Starting to work accounts in upstate New York served by National Grid and NYSEG. I submitted my standard LOA to National Grid and they came back saying it needs to reference the customer's right to designate a third party under the New York Public Service Commission regulations. Has anyone dealt with this? Do I need to cite a specific PSC rule number in my LOA?
New York utilities and the PSC — does the LOA need specific language?
Yes, New York utilities are particular about this. National Grid and Con Edison both want LOA language that references the customer's right under 16 NYCRR to authorize a third-party agent. I don't remember the exact section number but if you call National Grid's commercial team and ask for their preferred third-party authorization language they'll give it to you. Once I added that paragraph to my NY-specific LOA template I never had another rejection.
NYSEG was easier for me than National Grid. They accepted a generic LOA without any PSC citation. But I was working through their parent company Avangrid's commercial portal which may have streamlined things. Central Hudson is another one in the Hudson Valley area that has their own specific form. New York in general is more regulatory-heavy than most states when it comes to third-party access.
Each state has its own regulatory framework that affects how utilities handle third-party authorizations. New York, California, and Texas tend to be the most prescriptive. I recommend keeping state-specific LOA templates for any state where you do regular work. The upfront investment of customizing your LOA to meet each state's regulatory language saves significant time on every subsequent engagement in that state.
Update — called National Grid and got the exact language they want. Added it to my template and they processed the LOA in four business days. Now I have a New York template that works for Grid and most other NY IOUs. Thanks for the guidance everyone.