Joe Levi:
a cross-discipline, multi-dimensional problem solver who thinks outside the box – but within reality™

Help Keep Solar Affordable in Utah

Levi Solar Array. (C) 2016, Joe Levi.

The Utah Public Service Commission is scheduled to hold a Public Witness Hearing (Net Metering 14-035-114) today, 09 August 2017 to discuss Investigation of the Costs and Benefits of PacifiCorp’s Net Metering Program (Docket No. 14-035-114).

The following is an open-letter and submission of public witness comment to the Utah Public Service Commission. Please feel free to use parts of this in your letter to the Commission.



SUBJECT: Reject Solar “Penalties”, Help Keep Solar Affordable in Utah

Dear Utah Public Service Commission,


I apologize that I cannot attend today’s Public Witness Hearing in person. I, like the majority of those with Solar Panels, have a job which requires my presence. Please keep this in mind when evaluating the response to this issue – the lion’s share of us are at work.

I have 45 solar panels installed on my home. I heat and cool with geothermal. I drive a plug-in electric car. Some might call me the “poster-boy” for green energy.

In the winter, heating with geothermal is relatively expensive. Unlike most Utahns, my power bill is higher in the winter than it is in the summer.

To accommodate for this, I calculated how much electricity I use over the course of an average year, then sized my solar installation to produce an equivalent amount of energy over the year. The challenge for me is that – just like the farmers around me – I have to collect the sun during the summer, then “store” it for use in the winter. I obviously cannot have enough batteries to do this.

Rocky Mountain Power’s proposal de-incentivizes me from using clean solar power, and pushes those like me to use “dirty” energy sources like wood burning stoves and propane for heating.

Is this really the outcome the Utah Public Service Commission wants?


That’s just the over-simplification of this particular scenario. Let’s look at RMPs arguments.

I know how wholesale and retail work. I recognize that RMP “buys” power at “wholesale”, marks it up, and sells it to customers at “retail”. I realize that it’s that markup which pays for all the overhead required to deliver their product – power lines, transformers, linesmen, billing clerks, computer systems, executive golfing trips, etc.

On the surface, RMPs argument makes sense – but RMP isn’t telling the whole story, nor are they representing the actual costs. Their recent costs study illustrates this point. Let’s look at a few concerns with RMPs arguments:

  • First, transmission costs: the cost of delivering power from coal-fired power plants to neighborhoods up and down the Wasatch Front isn’t cheap. The cost of delivering power which I produce from my solar panels to my neighbors is virtually zero. RMP pockets those savings with no compensation to me.
  • Second, it’s not a fair comparison: to get a true cost comparison, RMP needs to evaluate equivalent products. Electricity produced by burning coal is not the same as electricity produced by rooftop solar panels. Yes, the perceived end-product is the same, which is how they’re trying to confuse the issue.
  • Third, under the current system, RMP gets to STEAL solar power: under the current plan, when a customer produces more solar power than they use in a year, RMP gets to keep it without compensation. The “banked power” account is “zeroed out” every year – with RMP keeping the solar power their customers produced with absolutely NO COMPENSATION.

Simple Solution

If you don’t have solar power, but want to help the Government Mandated “green” initiative, RMP offers to sell you blocks of energy from their “Blue Sky” program. You’ll pay a premium for power created from there, but many customers choose to do so to help the program expand. This program is divided into power generated from solar farms and power generated from wind farms.

What is the wholesale cost of power RMP pays for power from the solar farm component of the Blue Skies program? I’ve asked this for years and have never gotten an answer. Every time I’ve had a discussion with an RMP representative and have asked this question, they immediately change the subject and avoid the question.

Do you, as members of the Public Service Commission, know this answer? Why not? Why doesn’t RMP want to answer this very simple question?

  • Once we know that, the answer is simple:
  • Since RMP “buys” solar power (at wholesale) for X-dollars per KWH from their Blue Skies solar farms,
  • Customer “sells” solar power (at wholesale) to RMP at the same rate
  • Customer “buys” coal power (at retail) from RMP at the already approved rates (unless Customer opts-in to buying power at the Blue Skies rate)
  • RMP pays customer (actual cash, not electric “credits”, or “banked” power) every month or every year.

This is not only fair to all parties, it:

  1. reduces RMP’s need to expand its Blue Skies locations by leveraging roof-tops across the state, thereby reducing their out-of-pocket expenses, are reducing the delivery costs to get that power to customers,
  2. eliminates the disincentive of RMP’s current “take the annual excess” practice,
  3. removes the disincentive for customers to only make less solar power than they use in a given year, and
  4. removes RMP’s argument that it’s “not fair” because of their (currently inaccurate) wholesale/retail argument.

Don’t punish homeowners and businesses who have decided to or want to “go solar”, especially not based on a misleading study, incomplete information, and an unequal comparison of coal vs. solar power.



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