High bills and dirty power?

or

Local energy with affordable bills?

You can shape that decision today.

MGE and Alliant Energy are seeking approval from the Public Service Commission for higher energy rates.

They need to hear from you!

Together, we can make Madison a national leader in clean energy with fair & affordable energy bills.

Oppose Higher Energy Bills

and High Mandatory Fees

MGE and Alliant want to increase rates.

File a Comment Opposing Fee Hikes

Suggested Comments (see more below):

  • Minimize mandatory fees.
  • Expand energy efficiency instead
  • Increase clean energy goals and support

Submit Comments on MGE’s Proposal – deadline September 19, 2016

Submit Comments on Alliant Energy’s Proposal – deadline September 30, 2016

 

Regulatory Background Information


Alliant Energy’s Billing Scheme Proposal At A Glance – download PDF

alliantproposal2016Alliant Energy is an investor-owned utility regulated by Wisconsin’s Public Service Commission. As a monopoly, Alliant provides exclusive electric and natural gas services within its southwestern Wisconsin service territory. Their headquarters are in Madison, WI.

Billing Strategy Basics

Customers are charged monthly in two ways:

  • Fixed Fee – Monthly charge for connection
  • Use Rate – Based on energy consumption

Alliant is proposing to increase its mandatory fixed rates and lower its use rate for 2017 and 2018.

The Impacts

  • Decreases incentives for energy efficiency measures due to a lower rate of return.
  • Increases bills for low-energy users including seniors, low-income, students, apartment dwellers, and small businesses.
  • Reduces customer control over energy bills.
  • Reduces market for clean energy services.

What now?

Alliant’s proposal is under consideration by the Public Service Commission. Public comments can influence the final decision.

To make your voice heard Submit Comments on Alliant Energy’s Proposal – deadline September 28, 2016.

Public hearings are scheduled for 2pm and 6pm on Sept. 28th at 610 N Whitney Way in Madison.


MGE’s Rate Increase Proposal

Submit a Comment on MGE’s Proposal – deadline September 19th.

Draft Public Comments Contents

 


Should MGE change regressive rate structures that have higher customer charges and lower energy charges to make them more progressive?

HISTORY: In the last rate case (3270-UR-120) the primary arguments for raising the customer charge and lowering the energy charge was to prevent subsidization of distributed generation customers by other rate payers and to not over value energy conservation and renewable resources. Since that rate case the preponderance of data indicates that distributed generation and conservation are of benefit to all customers when all costs and benefits are included. It is also agreed that this raising of the customer charge and lowering of the energy charge does have a negative impact on the adoption of conservation and distributed generation, and therefore a negative impact on all ratepayers when all costs and benefits are considered.

APPROPRIATE COMMENTS ON THIS SUBJECT: MGE should lower the customer charge and raise the energy charge appropriately so that it is a structure similar to before the order in 3270-UR-120 but meets the revenue requirement for the new test year. Many experts now agree that distributed generation and energy conservation benefit all customers when all costs and benefits are included so there is no need to have the higher customer charge to ‘level the playing field’.

What was the public’s opinion regarding rate structures expressed in the 3270-UR-120 rate case and during the Community Energy Conversations (CEC)?

HISTORY: There were over 1,000 public comments in the last rate case. 95% of them were opposed to the new rate structure. There was a general appeal to all customers for participants for the CEC (Phase II of MGE’s public outreach effort). There were 98 separate conversations with a total of 500 participants. MGE listened to the concerns expressed about clean power, lowering pollution and increasing renewable energy, (somewhat reflected in their 2030 Framework) but did not listen to concerns about the rate structure change. The report published after the CEC gave a detailed list of all the comments gathered at the conversations. The report and our statistical analysis of the comments (an analysis that MGE and JSA failed to do) showed a large percentage of the participants were unhappy with the rate structure change and wanted MGE to reverse their position and go back to the old rate design. MGE did drop some of their most regressive future rate structure plans and did pledge to not change rates further until the public process was completed but they kept the basic change in rate structure, opposed by the public, as their proposal then and again now in the current rate case.

