PUCT Comments: Changing Transmission Cost Allocation Criteria
In this filing, TEBA discusses several options for changing the way the Public Utility Commission of Texas (PUCT) allocates transmission costs to large loads. As our comments state, TEBA’s membership includes a wide range of businesses — “While some of our membership will directly benefit from investment in significant new transmission upgrades, other members will have only indirect benefits. It is possible that they may even be harmed if the state does not prudently expand transmission access as it increases investment in the system.”In response, TEBA urges the PUCT to embrace “forward thinking transmission planning” and the addition of “more payers into transmission cost allocation at the same time [that the state] makes these investments.” Our comments also stress the benefits of the demand response programs that the current system encourages, and it floats a modified cost allocation approach in which new loads over a certain size would be required to pay for a minimum portion of their total planned capacity for a discrete period determined by the PUCT after energization, instead of their usage during a peak period.