Friday, December 19, 2014

open letter to SRP and all publically owned non-profit utilities...



"PROPOSED ADJUSTMENTS TO SRP’S STANDARD ELECTRIC PRICE PLANS
EFFECTIVE WITH THE APRIL 2015 BILLING CYCLE"


Most people never are concerned with documents as the one above from SRP (utility). These documents are arcane and hard to read, yet this particular one could easily be a bomb-shell for the Phoenix metro area with regards to solar power...

As it turns out this is a pattern across the nation, Wisconsin's solar is now dead, Texas, New Mexico, California, all have battles raging, with the utilities attempting to squash solar energy on roof tops, using the same game plan. A real "power" grab. Keep in mind that solar energy contributes a tiny fraction of overall energy today in the USA. Based on science, economics, engineering, and social factors - solar has been determined globally to be the only known wide-spread solution for the majority of our future energy needs.

SRP, a Phoenix based non-profit utility, has recently proposed rate and policy changes that will servery curtail all new solar projects (rooftop) in the Phoenix metro area. This is detailed in the "Blue book", a report which will be reviewed among a select few, and possibly adopted in 2015. After December 8, 2014, it is no longer possible to install solar under the existing policies that make solar energy work for private owners connected to the grid (without storage). the few select knowing this submitted applications recently. The applications submitted to SRP in a few days was more than 3 months worth... The door is now closed.

So here is an open letter to the SRP customers, the government of Arizona and SRP:

Problem statement:
SRP is one of the nation’s largest community based, non-profit utilities, historically very supportive of distributed roof-top solar. In the last week they have proposed to eliminate the option for roof-top solar. SRP’s ~1 million customers are affected. Instead SRP plans to rely in large part (over 85%) on non-renewable fossil fuel and nuclear based grid energy. Furthermore, they are depriving their customers from lower cost energy that is possible by customer based investments in alternative energy. Additionally these draconian measures will largely destroy the newly formed AZ solar industry, just as it begins the monumental task to transition AZ to a renewable energy future.
SRP’s proposed policy actions are a surprising reaction to a very real challenge; how to make solar energy affordable and deployed in a large scale. The global move towards solar energy (and wind) is a foregone conclusion based on science, engineering, economics, and social impact. (note 11) SRP’s choice to not participate in this energy transition is irresponsible.
Furthermore, SRP is pitting non solar customers against solar customer with a cute and over simplistic video (note 7) explaining how roof top solar works. This is at best misleading and certainly not fair to those customers pioneering our sustainable energy future. This video show peak demand out of synch with solar energy production, this is just simply incorrect. Solar without storage never claimed to be the end-all solution. SRP’s new rates & policy promise to be “balanced” and “avoid higher bills in the future”, showing how a non-solar customer “share of grid costs” are small and solar customer grid costs are much higher, completely missing the good impact solar has to the grid when peak demand is high, and the benefits to the human eco-system. And finally it misses the very real fact that it eliminates rooftop solar altogether. The same video claims to be making decisions based on what is best for its customers, yet SRP’s current actions and current plans do not line up with where the rest of the planet is moving.

Background:
For profit utilities in AZ are regulated by a publicly elected governing body (ACC), however SRP is exempt. SRP is now for the first time using this unfettered authority to circumvent state laws that are in place to support solar power for the people, by the people. They are doing so by changing rate plans and energy policy to make self-generated solar economically unfeasible (i.e. “freezing” net-metering, reducing solar production credits, charging higher base fees). While other states and utilities are moving forward, by supporting net-metering laws and setting aggressive renewable portfolio standards (RPS), and rewarding solar investments with financial aid, SRP chooses to undermine and end distributed solar. SRP is also exempt in having to achieve any RPS goals. The only current SRP plans are to include more carbon based (gas and coal) power generators (Pinal Central and Navajo Generating Station). No renewable energy projects are in the works, despite SRP claims to increase sustainable resources up to 2025. (note 1, 6).

