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Texas Retail Provider Says Eliminating HAN Functionality Would Stifle Innovative Products, Real-Time Billing, Controllable Load

July 9, 2018

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Reporting by Paul Ring • ring@energychoicematters.com

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GridPlus, a start-up retail electric provider newly certificated in Texas (see story here), has opposed a motion for rehearing filed by the joint Texas utilities concerning revisions to Smart Meter Texas (SMT), as GridPlus said the elimination of home area network (HAN) functionality would stifle product innovation.

The Texas PUC's final order in the proceeding granted a waiver of the requirements of 16 TAC § 25.130(g)(1)(J) with respect to SMT on the basis that there is an adequate substitute for HAN functionality, and denying the utilities' motion for rehearing, in and of itself, would not disturb this already granted waiver

However, the PUC in its final order adopted, with modifications, a settlement among various parties (including the utilities) in the case. Via a rehearing request, the utilities have sought clarifications concerning such modifications, including those related to the HAN waiver. The utilities have asked that if such clarifications are not granted, that the Commission vacate the order and return the case to SOAH. The utilities also said it is unknown whether any party would withdraw from the stipulation due to the modifications, if the requested clarifications are not granted on rehearing. Therefore, denying rehearing could result in the HAN issue being further adjudicated.

"GridPlus, a newly certified REP planning to utilize smart meter technology to provide innovative service offerings, urges the Commission to deny the Motion for Rehearing for the reasons expressed below," GridPlus said in its filing with the PUC

"GridPlus has not been involved in this proceeding, not due to any level of disinterest, but rather because it was not formed as a corporate entity until December 22, 2017, thus it was not in a position to intervene. At this time, however, GridPlus is concerned about the implications that would occur if the Motion for Rehearing was approved, therefore, GridPlus respectfully requests the Commission not adopt the Motion for Rehearing," GridPlus said in its filing

"If the Commission grants the Motion for Rehearing and amend[s] the Commission's Order in this docket it will completely eliminate the Joint Utilities' obligation to provide HAN functionality, whether through SMT or the Joint Utilities' advanced meter systems. And without HAN functionality, the wireless connectivity of smart meters via ZigBee and the like will end," GridPlus said in its filing

"Granting this complete waiver of HAN would cause severe unintended consequences to the ERCOT market and will prevent existing REPs and new entrants, like GridPlus, from offering new products that rely on real-time usage data. Entirely removing HAN will make the ERCOT market substantially less appealing for those who want to build robust, distributed grid infrastructure that will benefit all market participants, including end-use customers. Additionally, granting the Motion for Rehearing will result in smart meters becoming 'not so smart meters' eliminating much of the potential smart meters are just now beginning to realize due to advances in synergistic technologies. By eliminating the direct, two-way communication functionality between the customer (or their REP) and their utility's meter, the smart meter will no longer be able to accomplish many of the tasks for which the smart meters were originally purchased and deployed," GridPlus said in its filing

"GridPlus believes this would stifle the market's progress because it would make it impossible for REPs to offer new products such as real-timing [sic] billing and controllable load resource participation. Because of this, GridPlus respectfully requests that the Commission deny the Motion for Rehearing and clarify that the granted waiver will not go into effect until such time that SMT 2.0 or other new deployments provide a truly adequate substitute for HAN. An adequate substitute for current SMT functionality, including HAN, must be created and deployed before HAN is eliminated and an adequate substitute would be better formulated during a formal rule making proceeding," GridPlus said in its filing

"Granting the Motion for Rehearing, which would effectively remove the two-way connectivity of all smart meters, would be contrary to the legislature's intent in authorizing the purchase and deployment of the smart meter technology and the PUC's operational vision for the advance meter system. Both the legislature and the PUC understood the importance of more granular data (15-minute interval data) and they also understood the importance of making this data available in real-time. This is why these two concepts were memorialized in the law and in subsequent PUC rulemakings," GridPlus said in its filing

"Many of the smart meter features and benefits contemplated require that usage data be measured in 15-minute intervals and that the usage data be made available in real-time. For example, a smart meter cannot communicate with '...devices inside the premises, including but not limited to: usage monitoring devices, load control devices, prepayment systems, [or real-time payment systems]' if there was no way to wirelessly connect to the smart meter to collect interval data in real-time," GridPlus said in its filing

"As HAN functionality currently exists today under 16 TAC §25.130(g)(1)(J), it can provide energy usage reads every minute or less, wirelessly, through ZigBee technology and the like and through the distributed network of advanced meters currently deployed, totaling over 7 million. These advanced meters can also provide energy usage reads directly to the customer or its REP instead of back to through the TDU's systems, which is what SMT 2.0 would do. The HAN functionality today is fully capable of supporting all of the features and benefits the legislature and the PUC envisioned," GridPlus said in its filing

"As GridPlus currently understands the settlement stipulation between the parties, it will result in the creation of SMT 2.0 which will be a central database controlled by the Joint Utilities, it will produce a maximum of two on-demand reads per hour per ESIID, 24 on-demand reads per day per ESIID and then process 3,000 total on-demand reads per TDU per day subject to network traffic, including but not limited to market orders, interval data collection, planned and unplanned outages. This means a REP will have one point of connection to the meter data instead of over 7 million independent connections; one meter read every 30 minutes instead of every minute or less; and, a maximum of 3,000 usage requests per day per TDU instead of near unlimited requests. GridPlus does not believe this is an adequate substitute. The replacement of current HAN functionality with SMT 2.0 will remove the support mechanism (wireless connectivity) for many of the envisioned smart meter features and benefits and with it being a centralized system, it will fail to support the same number of users that can be served by the currently implemented system," GridPlus said in its filing

"Further, the costs of a centralized system to attempt to provide HAN-like capabilities will be an additional cost borne by all market participants. In the current HAN-enabled system, any access to real time data, storage and bandwidth costs will be entirely borne by the REP. This is a more scalable and equitable design, and it is already in place and paid for," GridPlus said in its filing

"The Order is also unclear as to when the Joint Utilities obligations to support HAN will be eliminated. Without clarification as to this timing, the market could end up being in a situation where the adequate substitute is not yet deployed but the HAN requirement has been waived. So, there is a possibility that there will be no HAN functionality or SMT 2.0 functionality until January 2020, or later," GridPlus said in its filing

"Further, [t]he Joint Utilities have also argued '...that the popularity and potential usage of HAN...have not materialized,' This is due to multiple outside factors. First, for end-use customers, SMT has been difficult to set up and use and, second, the technology needed to gather the data through the HAN (i.e., through ZigBee and the like) and then to take action to curtail load based on market conditions has not existed. GridPlus has spent significant engineering resources to develop that technology and it wants to use that technology to bring products supported by the delivery of usage data in real-time in the ERCOT market. GridPlus is confident that more technology will be developed in the future if the current HAN functionality remains in place or an adequate substitute is actually implemented," GridPlus said in its filing

"For all of these reasons above, GridPlus respectfully requests that the Commission deny the Motion for Rehearing and require the Joint Utilities to continue with their HAN obligations until an adequate substitute is created through a formal rule making proceeding, and then completely deployed. If the Commission denies the Motion for Rehearing and directs Staff to open a rule making proceeding, GridPlus commits to participate in the proceeding and use its utmost good faith with all parties concerned to reach agreement on the business requirements," GridPlus said in its filing

Docket 47472

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