Putting the “Public” in Public Utility Commission

Our Comments to the Public Utility Commission of Texas

Energy Market Redesign

Public Citizen has submitted these comments on PUC Project 52373, Review of Wholesale Electric Market Design:

Guiding principles for energy market redesign. We suggested the following three principles:

  1. Electric customers have a right to affordable, resilient, reliable, clean energy. The Public Utility Commission—and Texas’ energy market itself—exists for the benefit of Texans. The public should be deeply involved in the energy market redesign.
  2. Demand is one-half of the energy market equation and should be given equal attention. Energy efficiency, demand response, distributed generation, and distributed storage—including electric vehicles—are the best options for consumers. These are the most affordable and equitable solutions to ensure that electric supply can meet demand.
  3. Clean energy is the best option for public health and the climate. The PUC should never adopt a policy that would prolong the use of fossil fuels beyond what is necessary.

Suggestions for better use of residential demand response as a key solution for reliable and affordable electricity.

Public Citizen joined with other public interest organizations in filing these comments in PUC Project 52373:

Comment of public interest, consumer and community organizations on electric market redesign. These comments outlined the following beliefs:

  1. The public must be deeply involved in this process and the PUC should establish an office of public participation.
  2. Demand side strategies are half of the equation and should be given equal consideration. We must make investments in the grid, including energy efficiency, demand response, distributed generation like rooftop solar and batteries, and transmission to connect low cost solar and wind to customers.
  3. We should not discriminate against clean energy and should promote financial fairness for customers.
  4. Market reforms must all benefit consumers.

Comment of public interest groups on residential demand response. Our comments included the following key recommendations:

  1. Increase utility energy efficiency programs and focus on HVAC, building shell improvements, and both commercial and residential load management to reduce winter and summer peaks. The Commission has the authority to do this and used it in 2010.
  2. Increase Emergency Response Service beyond the $50m cap currently in place; create new ERS products focused on weather sensitive, residential loads.
  3. Study the potential for demand response and energy efficiency. The last potential study was produced by Itron in 2008. Smart thermostats didn’t even exist yet at that time.
  4. Include demand response in the definition of dispatchability when creating new ancillary service products.
  5. Create a minimum 10% goal for retail electric providers and load serving entities for demand response. After studying the potential for DR, adjust the goal upward, if needed.
  6. Change 4CP to 12CP to capture economic demand reductions in the winter.

Electric Weatherization Standards

Public Citizen has offered these comments in PUC Project 51840, Rulemaking Establishing Electric Weatherization Standards:

  • Comment on reliability and fuel supply.
  • Comment on impact to PUC of Railroad Commission’s proposed weatherization rule. (You can read our comments on the RRC rule here.)

Redesigning Texas’ Energy Market for the Public Good

Our electricity grid failed during Winter Storm Uri, causing suffering across Texas. Texans responded by demanding reforms—a stronger grid and fair energy pricing.

We offered four messages on resilience and market reform. Fact sheets on each of these messages are linked below:

  1. Failure was Foreseeable
  2. Invest in Weatherization
  3. Local Energy
  4. Energy Justice

Lawmakers responded with modest legislation, including Senate Bill 3, which weatherized fuel supply and power transmission. Public Citizen worked with Rep. Donna Howard to amend the bill to require consultation with the state climatologist. You can read about that effort here.