Since they asked, I sent in the following response to Forest City:
Mr. Nii,
I acknowledge receipt of this. While I am glad to see that further analysis will happen, I do not believe that the proposed testing methodologies are logical, nor am I surprised (based on historic weather patterns) that a significant number of people moved from in-buffer to above-buffer.
There are multiple flaws in the new methodology. One is that for many residents, they will be potentially using data from previous residents, rather than their own. At least in my neighborhood, there are significant differences in the number of people that live in a home, varying from two to seven people, which is why there is often a wide swing in electrical usage. Comparing it on a month to month basis is fair, but pulling in historical data pits you against a previous resident who may have only had two people in a home. The second is that there is an assumption that the weather conditions last year are similar to this year. Barring an argument for global warming, weather fluctuates on at least a three year cycle, something the new methodology doesn't take into account.
I would hope that instead of punishing residents with twisted ways of squeezing more money out of them, perhaps we could focus on installing more solar panels, improving the insulation on windows and door seals, and encouraging residents to turn off inductive electrical devices (such as cable boxes and WiFi routers) at night when they are not being used. The recommendations for water heater settings should also be reviewed, as they are wasteful for all but the largest families. I would be happy to assist in those efforts, since they might actually make a difference and help families not have to pay extra on their electrical bill.
I did receive a "Thanks for your reply!" email, but I doubt that anything will happen. My prediction is that Forest City will delay and hope this blows over as older residents cycle out and new ones arrive. At the very least, someone Googling around will find this and realize this problem isn't new.
