Scorecard Methodology
With so many types of utilities, scoring them all is a huge task. For this first edition of the Texas Clean Energy Scorecard, we divided our scorecard into four main categories: the 10 largest municipal electric utilities, the 18 largest electric cooperatives, the nine largest transmission and distribution utilities, and the 34 top-selling Retail Electric Providers which buy and sell electricity in the competitive markets.
For each of these four "types" of utilities, we have scored them on several categories unique to their type, though there is overlap between them.
Criteria for Scoring Clean Energy Efforts
Retail Electric Providers (REP)
In 1999, Texas passed SB 7, which “deregulated” most of ERCOT’s electric market beginning in 2002. Before SB 7,electric utilities controlled power plants, wires, and held a monopoly on customers within their service territory. After SB 7, areas opened to competition were separated into investor-owned utilities who own the poles and wires, generators who own power plants (like coal, natural gas, wind, nuclear, etc), and retail electric providers (REPs) who sell that power to customers. Within ERCOT territory, customers that live in “competitive areas” can choose their REP. In contrast, Texans living in the service territories of municipal utilities, electric cooperatives, or outside the ERCOT grid are served by their utility with a monopoly on providing electric service in the area. In the competitive part of the state there is widespread choice on who provides you with electric service.
Map of Competitive Areas: http://www.puc.texas.gov/industry/maps/maps/tdumap.pdf
Power To Choose Website: http://www.powertochoose.org/
Who and How We Judged
While there are more than 60 different registered retail electric providers that are operating or have operated since Texas deregulated the energy market, we looked at the top 35 companies that reported the highest residential and commercial sales based on data provided by the companies to the U.S. Energy Information Administration (EIA) in 2018, 2019, 2020 and 2021. In addition to providing some basic information like how much energy they sold into ERCOT’s energy market, we looked at a variety of criteria including what their average energy use per customer was, whether they reported “demand response” programs, whether they offered 100% renewable offers (and at what price), how much of their total sales was provided by renewable resources, whether they “bought” back electricity from solar panel owners (net metering), whether they allowed customers an online portal to look at their electric use, whether they offered a community solar program, if their corporate owners actually owned coal or other fossil fuel plants and whether they offered rebates for the use of electric vehicles. We judged them on criteria based off of the most recent publicly available information we could find either through EIA, the company’s own website, or the Public Utility Commission’s “Power to Choose” website.
Here are the criteria we used to score the Retail Electric Providers
1. Efficiency of Residential Customers, based on average per month energy consumption (kWh)? (0 to 3 Points) (0 to 3 Points)
Below 850 kWh: 3 points
850 - 1,150 kWh: 2 points
1,150 - 1,500 kWh: 1 points
Greater than 1,500 kWh: 0 points
2. Did the residential average monthly energy use go up, down or stay the same between years? I.e, Total Electricity Use Change (0 to 10 Points)
Average Use went Up More than 10%: 0 Points
Average Use Went Up Between 0 and 10%: 2 Point
Average Use Went Down Between 0 and 5%: 4 Points
Average Use Went Down Between 5 and 10%: 6 Points
Average Use Went Down Between 10 and 20%: 8 Points
Average Use Went Down More than 20%: 10 Points
3. Offered Dynamic (Time-of-Use) Pricing or a Demand Response product; reported to U.S. Energy Information Administration (EIA)? (0 to 5 Points)
Did not offer either a DR or Dynamic Pricing Product: 0 Points
Offered either a DR or Dynamic Pricing Product: 2 Ponts
Offered both a Dynamic Pricing and DR Product: 5 Points
4. Offered Time-of-Use Pricing, Residential Demand Response Programs, and Provide Information on How to Save Energy, on its Main Customer Website? (0 to 10 Points)
No Programs:0 Points
Demand Response Programs: 3 Points
Dynamic Pricing/Time-of-Use: 3 Points
Energy Savings Information Found on Website: 3 Points
Note: If a company offered all three types of programs/information, it was given the full 10 points.
