Petition to Arizona legislature – Dump Renewable Energy Mandates

In 2006, the Arizona Corporation Commission (ACC) imposed the Renewable Energy Standard and Tariff (REST) on non-government owned electric utilities. I request that the Arizona legislature repeal this mandate and let utility companies generate electricity by the method they see as most efficient, cost effective, and reliable. Most renewable energy sources are none of these things.

REST requires that electric utilities generate an ever increasing amount of electricity from renewable sources such as wind and solar. The mandated goal is to reach a total of 15% renewable generation by the year 2025. The commissioners wanted “to capitalize on Arizona’s sunshine and other ‘green energy’ opportunities” according to an ACC press release. Currently, Arizona produces about 7% of its electricity from renewable resources but that figure counts the 6% from hydroelectric generation. We currently get less than 1% from so-called green energy sources. The integrity of our electrical grid will be in danger when 15% of our electricity is generated by unreliable sources such as wind and solar.

In addition to utility-owned projects, REST requires the utilities to produce a growing percentage of the total electricity from “distributed generation,” i.e., residential or non-utility owned installations. That means, for instance, solar panels on your roof or on the roof of your business or on shopping malls. The distributed energy requirement started at 5% of the total portfolio in 2007 and grew to 30% of the total renewable mix this year. We all pay for the subsidies associated with this requirement.

The rationale for REST is essentially political correctness embraced by some gullible Corporation Commissioners. The stated rationale is two -fold.

First, the commissioners want to reduce our dependence on foreign oil. But in the entire U.S., only about 1% of electricity is generated by burning petroleum. In Arizona, petroleum generates less than 0.1% of our electricity. Besides, America has abundant domestic sources of petroleum if only the feds would let us exploit it.

The other rationale is to reduce emissions of carbon dioxide and thus forestall dread global warming.

Six reasons why we should lay REST to rest:

1. Electricity generated from renewable sources is much more expensive than conventional generation. That expense is reflected in higher electricity bills. For instance, my bill from Tucson Electric Power itemizes an expense for “Renewable Energy Standard Tariff” and another charge for “DSM Surcharge.” (DSM is demand side management, more on that later). In 2011, TEP raised about $35 million from these charges. The ACC estimates that from 2010 to 2025, the surcharges for electricity from REST will cost consumers $1.2 billion more than they would have paid for conventional energy sources.

The cost of being politically correct is essentially a regressive tax which will cause low income households to shoulder a greater burden than higher income households because the energy costs make up a larger portion of their budget.

electricity by source and cost

2. Renewable energy sources such as wind and solar are intermittent, unpredictable, and unreliable. Increased generation from unreliable sources will make our electric grid more susceptible to blackouts and brownouts. Solar and wind generation typically produce at only about 20% of rated generation capacity. Tucson Electric Power operates one of the largest solar PV arrays in the United States, a 5-MW system. But during five years of operation it has produced at only 19% of it rated capacity. Even in Arizona, clouds cause rapid fluctuation in the array’s power output.

3. Because generation from renewable energy sources is intermittent and unpredictable, these sources require backup generation which is usually by burning fossil fuels. Because the time and duration for backup generation need is unpredictable, the fossil-fuel fired backup generators cannot be run efficiently. Experience in Europe shows that backup generators actually use more fuel and produce more carbon dioxide emissions and pollutants such as sulfur dioxide than they normally would if they were run efficiently for primary generation.

A new report from the European Nuclear Energy Agency analyzed the effects erratic intermittent source generation on the electric grid: The report considers “six technologies in detail: nuclear, coal, gas, onshore wind, offshore wind and solar. It finds that the so-called dispatchable technologies – coal, gas and nuclear – have system costs of less than $3 per MWh, while the system costs for renewables can reach up to $40 per MWh for onshore wind, $45 per MWh for offshore wind and $80 per MWh for solar. The costs for renewables vary depending on the country, technology and penetration levels, with higher system costs for greater penetration of renewables.”

4. Use of renewable energy will not impact climate. By using data from the Carbon Dioxide Information Analysis Center, NOAA, and the IPCC, it is possible to estimate the temperature impact of carbon dioxide emissions. For instance, if we stopped all U.S. carbon dioxide emissions it could theoretically prevent a temperature rise of 0.08ºC by 2050. If Arizona stopped all carbon dioxide emissions it could theoretically prevent a temperature rise of 0.0015ºC by 2050. Will you notice? (Data from Science & Public Policy Institute report “Analysis of US and State-by-State Carbon Dioxide Emissions & Potential ‘Savings’ in Future Global Temperature & Global Sea Level Rise

Besides, the increasing emissions from other countries such as China will completely wipe out any imagined savings from REST.

5. Wind turbines cause health problems due to low frequency vibrations. (See here)

In the United Kingdom a new study “claims thousands of people are falling sick because they live near” wind farms. Wind turbine syndrome is alleged to cause dizziness; increased blood pressure, sleeplessness, and depression among other things. All due to low-frequency vibrations. In December 2011, in a peer-reviewed report in the Bulletin of Science, Technology & Society, Dr. Carl Phillips, one of the U.S.’s most distinguished epidemiologists, concluded that there is “overwhelming evidence that wind turbines cause serious health problems in nearby residents, usually stress-disorder type diseases, at a nontrivial rate.”

6. Political philosophy: Who is in charge of public policy, state legislators as representatives of the people, or the Arizona Corporation Commission?

