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Shock: Texas REPs Say TDUs Should Handle Some Billing in Texas Market The one-time fee for any opt-out of advanced metering granted to and exercised by Texas electric customers should be billed by the transmission and distribution utilities, not retail electric providers, a group of REPs said in comments to the Public Utility Commission of Texas.
Once electric service has been established, the REP acts as the exclusive billing agent in the Texas market (as noted below, certain construction charges are billed by the TDU). Indeed, outgoing Direct Energy President and CEO Chris Weston devoted a keynote address at last week's DNV Kema retail energy executive forum to the importance of the retail provider owning the customer bill.
The REP Coalition also said that TDUs should handle communication with customers concerning technical aspects of the opt-out request, while the REP would be involved with communications regarding the opt-out's impact on the customer's retail electric product.
"The REP Coalition maintains that customers should communicate and interact with the entity that is in the best position to answer questions and provide the service needed to facilitate the customer's opt-out request. Keeping with this fundamental premise, the TDU should be required to fulfill those customer communication and interface requirements related to the technical aspects of the opt-out request because effectuation of the request will involve the TDU's metering equipment and service performance. The REP, in turn, should be required to fulfill those communication and service requirements relating to the impact an opt-out request may have on the retail product in which the customer is currently enrolled and retail electric contract for such service," the REPs said.
"As an initial matter, the TDUs would be best suited to fulfill the communication and service requirements relating to the technical aspects of an opt-out, which would include explaining to the customer that an opt-out would involve modifying the communications function on the advanced meter. To date, the TDUs have served as the primary contact for customer questions about the installation of advanced meters. In each of the TDU advanced meter deployment dockets, the Commission allowed the TDUs to recover specific levels of expenditures for customer education purposes," the REPs said.
"The current Tariff supports the approach advocated by the REP Coalition here," the REPs argued. "It allows an end use customer to contact the TDU directly regarding the '[i]nstallation of non-standard facilities.' Disabling the communication capabilities of an advanced meter would in effect render that device 'non-standard'".
Similarly, the REP Coalition said that the Tariff supports requiring the TDU to directly bill the customer the one-time fee required to effectuate an opt-out request. "This direct billing of the one-time charge can be done similar to the manner used in the market today for construction charges," the REPs said.
However, if the Commission determines that the TDU should not be required to directly bill the one-time fee to the customer, "REPs must be adequately protected from the risk of non-payment," the REPs said.
The REPs also opposed a written verification proposed to be required for any opt-out, which would affirm the customer understands various consequences of their decision, such as potentially longer outage restoration times. "Obtaining this written acknowledgment from the customer would be difficult from an administrative perspective and may delay completion of an opt-out request due to the customer's own dilatory action. It is also unnecessary because the customer's informed request to opt-out after the receipt of pertinent information and payment of the one-time fee would serve as the customer's affirmation to obtain a non-advanced meter. However, to the extent the rule retains this acknowledgment requirement, the REP Coalition believes the TDU -- and not the REP -- should be required to obtain the acknowledgment from the customer," the REPs said.
In contrast, a group of TDUs said that the proposed rule, "strikes the proper balance by designating the retail electric provider ('REP') as the customer's point of contact for purposes of an opt-out election."
"The REPs have existing direct relationships with retail customers, and the REPs already have informational duties with respect to those customers, so the notifications required by the proposed rule will not impose any material additional burden on the REPs," the TDUs said.
"In contrast, the TDUs do not know -- and have no way of knowing -- which pricing plan a customer is on or what existing contractual obligations the customer may have to his or her REP. Inserting the TDU into the middle of this relationship would be inefficient and confusing to the customer. Stated otherwise, the REP is the only entity able to communicate advantageous customer pricing offers made possible with the AMS meter, and the REP is the only entity that understands the customer's current contractual agreement, including potential early termination fees. The Texas market was designed with the REP being the primary entity responsible for interacting with the customer regarding retail service, and this structure has proven to be successful," the TDUs said.
Texas Legal Services Center and Texas Ratepayers' Organization to Save Energy agreed that the REP should handle opt-out requests. "Under the current market structure the REP is responsible for communicating with the customer. All REPs should have customer service staff with knowledge of the meters being installed. The REP can communicate the customers service preference to the T&D as they do for all other discretionary services," TLSC and Texas ROSE said.
Docket 41111
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