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Texas REPs Express Concerns With Implementation of System-Wide Rates At Sharyland, Seek Detailed Plan

March 1, 2017

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Copyright 2010-17 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

In testimony in Sharyland Utilities' rate case to implement system-wide rates across its Cap Rock and McAllen territories, retail energy provider stakeholders raised certain concerns with the transition, and asked that the Public Utility Commission of Texas require the utility to adopt a detailed implementation plan

Testimony filed on behalf of NRG, the Alliance for Retail Markets, the Texas Energy Association for Marketers, and TXU Energy said that implementing system-wide rates, "necessitates certain operational considerations beyond a routine rate update."

The REP stakeholders raised concerns about any transition in the DUNS numbers, banking and tax identification information, and ESI IDs.

"Sharyland most likely will need to conduct flight testing at ERCOT in order to ensure that transactions continue to process as expected and at the approved rates following the transition," the REP parties said

Furthermore, the REP parties noted that Sharyland has proposed a new Optional Rate Structure for Churches that would provide relief for religious facilities with high demand and low energy usage. "Eligibility requirements and enrollment processes have yet to be provided and must be determined," the REPs said

The REP parties also noted that the current McAllen tariff does not make a distinction between non-residential customers placed in the secondary customer class based on demand, noting that all of these customers will be reclassified upon transition

The REPs noted that McAllen customers, as a result of the movement to system-wide cost-of-service rates will see a 60% increase in TDU costs (see story here)

"Based on my experience with the initial rate impacts of a transition to cost-based rates when the current SBC [Cap Rock] Division was opened to competition in 2014, increased end-use customer inquiries are expected with such a dramatic rate increase," the REPs' witness said

Accordingly, "it is vitally important for the transition to be conducted in a manner that ensures customers are not subject to incorrect and/or delayed billing, billing corrections, and overall confusion regarding applicable rates and classification changes. This is even more important given the expected financial impacts of Sharyland's proposal on certain customers," the REPs said

The REPs proposed that Sharyland be required to undertake the following actions to ensure a smooth transition:

• Provide timely notice to each customer and the customer's REP Of Record prior to the reclassification of secondary customers in the current Sharyland-McAllen service area. Thirty days prior to any such reclassifications, Sharyland should provide each affected REP of Record a list of affected customers by ESI ID and identify the receiving customer class for each under the system-wide standard tariff.

• Provide timely notice of eligibility to each customer and the customer's REP of Record for each premise eligible for the Optional Rate Structure for Churches. Sharyland should provide the REP of Record timely notice for any customer who enrolls in the subclass.

• Provide proactive customer outreach and education for customers in the current Sharyland-McAllen service area including, but not limited to door hangers and a website regarding the implementation of system-wide rates and possible changes to rate classes for certain customers

• Set the implementation date for any new rates to be the later of: September 1, 2017, or 45 days after the approval of a compliance tariff reflecting rates adopted under the final order in the rate case docket

• Identify all REPs that must complete flight testing to enable continued operations in the Sharyland service area upon the implementation of system-wide rates. Sharyland should then provide notice of the need for this flight testing to those REPs no later than June 1, 2017 in anticipation of the sign-up deadline for the second scheduled ERCOT flight test of 2017, the REPs said

• Schedule a series of market participant forums between the adoption of a final order in the rate case docket and the date for implementation of system-wide rates to address questions and updates

• Delay the transition of DUNS and conversion ESI ID formatting to a date after the initiation of system-wide rates. Should Sharyland move to consolidate DUNS or ESI IDs in the future, it should seek approval of any such actions through a compliance filing at the Commission, and initiate any approved changes concurrent with the beginning of a calendar year, and commit to reflecting any related costs savings in rates.

Docket 45414

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