5. Renewable Options and Fixed Price for a 12-month term Compared to its “normal” price with same term offered? (I.e. What was the highest renewable option the company offered for a 12-month fixed term price (in the Houston area) and how does the price compare to their “normal” 12-month fixed term price offering?) (0 to 12 Points)
Offered 100% Renewable Option: 4 Points
Offered 100% Renewable Option No More than 1 Cent
per Kilowatt Hour More Expensive than Normal Option: 8 Points
Offered 100% Renewable Option at a Price Equal to or
Cheaper than “Normal” Option: 12 Points
6. Renewable Energy Under Contract or Purchased Through Renewable Energy Credits in prior year (0 to 15 Points)
Did it invest in non-wind Renewable Energy Credits? (ie solar)+2 Points
Did it sign a direct PPA with a renewable developer (wind or solar)?+3 Points
0%: 0 points
Between 0 and 5%: 1 points
Between 5 and 10%: 2 points
Between 10 and 20%: 3 points
Between 20 and 30%: 4 points
Between 30 and 40%: 5 points
Between 40 and 50%: 6 points
Between 50 and 60%: 7 points
Between 60 and 80%: 8 points
Between 80 and 99%: 9 points
100%: 10 points
7. Community Solar Option for Residential Customers Offered? (0 to 6 Points)
Offered Community Solar Option: 2 Points
Offered Community Solar Option with Ownership Potential: +2 Points
Offered Community Solar Option providing Credit for Energy Production: +2 Points
8. Buys Back Excess Energy from Local/Rooftop Solar? (0 to 15 Points)
Offered Buy-Back Program: 5 Points
Offered Buy-Back Program with Rollover Credits: 5 Points
Offered Buy-Back at Full Retail Rate: 5 Points
9. Company Customer Satisfaction Rating on the Public Utility Commission’s (PUC) Power-to-Choose Website? (0 to 10 points)
1 Star: 2 Point
2 Stars: 4 Points
3 Stars: 6 Points
4 Stars: 8 Points
5 Stars: 10 Points
10. Owned by a Parent Company with Major Ownership Stake in Coal or Other Fossil Fuel Power Plants? (0 to 10 Points)
Owners do not invest in fossil fuels: 10 Points
Owners have an interest in natural gas power plants or products: 4 Points
Owners have an interest in natural gas and coal plants or products: 0 Points
11) Offered Incentives or Rebates for Electric Vehicle Charging Infrastructure or Electric Vehicles? (0 to 4 Points)
None: 0 points
Less than $100: 1 point
$100-$200: 3 points
>$200: 4 points
Note: Time of use pricing that benefits EVs is addressed in above question.
Municipal Owned Utilities (MOU)
There are 72 municipal utilities in Texas. Many of them are relatively small and serve a single town. In 2011, the Texas legislature approved a bill, SB 924, which required municipal utilities who sold more than 500,000 megawatt-hours of electricity annually to report to the State Energy Conservation Office each year on their energy efficiency, demand response, and renewable energy programs. While this requirement is a good one, the reports are spotty and often incomplete. Still we assessed the programs at the 9 largest city utilities that were required to report, and added some categories of our own, by also looking at reports filed with the Energy Information Administration and available on the utilities’ websites. We added Georgetown Municipal Utility, both because they have passed the 500,000 MWh threshold in recent years and because of their recent decision to transition to 100% renewable energy.
Map of all MOU’s w/ scored ones highlighted
Rural Electric Cooperatives (COOP)
There are 67 electric cooperatives in Texas. In an electric cooperative, customers are also “members” with the ability to vote on many utility decisions including the governing board of directors. Many co-ops are relatively small and serve a single area, but just like municipal utilities, under Texas Senate Bill 924 electric cooperatives that sold more than 500,000 MWh’s of electricity are required to report to the State Energy Conservation Office once a year on their energy efficiency, demand response and renewable energy programs. Thanks to the similarities of the reports the municipal utilities and co-ops need to file and their non-competitive status within their territories, we are able to score them based on the same metrics.
Here are the criteria we used to score the 18 largest electric cooperatives and 10 largest municipal utilities
1. How did their peak demand change from one year to the next? (0 to 7 pts.)
Note: Even for growing utilities, peak demand needs to be kept under control for ERCOT’s stability and the rates that customers pay. During peak times, the most polluting power-plants in the state produce power.
