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Memorandum in Opposition - S.6159-A/A.8798-A

This memo is submitted by Energy Coalition New York in opposition to the subject bill which would amend the Public Service Law to extend the net metering for farmers using farm waste electric generating equipment to non-residential customers such as food processors who would use such equipment.

Energy Coalition New York consists of New York State's major gas and electric utility companies: Central Hudson Gas & Electric Corporation, Consolidated Edison Company of New York Inc., National Fuel Gas Distribution Corporation, National Grid, New York State Electric & Gas Corporation, Orange and Rockland Utilities, Inc., and Rochester Gas and Electric Corporation. Coalition companies collectively employ more than 32,000 people, service more than 8.5 million customers and pay more than $3 billion in state and local taxes, assessments and fees. The member companies annually invest billions of dollars to make capital improvements to the electric and natural gas infrastructure located in New York State.

This bill represents a significant expansion of net metering by enabling food processors or other unknown commercial businesses who can afford to purchase farm waste electric generating equipment to take advantage of a net metering program targeted to farmers. This expansion would result in cost shifting with increased electricity costs for New York State's electric customers. The selected parties who take advantage of this bill would be paid for any excess electricity generated at the utility's full retail rate and these customers would also escape the tax and assessment obligations which ultimately would be borne by other customers. This subsidy would come at the expense of other customers who were not able to take advantage of farm waste electric generating equipment.

Legislation is currently pending which would study the implications of net metering cost shifting. It is respectfully requested that until the costs and implications of expanded net metering are fully understood, expansion of the current net metering statute should be held in abeyance. This legislation provides no specific rationale for its economic necessity nor its energy efficiency benefits. Without a specific justification which would require customers to subsidize specialized interests, there is no sound public policy reason to increase electric costs for electricity customers in New York State.

Based on the foregoing, Energy Coalition New York opposes the passage of the subject legislation.