APPROPRIATE COMMENTS ON THIS SUBJECT: MGE should listen to their customers as they pledged to do before initiating the public conversation process. They should propose rates with a lower customer charge and an appropriately higher energy charge sufficient to meet their revenue requirement.

Is MGE a Community Energy Company or an Energy Company of the Future? Are they working together with their customers?

HISTORY: ON their website and in their ads MGE refers to itself as a “Community Energy Company” and an “Energy Company of the Future” and says they are “Building Tomorrow’s Energy Company – the Power of Working Together”.

APPROPRIATE COMMENTS ON THIS SUBJECT: MGE is not acting like a ‘Community Energy Company’ (MGE asks for the community’s opinion and then does not listen) nor an ‘Energy Company of the Future’ (their 2030 Framework is not progressive compared to other cities and utilities and compared to what is feasible) and is not ‘working together’ with the public (there is no formal process to include the public in future decision making as promised in the plan for public outreach). MGE and the PSC virtually ignored public opinion about rate structure in the last rate case, and MGE has continued to gather similar negative public opinion since then (in the CEC) but still has not changed course. If they are not going to act like a Community Energy Company then they should no longer use that descriptor.

How can we get MGE and PSC to treat public comments equally with other participants in a contested case?

HISTORY: In the last MGE rate case (3270-UR-120) over 1,000 MGE customers submitted comments. 95% of them were opposed to the rate structure change proposed by MGE in that case. Most rate cases only garner a dozen or two public comments. The preamble to the order in that case mentions that there were 1,161 comments but has no information about what the public said. The normal practice in a rate case has the staff of the PSC develop a “Decision Matrix” that outlines the questions in the case that require a decision by the Commissioners. The matrix has the questions and the positions of all the “Parties” to the case. The parties have laid out their positions in direct testimony, sometimes in rebuttal and surrebuttal testimony and in briefs. It is all on the record but the staff still takes the time to develop the matrix and even has the parties help them fill in the parties’ positions. Nothing like that is done with the public testimony. It would be inappropriate to include every individual public opinion in the matrix but there should be a way of summarizing it so it can be included.

APPROPRIATE COMMENTS ON THIS SUBJECT: Public opinion should be included in the decision matrix used by the Commissioners for making decisions in a rate case. The Commissioners should designate a staff person or allow an interested intervenor group to summarize public opinion for inclusion in the decision matrix. The order should include reference to public opinion just as it includes the positions of the parties.

Issues less directly related to the rate case but still important:

How progressive is MGE’s 2030 Framework?

HISTORY: MGE released a framework in November of 2015, setting goals for 2025 and 2030. This was in the middle of phase II of the public outreach process. It is unclear why MGE chose to develop the 2030 plan before the whole public process was completed. The 2030 plan looks progressive to the general public, projecting 25 % renewables energy by 2025, 30% renewable energy by 2030, and 40% less carbon by 2030 (compared to 2005). But, if you compare the MGE 2030 Framework to their progress in the past 15 years at lowering CO2 and increasing their level of renewable resources it is clear that what they have proposed is ‘business as usual’. They will not have to do much more than what they are already doing to be able to meet the proposed goals of 30% renewable energy by 2030 and 40% less carbon. There are several other utilities and cities that have much more aggressive goals.

APPROPRIATE COMMENTS IF YOU AGREE: MGE should compare their goals to other comparable utilities and cities and be able to explain to the public, at an open forum, why they are unable to attain more progressive goals. MGE should have interim goals for all aspects of the framework, and more interim years than just 2025.

Have subsequent phases of the MGE public outreach process (Phase III and IV) been useful and have they affected decisions made by MGE?

HISTORY: MGE had a very well designed public outreach process that had great potential for putting them in touch with their customer’s opinions and needs. During the last rate case CEO Gary Wolter released a letter (dated October 2, 2014[1]) to his customers that said the following:

“Within the next few months, we will begin an extensive community conversation on these important issues. Our effort will include opportunities to share information and to gather input from all of our customers, business and community leaders, key community organizations, civic groups and others. This extensive and comprehensive effort we are planning could take twelve months or longer, and we will keep at it until the job is done. The effort will go forward regardless of the outcome of our current request before the PSCW. And, we will not seek further rate restructuring until the effort is completed.  What we may or may not request in the future will be informed by this important communitywide conversation.”

