Sierra Club Presentation to the Colorado Public Utilities Commission

This was written to be presented to the Colorado Public Utilities Commission on June 9, 2016. It was a Power Point presentation. I planned to show the slides. I planned to speak the comments under the slides while that slide was visible. The comments were not visible. The comments proceded with "||" were there for my reference only. None of the links, background, calculations, or justifications were part of this presentation. They only exist here. I did not give this presentation. They did not have any formal presentations. I gave a two minute "bumper sticker" speech. I gave them a hardcopy of the Power Point presentation and sent this link to them.

|| My two minute "bumper sticker" speech.

Your Honor, This is addressed to Xcel Energy. I know the Commission can intrepret.

You can fight Renewables and die in the solar death spiral or you can work to make Renewables work and live to be a leader.
Your industry is now market driven by Natural Gas costs. If you live by the market you die by the market.
You canít see the value of Renewables when you hide your Fuel Costs in your ďtariff du jourĒ.
WE canít AFFORD Renewables if they are being gamed.
In November, I am going to vote FOR Amendments 75 & 78 to stop fracking. If you spend time and money on defeating them you are fighting Renewables.
Buying Solar from Large Solar Arrays at 5 times the going rate of RECs plus adding Transmission charges is fighting Renewables.
Not connecting Rooftop Solar is fighting Renewables.
Using the Clean Air Clean Jobs Act to buy a Natural Gas Generator is fighting Renewables.
NOT buying Batteries to make Renewables FIRM is fighting Renewables.
Sooner or later you will decide to support Renewables. I hope it is sooner.
Thank you.


In this age where the average citizen has ZERO input into any legislative process and public policy, I most sincerely appreciate the Public Utilities Commission giving me this opportunity to present my thoughts.

I am addressing this to Xcel Energy When I say "You", I am meaning Xcel Energy Else I will say "The Commission" or "The PUC".

I recognize the Testimony and Rate Case is Public Service not Xcel Energy. And this is the COLORADO Public Utilities Commission.

Can be viewed online at:


Where I am heading ?

Rooftop Solar is GOOD. You need to buy Batteries. We have to think about the solution not the tariff.


This is a battery. It converts intermittent energy to FIRM energy.


Each of the 10 cabinets is the size of a giant refrigerator
There is a 3 phase inverter, and a monitor / control module.
The green grass comes extra.

I am buying you this battery. Well part of it anyway. 1 kWh for $542


|| Calculation Cost: 83% efficient = 1 kwh / .83 = 1.205 kwh. You put 1 kWh in the battery storage at 0 cost. Plus you need to add 205 watts from a Renewable Energy Credit (REC) purchase at 2 cents per kwh = .205 * $0.02 = $0.0041 per kwh. So, your virtual solar bank tied to a battery costs $0.0041 per kw ($4.10 per MWh). How did I come up with a REC purchase at 2 cents per kwh ($20 / MWh)? The customer signed a contract for that amount.

|| stores 2 hours of power at 50 KW.
|| L x W x H: 1,321 mm (52") x 966 mm (38") x 2,185 mm (86")
|| Weight: 1,720 kg (3,800 lbs)


Costs associated with energy have numbers in the USAGE UNITS, and RATE columns


Two lines are associated with renewable energy.


Here are those two Renewable Energy entries.

I bought that 542 dollar, one kwh on time with monthly installments.

Yes, even YOU can have a kwh. With nothing down and only 113 monthly payments of $4.78 !! But wait Ö thereís more. If you order now, weíll throw in that green grass.


Awh shucks. Itís not a battery after all. And it is not renewable.

There are 3 projects in Colorado. One is a new natural gas plant.


Note Capital dollars: generation engineering units are kW not kWh. It takes fuel to convert kW to kWh


Here is the fuel. This is using your new Gas turbine. And the bottom two lines say: Past Performance is No Guarantee of Future Results.

These two costs will show up in my Risk Summary later projected out 30 years.


|| The May 2016 price (When I printed this Chart) was $2.06
|| Two years ago the price was $4.50
|| I donít know what your long term contract for gas is
|| But I am comfortable saying it will be greater than $2.06


This is comparing different years, different technologies, and different storage costs.

I know you are working on a battery. So you understand the importance of them. This was YOUR project in 2010. It was with Wind not Solar but THIS is just Battery Cost. And you currently have PUC approval to spend $9.1 million on a utility-scale solar power system with one large battery and 6 house-capacity size batteries here in Denver.


If you want to get into the Solar Farm and Wind Farm business. You should pay the same $10 / MWh cost you are paying investors. And you have to pay Transmission. The Solar Farm arrays cost less per kWh but more when you add Transmission. And a LOT more when you pay the Solar Panel Capital.

I canít do a cost justification here because I donít know how divide ďutility-scaleĒ by ďlargeĒ.


For Solar, the home owners are providing the Capital. The battery cost reflects the efficiency of 83%. You are getting more than time. You canít justify old plants for peaking and ancillary services.

I am ignoring Transmission costs with rooftop solar. Transmission costs can NOT be ignored with Solar Farms and Wind Generation. (Unless your neighbor has a wind turbine in their back yard.)

I donít think you can sell the concept of Company owned Solar to the PUC when you are dragging your feet connecting FREE rooftop solar now. Plus wanting to add $7.94 to the customerís bill. (That is from page 35 of your testimony).