Increase more than 17%: 0 points
Increase between 17% and 11%: 1 point
Increase between 11% and 7%: 2 points
Increase between 7% and 4%: 3 points
Increase between 4% and 1%: 4 points
Between 1% increase and 2% decrease: 5 points
Decrease between 2% and 6%: 6 points
Decrease greater than 6%: 7 points
2. Did their total energy system use change from prior year, i.e., Total Electricity Use Change? (0 to 3 Points)
Increase more than 5%: 0 points
Increase between 0% and 5%: 1 point
Decrease 0% to 5% and 0% decrease: 2 points
Decrease greater than 5%: 3 points
3. How much has their average residential customer’s use changed and how much money has that saved them, i.e., Reduction in Residential Consumption and Increase in Savings? (0 to 10 Points)
Increase greater than 500 kWh/yr: 0 points
Increase between 500 and 250 kWh/yr: 1 point
Increase between 250 and 100 kWh/y: 2 points
Increase between 100 and 0 kWh/yr`: 3 points
Decrease between 0 and 150 kWh/yr: 4 points
Decrease between 150 and 300 kWh/yr: 5 points
Decrease between 300 and 450 kWh/yr: 6 points
Decrease greater than 450 kWh/yr: 7 points
and
Increase greater than $100/yr: 0 points
Increase between $100 and $0/yr: 1 point
Decrease between $0 and $100/yr: 2 points
Decrease greater than $100/yr: 3 points
4. Cost Competitive Renewables (Green Rate) Offering (0- 11 Points)
Green (meaning 100% Renewables) offered: 4 points
If also less than or approximately equal to standard rate: +7 points
Or if greater than the standard rate but less than or equal to a 1 cent premium: +4 points
5. What is the Quality of programs and incentives for residential Solar, Wind and storage (distributed generation)? (0 to 16 points)
Do they offer a solar, wind, or storage incentive (including financing incentives)? (4 pts)
Yes (solar/wind): 2 points
Plus storage: + 2 point
No: 0 points
Incentive details (4 pts)
Incentive or on-bill financing for home (and/or commercial ) installation: 2 points
Strong annual funding for rebate: + 2 points
Net-metering Policy (8 pts)
Net-metering disallowed, other disincentives, and/or solar rate that is less than net-metering: 0 points
Instantaneous Net metering and overage not purchased, or weak solar-price, or other monthly fees: 4 points
Net-metering over monthly billing cycle but overage not purchased: 6 points
Net-metering over monthly billing cycle with overaged purchased (and no per meter/monthly fee) or strong solar-price: 8 points
6. Community Solar Offerings (0 to 4 Points)
Community solar program offered: + 2 points
Size of program installation: + up to 2 points (depends on utility size)
7. Quality, Accessibility and Number of Energy Efficiency Programs? (0 to 20 Points)
Best Practices:
Online Portal (3 points)
Online portal offered: 1 point
Significant participation: 1 point
Innovative design: 1 point
Demand Response Incentives (2 points)
Smart thermostat program: 1 point
Smart thermostat program with significant participation or additional program(s): 1 point
Energy Audits (3 points)
Offered: 1 point
Both residential and commercial: 1 point
Significant Participation: 1 point
Energy Efficiency/Weatherization rebates (6 points)
Any Energy Efficiency programs, including light bulb giveaways: 1 point
Any weatherization programs offered with numbers for participation: 2 points
Reasonable participation in weatherization, EE programs: 3 points
Multiple weatherization, EE programs offered with numbers and significant participation: 4 points
Many weatherization, EE programs offered with significant participation: 5 point
Low-income focus: + 1 pt.
Education Programs (3 points)
Online/print education: 1 point
In person education (tours, events): 1 point
Significant participation or exemplary programs: 1 point
Other programs (3 points)
Subjective scoring up to 3 points for additional, innovative programs.
While subjective, the following criteria may be used.
BPI >=3: 1 point
BPI >=5: 2 points
BPI >=9: 3points
8. Reported Savings from Energy Efficiency Programs (SECO Reports) (0 to 5 Points)
The scores here are weighted towards kWh Savings provided to Customers and in some cases program spending percent per customer.. It should be noted that very few MOU or COOPs reported the kWh or spending information to the State Energy Conservation Office in their required reports or in an attachment to the report.
No reported savings or spending on EE programs: 0 points
If reported some kWh savings: 1 point
If savings kWh consumption reduced by >0.50% (or Spending on EE > 0.50%): 2 points
If savings kWh consumption reduced by > 1% (or Spending on EE > 1%): 3 points
If savings kWh consumption reduced by > 1.5% (or Spending on EE > 1.5%): 4 points
If kWh consumption reduced by >2% (or Spending on EE > 2%): 5 points
Note: this is limited to a 5 point score because for the variability of reporting and possible variability of the ways to count the savings.
