STATE OF NEW YORK PUBLIC SERVICE COMMISSION _______________________________________________ Proceeding on the Motion of the Commission as to the Rates, Charges,

Rules and Regulations of Niagara Mohawk Power Corporation d/b/a National Grid _______________________________________________ Cases 12-E-0201

Petition of Niagara Mohawk Power Corporation d/b/a National Grid for Approval of Certain Customer Assistance Programs on an Emergency Basis I. Introduction This past winter, customers within the service territory of Niagara Mohawk Power Corporation d/b/a National Grid (National Grid or the Company) experienced severe and pervasive winter weather resulting in one of the coldest winters on record in Upstate New York. These abnormally cold temperatures resulted in dramatically increased wholesale electric commodity prices, which, in turn, increased customers bills.1 Specifically, electric market prices in January, February and March were 122 percent higher than the previous year. At the end of January, the Commission approved the Companys request to defer collection of approximately $32 million of electric costs from residential and small commercial customers affected by increased electric commodity prices to help mitigate customer bill impacts.2 In addition, the Company developed and implemented a comprehensive outreach and education program to help customers manage winter bills. This outreach has been led in part by the Companys Consumer Advocates, who have also provided direct one-on-one assistance and counseling to low income customers. The Company also promoted its alternative payment

Commodity prices are dictated by present market conditions. The Company has no control over market prices and merely passes commodity costs through to its customers. 2 Case 14-E-0026, Petition of Niagara Mohawk Power Corporation d/b/a National Grid for Waiver of Tariff Rule 46.3.2, Order Granting Request for Waiver (issued and effective January 28, 2014). Specifically, the Company deferred electric supply costs under Rule 46.3.2 to be recovered from customers at a later date.

options, such as the budget billing program, which allows customers to spread utility costs over the course of the year in equal payments to eliminate monthly bill variances. However, despite significant delivery bill decreases in 2012 and 2013 and the Companys efforts to mitigate electric commodity bill impacts this winter, many customers within the Companys service territory are still struggling to recover from the financial impact of the increased commodity prices and, as a result, are facing hardship. The Company proposes two new emergency low income customer assistance programs (collectively referred to hereinafter as the Emergency Customer Care Programs) to provide incremental assistance to its most vulnerable customers, which will be funded utilizing existing deferred credit balances. In

addition, the Company will provide a corporate contribution of $1 million to reopen its Care and Share program to provide further financial assistance to qualifying customers. Accordingly, the Company respectfully requests that the New York State Public Service Commission (Commission) approve the Emergency Customer Care Programs as described herein on an emergency basis. II. Background and Discussion To assist all customers in managing their electric and gas bills, the Company hedges commodity prices to reduce market volatility, offers budget billing plans and educates customers on energy efficiency solutions. To further assist its most vulnerable customers, the Company provides financial assistance to its low income customers through various programs. This winter, the Commission approved the Companys petition to mitigate bill impacts for electric residential and small commercial customers and froze the sum of the February per kWh delivery and supply charges at January levels.3 During this time, the Company increased its outreach to customers through a variety of communications channels, including webinars, media outreach,
3

Id. at 5.

bill messages, updates on Facebook and Twitter and direct emails to provide background, actions and solutions. The hardship created by the increase in commodity prices this winter has been most significant for low income customers and the Company believes that further assistance is warranted. The existing low income programs, however, do not provide the needed flexibility or funding to address immediate needs. Accordingly, the Company intends to reopen the Care and Share Program and proposes to implement the Emergency Customer Care Programs detailed in Section B below. A. Care and Share Program

To help alleviate the financial burden on its low income customers, the Company will make a corporate contribution to reopen its Care and Share Program to assist customers facing disconnection as a result of unpaid bills. National Grids shareholders will fund the program with a $1 million contribution. The program will be available to electric customers who are HEAP eligible and have an arrears balance on their National Grid bill. The Company anticipates that approximately 6,000 customers may qualify for this program. Funds will be available on a first come, first serve basis and will be capped at $1 million, which is inclusive of administrative costs. Customers who do not receive incremental arrears forgiveness under the program

described in Section B(1) below will be eligible to receive a credit on their bill of up to $250.00. Customers who receive incremental arrears forgiveness under that program will be eligible to receive a credit of up to $100.00 under this program. This program is contingent upon the Companys partnership with HeartShare and the organization has agreed to administer this proposed program. Customers interested in receiving the Care and Share funds must apply directly to HeartShare.

B. Proposed Emergency Customer Care Programs The proposed Emergency Customer Care Programs are as follows: 1. Incremental Arrears Forgiveness Program The Company proposes to provide one-time incremental arrears forgiveness of $250.00 to qualifying customers in their May 2014 bill or as soon as practicable. Specifically, customers enrolled in the AffordAbility Program as of April 4, 2014 will receive the incremental arrears forgiveness and the Company anticipates that approximately 4,000 customers will benefit from this program.4 The Company therefore estimates the costs of this program to be approximately $1 million. Currently, there is a regulatory liability of approximately $2 million associated with the Companys AffordAbility program. The Company proposes to fund this emergency

assistance program utilizing up to that deferred credit balance.5 2. Incremental Low Income Discount Program (Customer Bill Credits) The Company proposes to provide a one-time incremental $20 credit to electric customers enrolled in the Low Income Discount Program during March 2014. The credit would be applied to eligible customers May 2014 electric bills or as soon as practicable.6 The

