Saturday, March 9, 2013

Objection to Revenue Decoupling (2009)

Objection to Revenue Decoupling
mar 10, 2009

Chairman Jones, Commissioners,

My name is Erik Hawkes and I strongly oppose Revenue Decoupling or any other ratepayer-funded energy efficiency and load reduction programs.

Why must the utility now compete with local businesses to offer energy efficiency and to install DG [distributed generation]?

Why must utility earnings now be immunized from sales fluctuations? This sounds like a planned economy to me.

Revenue Decoupling guarantees actual earnings at the level of authorized earnings.

According to Alternative B for case 08-00024-UT, the definition of revenue decoupling is: a utility rate design mechanism that results in utility revenues not being affected by changes in customers’ average energy consumption.

Will off-grid customers now receive a bill from the utility company?

Is net metering or even load displacement still possible?

Their idea of energy efficiency is this:
You have 2 options.
Build another power plant for 1 dollar per person; or drive consumption down and charge them only an extra 50 cents. [charge you more for less]
This logic says that B is twice as efficient.

This is ludicrous. If this passes, we will now pay more for the energy we consume, and also more for the energy we do not consume.

The correct approach should be to charge more for not being energy efficient (positive price tiering) - already this way.

Yet, 17.7.2 proposes to [bill] for being energy efficient so that PNM is not adversely affected by a shrinking market. Who said that PNM was guaranteed a fixed market, independent of changes in consumption?