9. Renewable Energy Goals: Does it have a renewable energy goal for the future? (0 to 5 points)
No goal: 0 points
Less than 35%: 2 points
Between 35 and 70%: 3 points
Between 70 and 100%: 4 points
100% achieved: 5 points
10. Renewable Energy under contract (or Purchased in prior year) (0 to 10 Points)
0%: 0 points
Between 0 and 5%: 1 points
Between 5 and 10%: 2 points
Between 10 and 20%: 3 points
Between 20 and 30%: 4 points
Between 30 and 40%: 5 points
Between 40 and 50%: 6 points
Between 50 and 60%: 7 points
Between 60 and 80%: 8 points
Between 80 and 99%: 9 points
100%: 10 points
11) Required State Energy Conservation Office (SECO) Report submitted? (0 to 5 Points)
Yes/not applicable (5points) or No (0 points)
12) Offered Incentives or Rebates for Electric Vehicle Charging Infrastructure or Electric Vehicles? (0 to 4 Points)
None: 0 points
Less than $100: 1 point
$100-$200: 3 points
>$200: 4 points
Investor-Owned Utilities (IOU)
There are 8 private investor-owned utilities in Texas that provide the transmission services, including powerlines, to keep the grid reliable. Four of these are located within the ERCOT region of the state and four are located outside of ERCOT. Following SB 1125, approved in 2011 by the Texas legislature, all 8 are required to charge residential and commercial electric customers that are located in their service territories a small “Energy Efficiency Cost Recovery Fee” that generates millions of dollars each year. These funds are used by the IOUs to run energy efficiency, demand response, and in some cases, renewable energy programs to meet state-required goals. In 2019, collectively these 8 utilities saved nearly 600,000 MWh of energy through their energy efficiency programs, or about 0.28% of the total energy they distribute. The same programs reduced peak demand by 481 MW, an 0.80% reduction overall.
For this scorecard, we looked at all 8 IOUs, relying on both the annual report these utilities are required to submit to the Public Utility Commission and data provided to the Energy Information Administration. We judged these transmission and distribution utilities on the breadth and depth of their energy efficiency and demand response programs, whether or not they provided rebates for solar development, how easy it is to “interconnect” solar in their territories, and how vigorously they helped working Texans least able to afford high utility bills.
1. Required Public Utility Commission (PUC) Report Submitted? (0 to 5 Points)
Yes: 5 points
No: 0 points
2. Peak Electricity Demand Reduced through Energy Efficiency and Demand Reduction Programs? (0 to 10 Points)
Less than 0.5 percent: 0 points
Between 0.5 and 0.7 percent: 2 points
Between 0.7 and 0.9 percent: 4 points
Between 0.9 and 1.2 percent: 6 points
Between 1.2 and 1.5 percent: 8 points
Greater than 1.5 percent: 10 points
3. Met Public Utility Commission Goal of 0.4% Reduction in Peak Electricity Demand? (0 to 5 Points)
Yes: 5 points
No: 0 points
4. Reduction of Customers’ Total Electricity Consumption from Energy Efficiency Programs? (0 to 15 Points)
Less than 0.10%: 0 points
Between 0.10% and 0.15%: 3 points
Between 0.15% and 0.25%: 6 points
Between 0.25% and 0.35%: 9 points
Between 0.35% and 0.5%: 12 points
Greater than 0.5%: 15 points
5. Percentage of its Texas Revenue Spent on Energy Efficiency Programs? (0 to 10 points)
Less than 0.2%: 0 points
Between 0.2% and 0.5%: 2 points
Between 0.5% and 0.8%: 4 points
Between 0.8% and 1.2%: 6 points
Between 1.2% and 1.5%: 8 points
Greater than 1.5%: 10 points
6. Spent per capita on Energy Efficiency Programs for Low-Income Households? (0 to 10 points)
Less than $5: 0 points
Between $5 and $8: 2 points
Between $8 and $12: 4 points
Between $12 and $15: 6 points
Between $15 and $20: 8 points
Greater than $20: 10 points
7. Energy Efficiency Programs’ per capita Savings for Low-Income Households? (0 to 10 points)
Less than 10 kWh: 0 points
Between 10 kWh and 21 kWh: 2 points
Between 21 kWh and 33 kWh: 4 points
Between 33 kWh and 45 kWh: 6 points
Between 45 kWh and 60 kWh: 8 points
Greater than 60 kWh: 10 points
8. Quality of Programs and Incentives for Residential Solar, Wind and Storage (0 to 16 Points)
