WattPal Original Research · Edition 2026.10
The Texas Electricity Plan Trap Index: Reviewing 760 Plan Listings Across Five Major Texas TDU Territories
How prevalent are bill-credit cliffs, inverted pricing curves, time-of-use daytime penalties, recurring base fees, and hidden one-time charges across Texas retail electricity plans? We audited the active Power to Choose catalog and extracted contract terms from binding Electricity Facts Labels (EFLs) to examine common pricing conditions.
Published Oct 12, 2026 · By WattPal Editorial Team · Open Dataset & Empirical EFL Research
760
Fixed-rate plan listings reviewed (from 1,885 PTC listings)
14.1%
Invert at 2,000 kWh via bill-credit cliffs (up to +6.4¢/kWh)
4.6¢/kWh
Max gap between lowest teaser rate & lowest true flat rate
14.2%
Verified EFLs charging recurring monthly base fees ($4.95–$32.99)
1. Executive Summary & Dataset Scope
Under PUCT Substantive Rule §25.475, every retail electric provider (REP) in Texas must publish standardized average price disclosures at exactly 500 kWh, 1,000 kWh, and 2,000 kWh per month on each plan's Electricity Facts Label (EFL). Because public shopping portals—including the official PUCT Power to Choose website—default to sorting plans by the 1,000 kWh benchmark, retail providers engineer contract terms specifically to depress that single number.
To measure how widespread these structural traps are across the Texas residential market, WattPal audited the live Power to Choose export alongside our fail-closed parsed EFL repository:
October 2026 Audit Funnel & Coverage:
- • Raw Power to Choose Feed: 1,885 total plan rows exported across Texas territories.
- • Deduplication & Scope Filtering: Removing Spanish-language duplicate listings (
[Language] = Spanish), variable/indexed plans, prepaid products, and non-standard municipal/co-op rows yields 760 active English, Fixed-Rate, Non-Prepaid residential plans across the 5 major ERCOT Transmission and Distribution Utilities (TDUs): CenterPoint (155), Oncor (154), TNMP (151), AEP Central (150), and AEP North (150). - • Deep EFL PDF Clause Extraction: In addition to benchmark curve analysis across all 760 plans, we examined 366 fail-closed, schema-verified EFL PDFs in WattPal's active cache to measure clause-level fees (recurring base charges, one-time enrollment fees, auto-pay conditions, and exact credit trigger brackets) that do not appear as standalone columns in the summary CSV.
2. Finding #1: Bill-Credit Cliffs & Rate Curve Inversions (14.1% to 17.8% of Catalog)
In a normal utility rate structure, a fixed monthly customer charge is spread across more kilowatt-hours as usage rises, causing the effective ¢/kWh rate to decline monotonically from 500 kWh to 1,000 kWh to 2,000 kWh. When a plan's disclosed 2,000 kWh rate is higher than its 1,000 kWh rate (kwh2000 > kwh1000), the plan exhibits Inverted Pricing—the mathematical signature of a targeted bill credit or usage tier cliff.
Inverted Rate Curves
107 / 760 (14.1%)
Active PTC fixed-rate plans where the effective rate jumps upward at 2,000 kWh (17.8% [65 of 366] among verified EFL PDFs).
Dominant Credit Size
$125 at 1,000 kWh
Among verified bill-credit EFLs, 75% (30 of 40) use a $125 credit triggered at ≥1,000 kWh; 25% (10 of 40) use a $100 credit.
Steepest 2,000 kWh Jump
+6.4¢ / kWh
Advertised at 7.5¢/kWh at 1,000 kWh, surging to 19.9¢ at 500 kWh and 13.9¢ at 2,000 kWh once the $125 credit dilutes or vanishes.
Across the 760-plan dataset, 78 plans (10.3%) carry an explicit minimum-usage fee or threshold credit flag in the Power to Choose feed, while an additional 29 plans (3.8%) embed tiered energy rate jumps or diluted fixed credits that still invert the 2,000 kWh rate without triggering the portal's basic filter flag. Because a $125 credit reduces the 1,000 kWh benchmark by 12.5¢/kWh, a provider can charge an inflated 18¢–20¢/kWh underlying rate and still display a 6¢–8¢/kWh headline rate at 1,000 kWh.
For a detailed walkthrough of how missing the 1,000 kWh cliff by even 20 kWh in spring or fall costs homeowners $350–$600+ per year, see our Texas Electricity Bill-Credit Traps Guide and 35,040-Interval Household Case Study.
