So, it’s been quite a while since our last long policy post, focusing on utility revenue decoupling in connection with Xcel’s current rate case (14AL-0660E) before the Colorado PUC. That’s because we’ve been busy actually intervening in the case!
A Climate Intervention
We filed our motion to intervene in early August. As you might already know, in order to be granted leave to intervene, you have to demonstrate that your interests aren’t already adequately represented by the other parties in the case. Incredibly, CEA’s main interest — ensuring that Colorado’s electricity system is consistent with stabilizing the Earth’s climate — was not explicitly mentioned by any of the other parties!
In our petition we highlighted our mission:
…to educate the public and support a shift in public policy toward a zero carbon economy. CEA brings a unique perspective on the economics of utility regulation and business models related to mitigating the large and growing risks associated with anthropogenic climate change. In addition, CEA has an interest in transitioning away from fuel-based electric generation in order to mitigate the purely economic risk associated with inherently unpredictable future fuel costs.
…and we were granted intervention. So far as we know, this is the first time that concern over climate change has been used as the primary interest justifying intervention at the PUC in Colorado. In and of itself, this is a win.
A Long and Winding Road
Throughout the late summer, we spent many hours poring over the thousands of pages of direct testimony. Especially Xcel’s decoupling proposal, but also (with the help of some awesome interns), the details of the company’s as-of-yet undepreciated generation facilities — trying to figure out how much the system might be worth, and so how much it might cost to just buy it out and shut it down (were we, as a society, so inclined).
Early on in the process, the PUC asked all the parties to submit briefs explaining why we thought it was appropriate to consider decoupling in the rate case, whether it represented a collateral attack on decisions that had already been made in the DSM strategic issues docket, and how it would interact with the existing DSM programs. We pulled together a response, as did the other intervening parties, and kept working on our answer testimony — a much longer response to Xcel’s overall proposal. The general consensus among the parties that filed briefs, including CEA, SWEEP, WRA, and The Alliance for Solar Choice (TASC, a solar industry group representing big installers like Solar City) was that decoupling was not an attempt to roll back previous PUC decisions related to DSM — and that addressing it in a rate case was appropriate. Only the Colorado Healthcare Electric Coordinating Council (CHECC, a coalition of large healthcare facilities and energy consumers) told the PUC that decoupling ought to be considered an attack on previous DSM policies.
The PUC staff unfortunately came back with a reply brief that disagreed and suggested, among other things, that maybe it would be better if we just went with a straight fixed/variable rate design to address utility fixed cost recovery. Never mind the fact that this kind of rate would destroy most of the incentives customers have to use energy efficiently.
And then we waited.
With baited breath each Wednesday morning we tuned in to the Commissioners’ Weekly Meeting, streaming live over the interwebs from the Windowless Room in Denver. We watched regardless of whether anything related to our dear little 14AL-0660E was on their agenda. Just in case they tried to sneak it by. Weeks passed. And then a month. The deadline for submitting our answer testimony approached.
Finally on October 29th, six weeks after submitting our brief, the commissioners finally brought up the issue of decoupling at their weekly meeting and in a couple of minutes, indicated that they’d be severing it from the proceeding, with little explanation as to why. However, because there were no details, and the order isn’t official until it’s issued in writing… we continued working on our answer testimony. The final order came out on November 5th, and prohibited submission of testimony related to decoupling. Answer testimony was due on November 7th.
Where to From Here?
Xcel might come back to the PUC with another decoupling proposal before the next Electric Resource Plan (in fall of 2015) . Or they might not. This means that a good chunk of the work that we’ve been doing since this summer will have to come to light in a different way. So for the next few posts, we’re going to explore some of the issues that came up in the preparation of our answer testimony, including:
- Decoupling and Distributed Energy:
How would decoupling interact with distributed energy resources like rooftop solar? What are the implications for utilities as the costs of those resources continue their precipitous decline?
- Decoupling and Demand Side Management:
How would revenue decoupling interact with demand side management programs in general — both utility and privately or locally funded — and what particular issues with Xcel’s DSM programs could decoupling address? What issues can’t it help address?
- Can Revenue Decoupling Scale?
Why doesn’t revenue decoupling as a policy really scale up to the point of taking existing generation facilities offline, or preventing new facilities from being built?
- Decoupling as a First Step:
Even if it can’t scale, why might decoupling still serve as a useful starting point for the decarbonization process? Can it give us a little bit of breathing room while we start the real negotiation? Or is it just another layer of financial protection for utilities who want to delay change as long as possible?
- Realism and Equity in Carbon Budgets for Colorado:
What is the true scope of the decarbonization challenge, in the context of the carbon budgets recently published by the IPCC in their Fifth Assessment Report (AR5), but localized to Colorado so we can actually wrap our heads around it. Why is this conversation so hard?
Featured image of binders (full of PUC filings…) courtesy of Christian Schnettelker on Flickr. Used under a Creative Commons Attribution License.