxy prices, and deferring the $6.5 million large customer group reconciliation balance pending further adjudication 1 1.
- DOE: Supports Eversource’s current proposal not to include the $6.5 million under-recovery in rates effective August 1, 2025, and looks forward to reviewing the forthcoming order and engaging in further discovery on this issue 2.
- CPCNH: Supports the proposed procedural schedule for the current phase of proceedings 3.
- OCA: Did not object to the proposed procedural schedule and has not stated opposition to Eversource's rate proposal in the current record. During hearings, the OCA representative indicated acceptance of the proceedings and proposals as presented 3 2.
- Municipal aggregations: These programs are active in the Eversource service territory and their load migration is an expected factor, but no specific opposition or support for the proposals in this docket is recorded in the excerpts 4.

There is no evidence in the excerpts of any stakeholder opposing the current Eversource proposal regarding rate setting for August 2025–January 2026 or the deferral of the $6.5 million reconciliation balance. The DOE, CPCNH, and OCA either support or have no objection to the proposals currently before the Commission 3 2.

The docket identifies several areas of growth and related key considerations:

1. Increased Use of Competitive Wholesale Market Procurement
- Growth: Eversource has transitioned from using owned generation assets to competitively procuring energy service (ES) for customers, with increasing portions of its load sourced via direct market participation in the ISO New England (ISO-NE) wholesale markets.
- Key Considerations:
- The Commission has progressively directed Eversource to increase the share of its small customer group load and all of its large customer group load to be sourced through market-based self-supply (from 12.5% in 2024, to 30%, to 50% for small customers by 2025, and 100% for large customers).
- The process requires balancing competitive solicitation for the remaining load, ensuring compliance with regulatory orders, and reflecting wholesale market price dynamics in retail rates 1, 1.

2. Enhanced RFP (Request for Proposals) Processes
- Growth: Eversource’s RFP process for procuring energy supply has expanded, with broad distribution to potential suppliers and more transparent selection criteria.
- Key Considerations:
- The RFP was distributed to all New England Power Pool (NEPOOL) Markets Committee members and posted publicly.
- Selection criteria include price, supplier qualifications, creditworthiness, experience, and compliance with market rules.
- Winning suppliers for August 2025-January 2026 included Constellation Energy Generation, LLC and NextEra Energy Marketing, LLC, each serving 25% of the small customer group load 2, 3.

3. Changes in Rate Setting and Reconciliation
- Growth: The energy service rate structure for both small and large customers has become more sophisticated, employing weighted averages of contract prices, proxy prices for market-based supply, and regular reconciliation of prior period over- and under-recoveries.
- Key Considerations:
- Small customers receive a fixed six-month ES rate, while large customers have monthly variable rates based on market participation.
- For August 2025-January 2026, the small customer rate is increasing from 8.929 to 11.196 cents per kWh, reflecting both market and administrative factors.
- Regular review of line-loss factors and working capital requirements are mandated to ensure accuracy and fairness in rate calculation 4, 5, 2.

4. Renewable Portfolio Standard (RPS) Compliance
- Growth: Ongoing management of RPS obligations outside the ES procurement process, primarily through purchases of Renewable Energy Certificates (RECs).
- Key Considerations:
- RPS obligations and REC pricing are managed separately from the main energy supply RFP.
- Regulatory changes, such as the DOE’s 2024 order reducing Class III REC requirements, can significantly affect reconciliation balances and compliance strategies 3, 4.

Each of these growth areas is tied closely to regulatory compliance, cost management, procurement transparency, and adapting to evolving wholesale market conditions.

The main financial and timeline risks and concerns in this docket include:

Financial Risks and Concerns:
- There is a $6.5 million under-recovery balance for the large customer group, stemming from Eversource's over-reporting of hourly load data to ISO-NE for 58 large customers, which increased the aggregate load obligation for those customers on default service supply. The Commission has deferred any decision about re-allocating or recovering this balance, pending further proceedings, and ordered that no additional interest accrue on this amount. The resolution of this balance has been delayed due to uncertainty about its provenance and accounting errors by the company 1, 2.
- The current energy service rate filing does not include a proposal to re-allocate this $6.5 million, in line with the Commission's directive to address the matter in a subsequent proceeding. This creates uncertainty for cost recovery and potential impacts on customer rates in the future 2.
- There is an RPS (Renewable Portfolio Standard) expense projected over-recovery of $8.2 million, primarily due to a large beginning balance, but offset by current period under-recovery as expenses exceeded revenues. This leads to rate credits, but also reflects volatility in RPS-related costs and revenues 2.
- Working capital requirements and related carrying charges for energy supply and REC (Renewable Energy Certificate) purchases are incorporated into rates, which can be impacted by timing differences in revenue collection and expense payments. These are sensitive to operational and market timing risks 2.

