Sign in Subscribe
Public utilities

Texas Public Power Association Responds to Public Utility Commission's Interconnection Draft

Strategic Insights

— 1 min read

The Texas Public Power Association (TPPA) has submitted its comments on the Public Utility Commission of Texas's (Commission) discussion draft regarding technical requirements and interconnection processes for distributed energy resources (DERs). As part of its response, TPPA expressed concerns about the potential safety risks and the need for standardized DER technical requirements. The association also emphasized the importance of prioritizing utility personnel safety and grid reliability, urging the Commission to adopt a safety-first and reliability-first perspective when evaluating new DER technologies.

TPPA is a statewide association representing 72 municipally-owned utilities (MOUs) in Texas, as well as several electric cooperatives and joint action agencies. The association serves approximately 5.1 million Texans across the state and maintains more than 8,500 miles of high-voltage transmission assets, providing over 13,800 MW of generation.

Key Takeaways:

  • TPPA opposed applying DER interconnection standards to MOUs and cooperatives, citing legal and practical considerations, as well as the Commission's lack of jurisdiction over interconnection in MOU service territories.
  • The association recommended revising the provision requiring DSPs to maintain records concerning applications received for DERs, suggesting a two-year retention period for records and requiring DERs to provide necessary information to DSPs as part of their application.
  • TPPA also suggested that the Commission require direct reporting from DERs to the Commission, rather than through DSPs, to ensure more accurate information and reduce data integrity issues.
  • The association expressed concerns about the proposed definition of DERs, recommending significant revisions to clarify the definition and exclude household devices, such as smoke detectors and 9V batteries.
  • TPPA suggested delaying the requirement for DSPs to create and file an open access tariff for wholesale transmission service at distribution voltage until after a DSP receives its first inquiry for interconnection.
  • The association proposed reworkings the definitions in 25.511 to enhance clarity and avoid applying to household devices.

Statistics:

  • TPPA represents 72 municipally-owned utilities (MOUs) in Texas.
  • The association serves approximately 5.1 million Texans across the state.
  • TPPA maintains more than 8,500 miles of high-voltage transmission assets.
  • The association provides over 13,800 MW of generation.
  • There are more than 140 MOUs and cooperatives operating in Texas.

Sources:

  • Project No. 54233, Texas Public Power Association's Response to Staff Discussion Draft (2025).
  • Review of Distributed Energy Resources, Project No. 51603, Texas Public Power Association's Response to Questions for Comment (2022).
  • 16 TAC § 25.91.
  • 16 TAC § 25.198(i).

Read more