SBUA Oregon Newsletter—Fall 2022

by admin on December 7, 2022

Greetings SBUA Oregon Members!

This newsletter informs you, SBUA Oregon members, and supporters on how SBUA in  Oregon is advocating for Oregon’s small business community to ensure fair and reasonable electricity and natural gas rates and service.

In Oregon, we are going pedal to the metal on implementing the recent state law to remove carbon-based sources from the State’s power supply and we have decided as a state that the ratepayers will foot the bill, so small business needs to be at the table in the rate cases. We also try to participate in other efforts like transportation electrification plans, Integrated Resource Plans, distributed energy generation, Energy Trust-related topics, and other state and local government efforts.

Important Links

The new Oregon Department of Energy (ODOE) 2022 Biennial Energy Report is out: https://energyinfo.oregon.gov/ber. On pages 60-61 see some small business use statistics. Also available is the ODOE Small-Scale & Community Renewable Energy Project Study: https://www.oregon.gov/energy/Data-and-Reports/Documents/2022-Small-Scale-Community Renewable-Projects-Study.pdf. The Study recommends financial and technical assistance grants for small businesses.

See what ODOE tells the Senate Energy and Environment Committee about these reports next week: https://olis.oregonlegislature.gov/LIZ/Committees/Meeting/List.

Click the link to watch SBUA & BestHQ Mastermind for Purpose where SBUA touched on understanding your utility bill and navigating Oregon’s Legislative Committee Days website:  https://www.youtube.com/watch?v=NIeYGBQirYA.

SBUA Board

SBUA is pleased to announce it has an Oregon-based board: Britt Marra, Carrie Ng, and Rajita  Kaundin. And we are equally pleased to introduce our new SBUA Oregon Advisory Committee—see the end of this newsletter for introductions.

Donate

Please donate to SBUA now to show your support for fair and reasonable electric and natural gas utility rates for Oregon’s small businesses!

Donations can be made on this website (utilityadvocates.org), by clicking the orange “Donate”  button on the right-hand corner of our webpage.

We await a Commission decision on whether it will allow us to access the same source of funds that the industrial and large commercial (like Target, Microsoft, etc.) and the residential customers receive—that’s intervenor funding—ratepayer dollars—after SBUA’s having provided excellent input in both rate cases from SBUA’s experienced experts William A. Steele and Danny Kermode, C.P.A.-retired, and solid representation. Please let the Commission know that you want to see SBUA have fair access to that funding! Email the Commission: puc.publiccomments@puc.oregon.gov.

PUC Dockets / Rate Cases

Shout out to the stellar work done by energy law student Grant Hart in these dockets!!

UG 435 NW Natural asked for a 9.7% increase in this 2022 rate case. SBUA secured a reduction to  9.2% for Schedule 3 and a Company promise to examine a possible intra-class subsidy. OPUC Staff’s forcing payment of part of the $10,000,000 COVID-19 costs onto small businesses adding approximately .8% per bill.

UE 399 PacifiCorp dba Pacific Power asked a 10.3%. SBUA secured 8.4% and increased rate design alternatives, specific small business web presence, and a Standard Industrial Classification (SIC) report. COVID-19 cost = $17,000,000.

AR 653 Division 21 Rulemaking, an offshoot of COVID-19 proceedings, includes extensive SBUA input, resulting in the inclusion of small commercial in reporting; the same notice of disconnection as residential; relief from wildfire or extreme weather, etc.

The COVID-19 impact on utility customers continues with PGE costs coming up soon.

SBUA plans to involve more in the:

  • Transportation electrification plans: (UM 2165); following SBUA outreach to Oregon Electric Vehicle Associate and Emerald Valley Electric Vehicle Association.  

Planning dockets including:

Integrated resource planning (the “LC dockets”) & distributed energy planning by utilities to meet energy load including new ways energy is distributed (UM 2005).

Clean Energy Plans (UM 2225) PGE and PacifiCorp implementing HB 2021 & planning to decarbonize their retail electricity sales with consideration for direct benefits to local communities and achieving 80% emissions-free energy by 2030 and 100% emissions-free by 2040.

