Local Power Politics: APS, AZCC and Things to Think About.

In my last political (well sorta) post I described how the local power company APS is organized and regulated by our Arizona Corporate Commission (AZCC) <link>. After that post and a few I did on local social media, I got a couple of requests to put this stuff all in one place. Well, I have a place to put it, and I'm getting tired of posting it over and over again, so here is my collection of gripes about our own AZCC and the power company APS. I decided to post this stuff on the blog because it related very directly with my efforts to keep the power bill as low as possible and the pitfalls, stumbling blocks and walls along the way.

I'm linking them all together on the (newly added) subject of 'Power Company' over on the top right of this page. Just scroll down to the 'P' and click on it.

The idea is that I can just put up a blog post, and then use a link to expand on my findings or thoughts easily without having to type them in all over again. Clever right? It also means that I can hit and run on social media. That means I can just slap a link on there and go off to the next place and do the same. There's a lot of social media sites that discuss this kind of thing out there.

No, I'm not a social activist, I'm a customer that is tired of getting raked over by politicians and corporations that are supposed to exist in our best interest.

Therefore, here are three 'Dockets' and one 'Announcement' that are recent and directly impact me and my neighbors in this area. They're real and verifiable. I try to put in links for the various items so people can double check me. Some of the text is my opinion, feel free to comment.

AZCC Docket # E-01345A-18-0111 - In the matter of the application of Arizona Public Service Company for approval of its Rate Rider RCP.

Last month (May, 2018) APS applied to the AZCC for a modification of the "rcp export rider for new on-site solar." This is currently being heard by the commission with no decision yet.

But, what the heck is this?

They invent names and acronyms to make it easier to describe things, but it also complicates reading this stuff to the point where people just give up and wander away. Resource Comparison Proxy (RCP) is a complicated series of observations to gather data, then calculations to show how much APS should be paying solar customers, people with solar that produce an excess of power and return it to APS.

What this is, is if your solar was installed after the cut off date, September 1, 2017, they want to change what they are allowing (as credits) for your excess power. Currently it's shown as $0.12900/kWh, almost 13 cents for each kWh you don't use and give to APS, and they want to lower it to $0.116 a little over a cent less.

They actually claim that it should be zero, but they're not going for that yet.

"... the avoided transmission and distribution capacity cost credit to be applied to the RCP should actually be 0%."

They already charge much more to supply power than they pay for it from the excess solar people provide, and now they want to lower that payment (actually credit). This is a decrease of over 10% to them. Essentially they're asking for a 10% decrease in what they agreed to just last fall in the last rate increase decision.

Yes, it's all above board and public in AZCC Docket #E-01345A-18-0111 and it's supporting documentation, but how many have heard about it? Is the news going nuts on this? Have you received any mail about it?

But wait you say, just last year APS agreed not to file for another rate increase until much later. That's completely true, but they're not asking for a rate increase, they're asking for a modification to a rider on your bill. See how it's done? You pay more, but they didn't do it, it's a rider on your bill. When you call them about it, they tell you it was approved by the AZCC.

Why aren't the solar companies complaining about this? Actually, the solar association has filed a response, they're angry that APS is attempting an end run around other agreements. For whatever good it will do.

Those that have solar already are managing to skate past it right now, but APS will be back before the AZCC soon. Those that are getting new solar will be impacted severely by the new rules, so this is a concern that everyone should be interested in.

E-01345A-18-0003 - In the matter of the application by Arizona Public Service Company to Implement Tax Expense Adjustor Mechanism.

This docket is actually in our (the customer) favor. When President Trump's tax changes came into effect, it lowered APS's tax rate to 21%, and they saved money. Someone realized, then insisted that APS revise their bill to reflect the savings instead of keeping it as a windfall. This was done under dockets #E-01345A-16-0036 and E-01345A-16-0123. The amount is a tiny percentage per kilowatt hour, but amounted to about $10 on my last bill.

The adjustment rate is supposed to be $.004258 per kWh, so the more you use, the more you get deducted from your bill. I question why they are paying it back by the kWh, it was a percentage decrease in taxes, why wasn't it a percentage decrease in our bill? When I looked closely at the docket, it was clear that they decided to play tax games with the requirement and deducted for various other things. They got to keep a heck of a lot of this windfall against their own expenses. One could also make a pretty clear case for discrimination; they get windfall money, then when caught, return it to their biggest customers by returning it based on how big their bill was. Our own APS sticking its hands in our pocket again. (actually, I may use that line in a complaint to the AZCC)

However, this also helps disguise the credit for money APS is saving in taxes as something APS is doing for us. It's not them giving us something, it's them not stealing something else from us. They even called it "TEAM" for Tax Expense Adjustor Mechanism, and shows up on the bill as "Tax Expense Adjustor."

PUBLIC NOTICE OF APS'S REQUEST FOR APPROVAL OF A FOUR

CORNERS SCR ADJUSTMENT (DOCKET NOS. E-01345A-16-0036 AND

16-0123)

"On April 27, 2018, APS filed a request for a Four Corners SCR Adjustment to allow recovery of an annual revenue requirement of $67.5 million. APS estimates that the average residential monthly bill impact would be an increase of approximately two percent. A copy of the request is available from APS  azenergyfuture.com), and at the Arizona Corporation Commission's eDocket website (edocket.azcc.gov), for public inspection in the above-referenced docket numbers"

The item above and the quote was one of those inclusions in the bill that we all toss out while looking to see how much they gouged us this month. What it's referring to is the pollution lowering devices called "Selective Catalytic Reduction" that they are installing at the Four Corners Power Plant. That particular power plant is coal fired and was cited for pollution. It's a long story beyond this author's willingness to write about right now. 

