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Texas TDUs Propose Changes To Subst. Rules Governing Advanced Meters

July 24, 2018

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

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In light of the Texas PUC's recent approval of changes to Smart Meter Texas, AEP Texas Inc. ("AEP Texas"), CenterPoint Energy Houston Electric, LLC ("CenterPoint"), Oncor Electric Delivery Company LLC ("Oncor"), and Texas-New Mexico Power Company ("TNMP") (collectively, the "Joint TDUs") have filed with the PUCT suggested revisions to 16 TAC § 25.130, which governs advanced metering

Among the proposed changes are:

--- Modifying the rule language that TDUs provide AMS with the capability to provide 15-minute "or shorter interval" data to REPs, by deleting the "or shorter interval" language, such that the requirement would be to provide only 15-minute data

The TDUs said that, "The Joint TDUs suggest the deletion of 'or shorter interval' to reflect current AMS requirements. The Joint TDUs have deployed meters that provide 15-minute data to REPs, customers, and ERCOT on a daily basis. Thus, the language suggesting intervals shorter than 15 minutes is unnecessary. At this point, a proposal to require data be provided for intervals shorter than 15 minutes would be a significant change that should follow the proposed revision process suggested by the Joint TDUs," in their suggested changes

--- Deleting from the rule the requirement that an advanced metering system provide a means by which the REP can provide price signals to the customer

The TDUs said that, "Although the term 'price signals' is not defined in § 25.130, in the last 10 years, REPs have not sent 'price signal' messages to customers through SMT, and the Joint TDUs are unaware of any other price signals being sent through SMT. To the extent REPs have been sending their customers 'price signals,' those are being communicated to customers outside of SMT and advanced meters. Thus, this required AMS feature has not been used and should be deleted. In addition, as described in more detail below, customers have not widely adopted the home-area network ('HAN') functionality required under § 25.130(g)(1)(J), and the Commission found in Docket No. 47472, that on-demand readings provide an adequate substitute for HAN. Without HAN functionality, SMT will not be capable of sending a REP's price signals to customers."

--- Deleting from the rule the requirement to offer HAN functionality except for those customers which the PUCT recently ruled shall continue to have access to such functionality

The TDUs said that, "The HAN functionality that has been provided in the Joint TDUs AMS deployments for approximately 10 years has not been widely adopted by customers. In Docket No. 47472, the evidence established that as of April 4, 2018, only 7,668 HAN devices had been provisioned on SMT. The Commission granted the Joint TDUs' request for a waiver from this subsection and found that on-demand meter reading functionality through SMT provides an adequate substitute for HAN functionality. That order also requires that HAN functionality continue to be supported for customers with a HAN device paired to a meter and in use at the time that SMT 2.0 is implemented. Thus, this subsection should be revised to be consistent with the Commission's July 12, 2018 order in Docket No. 47472."

--- Deleting from the rule the requirement that REPs, at their expense, may require the TDU to provide a non-standard advanced meter or AMS features not offered in the utility's tariff, subject to various conditions

The TDUs said that, "The existing subsection (g)(2) provides a mechanism through which a REP could require a utility to provide nonstandard meters and advanced meter features. Because § 25.130 was adopted before utilities began AMS deployment, utilities had not determined whether they would deploy AMS or what type of meters and technology they would deploy. This provision provides a process for addressing situations in which a REP requires a non-standard advanced meter or meter feature, or requires an additional metering technology that is technically feasible and generally available. Now, 10 years after adoption of § 25.130, this provision has become obsolete."

"Over the last few years, it has become apparent, however, that § 25.130 would benefit from having an explicit process through which utilities, REPs, or other third-parties could seek a change to a meter feature or a change to SMT business requirements. The Joint TDUs propose that an explicit new process replace the existing subsection (g)(2). The proposed process envisions that the minimum service features to be provided by an AMS could be amended either through a rulemaking or a contested case and that the Commission would determine whether the proposed change would be made," the TDUs said

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