Rationing electricity:

Above, I mentioned DSM – demand side management. The REST program requires electric utilities reduce the amount they produce, i.e., ration electricity. “Arizona’s public utilities will be required to achieve annual energy savings of at least 22%, measured in kWh, by 2020, with the savings to increase incrementally as a percent of retail energy sales in each prior calendar year to reach that goal.” ( ACC Source).

One of the ways to achieve DSM is through use of the so-called “smart grid” and “smart meters.” Smart meters placed on your house or business will allow the electric company to monitor and control your electricity use via radio-controlled commands to your meter. If you use too much air-conditioning, for instance, the electric company will be able to turn it off.

Because these systems are radio controlled they are vulnerable to mischief by hackers who may decide to turn off the A/C in a shopping mall or neighborhood.

Renewable energy is not as green as advertized.

For example, many PV solar panels rely on polysilicon being manufactured in large quantities and at high quality. A byproduct of polysilicon production is silicon tetrachloride, a highly toxic substance that poses a major environmental hazard. Wherever silicon tetrachloride is dumped, the land becomes totally infertile. A major environmental cost of photovoltaic solar energy is toxic chemical pollution (arsenic, gallium, and cadmium) and energy consumption associated with the large-scale manufacture of photovoltaic panels.

A Cato report found that the materials required for thermal-solar projects were 1,000 times greater than for a similarly sized fossil-fuel facility, creating substantial incremental energy consumption and industrial pollution.

A wind farm uses about 85 times the area required by a gas-fired plant, about 10 to 80 acres per megawatt capacity. Solar requires about 10 acres per megawatt, still much larger than fossil fuel plants. This large footprint may impact wildlife.

Besides chopping up birds, a study from M.I.T. says wind turbines cause a rise in local temperatures of up to 1.8ºF because the turbines disrupt local air flow that can transport heat away from the land surface.


My argument here is not against any use of renewable energy because there may be circumstances where such use is appropriate. My argument is against government mandated use which raises our electricity rates unnecessarily, distorts the market, and makes our electric grid less reliable.

Renewable energy mandates are bad for ratepayers, bad for the environment, and even bad for the state’s economy because of the increased electrical costs on business and the expense of government subsidies required by the mandate. The mandate fails to accomplish the stated rationale and is essentially just a politically correct eco-fad (with a little crony capitalism thrown in) that increases our electricity costs but provides no benefit. When the new Arizona legislature convenes in January, tell them to lay REST to rest. Dump the mandates.


There is a new paper from the University of Delaware that claims “Renewable energy could fully power a large electric grid 99.9 percent of the time by 2030 at costs comparable to today’s electricity expenses…” The claim is based on computer modeling: garbage in, garbage out. Anthony Watts injects some reality to this nonsense:

UPDATE 2: Privacy concerns with smart meters, from National Geographic.
In theory, the information collected by smart meters could reveal how many people live in a home, their daily routines, changes in those routines, what types of electronic equipment are in the home, and other details. “It’s not hard to imagine a divorce lawyer subpoenaing this information, an insurance company interpreting the data in a way that allows it to penalize customers, or criminals intercepting the information to plan a burglary.

UPDATE 3: An executive of a solar company argues against mandates and subsidies for renewable energy. Read the whole article here.

“In reality, it [solar] is hopelessly inefficient from an economic sense to be a fix for our CO2 concerns.” “Subsidies are much worse that just wasteful, they’re diabolical. They lull us into thinking we have almost solved the problem and they hinder us from seeking the real solutions.”

The cost of energy conservation

One would normally expect that if we use less of a commodity we would pay less.  But in the perverse world of government mandated energy policy, conservation costs us more.

A case in point: As a result of Arizona’s effort to boost renewable energy use and energy efficiency, we are using less natural gas.  That puts Southwest Gas in an bind.  They contend that with lower usage, they are unable to recover fixed costs to provide service.  Southwest Gas and other utilities are therefore urging the Arizona Corporation Commission to allow the utilities to impose a surcharge to gas customers, that is, allow the utilities to “decouple” charges from actual usage.  That policy will, of course, cost ratepayers more.  Not a good incentive for conservation.

We are already paying the cost of renewable energy mandates for electricity.  The Arizona Corporation Commission, in its benighted wisdom, requires electric utilities to produce an increasing percentage of electricity from much more expensive renewable sources due to fear of the phantom menace of global warming.

Tucson Electric Power Company notes that in 2011 it collected an extra $36 million from ratepayers to pay for renewable energy installations (mainly solar), and that in 2012 it expects to collect an extra $44 million in ratepayer money for these projects.

The Arizona Corporation Commission is not serving the public with these policies.  It is mandating that we produce electricity from more expensive and less reliable sources.  To put that in perspective the Energy Information Administration calculated the costs of electricity generation in dollars per megawatthour as follows:

Conventional coal power: $100.40; Natural gas: $83.10; Nuclear: $119.00; Onshore wind power: $149.30; Offshore wind power: $191.10; Thermal solar power: $256.60, Photo-voltaic solar power: $396.10. Note also, that the availability, i.e., the ability to produce electricity on demand, according to EIA, is 85% for coal, 87% for natural gas, 90% for nuclear, but only 34%-39% for wind, and 21%-31% for solar.

I urge the state legislature to take the power of issuing mandates away from the Commission and repeal the renewable energy standards.  That way utilities will be free to seek more efficient and cost effect ways of providing electricity.

See also:

Solar energy cannot economically compete in electricity generation