I am Rachael Gutierrez speaking on behalf of Adam Friedman, Director of the Pratt Center for
Community Development. I applaud the Public Service Commission for its efforts to plunge into such a
broad rethinking of how energy services are delivered in New York and how to create a utility structure
that will encourage a clean energy future. I am particularly excited by the emphasis on facilitating
distributed generation so that communities can have both greater powers to decide and implement
their energy future. It is imperative that we transition to clean technologies that reduce climate
change inducing emissions as quickly as possible and everyone has a role to play in this process.
With this in mind, it is vital that we ensure the PSC proceedings and process for developing the REV is
inclusive for all New Yorkers and is undertaken in a clear and transparent manner. It is critical that
communities from the Upper East Side to Brownsville and across New York State are engaged and
considered equal participants in the distributed generation marketplace. And it is important that as
ESCOs are formed to work with communities across New York, regulations are in place to ensure
consumer protections.
Specifically the Pratt Center calls on the PSC to consider the following:
• Communicate the goals of REV in a more accessible and clear manner. The REV intends to be
transformative. The operations, financing and adoption of new technologies for the utility
system are complicated subjects. But this should not prohibit concerted efforts from being
made to ensure all participants in the marketplace can understand the underlying goals and the
strategic decisions necessary for implementation, and what the final outcomes of REV looks like
for energy consumers. A clear example of the accessibility issue is highlighted in the process of
signing up for email updates from the PSC website. This should be the easiest first step for
interested parties, yet the multiple registration steps make it exceedingly difficult to access the
desired information. The registration process is used as a very simple example of how
complicated this process is. Pratt Center asks that the PSC find a simplified approach to
communicating REV’s goals and expected impact.
• Engage Low and Moderate Income and Environmental Justice communities in an equal
manner to other communities. Currently REV predicts that these groups will not be equally
engaged by the marketplace and places the onus on NYSERDA to ensure they have access to
clean energy. Although they may face alternate challenges to implementation, and NYSERDA’s
support will be needed to break down certain barriers, it should not be presumed that they
cannot be active participants in this new utility model. Doing this ignores the ability that
individuals and community organizations within LMI/EJ communities have to educate and
empower their local businesses and neighbors to engage and participate as partners in a
distributed generation marketplace. Rather than presuming that these communities are unable
to develop innovative market solutions that support ownership models within their
neighborhoods, the PSC should ensure that the LMI/EJ communities have the tools they need
to be equal and active partners in the energy future.
• Ensure consumer protections are in place through the regulation of ESCOs. REV states that
ESCOs will be allowed greater access to information about customer energy usage, along with a
much more active role in supporting customers with their energy needs. Since education and
support will be important components ensuring REVs success, it makes sense that a new
marketplace for expanded services is needed. However, even within the current framework of
ESCO’s engagement of end-users, many times business owners feel pressured and harassed by
ESCOs. Conversely, residential consumers that want to be more energy efficient and pursue
clean DG often want to disclose their household energy information, but face bureaucratic
hurdles in obtaining or releasing it. It is important that consumers are both aware of the new
marketplace prior to being approached by ESCOs, that appropriate protections are created to
safeguard consumers when engaging with ESCOs, along with clear protocol on when and how
ESCOs can access and use customer information that protect consumers who want protection
but that facilitate the release of information for consumers who want to reduce their
consumption.
We acknowledge the visionary nature of the REV concept and understand that the process still has a
long ways to go. As these proceedings continue, we look forward to seeing a clearer, more transparent
and accessible process, resulting in a modern, efficient, environmentally responsible utility system that
sees all end users as important and equal.
Thank you for your consideration of our comments.