policy

Energy Alabama Signs On to Comments Opposing TVA’s NEPA Rule Changes

Energy Alabama, and a host of energy and conservation groups, signed on to comments prepared by the Southern Environmental Law Center opposing changes to TVA’s implementing regulations for the National Environmental Policy Act (“NEPA”).

Energy Alabama is extremely concerned that TVA’s proposed changes undermine transparency, stifle public involvement in TVA’s decisions, and bestow upon TVA almost boundless discretion to decide whether and how it must review the effects of its activities on the people and environment throughout its seven-state service territory, which includes nearly all of Tennessee, and portions of Alabama, Georgia, Kentucky, Mississippi, North Carolina, and Virginia.

To view the full comments, please visit: https://alcse.org/wp-content/uploads/2017/09/2017-09-06-Comment-on-TVA-Proposed-NEPA-Rule.pdf

Perfect Utility Rate Design

6 Reasons Time of Use Rates Are the Best Option

Previously we discussed the pros and cons of the available utility use rates. In that post we mentioned that while none of the options are perfect we do have a favorite, so here’s

6 Reasons Time of Use Rates Are The Best Option

 

  1. Time of Use (TOU) Rates will lower your bill.

With some simple adjustments to your electricity use habits, you would save a significant amount of money with TOU rates versus standard consumption rates.

  1. A true Time of Use Rate system wouldn’t charge any unwarranted fees.

Utilities are notorious for trying to increase fixed charges and fees. With a true TOU rate, you are only charged for the amount of electricity you consumed (based on when you used it) with no extraneous charges.

  1. Time of Use Rates rates encourage the use of solar.

The current system for most utilities across the country charges a “fixed rate,” meaning you are charged that rate regardless of the amount of electricity you use. Without these fixed charges, TOU rates can encourage the use of solar, especially if the peak rates are during daylight hours.

  1. Time of Use Rates can be available to everybody, whether you’re a business owner or a resident.

Additionally, in most states, TOU rates are already available on a voluntary basis.

  1. Time of Use Rates are good for the consumer and the utility.

If implemented properly, TOU rates are directly related to when the system (e.g., the grid) experiences the most cost. By changing your behaviors, you’re not only saving money but also helping the entire system.

  1. There’s only one downside.

Many don’t know of – or have not seen the benefits of – TOU rates. As such, consumer education would be the greatest barrier for getting TOU rates off the ground. Consumers would need to be educated on how they can actually save money with TOU rates – because, unfortunately, you would not be able to switch to TOU rates and have your bill magically decrease. Saving money with TOU rates would require some work on the part of the consumer. Here are a few things that you would have to do to save more money with TOU rates:

  • Plug devices such as computers, televisions, game
  • consoles, and printers into power strips and turn off the switch when these devices are not in use during peak demand hours.
  • Program your AC/heater to not run as much during peak hours.
  • Use your washer and dryer during non-peak times.
  • Install automatic timers to only run your water heater during non-peak times (trust us, you’ll still have plenty of hot water).
  • Use solar during peak demand hours!

With some careful alteration of your electricity habits, most consumers would save hundreds of dollars a year on electricity with TOU rates compared to standard consumption charges. TOU rates are good for utilities and your electricity bill – and all that’s needed is to get the word out.

Understanding Public Utility Regulatory Policies Act of 1978 (PURPA)

Defining PURPA

Passed in 1978 as one part of the National Energy Act, the Public Utility Regulatory Policies act (PURPA), provided a major benefit to the production and integration of renewable energy.

The National Energy Act was conceived in reaction to the energy crisis of 1973. It contained a plethora of legislation that would aim to drastically cut the demand for imported oil. One such act, now today as PURPA, would give manufacturers of renewable energy a toe-hold in the door to large scale energy manufacturing and deployment, which is always appreciated. PURPA was meant to promote better energy conservation, domestic power production, and renewable energy construction and integration.

Prior to PURPA, electric utilities were structured in what is known as vertical monopolies, which basically means that they control all aspects of energy supply: the generation, distribution and control were all controlled by one company, which was originally thought to be more effective method of energy maintenance. Well, that is until PURPA was introduced and broke that model and would make it much easier for other energy companies to integrate into the grid.

PURPA also eliminated “rate structure” promotions offered by utilities. Rate structure decreased the cost of electricity by kWh with increasing usage, with smaller increments included, as well.

