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Load Group Opposes Oncor Rate Case Settlement For Failing To Allow Smaller Load To Elect 4CP Billing

August 08,2017

Brasovan Energy's Electricity Users Coalition (BEEC) filed an objection to a stipulation in Oncor's rate case, as BEEC opposes tariff language that would limit 4CP billing for delivery rates to customers above 700 kW.

"Oncor's rate payers have paid for billions of dollars in smart meter infrastructure over the past several years and will continue to pay for it in the future. However, the benefits of this infrastructure, other than increased earnings for Oncor, have largely gone unrealized. One of these benefits should be the expansion, at the customers option, of better delivery cost price signals to customers below the historic IDR meter threshold," BEEC said

"Without a new price signal only 6,065 of the 3,409,463 ESI's in Oncor's service territory will have an incentive to change their behavior during system peak events (based on average test year ESI counts for retail customers). That is only 0.178% of all Oncor accounts," BEEC said

"The main reason for limiting 4CP billing to IDR customers in the past was the lack of data and the difficulty in communicating that data back to Oncor. Neither of those problems now exist due to the SMT investments that have been made. Now that the data is available it is our understanding from Oncor that their new billing system (which is also being paid for by rate payers) could accommodate 4CP billing for customers down to approximately 25 KW by January 1, 2019," BEEC said

"The lack of incentive to change the peak behavior is a detriment to the millions of customers on the Oncor system that are paying the billions of dollars for this infrastructure. Given the incentive — an opportunity to reduce costs - many customers may avail themselves of this option and work to lower their usage during peak events. This would reduce system loading which could lead to a reduced need for infrastructure investments in the future. Thereby benefiting all Oncor customers and rate classes," BEEC said

"This possibly reduced need to make ever continuing investments may be the reason that Oncor, when this issue was first raised in the negotiated settlement process, instead added the language that exists in the stipulation now," BEEC said alleged. "This language basically solidifies their desire to limit 4CP billing to customers that are 700 KW and above in the new tariffs. Not allowing customers the ability to be billed on a 4CP basis is a departure from more than 20 years of precedent where customers were able to pay for an IDR meter and obtain 4 CP billing. If Oncor's recent tariff changes and/or the stipulation language are allowed to stand, only 0.178% (less than one-fifth of one percent) of Oncor's ESI's could receive the benefits of 4CP billing. Hence a very small part of Oncor's total load will be given a direct incentive to lower usage during peak events," BEEC said

"In stark contrast to this is the fact that almost 100% of Oncor's load could be billed on a 4 CP basis. Not allowing ratepayers to at least have the option of being billed on 4CP if they want would be a HUGE waste of money. Money, that Oncor ratepayers should rightfully expect, should be used as effectively as possible to lower their costs and provide high quality services to them," BEEC said

"Indeed, as you know, it is incumbent upon the Texas PUC to make sure the investments made by Oncor are utilized to the greatest extent possible to benefit the Oncor ratepayers. Hence, we believe that it is incumbent upon the PUC to not accept the stipulated settlement order as filed," BEEC said

Texas   Oncor   Pricing  

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