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Texas PUC Staff Recommends That Residential Customer Participation In ERCOT ERS, And TDU Load Management Programs, Should Be Eliminated
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Texas PUC Staff have recommended that residential customer participation in ERCOT Emergency Response Service (ERS) and TDU load management programs, "should be eliminated entirely or at the least significantly reduced."
Staff's recommendation was made in an initial annual report on the residential load reduction goal
Staff noted that residential customer participation in a retail electric provider responsive device program is prohibited (§ 25.186(c)(D)) while enrolled in emergency programs such as ERS (§ 25.507) or a TDU load management program (§ 25.181)
However, Staff reported that, "the data clearly indicates that such overlap currently exists."
Nearly 8,000 ESI IDs were enrolled in both a REP and TDU program during one quarter, while over 3,500 ESI IDs were enrolled in both a REP program and ERS in another quarter
Staff reported that, "REPs have previously mentioned that they have limited visibility into customers signing up for multiple programs. In some cases, the residential customer may also be unaware of their participation in multiple programs (e.g., tenant/landlord situation or a previous homeowner signing up for a program that was never canceled)."
Staff noted that a recent report prepared for ERCOT by a consultant found that weather-sensitive load (residential customer) participation in the ERS program is administratively burdensome.
Staff reported that, "ERCOT TDU load management programs (combined residential and commercial programs) offered 380.4 MW of demand response in 2024 and 410 MW in 2025. It is worth noting that these programs have never been deployed by ERCOT."
Staff reported that, "Staff is actively engaged with the REP community and ERCOT to understand this situation further before recommending active enforcement of § 25.186(c)(D)."
Staff's report also included an analysis of residential demand response, reviewing 334 ERCOT daily peak demand periods, from January 1, 2025 to November 30, 2025.
During this time, REPs deployed at least one customer, identified by a unique electric service identifier (ESI ID), on 302 days (90.42%).
Staff said that, overall, the number of ESI IDs deployed during an ERCOT daily peak demand period was "relatively low" on most days -- nearly 85% of days examined involved fewer than 100 deployments.
Among the days where at least one ESI ID was deployed, there was a considerable amount of variance in the number of deployments, ranging from one to 42,776 ESI IDs deployed on a given day
The average total residential load reduction goal is set by § 25.186 at 0.25 (i.e., a 20% reduction in load by participating residential customers). The 0.25 goal set forth in rule is based on a ratio of MWs reduced to actual consumption among participating consumers, while the percentage reduction value is determined based on a comparison of the reduction estimate to the estimated baseline consumption value absent reductions associated with these programs.
Staff reported that, "existing programs are currently quite far from achieving this goal, reaching an average load reduction ratio of approximately 0.026 (or a 2.50% reduction, on average, by participating residential customers)."
This level of demand reduction translates to just 10% of the amount needed to achieve the goal established by the rule, Staff said
Staff said that a ratio of totals, an alternative approach to calculate a percentage reduction value, also provides a measure of the overall system impact of these programs. Specifically, this value is obtained by calculating a ratio of aggregate reduction to aggregate baseline load across all days, expressed as a percentage. This provides a measure of the proportion of energy that would have been expected to be consumed but was saved because of these programs. For the period covered by Staff's report, this metric is equal to 3.02%, with an estimated 197 MWs reduced as the result of REP program deployments.
Nevertheless, Staff said that, "Even across this limited time frame, there appears to be a positive trend in REP program performance that is worth highlighting."
"Deployments tended to be substantially larger in the Summer and Fall months compared to the Winter and Spring, both in terms of the number of ESI IDs deployed and the associated MW reduction estimate. Additional data is needed to determine whether this observation is indicative of true improvement or simply the result of some underlying temporal factors," Staff said
Staff further noted that wholesale energy prices have been lower, on average, than in previous years, "which may diminish demand response incentives".
ERCOT's average wholesale price for 2025 was about $37 per MWh, or about one-half of the 2023 price, and well below the 2021 price of $179.24 per MWh
No zonal average price in 2025 exceeded $42 per MWh, while average zonal prices in 2021 were as high as $221.52 per MWh
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Staff Reports Some ESI IDs Are In Both REP And ERS/TDU Programs, Which Is Prohibited
Staff Report: Existing REP Residential DR Programs "Quite Far" From Achieving Rule's Load Reduction Goal
July 1, 2026
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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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