Which brings us to the Solar Death Spiral. Solar energy bills are zero. You have less income. You use a Solar Rate Adjustment to cover your costs. That increased rate drives your Non-Solar customer away to Solar. Repeat until bankrupt.


Investment in solar lowers the solar userís cost. During the day energy goes out the Solar meter and into the non-solar meters. Xcel gets Solar FREE energy and sells it at full price. Xcel replaces the kWh at their convenience and price.


Reading the testimony on Pages 30, 35, and 44 doesnít fit the facts.



Your description of the solar bank is amazingly clear. The lawyers must have called in sick that day.


In addition to converting Intermittent to Firm energy, You can control your battery to control your distribution and transmission costs. The Battery SCADA Control can use the net meter as the remote setpoint.


This is a Virtual Net Metering Bank carried from your Solar Bank concept. I think this is more important than spending your money on Production meters. Your testimony on page 35 says you want to install them. Is this so you can differentiate investors from solar consumers? Because you pay investors $10 not $20 / MWh. A check box on the bill would do the same. You wouldn't pay for that production at a lower price than what you sell it for back at the customerís other meter. That would be unconscionable.


I took the production numbers from your testimony. I filled in the knowns and back fit the fourth entry. What is the breakout of Profit (or waste or hidden costs) at $68.88 / MWh ? We canít get to Renewables if we donít call Fuel Cost what it is.


The Solar Farm arrays cost less per kWh than rooftop but more when you add Transmission. And a LOT more when you pay the Solar Panel Capital. How do you justify purchasing Solar Panels when there is FREE solar waiting to connect? Why is High priced Solar with Transmission and a bad power factor better? Aren't your costs supposed to be Pass through?

June 12, 2016 - Revision
CORRECTION TO Page 15 Ė This page uses Production Rate correctly

Production $219,683,574 / Annual kWh 8,880,334,513 = $0.0247382 / kWh
The testimony submitted on June 9, 2016 incorrectly used
Total Fixed Cost of Lost Revenue NOT Cost of Production
Total Fixed Cost of Lost Revenue includes Production, Transmission, DSM,
and Riders: CACJA, PCCA, TCA, and DSMCA for a Total of = $0.04852 / kWh


$50 / MWh is not Economy by scale

|| 19 panels = 4.1 kW
|| 2317 panels = 500 kW
|| 65 in x 39 in x 2317 / 1296 sq in per sq yard = 4532 yards
|| 100 yards 45.3 yards wide -- football field is 53.3 yards wide


These are rates only Ė NO Capital. The negative dollars reflect where it is cheaper to pay you to take the energy than shut down and re-start a system. (I'll bet they wish they had batteries.) Here is your Solar Bank at $4.10. Wind is O&M Ė the gear box is unreliable and they are 10 percent of the equipment costs. An aside: Is anyone aware of using a Turbine Blade connected directly to a Brushless DC generator connected directly into the DC back end of a battery? I think the $50 REC Contract price is Greed in the Solar Utility Industry. I suspect Fort Saint Vrain numbers reflect Natural Gas Costs in 1998. Your current Retail Energy is at $87.35. Zuni is there AND BELONGS there because you are in a risk adverse industry and everything is in the present NOW. Enron's numbers reflect them gaming the system.


Storage does not have an energy rate AND is shared by everyone. This is comparable to your tariff for $7.94 because it is shared by everyone. It is different because this is DEDICATED to Buying Batteries.

I'm saying $7.94 is DIVIDING the Rooftop Solar against everyone else. And doesn't tell us where it is spent. The Annual $27.87 Storage is saying we are all buying CLEAN FIRM Energy. And it's less than the cost of your CACJA at $38.40. CACJA is not buying renewables.

The $50 REC Contract Solar large array investors can buy their own batteries.


Storage is a Fixed charge I added distribution and made up the numbers. The Renewables rate is the average of Solar, Wind, and $10 REC Investor costs The Fuel Cost Adjustment rate is the average of Gas Turbine May 2016 costs and May 2014 costs.

The Net Meter bank is at work in Distribution and Transmission.


In November, I am going to vote FOR the amendments to stop fracking. If the amendments pass, the cost of Natural Gas is going to go up. Your risk is: $1.88 Billion (with a B). That is gas turbine costs from May 2016 and May 2014.

Your industry is now market driven. If you live by the market you die by the market. Renewables are not market driven. But they are intermittent and you are in you are in a risk adverse industry. You need a battery to make renewables FIRM.

What is the best solution for risk? Buy TIME. Buy a Battery.


The $48.52 should be labeled Total Fixed Cost Lost Revenue
Enough said.

|| (I should have included Electric Vehicles in the last point.)


To the Commission: Their testimony on Page 5 talks about closing tariffs, initiating new tariffs, and modifying others. I would like them to stop using the tariff du jour.

We can't get to Renewables if we don't call Fuel Cost what it is. We can't afford Renewables if we are being gamed. We can't make Renewables FIRM if we don't have Batteries.


I think the Commission needs to look at the Battery as a serious element of today's energy mix. And I think Hawaii will help provide that viewpoint. I hope you will contact them.


I thank Bryce Carter, Conservation Programs Manager, of Sierra Club for suggesting I present this. I thank Xcel Energy for putting up with my rants. Sooner or later you will decide to support Renewables. I hope it is sooner. And I thank YOU the Commission for listening to it.

09June2016 Creative Commons License
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