Company anticipates that approximately 110,000 customers will be eligible for this credit. The Company therefore estimates the costs of this program to be approximately $2.2 million.
It should be noted that the incremental arrears forgiveness will not be displayed as a separate line item on customer bills, but rather will be reflected as a Miscellaneous Credit on the bill. The Company will notify customers of the arrears forgiveness through a message on the bill. 5 Absent approval to use the credit balance for the Emergency Customer Care Programs, the balance would be used as additional funding for the AffordAbility Program in future years. See Cases 12-E-0201 and 12-G-0202, Proceeding on the Commission as to the Rates, Charges, Rule and Regulations of Niagara Mohawk Power Corporation d/b/a National Grid, Joint Proposal (approved March 15, 2013), at 33-34 (The Company will have no obligation to spend in excess of the annual rate allowance unless and until the Commission authorizes the Company to defer additional amounts for future recovery. Any under expenditures will be deferred for future use in the AffordAbility Program.). 6 The incremental credit will not be displayed as a separate line item on customer bills, but rather will be reflected as a Miscellaneous Credit on the bill. The Company will notify customers of the credit through a message on the bill.
4

Currently, there is a regulatory liability of approximately $3 million associated with the Companys electric Low Income Discount Program. The Company proposes to fund this

emergency assistance program utilizing up to that deferred credit balance. C. Outreach and Education 1. Current and Continuing Outreach National Grid launched a comprehensive communications strategy targeted toward key stakeholders, including customers, community leaders and the media, to facilitate dialogue and increase understanding regarding the recent electric supply cost increases. The Companys goal has been to help key constituencies understand the root cause of increased commodity bills, what National Grid has been doing to help and how the Company can partner with customers to help them manage their bills. Outreach initiatives included the following: three regional webinars targeted to government and municipal leaders, social service agencies and Department of Public Service Staff; a series of direct customer emails targeted to residential and small commercial customers; Consumer Advocate outreach, including webinars, one-on-one customer counseling and partnering with key social service agencies; producing brochures for customer-facing employees, including field workers, who encounter customers with questions; and updating the Companys website to ensure that Help With Winter Bills is the first thing customers see on the Companys landing page. The Company has also reached out to customers through Facebook & Twitter, media outreach; interactive voice response (IVR) messaging, bill messages and inserts, fact sheets, and Q&As. During this outreach effort, customer service representatives were provided with enhanced

training to ensure they have the appropriate knowledge and tools to assist with customer inquiries. The outreach strategy has been continuously reviewed to ensure that customers and other stakeholders remain informed of issues that may impact their utility bills. 2. Expositions

The Companys Call Center and Customer Advocates received an unprecedented number of customer inquiries and referrals this past winter. To date, the Customer Advocates have participated in numerous outreach activities throughout Upstate New York designed to help customers understand and manage their electric bills. The Companys Customer Advocates have also helped low-income customers identify potential assistance programs and resources. While the Company is pleased with the success of these activities, it believes that more can be done to educate and provide assistance to customers in its service territory. The Company plans to continue its outreach efforts by holding a Customer Assistance Exposition on June 5, 2014 in Syracuse (Syracuse Expo). The Syracuse Expo is the first exposition of its kind initiated by the Company. The Syracuse Expo will provide an opportunity for low-income customers to learn about available assistance programs and meet with lowincome organizations in the area.7 The Company intends to host similar expositions in Albany and Buffalo at a later date. The expositions will provide information to assist customers in making educated decisions regarding available programs and their future energy usage.

The Company anticipates that the following organizations may take part in the Syracuse Expo: the Department of Social Services (DSS), the Home Energy Assistance Program (HEAP), the Supplemental Nutrition Assistance Program (SNAP), the Office of Aging, NYSERDA, the Central New York Food Bank, Catholic Charities, Literacy CNY and the Syracuse Educational Opportunity Center.

III.

Request for Emergency Approval Pursuant to Article II, Section 202 (6a) of the State Administrative Procedures Act

(SAPA), the Company requests that the Commission waive the notice requirements of the SAPA and approve the Companys Emergency Customer Care Programs on an emergency basis as they are necessary for the public health, safety or general welfare. If approved, the Emergency Customer Care Programs will help customers offset the financial hardship experienced as a result of the increased winter electric bills. The Company requests waiver of the notice requirement because, without waiver, customers could wait months, as opposed to weeks, for much needed financial assistance. Specifically, the Company requests emergency treatment so that the incremental assistance can be applied to customers May 2014 bills, which are anticipated to reflect continued high electric supply prices and include a net charge for the reconciliation of March commodity costs. The Company anticipates that by June electric supply costs will be lower than during this winter. Further, the reconciliation of Aprils electric supply costs is anticipated to have less impact on customer bills in June. Thus, waiting beyond the May bills to provide the incremental assistance would be less beneficial for customers. Accordingly, the Company respectfully requests the Commission waive the relevant notice requirements. IV. Conclusion For the reasons set forth above, the Company respectfully requests that the Commission approve the Emergency Customer Care Programs described herein on an emergency basis. Please contact me with any questions regarding this filing.

Respectfully submitted, /s/ Kara J. Krueger Kara J. Krueger Associate Counsel Niagara Mohawk Power Corporation d/b/a National Grid 300 Erie Boulevard West Syracuse, New York13202 315-428-6611 kara.krueger@nationalgrid.com

VERIFICATION

I, Nancy Cianflone, Director of Program Development and Governance National Grid USA Service Company Inc., do hereby affirm that the contents of this document are true to the best of my knowledge.

Signed: /s/ Nancy Cianflone Date: April 17, 2014

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