This public outreach process held great promise and all the intervenors and public groups were anxious to see it succeed. The four phase process for the promised public outreach was developed with the help of Justice and Sustainability Associates (JSA), and described in a report written by JSA following Phase II, the Community Energy Conversations (CEC).

Phase I – JSA, MGE, and other stakeholders created an information rich environment prior to initiating actual conversations. This Phase continued through June 2015.

Phase II – JSA planned, conducted, documented and facilitated numerous Community Energy Conversations (CEC) designed to engage customers and the public to contribute guidance for future energy decisions – including MGE’s Energy 2030 Framework.[2]

Phase III – JSA will design, convene, document, and evaluate a large group citywide civic conversation in the form of a Community Energy Workshop (CEW) that confirms guidance received up to that point and further deliberates remaining relevant issues. By the end of Phase III, JSA will present MGE with a draft plan to launch a Community Energy Partnership (CEP).

Phase IV – JSA recommended the formation of a long term collaborative Community Energy Partnership (CEP) in the summer or fall of 2016 based on the outcomes of Phase III and in anticipation of support of further developing MGE’s Energy 2030 Framework. The CEP would help MGE develop the Energy Company of the Future.

Did Phase III, the Community Energy Workshop (CEW) affect MGE decisions?

For Phase II, the CEC, all MGE customers were invited and encouraged to participate in the Conversations. For Phase III, the Community Energy Workshop (CEW), participation was by invite only. Usually an organization was requested by MGE to send a representative but in some cases a particular individual was designated by MGE. There were 200 participants gathered on April 19, 2016. There were individual tables of 8-10 with facilitators and scribes at each table. All the videos and remarks that preceded each of the three discussions were prepared by MGE. MGE refused permission for anyone else to offer information to the participants. The evening produced 130 pages of comments in response to three proscribed questions. Requests for print outs of the comments and a list of the participants was denied. It is difficult to know whether the 130 pages of comments were heeded by MGE in its decisions since no one but MGE has access to the data.

APPROPRIATE COMMENTS ON THIS SUBJECT: MGE should release the information gathered at the CEW. It is information gathered from the public at a public meeting, there should be no concerns about confidentiality. MGE should allow a spectrum of opinions/views before asking the public their opinion in any future forums. All meetings held to solicit public opinion should be open to any MGE customer that wants to be heard.

 What happened to the projected Phase IV Community Energy Partnership (CEP):

HISTORY: The final phase of the community outreach was supposed to be the development of a Community Energy Partnership (CEP). It would be the framework for ongoing public input. One of the question asked at the CEW (April 19, 2016) was – what should future community engagement look like? There was no longer mention of a CEP, now it is merely future community engagement. It is now four months later and there is still no CEP and not even a formal description of what future community involvement would look like. The only thing ‘developing’ seems to be ‘one on one’ conversations between MGE and individual organizations. The discussions of each group are confidential so individual groups are only aware of what is said or agreed to in their own conversations. This hardly seems like a community partnership and certainly not open discussions.

APPROPRIATE COMMENTS ON THIS SUBJECT: IF MGE wants to continue calling itself a “Community Energy Company” it should develop and announce a real long term Community Energy Partnership (CEP) that allows for broad open community involvement in decision making.

What is the quality of MGE’s customer education in preparing them to help with decision making?

HISTORY: MGE published a ‘discussion guide’, for use at the Community Energy Conversations (CEC) that was biased and leading (according to data gathered from the public at the CEC meetings in summer 2014). MGE continues to have it available on their website. MGE consistently denies requests of outside groups who want to provide information at public and shareholder meetings.

APPROPRIATE COMMENTS ON THIS SUBJECT: MGE should provide, or allow others to provide, unbiased information to shareholders and customers when MGE reaches out to talk to and gather opinions from them.

 

[1] This letter was entered on the record (PSC REF# 22067) to formalize part of an agreement between MGE and CUB and CW to collaboratively work on better approaches to rates and customer programs.

[2] This Phase of the public process was unsuccessful in reaching MGE as was covered in a section above.