Timeline Risks and Concerns:
- The adjudication regarding the $6.5 million under-recovery is ongoing, with filings and hearings deferred to a later phase. This means the issue will not be resolved or reflected in rates effective August 1, 2025, but will be the subject of future proceedings as scheduled by the Commission 1, 2.
- The Commission has approved a revised procedural schedule, with key deadlines for supplemental filings, data requests, technical sessions, and testimony running from August through October 2025, culminating in a hearing on October 23, 2025. The schedule supersedes any previous deadlines, but any delay or need for additional hearing time could affect when new rates or decisions become effective 3.
- The hearing originally scheduled for August 28, 2025, was cancelled and rescheduled for October 23, 2025, indicating adjustments to the timeline that could impact decision-making and implementation of new rates 3.

In summary, the principal risks are centered on delayed resolution of significant cost recovery issues, resulting rate uncertainty, and the potential for further timeline adjustments as the docket proceeds.

Key events and scheduled submissions in the Eversource 2025 energy service solicitation proceeding (NH PUC Docket DE 25-017) are as follows:

- May 6, 2025: The Community Power Coalition of New Hampshire (CPCNH) filed a late petition to intervene, granted May 22, 2025 1, 1.
- June 20, 2025: Eversource filed its petition to adjust energy service rates for effect on August 1, 2025, with supporting pre-filed testimony 1, 1.
- June 24, 2025: Hearing held regarding the August 2025-January 2026 rate period 1.
- July 17, 2025: Commission issued a supplemental order of notice, ordering a further phase to address reconciliation balance and related issues; set deadlines for interventions and procedural schedule proposal 2, 2, 2.
- July 25, 2025: Deadline for Eversource, with concurrence of other parties, to file a proposed procedural schedule 2, 2.
- August 1, 2025: Deadline for entities or individuals to petition to intervene 2, 2.
- August 8, 2025: Deadline for parties to object to petitions to intervene 2, 2.
- August 15, 2025: Commission decision on petitions to intervene (per procedural schedule) 3, 3.
- August 18, 2025: Eversource supplemental filing due 3, 3.
- August 22, 2025: New Hampshire Department of Energy to file updated position 2, 2.
- August 29, 2025: Parties’ data requests to Eversource due 3, 3.
- September 15, 2025: Data responses from Eversource due 3, 3.
- September 24, 2025: Technical session scheduled 3, 3.
- October 3, 2025: Parties’ testimony/technical statements due 3, 3.
- October 10, 2025: Technical session/settlement conference deadline 3, 3.
- October 23, 2025 (at 9:00 a.m.): In-person hearing scheduled (replaces the previously scheduled August 28, 2025 hearing) 3, 3.

Additional future events for the next default service rate period are proposed for late 2025, with a hearing requested for December 17, 2025, and service to begin February 1, 2026 4.

Docket DE 25-017 concerns the 2025 energy service solicitations for the Public Service Company of New Hampshire (PSNH), operating as Eversource Energy. The proceeding covers several key areas:

- Competitive procurement of energy service for PSNH/Eversource customers, with the process and schedule for solicitations, selection, and regulatory approvals specified. For the service period beginning August 1, 2025, PSNH will procure 50% of small customer group load through direct wholesale market participation and 50% through competitive solicitation, while 100% of large customer group load will be procured via direct wholesale market participation 1.
- Rate setting for the August 1, 2025 through January 31, 2026 period, including a proposed small customer weighted average fixed rate of 11.196 cents per kWh, up from the current 8.929 cents per kWh 2.
- Ongoing adjudication and reconciliation of a $6.5 million under-collection balance from large customers, with a review and re-allocation of this deferred balance part of the current docket per Commission orders 3, 4.
- All agreements for energy service remain subject to Commission approval, and PSNH/Eversource continues to be responsible for retail billing and customer service 1.
- The docket also addresses compliance with Renewable Portfolio Standard (RPS) obligations, which Eversource manages outside the energy service RFP process via renewable energy certificate purchases 1.
- Procedural schedules, hearing guidelines, and requirements for filing and serving documents are outlined, with hearings scheduled and modified as needed 5, 6.
- The docket includes a service list with the contact information for all parties involved and specifies notice and accessibility requirements for hearings 3.

In summary, Docket DE 25-017 sets the structure for Eversource’s 2025 energy service procurement, rate adjustments, regulatory compliance, and resolution of outstanding reconciliation balances.