Submitted to CPS Energy and San Antonio Mayor during the CPS Rate Case Input Session, Monday, Sept. 9, 2013.
The Re-Energize San Antonio Coalition opposes the proposed CPS rate hike because it promotes unsustainable growth, fueled by dirty energy, and unfairly burdens residential ratepayers, especially middle-class and poor San Antonians who have been disproportionately hurt by the Great Recession. Any change in costs to rate-payers must be prefaced – at the very least – by the following conditions and actions.
- CPS must prioritize energy conservation and efficiency. The rates must create energy-conservation incentives for all users, not just home-owners but also businesses, non-profit organizations, and governmental offices. City policies and CPS internal policies and budgets should prioritize energy conservation and create disincentives for unsustainable growth
- To that end, CPS’s rate change should set up multiple tiers. For example, the first “x” kilowatt hours used each month (e.g., the minimum amount of electricity necessary for a family of five to maintain a healthy home) should cost less than the current rate. The next “y” kilowatt hours used each month (e.g., an amount between “x” and the current median household usage per month) could be billed at the current rate. The third tier (e.g., from the median – 50th up to the 75th percentile of the current usage) of kilowatt hours per month could be billed at 105 percent of the current rate, and any usage above the 75th percentile could be billed at 120 percent of the current rate.
- Similarly, CPS’s rate change must not unfairly burden residential and small-business rate-payers. There should be no discounted or “wholesale” rates for energy-intensive businesses. If CPS needs to develop new energy-producing facilities, the funds should come from the businesses that use that energy to make their profits. Any rate “breaks” should be based only upon measurable social benefits that the business provides, such as employing large numbers of workers at living wages. Wholesale rates to other communities should be predicated upon their engaging in similar energy conservation efforts, linked with their retail rates for selling that energy. There should be multiple tiers of energy rates for businesses, too, to reward energy efficiency and conservation. Profitable businesses should be willing to invest some of those profits in San Antonio’s future. Already we have many examples of companies taking that “high road,” but CPS needs to embed such investment as a requirement in its rate structure.
- Most of the increased income from residential rate changes should be earmarked for extensive and effective programs for improving the energy-efficiency of homes – specifically, those owned by working-class or impoverished families. The remainder of the increased income from residential rate changes could be applied to help small-scale landlords of rental units upgrade the energy efficiency of apartments and houses. Some of the increased income from business rate changes should be earmarked for investment in city-owned and public/private decentralized local renewable energy-production – to replace non-renewable sources now used, but also to prevent the city from being “captive” to some of the energy-producers from which we now buy wind-generated energy. Another portion could be earmarked for improving the energy-efficiency of not-for-profit institutional buildings, such as schools.
- Emphasis on co-investment in local solar production should be expanded not reduced. Net metering is an excellent way to promote energy efficiency in homes and businesses and increase the amount of energy being produced in the community. And other models are worth exploring: e.g., encouraging homeowners to buy a share of a solar array located on a school’s roof, and then allowing that share to be sold as part of the value of their house. Community-based decentralized solar programs should be made accessible to all, including low-income families.
- CPS should support dramatic changes to the city’s building code and other policies so that they require energy-conservation measures, such as solar hot water systems on all new or newly renovated apartment buildings. CPS should support immediate adoption of the 2012 IECC building energy codes for new residential and commercial construction. CPS should be proactive in rapidly implementing the higher energy efficiency goal suggested by the 2004 KEMA study. Furthermore, the KEMA study is almost 10 years old, so it does not take into account advances in technology. CPS should actively encourage a new study of how San Antonio could become even more energy efficient.
- Existing customers should not shoulder the burden of increasing system growth by paying for the connection of new developments. CPS Energy should revise their interconnection policy and charge much more for large commercial and residential development, so that most of the cost of new growth is borne by those promoting (and profiting from) the growth. These charges could be reduced for development that exceeds the 2012 IECC codes by 20 percent or more.
Pollution and Public Health
- CPS must effect the rapid reduction of threats to public health due to its use of dirty or dangerous energy sources. CPS should put in writing its commitment to close the Deely coal-fired power plant by 2018 or earlier. The plant should be shut down as soon as possible, because the public has already paid too much in health costs.
- CPS should prepare to close STP 1 and 2 (nuclear power plants) at the end of their original operating permits, if not earlier. This facility has been experiencing increasing problems, costs and risks as it ages. In fact, one of the units was inoperative for much of 2012 due to ongoing problems.
- CPS must plan for decreasing use of natural gas-fueled power production. Although the actual combustion of natural gas may be less polluting than coal or petroleum fuels, the entire process of extraction, especially the use of fracking, is extremely polluting. The people of San Antonio should not have to pay for this relatively cheap non-renewable energy source by enduring air pollution, greenhouse-gas-induced heat waves, and other by-products of this CPS energy source. Until natural gas can be phased out completely as a fuel for CPS energy, CPS should buy gas only from producers following best practices and reducing pollution, waste and water use. By establishing standards to ensure that the gas it purchases, uses and sells is produced with the least polluting technologies all the way back to the well head, CPS can help establish new standards for the industry and reduce smog-forming ozone.
- CPS must be pro-active in exploring and implementing technologies for genuinely renewable and environmentally friendly energy production to replace old, dirty, and dangerous energy sources. For example, CPS should investigate and procure geothermal energy production as a source of base-load renewable energy to meet the growth needs. Significant deep geothermal resources exist near San Antonio. CPS Energy should help develop these renewable and low-emission sources of energy for its generation portfolio. CPS Energy should update its generation plan and incorporate geothermal energy as part of its renewable contracts along with its large-scale investments in wind and solar energy.
The Re-Energize San Antonio Coalition includes Energia Mia, The Esperanza Peace & Justice Center, People’s Power Coalition, the Sustainable Energy and Economic Development (SEED) Coalition, Public Citizen’s Texas office, and Sierra Club.