PURPA’s Role in Renewable Energy

PURPA enabled non-utility generators (NUG’s) to generate and attach energy to the energy grid by breaking the monopolies that held control of it. Not only that, but PURPA also forced utility companies to purchase energy from other energy producers, like producers of renewable energy, if that cost was less than their avoided cost, or the cost of producing the extra energy on their own and delivering it to the consumer. As a result, more and more cogeneration plants were built and implemented into the system. These plants were required by law to harness thermal energy in the form of steam, which would otherwise be wasted if energy alone was produced.

Controversy with PURPA

PURPA was not as big of an issue back in the 1970’s. However, more and more utility providers are having issues with PURPA. Specifically, having to accept renewable energy providers, specifically providers of solar energy, due to the fact that solar energy has become gradually more affordable and viable in energy production over the last few years.

One such controversy has erupted in Montana where the state’s largest investor-owned utility company, known as NorthWestern Energy, filed a claim with the state’s public service commission stating that the current rates of qualified providers (QF’s), which were stalled at $66 per mega-watt hour, was out of date as of 2013. The commission granted the proposal and altered the terms of which QF’s that provided between 100 kilowatts and 3 megawatts received the current avoided cost rate. None of the projects met the criteria.

The Federal Energy Regulatory Commission (FERC) declared that the Montana State Commission had ruled in a way that was inconsistent with PURPA. However, as of this writing, they have not made any movements to rectify the commissions movement, which begs the question as to how seriously PURPA is being enforced.

In another instance, a North Carolina based utility company, Duke Energy, is currently backing a bill that would bring all renewable energy construction to a slow crawl. Introduced by Rep. Dean Arp (R-Union), House bill 909 is encouraging the once halted negotiations between Duke Energy, renewable energy advocates, and other PURPA stakeholders.

The bill would remove all North Carolina renewable energy projects from the umbrella of PURPA, and would throw those projects into a bidding process lead by Duke Energy. The bidding would have a ceiling of a predicted 400 megawatts.

“This bill would crush renewables in every sense, except perhaps in agriculture,” said Chris Carmody, the executive director of the North Carolina Clean Energy Business Alliance. You can read more on the North Carolina controversy here!

But Montana and North Carolina are not the only states seeing conflict with PURPA. Utah and Oregon utilities are starting to call for new contract lengths, rates, and other changes. Solar companies have since stated that the proposed changes would make it impossible to finance solar projects. It is not farsighted to say that further controversy could emerge in the near future.

New Legislation Affecting PURPA

PURPA is seeing a steady decline in significance as most of the contracts signed in the 1980’s are coming to an end. Furthermore, PURPA was amended in 2005 under the Energy Policy Act of 2005. The amendments to PURPA begin on Section E, subsection 1251 through 1254 of the Energy Policy act. Here is a short list of what amendments were made:

  • Each electric utility service shall make available upon request net metering services to any electric consumer the utility serves
  • Each electric utility shall develop a plan to minimize dependence on 1 fuel source and to ensure that the electric energy it sells to consumers is generated using a diverse range of fuels and technologies, including renewable technologies.
  • Each electric utility shall develop and implement a 10-year plan to increase the efficiency of its fossil fuel generation.

Are Fixed Utility Charges Bad for Customers?

As solar energy and energy efficiency becomes more common, many electric companies have responded by dramatically increasing, or attempting to increase, monthly fixed utility charges.

What are fixed charges?

Fixed charges are static charges that occur on a regular basis. Most utilities have fixed charges, sometimes called an availability charge, on your monthly bill. Typically, this charge is small (less than $15-$20/month) and is normally in place to cover fixed costs a utility must provide in order for you to receive their service. An example of a fixed cost is the meter on your house and/or the expense to read it each month.

Throughout the United States, utility companies and, to a lesser degree, electric co-ops are charging solar users a fixed cost to re-coop the perceived loss of revenue from the users going off the grid, reducing their demand from the utility, or even just to discourage the use of new technologies.

The idea of large fixed cost increases originates from a suggestion in the “Disruptive Challenges” report released by Edison Electric Institute in January of 2013. Since the report was released, many solar users have seen fixed charges affect their monthly meter bill; sometimes costing as much as 50 dollars extra each month.

