Acadia Center Comments on D.P.U. Dockets 21-80, 21-81, 21-82 on Massachusetts Utilities’ Proposed Grid Modernization and Advanced Metering Infrastructure Plans

In May 2021, the DPU required each electric distribution company to submit an updated grid modernization plan, as well as a plan to achieve full-scale deployment of advanced metering infrastructure. On July 1, Eversource, National Grid, and Unitil submitted separate plans that included a ten-year grid modernization vision, a five-year strategic plan, and a four-year investment plan covering 2022-2025. If implemented successfully, these proposed plans will deliver significant benefits for customers and will enable critical energy system upgrades. However, Acadia Center is concerned that the proposed plans fall short in the following areas: 1) the proposed timelines for implementing time-varying rates (TVR) are far too slow, 2) by using an opt-in approach to TVR, the EDCs’ assumed customer participation rates are significantly lower than would be optimal to deliver the maximum possible benefits to customers 3) the AMI plans do not propose specific AMI deployment performance metrics, 4) the plans either make passing mention or no mention of environmental justice 5) the EDCs must prioritize data access for customers and third-party vendors. The EDCs should implement plans to ensure robust data access and transparency to support greater customer control of their usage and bills, as well as the ability of third-party providers to offer innovative programs and services.