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Texas REPs Oppose Re-introduction of Priority Move-In Charge Once AMS Deployments Complete
July 5, 2011
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Retail electric providers in Texas have opposed the proposal from transmission and distribution utilities to include a separate Priority Move-In charge for premises with provisioned advanced meters with remote connect/disconnect capability (38674).
In a project addressing various changes to the delivery tariff to update timelines due to the advanced metering system (AMS) and proposed elimination of the rescission period, the TDUs sought the separate Priority Move-In charge, arguing that without an additional charge, all Move-Ins will be submitted as Priority Move-Ins (see 6/22). The distinction between Priority Move-In and Standard Move-In under remote connect capability only comes into play when an advanced meter is not communicating with the TDU, and a truck must be rolled to complete the Move-In.
However, the REP Coalition said that such an additional charge would contravene the treatment of meter-related Discretionary Service Charges (DSC) in the settlement agreements and final orders addressing various TDU AMS deployment plans.
"[T]he Joint TDUs' request is clearly contrary to the negotiated settlements and Commission orders approving those settlements in the TDUs' AMS deployment plan/surcharge proceedings. Stated another way, there can be no 'erroneous' interpretation about the effect of those settlements and orders on a TDU's DSC for Priority Move-In service ... Notably, the final orders approving AMS deployment plans and surcharges for three TDUs (CenterPoint, Oncor, and AEP TCC/AEP TNC) include move-in connection service charges within the group of DSCs that are subject to annual rate reductions as advanced meters are deployed. In fact, the final orders in Docket No. 35639 (CenterPoint) and Docket No, 35718 (Oncor) specifically reference their respective charges for Priority Move-in service within the group of affected DSCs," the REP Coalition noted.
The Joint TDUs opposed the REPs' suggestion, made in initial comments, to extend cut-off deadline for submission of requests for same-day reconnection of service to a premise with an advanced meter that is not communicating with the TDU (and cannot be reconnected remotely) from the proposed 2 p.m. deadline to 5 p.m.
The TDUs said that the 2 p.m. deadline is the latest feasible cut-off because, when communication of the initial remote signal is unsuccessful, communication may be retried several times to exhaust all possibilities of completing the request using the automated AMS system before it is deemed necessary to route the order to the field, and roll a truck. These additional attempts at automated completion can take up to two hours, the TDUs said.
"Thus, for a reconnect order that arrives at 5 PM, it may be 7 PM before it is clear that the order is going to have to be worked through other means," the TDUs noted.
"If the TDU is required to complete the work that day, personnel likely will have to be brought back in, incurring overtime costs, and often resulting in the technician being in the field after dark, which in the middle of winter occurs shortly after 5 PM. This is particularly problematic for those TDUs with broad service territories that encompass sparsely populated areas, who could be forced to send a technician hundreds of miles at night to work a reconnect order, or in urban areas where entering a back yard or apartment complex to perform a reconnection at night may pose a real danger. Unfortunately, TDU crews encounter volatile and dangerous situations frequently when performing on site service work after dark. By contrast, if the reconnect order is received by 2 PM, the TDU will likely know by 4 PM if it is going to have to roll a truck. In many cases, the order can be assigned to personnel that are already in the field, requiring at most a hold-over rather than a call back of a technician, and there is a good chance the reconnection will be completed before nightfall," the TDUs said.
The Alliance For Retail Markets, Direct Energy, and Reliant Energy (joint REPs) offered support for the elimination of the rescission period, except where federally required, which had drawn opposition from consumer groups and the Texas Energy Association for Marketers in initial comments.
"Mandating same-day switching for customers with advanced meters and yet allowing those customers to reverse that switch within three business days without penalty is contradictory on its face," the joint REPs said, which agreed that same-day switching should be the Commission's priority.
The joint REPs further said that, if the proposed amendments to the tariff require same-day switching and the right of rescission remains, a REP will need to employ a manual process via MarkeTrak to undo a switch every time a customer with a provisioned advanced meter timely exercises the right of rescission. "This will create a significant administrative and operational burden for REPs," the joint REPs said.
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