Do they offer a solar, wind, or storage (distributed energy programs) incentive? (4 pts)
Yes (solar/wind--distributed energy programs): 2 points
Plus storage: + 2 point
No: 0 points
Incentive details (4 pts)
Incentive or on-bill financing for home (and/or commercial ) installation: 2 points
Annual funding for rebates: +2 points
Net-metering Policy or disincentives (8 pts)
Net-metering disallowed, other disincentives, and/or solar rate that is less than net-metering: 0 points
Instantaneous Net metering and overage not purchased, or weak solar-price, or other monthly fees: 4 points
Net-metering over monthly billing cycle but overage not purchased: 6 points
Net-metering over monthly billing cycle with overaged purchased (and no per meter/monthly fee) or strong solar-price: 8 points
9. Quality and accessibility of Energy Efficiency Programs offered? (0 to 15 points)
Six Best Practices:
Online Portal (3 points)
Online portal offered: 1 point
Significant participation: 1 point
Innovative design: 1 point
Demand Response Incentives (3 points)
Smart thermostat program: 1 point
Smart thermostat program with significant participation or additional program(s): 1 point
Significant participation: 1 point
Energy Audits (3 points)
Offered: 1 point
Both residential and commercial: 1 point
Significant Participation: 1 point
Distribution improvements (3 points)
Energy efficiency/Weatherization rebates (6 points)
Any EE programs, including light bulb giveaways: 1 point
Any weatherization programs offered with numbers for participation: 2 points
Reasonable participation in weatherization, EE programs: 3 points
Multiple weatherization, EE programs offered with numbers and significant participation: 4 points
Many weatherization, EE programs offered with significant participation: 5 points
Low-income focus: + 1 point
Education Programs (3 points)
Online/print education: 1 point
In person education (tours, events): 1 point
Significant participation or exemplary programs: 1 point
Other programs (3 points)
Subjective scoring up to 3 points for additional, innovative programs
10. Offered Incentives or Rebates for Electric Vehicle Charging Infrastructure or Electric Vehicles? (0 to 4 Points)
None: 0 points
Less than $100: 1 point
$100-$200: 3 points
>$200: 4 points
Additional Scoring for vertically integrated (full service) IOUs (+0 to +30)
If the Investor Owned Utility is vertically integrated, meaning it both sells electricity and delivers it to the customers/households (mostly outside the ERCOT competitive region), than it is also scored on the following questions. These vertical IOUs include El Paso Electric Power Company, Entergy, Southwestern Public Service Company (Xcel) and Southwestern Electric Power Company (SWEPCO). They could score an additional 30 points. This additional score (+0 to +30) can be seen at the end of the general description of the company.
11. Competitive Renewables (Green Rate) Offered? (0- 11 points) (only applicable to vertically integrated IOU)
Green (meaning 100% Renewables) offered: 4 points
If also less than or approximately equal to standard rate: +7 points
Or if greater than the standard rate but less than or equal to a 1 cent premium: +4 points
12. Renewable Energy Goals: Do they have a renewable energy goal for the future? (0 to 5 points) (only applicable to vertically integrated IOU)
No goal: 0 points
Less than 35%: 2 points
Between 35 and 70%: 3 points
Between 70 and 100%: 4 points
100% achieved: 5 points
13. Renewable Energy Under Contract or Purchased in Prior Year (Renewable PPAs)? (0 to 10 points) (only applicable to vertically integrated IOU)
0%: 0 points
Between 0 and 5%: 1 point
Between 5 and 10%: 2 points
Between 10 and 20%: 3 points
Between 20 and 30%: 4 points
Between 30 and 40%: 5 points
Between 40 and 50%: 6 points
Between 50 and 60%: 7 points
Between 60 and 80%: 8 points
Between 80 and 99%: 9 points
100%: 10 points
14. Community Solar Offerings? (0 to 4 Points) (only applicable to vertically integrated IOU)
Community solar program offered: + 2 points
Size of program installation: + up to 2 points (depends on utility size)
