|
|
|
|
|
CenterPoint-TDU Asks Texas PUC To Allow Utilities To Market, Deliver Energy Efficiency "Directly" To Customers
The following story is brought free of charge to readers by VertexOne, the exclusive EDI provider of EnergyChoiceMatters.com
In comments at the Texas PUC in a project reviewing energy efficiency, CenterPoint Energy Houston Electric, LLC (CenterPoint Houston) said that the PUC should, "[a]llow[] electric utilities to deliver energy efficiency incentives directly to customers and increase direct marketing capabilities to drive awareness and participation."
CenterPoint Houston said, "CenterPoint Houston feels that it [sic] important to focus on the customer experience by providing tangible value and making the energy efficiency programs accessible and equitable."
In contrast, the REP Coalition said in comments to the PUC that, "both EE [energy efficiency] and DR [demand response] are first and foremost competitive energy services under Commission rule that are and should be offered in
the competitive market."
The REP Coalition said, "The Commission’s rules both reinforce and caveat this distinction by
acknowledging the separation of the TDU’s administration of EE programs from the prohibited
competitive energy services. Therefore, to the extent EE and DR will also continue to be
incentivized through TDU EE programs, it is important to consider how those incentives can be
aligned and co-optimized with the organic wholesale market incentives that arise from ERCOT’s
competitive retail market."
"Any financial incentives from TDU EE programs for residential or small commercial DR
initiatives should be viewed as a way to augment retail electric providers’ ('REPs') economic
motivation to offer DR products to those customer segments, not a substitute for those offers," the REP Coalition said
The REP Coalition said that, in considering initiatives to expand the growth of DR in the areas of the state open to retail
competition, three fundamental principles should govern:
(1) "DR is a competitive energy service;
(2) "REPs should be the entities that provide DR service to customers; and
(3) "to the extent TDU EE programs remain involved in EE and DR, they should be
focused on structural improvements and incentive payments (e.g., AC tune-ups,
heat pump installations, funding for smart thermostat deployment, demand-related
cost incentives through REP dispatch), which can make DR more effective, rather
than through load control programs directed by TDUs."
The REP Coalition further said, "REPs -- and not third-party DR vendors -- are best suited to facilitate load
resource participation within the framework of ERCOT's competitive wholesale and retail markets."
"In competitive
portions of ERCOT, REPs are the primary customer-facing entity for electric service and bear
responsibility for customer usage in wholesale settlement. Further, a key design feature that has
allowed the retail market to be so successful is the requirement for REPs to own the customer
relationship for electric service. This simplifies the customer experience, allows competition on a
level playing field, and ensures established customer protections will govern the customer/market
entity relationship," the REP Coalition said
"REPs are responsible for procuring power for their customers, and if the REP does not
have direct access or visibility into the customers consumption/habits, that makes it
increasingly difficult to forecast the appropriate amount of power to procure for each
particular time interval of service. If there are large unanticipated swings in the
customer’s consumption due to third party DR activity, the REP will have an even more
difficult time forecasting and managing their customer load," the REP Coalition said
"Placing the responsibility for DR programs with REPs, rather than third-party DR
providers, avoids policy concerns such as the lack of customer protection rules
applicable to these third-party providers," the REP Coalition said
Commenting on the current bonus structure for TDUs regarding their performance relative to energy efficiency targets, the REP Coalition said, "While the REP Coalition is not recommending specific changes to the bonus calculation
for TDUs set out in the rule, to the extent that REPs will be leaned on to achieve demand reduction
goals in ERCOT, a credit (funded through TDU Energy Efficiency dollars) to REPs that are able
to achieve those goals may be appropriate to serve a similar 'bonus' purpose for REPs as the
existing bonus serves for TDUs."
In separately filed comments, Octopus Energy recommended setting aside a
portion of expanded EE program funding to be allocated to REPs to facilitate delivery of EE and DR
products and services to retail customers
"Octopus Energy supports aggressive expansion of the state’s commitment to DERs
including EE and DR. Given their relationship to retail customers, REPs should be key players in
delivering EE and DR to customers, especially residential customers. We strongly recommend that
the Commission consider modifying delivery models for utility EE and DR to better utilize this
relationship," Octopus said
"For example, we recommend that the Commission consider both an increase in the
funding available for EE and DR programs, as well as establishing a percentage of that increased
funding for utility programs to be delivered by REPs. Under current programs, a REP must apply
for funding from each individual utility, and each utility may have different program rules even
for similar programs. Just as REPs can better deliver retail products and services to customers with
the standardization that comes from having a pro-forma TDU tariff, creating standardized
programs across ERCOT utilities and providing adequate funding opportunities that are dedicated
to facilitating REP delivery of EE and DR would dramatically improve the ability of REPs to reach
their customers," Octopus said
Project 56517
ADVERTISEMENT ADVERTISEMENT Copyright 2024 EnergyChoiceMatters.com. Unauthorized copying, retransmission, or republication
prohibited. You are not permitted to copy any work or text of EnergyChoiceMatters.com without the separate and express written consent of EnergyChoiceMatters.com
Retail Provider Seeks Set-Aside For REP Delivery Of Utility-Funded EE & DR Programs
May 24, 2024
Email This Story
Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
NEW Jobs on RetailEnergyJobs.com:
• NEW! -- Energy Regulatory Specialist
• Sr. Market Risk Analyst -- Retail Supplier
|
|
|
|