FTC Staff Reply Comment Before the State of New York Public Service Commission in the Reforming the Energy Vision Proceeding, Responding To Third-Party Comments on the NY PSC Benefit-Cost Analysis

The FTC staff submitted a reply comment to the New York State Public Service Commission (NY PSC) regarding that agency’s Reforming the Energy Vision (REV) proceeding. The FTC staff comment recommended that the principles set forth in the NY PSC Staff White Paper on Benefit-Cost Analysis (Staff BCA) recognize how customers can benefit from a greater ability to match the electric services they receive to their preferences among such services. The comment also noted that the principles need to take into account a broader spectrum of benefit and cost criteria, such as service quality, customization of services to match customer preferences, and the effects of increased competition on price. It also suggested that the Staff BCA include sensitivity analysis to allow electricity distributors and the NY PSC to respond appropriately if future technological, economic, and environmental conditions differ from conditions that the Staff BCA currently anticipates.