Various non-LSE third party big data companies have filed comments with the Public Utility Commission of Texas opposing a strawman concerning rules for Smart Meter Texas

In general, the big data companies object to the strawman's proposed distinction between "End-Use Customer" functionalities of SMT and "Non-End-Use Customer" functionalities, and the attendant different cost recovery methods proposed for each. The distinction may be seen as "core" and "non-core" functionalities, or 'required" versus "optional" functionalities of SMT

Notably, only End-Use Customer functionalities are proposed to be recovered from customers via base rates and or the DCRF. Non-End-Use Customer functionalities would be recovered through discretionary service charges, applicable to only those entities requesting such service.

Such a design ensures that all customers, who must pay base rates or DCRFs regardless of their usage of SMT, do not subsidize specific functionalities of individual companies and their customers who want bells and whistles to facilitate their offering of certain services to customers.

Not surprisingly, third party data providers objected to the proposed dichotomy.

"The first problem is the distinction made in the definitions of End-Use Customer Functionality and Non-End-Use Customer Functionality. By attempting to separate the 'bare minimum' end-use customer functionality from features that are believed to be somehow extraneous, the proposed rules would relegate SMT to a minimalist website with only one function, namely to allow customers to log in and view or download their energy usage, and nothing more," Mission:data said in comments.

"Instead of downloading their own data from SMT for self-analysis, the vast majority of customers should be expected to interact with their electricity use data from inside a Third Party's website or mobile app. That means the user experience of sharing usage data with a Third Party becomes essential to realizing the customer value of SMT, yet improvements to that user experience would, under the Straw Proposal, have to be paid for by Third Parties," Mission:data said

Earth Networks Connected Savings and OhmConnect likewise said of the dichotomy, "This proposed distinction is highly problematic, and we strongly urge that this concept be eliminated. Virtually all changes that would support the healthy performance of SMT ultimately benefit customers, a few directly and most indirectly." [emphasis added].

"[I]t should not be the responsibility of users of the platform, whether end-use retail customers, REPs, or competitive energy service providers, to make the business case for (and pay for analysis of the costs associated with) an improvement to the platform," the Texas Advanced Energy Business Alliance said

The Texas Advanced Energy Business Alliance also complained that, even though SMT currently provides certain data to third parties, because it's different than the standard developed by the feds (after SMT led the way), and, because, shockingly, companies would otherwise need to tailor their business processes when entering a new market, SMT should therefore be changed to adopt the federal standard (presumably with costs for the change borne by all Texas ratepayers pursuant to the Alliance's comments on cost recovery noted above).

"SMT currently offers automated collection and transfer of meter data through a customized application program interface, or API. However, because this API was custom-built for SMT (prior to the Connect My Data standard being finalized), it is unfamiliar to many service providers and app developers, many of whom have already designed their solutions to comply with the Connect My Data data protocol," the Texas Advanced Energy Business Alliance said

In contrast, the Texas Office of Public Utility Counsel said of cost recovery, "OPUC agrees with Staff that captive end-use customers should not bear the costs associated with non-end use customer requests and would like to explore the use of this option at the workshop."

"OPUC does agree that market participants should not be able to require costs incurred by TDUs to be borne by captive ratepayers when those costs are unreasonable," OPUC said

"OPUC supports the Staff's efforts to clarify that use of the DCRF is not appropriate for cost recovery associated with non-end-use customer costs," OPUC said