Texas REPs Say CenterPoint-TDU's "Vague" Low-Income Discount Proposal, Proposed To Be Administered By REPs, Not Feasible

September 26, 2023

Email This Story
Copyright 2010-23 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

The following story is brought free of charge to readers by VertexOne, the exclusive EDI provider of EnergyChoiceMatters.com

In testimony before the Texas PUC, the Texas Energy Association for Marketers (TEAM) said that a proposal from CenterPoint Energy Houston Electric (CEHE or CenterPoint) for a special low-income customer rate (discount) under Rider TEEEF, with the program administered by retail electric providers, is not feasible

Rider TEEEF collects the costs of Temporary Emergency Electric Energy Facilities used by CEHE

As previously reported, in its initial testimony, CEHE said that the potential low-income discount program could identify customers that are receiving Low Income Home Energy Assistance Program (LIHEAP) aid in the Company’s service area, who would be eligible to apply for an alternate TEEEF rate. Those customers receiving LIHEAP would have an opportunity to apply to have the TEEEF rate excluded from their CenterPoint Houston charges.

Further, CEHE said in its initial testimony, "The Company is proposing that customers would apply annually through their REP."

A witness for TEAM stated, "TEAM is sensitive to affordability concerns for low-income residential customers, as well as all customers. If CenterPoint’s Rider TEEEF is approved as proposed, a residential customer using 1,000 kilowatt hours per month will pay a total of $3.24 per month. While reduced customer costs should always be considered, in this case the total customer costs would actually be higher under CenterPoint’s proposal. Further, it is clear that CenterPoint has not performed the due diligence necessary to propose a fully formed, feasible process for implementing its proposed low-income rate exemption. In CenterPoint’s own words: 'The Company is proposing a methodology that is feasible for the TDU and is open to working with parties to develop solutions that resolve the feasibility concerns of parties and or the Commission.'"

A witness for TEAM stated:

"As the party that bears the burden of proof in this proceeding, it is incumbent upon CenterPoint to put forth a complete proposal that is actually possible. However, with regard to the low-income rate exemption proposed by CenterPoint:

• CenterPoint cannot identify how many or which customers would be eligible for the rate exemption; therefore, CenterPoint cannot request actual rates for approval in this proceeding that reflect the exemption.

• CenterPoint does not propose to cover the cost of any proposed benefit to low-income customers. Instead, CenterPoint proposes to be made whole for any such TEEEF exemptions by increasing rates for the remainder of the distribution customers.

• CenterPoint has not proposed a feasible means to identify and enroll 'eligible customers.'

• As described by [a CEHE witness], CenterPoint’s proposal would put a cost and time burden on REPs to establish and maintain a system to enroll customers as eligible for the proposed rate relief and would require REPs to provide that information to CenterPoint. CenterPoint has no intent to reimburse REPs for the cost and time burden and proposes no means to cover the cost to REPs.

• The eligibility criteria that CenterPoint proposes for REPs to use is based off customer eligibility under the Low Income Home Energy Assistance Program (LIHEAP); however, REPs do not have this information. It is unclear if or where information on LIHEAP eligibility exists in a way that could be matched to customers, and if such confidential information could be shared for that purpose if it did exist.

"Therefore, CenterPoint’s proposal amounts to little more than a vague concept that is not ripe for a decision and should be denied."

A witness for TEAM further stated, "REPs do not receive any sort of information from TDHCA [the Texas Department of Housing and Community Affairs] with regard to which of the customers they serve receive LIHEAP assistance. LIHEAP funds are not provided directly from TDHCA to the customers. Instead, LIHEAP distributes funds to local subrecipients across Texas that work directly with customers to determine eligibility, benefit level, and priority of benefit for electric bill payment assistance. The funds from those agencies may come from a variety of sources, and not necessarily only from LIHEAP funding. (For example, one agency may receive funding from LIHEAP, REP donations, and customer donations.) REPs do not receive a 'list' of customers who receive LIHEAP funding, and it is unclear if a list exists in any capacity that could be leveraged for this purpose. Therefore, utilizing a list of customers that receive LIHEAP assistance is not a feasible method for determining qualified customers for TEEEF rate exemption."

A witness for TEAM further stated that the use of the optional low-income list administrator (LILA) low-income customer list, to which REPs may opt-in, would not be feasible under CEHE's proposal

A witness for TEAM stated, "First, this is not a permissible use of the information and would require impermissibly sharing data with a third party. Second, CenterPoint appears to contemplate an annual enrollment process to be administered by the REPs. The LILA lists could not be used for this purpose. The list for each REP changes every month as customers switch REPs and their HHSC eligibility changes. CenterPoint’s proposal would require all REPs, including those who do not receive a list, to establish a new manual process to effectuate this proposal. REPs who do not participate would also have to establish additional processes they may not have had in place. Again, the eligibility requirements for LIHEAP and HHSC programs may overlap but are not necessarily the same."

A witness for TEAM also stated, "CenterPoint’s proposal is contrary to the concept of systemwide rates because it seeks to rely on REPs to administer the rate exemption on an ad hoc basis rather than having CenterPoint take the responsibility for identifying and maintaining a list of qualified customers. When asked if it was willing to take sole responsibility for identifying and enrolling qualified customers, CenterPoint stated that the proposal in [its] testimony did not contemplate CenterPoint enrolling or identifying eligible customers."

"Any new processes to accommodate a rate exemption of the kind proposed by CenterPoint will take time to implement. Further, not all REPs are a party to this docket. A low-income rate exemption implicates broader policy issues than those specific to this case. If the Commission finds merit in this concept, a separate Commission process involving all REPs, and potentially TDUs charging similar riders, would be a more appropriate venue in which to vet implementation solutions, including the cost of those solutions," a witness for TEAM said

In separately filed testimony, the Office of Public Utility Counsel (OPUC) stated, "Regarding the affordability alternative presented by CEHE for the alternative rate design that excludes low-income customers from paying the TEEEF Rider rates, CEHE should be required to develop a much more detailed program and involve all stakeholders including Retail Electric Providers (REPs), Texas Department of Housing and Community Affairs (Comprehensive Energy Assistance Program), and the Low-Income Home Energy Assistance Program (LIHEAP) administrator in the process. Then a decision can be made as to whether the program should be implemented. The Company at least initially should pay for the costs of the program through corporate contributions and not shift the cost burden to their other customers not participating in the program given the lack of a good estimate of the number of CEHE's Residential customers that will enroll in the program, the likelihood that it will be a small percentage of Residential customers especially if LIHEAP is used to facilitate qualification of eligible customers, and the lack of experience by CEHE with this type of program."

Docket 54830

ADVERTISEMENT

ADVERTISEMENT
NEW Jobs on RetailEnergyJobs.com:
• NEW! -- Pricing Analyst - Retail Power
• NEW! -- Electricity Pricing Analyst -- Retail Supplier
• NEW! -- Business Development Manager -- Retail Supplier
• NEW! -- Call Center Manager -- Retail Supplier
• Senior Billing Subject Matter - (Remote) -- Retail Supplier

HOME

Copyright 2010-23 Energy Choice Matters.  If you wish to share this story, please email or post the website link; unauthorized copying, retransmission, or republication prohibited.