Texas REPs: PUC Should Explore Having TDUs Bear Financial Responsibility Arising From Extended, Unilateral Disconnection Moratoriums

REPs: Hurricane Beryl Disconnection Moratoriums Caused ~$100 Million In Bad Debt

Several REPs Allege That CenterPoint-TDU's Blaming A Lack Of Customer Contact Info From REPs Is A "Distraction" From CenterPoint-TDU's Failings

August 30, 2024

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Reporting by Paul Ring • ring@energychoicematters.com

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The Texas PUC should examine requiring TDUs to assume certain financial responsibilities arising from "unilateral" disconnection for non-pay moratoriums, various retail electric providers said in comments to the PUC

The REPs' comments were made in a project examining issues arising from Hurricane Beryl

A group of REPs calling themselves the Aggregated REP Group alleged that various TDUs impacted by Beryl "unilaterally" declared disconnection moratoriums following the storm. The Aggregated REP Group included, among other REPs, Reliant, Just Energy, Gexa, Constellation, Shell Energy Solutions, APG&E, Chariot Energy, and Rhythm

Various groups of REPs generally noted that REPs remain responsible for paying TDU charges under the standard timeframe (as well as the REP's own electricity supply costs) while such DNP moratoriums are in place. Various REP groups also noted that moratoriums can exacerbate customer payment problems by allowing a large balance to accrue which may be difficult to manage once the moratorium is lifted

The Aggregated REP Group said that a "preliminary rough estimate" of bad debt attributable to the Hurricane Beryl DNP moratoria is $70 million to $100 million or more, with the REPs noting that the total amount of bad debt is, "still in flux as the dust settles."

In separate comments, the Alliance for Retail Markets recommended that the PUC should open a project to review the TDUs' authority to adopt disconnection moratoriums outside of the criteria for DNP suspensions enumerated under PUC rules.

"That project should further explore the financial responsibilities that TDUs should be obligated to bear for extending disconnection moratoriums outside of the parameters established in the Commission’s rules," ARM said

ARM proposed, as one example of a financial requirement to be borne by TDUs for moratoriums which exceed the rules' stated conditions for a DNP moratorium, requiring that TDUs cease the collection of delivery charges from REPs for customers who could have been disconnected but-for the moratorium.

The rule already requires the TDU to cease charging TDU charges to a REP, except securitization charges, when a TDU refuses to disconnect a critical care customer, ARM noted

ARM offered another proposed example under which TDUs would be required to make monetary donations to "a customer bill payment assistance agency" to help mitigate unpaid balances that accrue during a lengthy disconnection moratorium

The Aggregated REP Group proposed vesting with the Commission only, not the TDUs, the authority to adopt a DNP moratorium after a disaster

Because TDUs receive payment from REPs for wires charges even when the customer does not pay the REP, "a TDU’s decision to declare a disconnection moratorium following a natural disaster is divorced from the financial implications for end-use customers and REPs," the Aggregated REP Group said

"Accordingly, a process where only the Commission may declare a disconnection moratorium following an unexpected, wide-spread outage resulting from a natural disaster ensures an objective decision that takes into account the needs to the TDU, the REP, and the end-use customer," the Aggregated REP Group said

TDU Communications To Customers, REP Obligations

The various REP filers also criticized CenterPoint Energy Houston Electric's (CenterPoint or CEHE) framing of CEHE's communication problems post-Beryl as the result of the lack of sharing of customer contact information by REPs to TDUs

The Aggregated REP Group said, "CenterPoint has indicated that their inability to access the customer contact information held by REPs for use in conjunction with the CenterPoint PowerAlert system was a cause of the lack of communication with customers."

"This assertion is a distraction," the Aggregated REP Group said

The Aggregated REP Group faulted CEHE's online outage tracker and other communication infrastructure for CEHE's poor communication

In separate comments, ARM noted that the TDUs' tariffs already require REPs to include customer contact information in certain TX SET transactions if available.

"[N]nothing that prevents TDUs from using the customer contact information already in their possession from standard market transactions to support emergency communications. Stated another way, there is not a customer contact information 'issue' to solve," ARM said

Even if additional sharing of customer contact info by REPs with TDUs is mandated, "[this] will not solve for the TDUs having timely, premise-specific outage information to communicate," ARM said

"Specifically, TDUs should be required to provide premise-specific outage notices, status updates, and restoration times to impacted customers. TDU communications should be concise and focused on outage status (including information such as the cause of the outage) and the estimated and actual time of restoration. TDUs should refrain from sending lengthy statements about the TDU’s general restoration activities, which would be more appropriately shared via other methods, such as press releases and social media posts. The Commission may consider establishing standards regarding these factors," ARM said

"ARM is aware of instances where customers had opted in to CenterPoint’s outage notifications, but received lengthy general statements about restoration efforts (instead of specific updates), received inaccurate information, or received no alerts at all," ARM alleged

ARM suggested that TDUs be required to maintain a system similar to Smart Meter Texas under which REPs could obtain real-time outage information for impacted ESI IDs, dubbed by ARM as the "ESI ID Outage Database".

Using information provided by the TDU such as through the database, REPs would then be able to respond to customer inquiries about the status of an outage (though ARM said: "note that REPs may differ in their utilization of this information.")

The Aggregated REP Group reiterated, "If a TDU does not have the infrastructure and internal systems in place to receive and respond to communications from customers regarding outages, the mediums of communication available to the TDU (phone, text, email, etc.) to push out generic information not specific to that customer’s outage is not the primary concern."

The Aggregated REP Group said that it would be helpful if the TDUs:

• Maintain operational online outage tracker maps, which should help decrease customer concerns and calls

• Use customer contact information received from REPs to provide premise-specific outage notice, status update and restoration times to impacted customers

• Provide real-time outage information to REPs for ESI IDs for which they are REP of record via a central platform (similar to Smart Meter Texas) that REPs can query

Project 56822

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