Texas PUC Staff Oppose New Charges On Retail Electric Providers Proposed By TDU
August 21, 2018 Email This Story Copyright 2010-17 EnergyChoiceMatters.com
Reporting by Paul Ring • firstname.lastname@example.org
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Staff of the Public Utility Commission of Texas have filed testimony opposing Texas-New Mexico Power's proposal, in its current rate case, to institute a new Inadvertent Gain fee and a new fee for a meter reading for purpose of a mass transition
PUCT Staff said in testimony that the proposed Inadvertent Gain fee should be rejected because, "TNMP has failed to meet its burden of proof regarding the new fee."
"The direct testimony and application submitted by TNMP includes a single sentence noting that TNMP is proposing the new fee. The rate filing package submitted contains a single spreadsheet showing the calculation of the proposed fee. TNMP has not provided any justification or support for the proposed new fee. In light of this lack of support provided in its direct case, it is my opinion that TNMP has failed to meet its burden of proof to initiate a new discretionary service charge," a witness for Staff testified
Similarly, Staff testified that TNMP's proposal to increase its mass transition fee should be rejected, as Staff testified that, "TNMP provided no support for its proposal to begin charging for this service, and therefore has not met its burden of proof."
"Additionally, TNMP's proposal appears to conflict with the Provider of Last Resort (POLR) rule, 16 TAC § 25.43(p)(16)," Staff testified
Staff noted in testimony that 16 TAC § 25.43(p)(16) provides that a TDU shall create a regulatory asset for the TDU fees associated with a mass transition, and that such rule states that the TDU shall not bill as a discretionary charge, the costs included in this regulatory asset, which shall consist of the following: (A) fees for out-of-cycle meter reads associated with the mass transition of customer to a POLR provider; and (B) fees for the first out-of-cycle meter read provided to a customer who transfers away from a POLR provider, when the out-of-cycle meter read is performed within 60 calendar days of the date of the mass transition.
Staff also testified that TNMP's proposed Rider AVM - Rate Case Additional Vegetation Management should be denied because it constitutes unauthorized piecemeal ratemaking and because it is not based on historical costs, but rather prospective in nature and therefore not known and measurable.
Staff also testified that TNMP's proposed 4CP Distribution System Charge rate design for Transmission Service customers should be rejected, and the standard Commission-approved NCP rate design should be implemented for Transmission Service customers.
Staff also opposed TNMP's proposal to adjust the class allocation of transmission expenses in the TCRF rider
TNMP proposes to adjust the allocation of the FERC account 565 so that no customer class gets more than 150% of the system increase, which equates to a 19.77% change. This means that TNMP has adjusted the 4CP demand allocators used to allocate transmission costs so that no class would experience a rate increase greater than 19.77%.
Staff testified that, "Approval of TNMP's request would constitute a departure from Commission precedent in the allocation of wholesale transmission costs. which requires an allocation based on actual, unadjusted 4CP demand coincident with the ERCOT 4CP. TNMP's request is also inconsistent with 16 TAC § 25.192(b)(1) and (d), as well as PURA 35.004 (d), which require transmission cost recovery based on ERCOT 4CP."