3. Finding #2: The 3.5¢ to 4.6¢/kWh Gap Between Advertised Teasers and True Flat Rates
When Texas shoppers sort Power to Choose from lowest to highest price at 1,000 kWh, the top results in every utility territory are dominated by bill-credit teaser plans. Removing plans with bill credits, minimum usage fees, time-of-use windows, and inverted 2,000 kWh curves reveals a 3.5¢ to 4.6¢/kWh structural gap between the lowest advertised teaser rate and the lowest true flat-rate plan:
| TDU Territory | Lowest Advertised 1,000 kWh Rate (Teaser) | Lowest True Flat-Rate Plan (No Cliff or TOU) | Teaser Illusion Gap | Teaser Rate at 500 / 2,000 kWh |
|---|---|---|---|---|
| Oncor Electric Delivery | 5.2¢ / kWh | 9.8¢ / kWh | 4.6¢ / kWh | 18.1¢ (500) · 11.4¢ (2,000) |
| CenterPoint Energy | 6.2¢ / kWh | 10.6¢ / kWh | 4.4¢ / kWh | 19.1¢ (500) · 12.4¢ (2,000) |
| AEP Texas Central | 5.7¢ / kWh | 9.7¢ / kWh | 4.0¢ / kWh | 18.5¢ (500) · 11.9¢ (2,000) |
| AEP Texas North | 6.2¢ / kWh | 10.0¢ / kWh | 3.8¢ / kWh | 19.0¢ (500) · 12.4¢ (2,000) |
| TNMP (Texas-New Mexico Power) | 8.0¢ / kWh | 11.5¢ / kWh | 3.5¢ / kWh | 21.1¢ (500) · 14.1¢ (2,000) |
Source: WattPal audit of 760 active English fixed-rate non-prepaid plans on Power to Choose. "True Flat-Rate Plan" excludes listings with PTC-flagged minimum usage fees/credits ([MinUsageFeesCredits] = True), TOU schedules ([TimeOfUse] = True), or inverted 2,000 kWh pricing (kwh2000 > kwh1000).
4. Finding #3: Time-of-Use (TOU) Daytime Penalties & Provider Concentration
Across the 760 active fixed-rate plans, 41 plans (5.4%) use Time-of-Use pricing—primarily marketed as "Free Nights" (typically 9:00 PM to 6:00 AM or 8:00 PM to 5:00 AM) or "Free Weekends." Our EFL audit highlights three critical mechanisms that make TOU plans expensive for typical daytime air-conditioning households:
1. Inflated Paid-Hour Rates (21.8¢ to 28.7¢/kWh All-In)
To cross-subsidize free overnight hours, TOU plans charge steep daytime energy rates that—once combined with regulated TDU delivery fees—reach 21.8¢ to 28.7¢/kWh during peak afternoon cooling hours.
2. Standardized EFL Assumed Night Share (~35%)
When computing the 500, 1,000, and 2,000 kWh EFL benchmark rates under PUCT §25.475, providers apply a standard residential load profile (~32%–35% night share). However, households working from home or running afternoon HVAC often consume 68% to 75% of their electricity during paid daytime hours—driving their realized effective rate 2.5¢ to 4.5¢/kWh above the EFL estimate.
3. Uncredited TDU Delivery Pass-Throughs & Provider Concentration
Many "Free Nights" plans waive only the retail energy charge during free hours while still billing regulated TDU delivery charges (5.6000¢ to 7.7710¢/kWh) on every overnight kilowatt-hour. Furthermore, gimmick reliance is heavily concentrated by brand: while some providers offer 100% clean flat-rate catalogs, several major REPs structure 60% to 92% of their active listings around bill credits or TOU schedules.
Explore our Are Free Nights Plans Worth It? Guide and compare our EV Night-Shifter Sample Report against a standard daytime home.
5. Finding #4: Recurring Base Charges, One-Time Fees & Cancellation Traps
Beyond energy rate curves, our clause-level audit of 366 fail-closed, schema-verified EFL PDFs and 760 PTC contract rows uncovered four widespread fee and eligibility constraints:
Recurring REP Base Charges
14.2% (52 / 366 verified EFLs)
Charge a mandatory monthly REP base fee on top of TDU delivery fees: 46 plans charge $4.95/mo, 5 charge $9.95/mo, and 1 charges $32.99/mo—penalizing low-usage apartments by up to +6.6¢/kWh at 500 kWh.
One-Time Enrollment / Bundle Fees
8.2% (30 / 366 verified EFLs)
Embed a $49.99 one-time fee (such as a smart-home bundle or enrollment fee) inside the EFL text that is excluded from the headline 500/1,000/2,000 kWh average rate disclosures.
New-Customer-Only Restrictions & Auto-Pay
77.2% (587 / 760 PTC plans)
Are restricted strictly to new customers, preventing existing customers from renewing into the same promotional rate. Additionally, 10.4% (38 of 366 EFLs) include a $5.00 auto-pay/paperless billing condition.
Early Termination Fees (ETFs)
98.0% (745 / 760 PTC plans)
Impose a cancellation penalty: 88.9% (676 plans) charge a flat exit fee (mean $151.97, median $150, max $395 on 36-month contracts), while 9.1% (69 plans) charge $20 per remaining month. Only 2.0% (15 plans) have a $0 ETF.