Pro and con reasoning:
SRP reasons that the policy changes are due to “unrecovered grid costs associated with customer generation” (note 8). By SRP’s own measure (note 2) 206 GWh of solar energy was generated in 2014 out of 33’567 GWh total, or 0.6%. Any possible “cost” burden of a power generation source that amounts to 0.6% would seem quite insignificant. It is simply not a plausible argument that we need to limit all new solar power today due to a cost burden now or in the near future. Even if solar were to grow by a factor of 10 in the next few years it would amount to 6%, hardly an urgent matter that requires a full stop to solar energy and the dismantling of the local solar industry. Germany now produces 7% of their energy with solar (note 4). How is it that Germany can achieve this level and SRP cannot? Possibly they have more sun than Arizona… In fact wholesale power prices in Europe’s biggest economy (Germany) dropped 32 percent since 2010 due to record wind and solar output. Imagine the very positive economic benefit of SRP reducing the cost of living in Arizona with a rate decrease… (note 9).

Proposal:
Due to Arizona’s natural resources, solar is the only current option that is sustainable and affordable. The solar pioneers that are investing their own capital and taking all the risk deserve a cost savings on their energy bill, as they are helping pave the way for the rest to follow. This is not a problem as SRP frames it, it is how proper incentives work. In any case, SRP does not clearly define what the so-called “unrecovered grid costs” are, citing that the “self-generation customer does not pay for the full amount of the fixed costs” How big is this problem? If solar is 0.6% of the energy mix, how urgent is this matter? If we are going to talk about future costs let us do so in an open and detailed way (balance sheets, future generation plans, etc.). Let us debate this over the next few years, and make small adjustments along the way as Germany has done with their incentives in order to provide stability. A proper analysis will consider the full costs of fossil and nuclear fuels; from mining to waste production and mitigation. Disclosing the full impact on our shared human eco-system. A full report will consider the effects of strip mining public land, uranium superfund sites in the Navajo lands, mercury in our food, depletion of water resources, haze over the Grand Canyon, and so forth (note 10). Our land is not free - unlike the sun’s rays. Some consideration must be given to the ominous impact of global warming. It is not a simple matter, nor should it be treated as such. A much longer instructional video based on real science and engineering by SRP would be appropriate in order to be “fair” and in the public’s true interests.

Conclusions:
If in fact after this thorough study over the next few years it turns out that the future cost of cleaner energy will be higher - due to less expensive (existing) options no longer being an option, let us not run away from this fact now. Let Arizona and SRP aggressively solve the problem in hopes of mitigating it. When the USA set the goal to land a man on the moon it did so without having all the answers, yet we found a way and grew stronger in the process. As a community based, non-profit utility one would hope and expect that SRP would take a longer perspective, be part of the solution to our energy future, and support the local and global solar industry to find ways of cost reducing these sustainable solutions.

Immediate actions:
SRP should perform the following five achievable actions: pledge to support the utility laws in place today (e.g. net-metering), immediately match RPS goals that other progressive utilities can achieve, provide stability to the nascent solar industry which we need to pin our future on, and enable the participation of SRP customers that do not have the ability to own solar on their own property.
Specifically:

1)  a pledge to be bound to the same ACC laws as the other utilities in AZ. RPS and Net-metering is a state law, and should not be “frozen” without proven cause and viable solar alternatives (e.g. feed in tariffs, etc.).

2) SRP to take a leadership role as one of the nation’s largest public power utilities, and to better serve the citizens of AZ by increasing its own RPS goals to match that of California. A goal easily achieved given our abundant solar exposure, low cost and willingness by private public and business to fund and develop solar power plants, and wide-spread popular support for solar. If SRP is unable they should be able to explain in detail why Germany can deploy so much solar and Arizona cannot. We will attract the businesses of the future to our state and all will benefit.

3) to maintain or improve the current policies and rate plans for renewable generation until solar and wind provide more energy than 13% (% basis of total production), this is based on the current goal set by leading utilities in the USA such as PG&E. Only small adjustments are allowed after this period to not destabilize the solar industry (note 3).

4) for those that rent living space, or cannot install solar on their business or residence - provide support for privately funded energy co-ops (collective ownership) in order to not disenfranchise those that are willing to risk some investments in order to help provide a sustainable future. Virtual net metering is a simple matter of accounting for SRP, and shows leadership and equality, providing a more competitive alternative to what is offered today by the SRP Community Solar™ program. Again, others have paved the way such as Clean Energy Collective. (note 5)

5) SRP to plan and install more utility solar power plants, and begin to solve the matter of utility energy storage.

Notes:
8) page 154 in the following document:  http://www.srpnet.com/prices/priceprocess/pdfx/BlueBook.pdf