But, quoting directly from the AZCC filing:

 "(SCR Adjustment) to permit recovery of a $67.5 million annual revenue requirement."

You certainly see what is going on, the clue should have been "recovery." They want to pass the 67 million dollar per year cost of this stuff to their customers. Another quote from the same document:

"That would equate to an approximate 2% customer base rate bill impact. Additionally, APS requests that the SCR Adjustment become effective as soon as possible, but no later than January 1, 2019"

Yes, you read it right, they want to add another 'fee' to the bill to cover this and this one is a straight 2% increase in the base rate. Ever wonder why the base rate applies to all customers. This should give you a hint. You can read it yourself at <link>. It's also on the public record at the AZCC site under the unassuming name: "Motion/Request - Miscellaneous," but I suppose that's a little less noticeable than, "Motion to Screw Our Customers into Paying for Our Mistakes." The link to the document there is <link>.

AZCC Docket # E-01345A-18-0002 - In the matter of the formal complaint against Arizona Public Service Company filed by Stacey Champion and other Arizona Public Service Company customers

This docket is a direct complaint from a group of citizens against APS's latest rate increase (and fees of course). The dockets that the rate increase was approved were E-01345A-16-0036 AND E-01345A-16-0123. These two dockets were combined because they related to the same things. Eventually, they excluded existing solar, customers for the most part (more on that below), but most of us don't have solar, so the latest rate increase (and fees) from APS is directly impacting us; this also has significant impact on any new solar installations.

Stacey Champion, the named complainant, and a group of several hundred people gathered from a web campaign filed this, but as everyone suspects, APS is dealing in an underhanded fashion with the public and the AZCC. Want some facts to look up for verification? APS used the upcoming 2018 election as leverage against the Corporation Commission in writing and they did it on the public record. The following is a quote I copied and pasted:

"Unfortunately, APS is concerned that delay will only push this matter closer to the November 2018 election, which risks distorting this process and increasing customer confusion."

Which means: There's an election coming up and you guys may not get our funding if you don't end this now in our favor. Or maybe, if the complaint isn't decided soon, the voters may notice and vote against you. At any rate, it's pretty clearly a threatening statement. You want to see where they said this, go look at it on the state web site at this <link>. I think it's on page three.  Fortunately, Stacey Champion's lawyer noticed what they were doing and put this in the response:

"As for the November 2018 election, it is irrelevant to this proceeding and APS' professed concern that it "risks distorting this process and increasing customer confusion" should not trump Ms. Champion's right to due process."

Basically, Stacey's lawyer said, "We see what you're doing, and it's bullshit." If you want to read this it's at this <link>.This one is on page 4.

I also ran across the following part of a sentence when reading through an APS response to Stacey's complaint. I cut and pasted this right out of the document on the AZCC web site at <link>.

"(iii) an agreement with the solar industry to resolve a multi-year, otherwise intractable dispute regarding distributed generation that included a confidential agreement to avoid undermining the rate settlement through ballot initiatives, legislation, or advocacy at the ACC, "

What this means is that the solar industry in this state got together with APS and agreed that the solar folk wouldn't put up a ballot initiative, sponsor legislation or lobby the Corporate Commission. Since it is confidential, we don't get to see what the Solar companies got in return for GIVING APS FREE REIGN ON THIS RATE INCREASE.

Excuse my language, WHAT THE HECK??

We were all sold down the road by a secret agreement between APS and the Solar Industry ...

Yeah, this really makes me want to talk to a solar company in this state.

Now, if you do actually read this far, think about it a bit. Here is publicly held documentation that APS is using the upcoming election as a tool against the Corporation Commission and they entered into a secret agreement with the solar industry to shut them up. Now act accordingly. I suggest you visit Stacey Champion's site, read the documentation and contribute to the effort. Stacey is taking on APS for us, and they're driving her down with legal fees. If she has to withdraw because she can't afford it, that's the end of the effort to get this back for a rehearing.

https://www.fundedjustice.com/StopTheAPSGreed?ref=ab_6Ezo8KIX4xn6Ezo8KIX4xn

You can also file a complaint directly with the AZCC in support of Stacey's docket. Heres how to complain:

 What you have to do is go to

http://eservice.azcc.gov/Utilities/Complaint

And file a complaint.

You MUST state that you're commenting on the existing docket number E-01345A-18-0002 in the first line so they can see what you're doing. I started mine off with:

"In support of Docket Number: E-01345A-18-0002 It appears that APS did not deal in good faith with its ratepayers, the Corporation Commission or the public in general. "

The "In support" part means you agree with Stacey Campbell that APS is a bunch of thieves, and it also shows up in a listing of the documents filed on this docket. You also have to fill out all the blanks in the form to identify yourself as a customer of APS so you will be taken seriously. At the bottom of the form is a space to type in exactly what you think about this.

We have elected representatives in the state legislature, time to actually use them and see what happens, so here are the two for District 1. I'm listing their web pages so you can get to the mail facility easily.

David Stringer is at:
https://www.azleg.gov/House/House-member/?legislature=53&legislator=1748

and Noel Campbell is at:
https://www.azleg.gov/House/House-member/?legislature=53&legislator=1718

State Senator Karen Fann is at:
https://www.azleg.gov/emailazleg/?legislatorId=1774

Just click on their email address and let them know what you think about this.

Sorry this is so long, but I wanted to get the actual links in so you can see for yourself what I have seen.

I really hope I made you angry.

Oh, one other thing: the spam will really be flying on this post, so be warned: talking about how great your solar plan is, sales blurbs or obnoxious comments will be deleted without remorse.