Is It Fair to Make All ERCOT Load Pay for Smart Meter Texas Portal Via Admin Fee?
October 06,2014
In comments urging that ERCOT assume ownership of the Smart Meter Texas portal, several retail electric providers have suggested including costs of the portal in the ERCOT administrative fee.
However, while a simple and straightforward approach, there are several considerations which may make inclusion of SMT portal costs in the ERCOT admin. fee inappropriate.
First, such a cost recovery mechanism would socialize costs of SMT operation over all ERCOT load equally (since LSEs will pass-on the higher admin. fee).
However, not all customers will use SMT to the same extent (if at all). Unlike say, transmission, where all customers equally benefit from assets, it is easy to identify varying levels of SMT use and access. Do cost causation principles dictate that a usage-based fee apply to SMT?
Moreover, recovering all SMT costs in the ERCOT system admin. fee gives non-LSE third parties, who are expected to be heavy users of SMT once third-party functionality goes live, a free ride to build their business model around customer data. Unlike REPs, who must pay the ERCOT system admin. fee (and attempt to recover it from customers as competitive dynamics allow), third-party providers of non-load-serving energy services will be able to access customer data without incurring any charge, thus being able to extract value from "big data" without paying any of the freight for the creation and operation of the very tool enabling their business model.
Additionally, customers with IDR meters have separate portals for their data. Customers also have the right, by tariff, to opt-out of smart meter installation. There are also utilities in ERCOT which have not installed smart meters. Recovery through the admin. fee would make these groups pay for a service from which they cannot benefit