Client: Environmental Defense Fund (EDF) and Conservation Law Foundation (CLF)
Author: Joshua R. Castigliego
March 2024
On behalf of the Environmental Defense Fund (EDF) and Conservation Law Foundation (CLF), Researcher Joshua R. Castigliego provided expert testimony before the Massachusetts’ Department of Public Utilities (DPU) in response to National Grid’s petition to increase its base distribution rates and approve its proposed performance-based ratemaking (PBR) plan, referred to as its Comprehensive Performance and Investment Plan (CPIP). In his testimony, Mr. Castigliego specifically focused on the Company’s Infrastructure, Safety, Reliability, and Electrification (ISRE) Mechanism and performance incentive mechanisms (PIMs, including investment-based “IPIMs” and operating-based PIMs) included in its proposed CPIP. He also addressed National Grid’s proposed electrification pricing option and low-income discount rate proposal.
Based on these assessments, Mr. Castigliego found that the Company’s proposals on these topics were insufficient and should either be rejected or strengthened by DPU to better protect ratepayers and address the affordability challenges facing the National Grid’s customers. Mr. Castigliego also offered recommendations on these topics to better align National Grid’s proposals with the Commonwealth’s climate and clean energy goals and support a more equitable distribution of benefits resulting from the Company’s investments and programs