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Public utilities

Oncor Electric Delivery Company LLC's Supplemental Response to the Public Utility Commission of Texas

Strategic Insights

— 2 min read

As the Public Utility Commission of Texas (Commission) continues to develop the Compliance Reporting Portal (CRP), Oncor Electric Delivery Company LLC has submitted a supplemental response to address additional concerns regarding the new compliance reporting mechanisms. The document highlights the importance of consistency between the CRP's filing instructions and the existing Rate Filing Package for Cost-of-Service Determinations. Oncor identifies two main issues that require attention: the inconsistency between the CRP's proposed new filing instructions and the existing instructions for completing Schedule M, and the shift in deadlines for submitting project cost estimates.

Key Takeaways:

  • Oncor Electric Delivery Company LLC has identified two issues with the proposed new Compliance Reporting Portal (CRP) filing instructions: inconsistency with Schedule M and the shift in deadlines for submitting project cost estimates.
  • The inconsistency arises from the requirement for transmission service providers to provide Initial Estimated Project Costs, rather than Final Estimated Project Costs, in Monthly Construction Progress Reports (MCPRs), which creates a discrepancy with the instructions for completing Schedule M.
  • The shift in deadlines for submitting project cost estimates requires transmission service providers to submit Initial Estimated Project Costs no later than 45 working days prior to the start of construction for non-CCN projects, which may lead to inaccurate cost estimates and greater variance between estimated and actual project costs.
  • Oncor suggests maintaining the current instructions or modifying the CRP instructions to allow transmission service providers to submit Initial Project Cost Estimates and Final Project Cost Estimates the month that construction begins.
  • Staff from the Public Utility Commission of Texas has been working to address both issues and has indicated that they are amenable to maintaining the existing timeline for submitting initial project costs in the month of construction.

Statistics:

  • 45 working days: The proposed new instructions require transmission service providers to file Initial Estimated Project Costs no later than 45 working days prior to the start of construction for non-CCN projects.
  • 6: The number of months that cost estimates for non-CCN projects can vary widely in the leading up to the start of construction.
  • 2-3 months: The timeframe during which new constraints may be discovered, material and labor costs can fluctuate, and other issues are identified that impact costs.

Sources:

  • Public Utility Commission of Texas, Filed Date - 2025-06-26 04:55:30 PM, Control Number - 57925.
  • Oncor Electric Delivery Company LLC, Document dated May 1, 2025.
  • Transmission & Distribution (TDU) Investor-Owned Utilities Rate Filing Package for Cost-of-Service Determination, Project No. 49199, dated July 16, 2020.
  • Instructions for Monthly Transmission Construction Process Report, dated December 29, 2014.

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