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Owen's comments on LG&E KU IRP

July 12, 2002

Good morning! My name is Elisa Owen. I am an ordained Presbyterian pastor and the Executive Director of Kentucky Interfaith Power and Light (KIPL), an organization that seeks to nurture the conscience of our state when it comes to our earth’s climate. It isn’t that we think people in religious organizations are the only folks with a conscience. Still, traditionally the religious faiths have spoken, when we are at our best, compelling truths into the world about what it means to be human and how we as individuals and societies might come to celebrate, rightly value and put in their proper place the griefs and the sufferings that are intrinsic to the mystery of Life in which we are privileged to participate.

Today on behalf of KIPL and on behalf of my two young children, ages 10 and 13, I come before you to make comments on the Integrated Resource Plan(IRP) submitted to the Kentucky Public Service Commission (PSC) by our monopoly utility, a private business that precisely because it has been granted the privilege of being the sole provider of electric service in our area, is subject to public regulation. The commission is charged, in fact, with ensuring LG&E/KU provides electricity to its customers in a way that serves the public interest. I am here because I do not think LG&E/KU’s plan demonstrates that the company considered the public’s interest, traditionally defined as low cost, reliable electricity, as they prepared it. Why? Because LG&E consistently refused, throughout the plan, to make clear to its customers that its definition of “low cost” and “reliable” electricity is as holistic as the definition all other upstanding corporate citizens are using these days.

By a holistic, contemporary definition I mean simply one that takes into consideration the obvious, scientifically corroborated, and mutually reinforcing challenges facing not only our own nation, but also the entire global community; those of climate change and gross economic, social, and racial inequality. Given those realities, and the ways they were and continue to be highlighted by the ravages of our recent coronavirus pandemic, I would have expected any monopoly utility serious about acting in the public interest, as they are required to do by law, to use, throughout its IRP presentation, a contemporary definition of “low cost” and “reliability” which goes beyond the cost of each kwh of electricity they sell to include the production of these kwh’s impacts on the health of their customers and the environment in which their generation plants operate. Instead, in its IRP, LG&E/KU did the opposite. They stated clearly that they understood the provision of low-cost, reliable electricity to be only about the cost per kwh that customers have to pay. When they did that, they abdicated their corporate responsibility to communities like Dawson Springs and Mayfield, KY who are currently cleaning up from the ever more frequent violent storms that human burning of fossil fuels is clearly fomenting. Given the way that storm destroyed the electric grid in that area, reliable electricity is much harder to come by for customers in those areas these days. They also abdicated any responsibility their decision to continue to burn fossil fuels until 2066 has had or will continue to have in creating the gross health disparities that affect largely people of color who live across the fence from their large Mill Creek coal fired power station in West Louisville and largely low-income folk living within a mile of their Trimble County plant.

In addition to their insistence on using a clearly outdated understanding of “low cost” and “reliability” throughout their IRP, LG&E/KU also abdicated their corporate responsibility to work with and for the communities they serve by claiming that unless and until government regulation forces them to consider the reality of climate change and human health inequities and the ways their current business model exacerbates the worst impacts of both, they were going to continue to ignore them both. This position was stated multiple times in the Integrated Resource Plan. Thus, I simply want to ask the Public Service Commission to provide the regulatory framework to force LG&E respond to the climactic and societal problems to which they and we know their current business model contributes, but for which they have been up front that they will not change unless and until they have someone else act as the moral compass they appear to lack. In reading their IRP I came to see that a moral compass is not something the leadership of LG&E/KU demonstrates in presenting its outdated, dangerous plan, to the detriment of not only those of us that live in their service territory, but also to the detriment of the rest of the world who will suffer terrible costs of this willful abdication of moral agency by the monopoly utility in our area.

In response to their need for an outside moral compass I would ask the commission to:

  1. Find a way to compensate LG&E/KU fairly for not only the kwh they generate, but also for the “negawatt” hours the robust DSM programs you ask them to create for the purpose of reducing their peak load generation requirements.

  2. That you consistently refuse them permission to build new generation capacity of any sort unless and until they take the steps to support their customers in becoming as efficient as possible. (Something that will happen if the economic incentives are there to compensate negawatts just as megawatts are compensated.)

  3. That you work with LG&E/KU to support them in becoming an active member of a nearby RTO, through which they can procure solar and wind power that does not need to be generated in our own back yard and thus reduces somewhat the intermittent nature of those renewable sources by expanding the area from which they can be sourced.

  4. That you disallow any construction of new natural gas or LNG generation capacity unless and until LG&E/KU has proven that they have exhausted all possibilities of procuring renewable power (hydro, wind, merchant solar, roof top solar and geothermal) on the existing transmission and distribution grids AND reducing its peak load through DSM programs.

I already grieve that my girls are growing up in a world where the continued thriving of the land, water and air that they will need to sustain they and their families has been called into question by human activity, specifically our insistence of continuing to use fossil fuels to power our economies. Our knowledge of our own complicity in the more dangerous weather patterns that are already plaguing our world increases uncertainty and anxiety in societies already plenty full of both. I believe with every cell in my body that God has given human beings a great and irreplaceable gift in the creation that sustains our fragile life on this earth. All I am asking for today is that our Public Service Commission recognize that gift and commit itself to the holistic definition of “low cost/reliable” electricity that, especially since our IOU has abdicated its own moral responsibility for its impacts on the planet, is unconscionable that it not adopt. LG&E/KU has made clear it will not act in the public interest unless and until it is made to do so. The time has come to force it to become not the utility we have, but instead and without doubt, the one we desperately need.

