A Proposed Response

Texas State Congressman Matt Shaheen (R, Dist 66 [which includes my county]) has tweeted access to a Request for Comment regarding last week’s snow and cold storm with various utilities’ associated failures to keep supplies of electricity, natural gas, and potable water flowing in major areas of the State.

Kudos to Shaheen for publicizing this RFP.

Below are my inputs.

  1. All, without exception, ERCOT board members and senior executives (C-suite equivalents and their deputies) must reside within Texas. Half of the board members, a separate half of the C-suite, and a separate half of their deputies must reside in separate rural regions of Texas. Within that last, a C-suite executive and his deputy must not reside in the same region.
  2. Each of these board members, senior executives, and their deputies must have demonstrated expertise and empirical experience in energy and potable water supply—e., they must be energy and water engineers. Personnel with legal expertise can serve as board consultants and as assistants to the senior executives’ deputies.
  3. The State government must encourage—but not mandate—all utility providers to amortize their bills that result from the sort of event the storm of 15-19 Feb 21 represents over the succeeding 12 months. Single bills of $9,000-$17,000 (to the extent these numbers aren’t just press hype) shouldn’t occur; they should be spread over the succeeding year.
  4. Exceptionally high single-month bills like those suggested in 3) above should be investigated for their legitimacy—but from the going-in assumption that they are legitimate free-market, high demand/limited supply prices. “Price gouging” is what must be proven.
  5. All utility providers and their suppliers must winterize their systems against worst-case scenarios, with the minimum threshold being a 100-year temperature excursion, sustained for more than “a few” hours. The current winterizing was against only “bad” case scenarios. This winterizing must come solely at the expense of the individual utility, that utility’s customers, and each utility’s supplier(s). The costs should be amortizable over a reasonable period of time, and PUCT should allow the rate increases needed for cost recovery within that amortization schedule for those utilities within its jurisdiction. Other regulators must be required to do the same. The amortization schedules should be those initially proposed by the utilities/suppliers, and the regulators should be spring-loaded to accept them, rejecting a particular schedule only for concrete, measurable cause(s).
  6. Utilities with out-of-state suppliers that can’t or won’t comply with 5) above should be encouraged to find Texas-domiciled suppliers with which to replace them. Failure to find substitutes should not absolve the impacted utility of its responsibilities or liabilities related to energy/water supply so long as they are making concrete, measurable, publicly viewable ongoing efforts to find Texas-domiciled replacements. The Texas government should support the search efforts with its own research facilities, but not with taxpayer funds.
  7. Eliminate energy subsidies—both renewable and hydrocarbon

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