6. Finding #5: TDU-Level Delivery Tariffs & Trap Breakdown
While the percentage of bill-credit traps (~13.6%–14.6%) and TOU plans (~5.2%–6.0%) is nearly uniform across Texas utilities because major REPs syndicate identical plan structures statewide, underlying all-in prices vary by up to 3.0¢/kWh across the audited territories, with regulated TDU delivery tariffs contributing to the difference. Specifically, TNMP's $7.56/month fixed charge and 7.7710¢/kWh volumetric delivery rate contribute to its median 1,000 kWh plan price of 15.10¢/kWh—compared to 12.10¢/kWh in AEP Central and 12.65¢/kWh in Oncor:
| TDU Utility | Active Plans | Regulated TDU Delivery Tariff (Oct 2026) | Inverted / Credit Cliff Plans | TOU Plans | Clean Flat-Rate Plans | Median 1,000 kWh Rate (Mean) |
|---|---|---|---|---|---|---|
| Oncor | 154 | $4.06/mo + 6.8673¢/kWh | 21 (13.6%) | 8 (5.2%) | 125 (81.2%) | 12.65¢ (12.32¢) |
| CenterPoint | 155 | $4.90/mo + 6.5333¢/kWh | 22 (14.2%) | 8 (5.2%) | 125 (80.6%) | 13.10¢ (12.77¢) |
| AEP Central | 150 | $3.24/mo + 5.7000¢/kWh | 21 (14.0%) | 8 (5.3%) | 121 (80.7%) | 12.10¢ (11.95¢) |
| AEP North | 150 | $3.24/mo + 5.6000¢/kWh | 21 (14.0%) | 8 (5.3%) | 121 (80.7%) | 12.70¢ (12.54¢) |
| TNMP | 151 | $7.56/mo + 7.7710¢/kWh | 22 (14.6%) | 9 (6.0%) | 120 (79.5%) | 15.10¢ (14.62¢) |
| All 5 ERCOT TDUs | 760 | Regulated Pass-Through | 107 (14.1%) | 41 (5.4%) | 612 (80.5%) | 12.90¢ (12.84¢) |
You can browse live filtered plans in your utility area using the WattPal Plan Explorer, test monthly usage profiles in the Plan Cost Simulator, or inspect individual EFL clauses with our EFL Inspector.
Independent & Unbiased: Why WattPal Charges a One-Time $9.99 Fee
Although 80.5% (612 of 760) of active fixed-rate listings on Power to Choose are clean flat-rate products without usage cliffs or TOU windows, the remaining 19.5% (148 plans) using bill-credit cliffs or TOU schedules dominate the top rankings on conventional comparison sites because they engineer artificially low 1,000 kWh teaser rates. Meanwhile, commission-funded shopping sites collect affiliate commissions from retail providers for each enrollment, creating a financial incentive to promote high-margin plans.
WattPal is 100% reader-funded: we charge a transparent, one-time fee of $9.99 (or $4.99 with code WELCOME50) to simulate eligible verified plans in your utility territory against your 15-minute Smart Meter Texas interval usage. We accept $0 in retail provider kickbacks and never gate our public research or aggregate data behind email capture.
Editorial Methodology, Definitions, Exclusions & Limitations
1. Data Sources & Snapshot Date: The October 2026 edition of the WattPal Texas Electricity Plan Trap Index is derived from (a) the official PUCT Power to Choose bulk CSV plan export (1,885 raw rows) and (b) WattPal's fail-closed, schema-v3 verified EFL PDF extraction cache (366 verified English fixed-rate EFL documents), governed by PUCT Substantive Rule §25.475. Technical pipeline details are documented in Under the Hood: How WattPal Analyzes Plans and our How to Read a Texas EFL Guide.
2. Inclusion & Exclusion Criteria: From the 1,885 raw Power to Choose listings, we exclude Spanish-language duplicates ([Language] = Spanish, 941 rows) to prevent double-counting identical tariffs, variable/indexed rate products, prepaid plans ([Prepaid] = True), and minor municipal/co-op rows outside the 5 primary ERCOT investor-owned TDUs (Oncor, CenterPoint, AEP Texas Central, AEP Texas North, and TNMP). This yields 760 active English, Fixed-Rate, Non-Prepaid residential plans.
3. Mathematical Definitions: A plan is classified as having an Inverted Rate Curve (Bill-Credit Cliff) when its disclosed 2,000 kWh effective rate exceeds its 1,000 kWh effective rate (kwh2000 > kwh1000). The Teaser Illusion Gap is defined for each TDU as min(kwh1000_clean_flat) - min(kwh1000_all_fixed), where clean_flat (referred to as a True Flat-Rate or Clean Flat-Rate plan in summary tables) excludes listings with [MinUsageFeesCredits] = True, [TimeOfUse] = True, or kwh2000 > kwh1000 in the PTC feed; on the WattPal Plan Explorer, the True Flat badge additionally verifies from parsed EFL clauses that no recurring base fees, one-time enrollment fees, or autopay conditions apply. Regulated TDU delivery charges reflect active October 2026 tariffs.
4. Known Limitations & Edition Comparability: Retail electric providers update plan offerings and EFL URLs daily; point-in-time percentages reflect the October 2026 audit window. Clause-level fee percentages (recurring base fees, $49.99 one-time fees, and $5.00 auto-pay conditions) are reported across the 366 fail-closed, schema-verified EFL subset and may differ slightly across unparsed or malformed provider PDFs. Future editions of the Trap Index will preserve identical TDU filtering and mathematical definitions to support longitudinal tracking.
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