Thank you for hearing my concerns and suggestions regarding how you might help alleviate them.

Elisa Owen

Executive Director

Kentucky Interfaith Power and Light


Dear Governor Newsom, The undersigned ___ California and national organizations submit this letter to urge you to take a stand against the misrepresentation of equity that has dominated the Public Utilities Commission’s (CPUC) Net Energy Metering (NEM) proceeding. Utility companies and other proponents of the “cost shift” argument—that (affluent) solar customers are shifting utility costs onto (low-income) non-solar customers—have weaponized equity to limit or even eliminate the NEM program in California. This is a tactic being used by utilities in other parts of the country to attack rooftop solar. As reflected by the modifications to the NEM program in the CPUC’s December 2021 Proposed Decision, this cost-shift argument has gained traction, dangerously ignoring and perpetuating the disproportionate impacts of pollution and energy violence in disadvantaged communities (DACs). We therefore urge you to stand with California’s DAC residents, reject the misrepresentation of equity in the NEM debate, reject the “solar tax,” and maintain the solar credit to grow rooftop solar in DACs. It is critical to confront the misrepresentation of equity issues at the heart of California’s NEM proceeding. The Proposed Decision seeks to tax solar and dramatically decrease the NEM solar credit, explicitly to address a purported shifting of costs onto low-income customers. The CPUC’s NEM analysis, however, suffers from three fatal flaws. First, the CPUC has not examined individual energy bills to determine the current NEM program’s specific impact on low-income customers who are not participants in the program. Therefore, there is no body of data regarding the purported NEM cost shift onto low-income customers—what the proposed solar tax is meant to avoid. Second, instead of studying actual utility bills, the CPUC bases its “cost shift” assertion on deeply flawed modeling tools that entirely ignore certain significant benefits of NEM to California DACs and the enormous harms (economic and otherwise) of continued reliance on fossil fuels. Specifically, the flawed modeling tools ignore or underestimate: - The significant reduction in greenhouse gas emissions from not having to operate or build fossil fuel infrastructure that the NEM program displaces, and the disproportionate harms that climate-induced disasters and the climate emergency impose on DACs. - The public health benefits of fewer fossil-fuel power plants in DACs. This includes the significant, disproportionate and cumulative costs of criteria, toxic, and water pollutants on DAC residents who live, work, or play around fossil fuel extraction and generation infrastructure. - The significant decrease in transmission and distribution costs that the NEM program saves all ratepayers. For example in 2018 alone, the California Independent Systems Operator, citing increased rooftop solar and energy efficiency, canceled 20 transmission projects at a $2.6 billion savings to all ratepayers. - The increased electricity system reliability and resiliency in DACs that NEM provides as a distributed, decentralized power system. This includes the public health and safety benefits of stopping power shutoffs. - The avoided environmental and land use harms from fossil fuel plants and badly-sited utility-scale solar and wind projects, including significant impacts to biodiversity, habitats and species, and the elimination of natural carbon sinks. - The significant costs of utility-caused wildfire mitigation, such as the costs for undergrounding of transmission lines and associated power shutoffs that the NEM program saves all ratepayers. - The local economic and job benefits that NEM creates, including local clean energy installation jobs which are more numerous than utility-scale clean energy jobs and fossil fuel jobs. Third, the CPUC fails to consider the impact of undermining rooftop solar benefits on DACs—both for existing NEM participants and for those without access to solar. Existing NEM participants would suffer increased energy costs and a devaluation of their solar investments. Those without access to solar would continue to be denied; and the continuous growth since at least 2010 of rooftop solar installations by low- and moderate-income customers would come to a halt. This includes expansion of solar in DACs, particularly in the San Joaquin Valley, as well as low-income customers in the Solar on Multifamily Affordable Housing and the Multifamily Affordable Solar Housing programs. A solar tax and/or a reduced NEM solar credit would simply reduce the scale of rooftop solar deployed in California. It would undermine the necessary shift away from fossil fuels, and towards safely and reliably retiring our most polluting gas plants in DACs. California’s solar cost-shift debate is simply a distraction from the real question at hand: how to eliminate the barriers to greater deployment of renewables in DACs and low-income communities. This requires increased and targeted funding of rooftop and community solar in DACs, and the expansion of the NEM program. Ensuring swift solar adoption in DACs should be a primary focus for the renewable energy transition. Overall, weakening the NEM program, as proposed by the CPUC, simply imposes additional barriers to the achievement of California’s—and the country’s—climate and equity goals. The only beneficiaries of a weakened NEM program are the state’s private electric utilities, who have weaponized the purported equity issue to perpetuate their stranglehold on the state’s centralized, fossil-fuel intensive, power system. We respectfully urge you to stand with the people of California, not the private utilities, and reject the misrepresentation of equity in the CPUC’s NEM proceeding: reject the proposed solar tax and dramatic reduction of the NEM solar credit

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