Fixed charges not only affect existing solar users, they have the potential to deter future users as well. Solar paying for itself is one benefit that is slowly being taken away; with one user saying, “I think the fixed fee for solar is excessive. When I do the cash flow that amount takes 25 percent of my monthly profit. It would take an extra three to four years to get the project paid off.” Most fixed charges push the payback on installations from a 10-year plan closer to a 13- or 15-year plan before the consumer begins to see that benefit.

David Shaffer, an attorney and development director of Minnesota Solar Energy Industries Association, said a high fixed charge, “decreases the cost-effectiveness of solar arrays and elongates the payback period,” he said. “Selling solar is based on the payback. If you get payback in under 10 years it’s a great deal, but if it’s beyond 10 years it gets more difficult.

Fixed charges cut into the viability of selling solar in those (rural) areas because financially it doesn’t make sense.” Another issue with fixed rate charges is their inconsistency. During 2014, as many as 23 fixed charges proposals were being considered by state regulators across the country and that trend continued through 2015.

In Minnesota alone there are different fixed charges depending in the company. Meeker Cooperative has a $55 net metering charge on an almost 40 kilowatt system, Xcel Energy has a flat fee for $10 a month for all customers but nothing specific for solar users, Minnesota Power has a monthly fee of $2.55 a month for a 20 kilowatt system, and the list goes on.

The increase in fixed charges hits close to home in the Southeast too. In the Southeast, electricity markets are primarily served by large integrated utilities. The Southeast also lacks a single regional transmission organization or independent system operator that establishes the economics of real-time transmission costs and contracts for ancillary services, or anything that supports the transmission of electricity from its generation site to the customer. Therefore, the responsibility falls to the co-ops, municipal utilities, and regulators to create smarter rate design and make economic decisions on the cost of service and constituent feedback. This often means individual states or regions are at the mercy of one company or local regulators who may not be as well versed in the intricacies of the electric market.

In a report conducted by the Kansas Corporation Commission, they concluded that increased fixed charges in Kansas would increase electricity use by 1.1 to 6.8%, varying by utility and season. This means the projected increase would be greater than all the energy savings from all the energy efficiency programs in the state. The same report found that such a change in rate structure and consumption would offset the financial benefits of decades of energy efficiency efforts and penalize customers who have already invested in or installed energy efficiency measures under the previous rate structure. The increase in fixed charges would weaken the incentive for future investors in energy efficiency, which could have negative impacts on the local economy and environment.

There is hope the trend may stop sooner than later. Regulators and stakeholders of utilities have begun seeking a new approach to fixed costs, with one idea being a demand charge that reflects the amount based on customer usage. One reason for this is the benefit energy efficiency will provide to the utility companies and customers alike. Contrary to some utility claims, solar is projected to decrease system costs for utilities. A new study by Rocky Mountain Institute shows that distributed energy resource (DER) customers with solar and battery storage provide value to the grid by reducing peak demand, deferring or avoiding system upgrades, relieving congestion, and providing ancillary services. In addition, other studies by utility regulators have found the value of distributed solar to exceed retail rates. For example, Nevada regulators found that the value rooftop solar adds to the grid is 18.5 cents/kWh, Mississippi 17 cents/kWh, Maine 33.7 cents/kWh, Minnesota 14.5 cents/kWh, and Vermont 25.7 cents/kWh.

Implementing fixed charges as blunt instruments will only result in a missed opportunity for utilities to align the interests of customers using DERs with those of the grid as a whole. Although still a work in progress, one thing is for certain. Massive hikes in fixed charges are bad for consumers, utility companies, and solar users everywhere.

Alabama Power’s Higher Fixed Charge Rate Options Deserve Careful Scrutiny

A few “lucky” Alabama Power customers will soon receive invitations to switch to one of two new rate pilot programs, called “Residential My Choice” or “Residential My Choice Plus.” Both raise the fixed monthly charge – by 260 percent and 400 percent, respectively – and lower the charge that’s based on how much power a household consumes.

It’s a worrisome move that could have implications far beyond the bills of a few customers.

The Alabama Public Service Commission (PSC) approved the new rate programs very quickly, just two weeks after they were requested on May 25. They’re voluntary and experimental… for now.

To continue reading our joint editorial in AL.com, please visit: http://www.al.com/opinion/index.ssf/2017/06/alabama_powers_fixed_charge_in.html