Clean & Efficient Energy for Small Business Customers (ETO Update)

Energy Trust of Oregon (“ETO”):  

Federal Legislation Passed for Small Businesses

2022 federal legislation has seen a tremendous and transformative policy change on how small businesses can make a beneficial transition to clean & renewable energy.

The Inflation Reduction Act: https://www.whitehouse.gov/briefing-room/statements-releases/

SBUA Call for Action

Another way to aid SBUA efforts 

Supporters can contact their utilities to ask the utility company to treat small business customers fairly for intervenor funding (Ratepayer Funds) by including small businesses at the intervenor funding table.

SBUA Oregon Advisory Committee

SBUA Oregon has organized an SBUA Oregon Advisory Committee, a first for SBUA anywhere. Members are from small businesses from different industry sectors and met for the first time on 11/10/22 to review a draft Charter and get acquainted with one another and SBUA activity in Oregon.

Read down below to learn more about the initial Advisory Committee members:

Tye Gabriel, East Portland Chamber of Commerce Board Member, East Portland

Tye currently serves as part of the East Portland Chamber of Commerce Board of Directors. As a board member Tye participates in community guidance by shaping the future of the chamber and the community it serves. Tye’s role also incorporates networking with businesses, organizations, and community members. Tye is a sales specialist for Generations LLC, the west coast senior living residence operator. The specific senior residence community that Tye serves currently is CherryWood Village in Portland, Oregon.

Jan Wilson, Nonprofit Leader/Attorney, Tualatin/Tigard

Jan has had a career as an environmental attorney for two decades and served as the executive director for both EarthShare Oregon & Tualatin Riverkeepers most recently. Jan’s leadership skills in these nonprofits include extensive community outreach and understanding the logistics of what it takes to run and manage a nonprofit organization. Furthermore, Jan has contributed her skillset to SBUA and brings that helpful experience to the advisory committee.

Todd Kimball, Small Business Consultant, Portland Metro Area

Todd currently serves as an Advisory Board member for BestHQ. Todd’s engagement with BestHQ involves bringing small businesses and large businesses together for networking opportunities through sustainable means. Todd has also contributed to assisting SBUA in past matters and understands key aspects of SBUA and its significance in energy and utility discussions.

Ann Fisher, Attorney/Energy Consultant, Beaverton

A small business owner, and having worked in electric utility issues 25 years ago, Ann Fisher also specializes in legal practice areas such as general business, commercial law, litigation contracts, etc. Ann has interacted with the following state agencies Bonneville Power Administration and Oregon Public Utility Commission contributing to her understanding of the energy legal landscape in the  Pacific Northwest.

Mike Shea, Architect, Portland Metro Area

Mike is a principal at Soderstrom Architects where they concentrate on higher education projects, federal projects, and facilities for the  Bonneville Power Administration, including their net-zero Ross Maintenance Headquarters in Vancouver, Washington. Mike’s portfolio includes other net zero and sustainable projects reflecting career-long interest in energy conservation and renewables.

Les Oehler, Small Business Manager, Corvallis

Les Oehler’s experience includes managing a family business of four jewelry stores in the mid-Willamette valley. Les is currently the CEO at Studio 311 & TOBY POMEROY Fine Jewelry and is familiar with the Oregon Public Utility Commission’s impact on small business utility rates.

Gordon Feighner, Restaurant Owner, Portland

Gordon Feighner is co-owner and manager of two popular Portland restaurants, Jam on Hawthorne and Cricket Cafe. An economist by training, Gordon spent five years working as a utility analyst for the Citizens Utility Board of Oregon. Gordon brings a great understanding of energy usage in the hospitality industry, and his background in utility economics in Oregon assures a great perspective on the interaction of that industry and the investor-owned utility work where SBUA engages.

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Attention Small Business Owners:

More and more, small businesses are relying on wireless, broadband, and Voice over Internet Protocol for their communications services. Unfortunately, California’s service quality standards have not kept pace. Many small businesses in California experience slow broadband speeds for what they pay, and they are frustrated with the quality and reliability of their communication services. At the same time, service providers are raking in so many millions of dollars in profits that current enforcement fines aren’t enough to motivate them to sufficiently improve their networks. This pattern must change. 

Small business owners like you can help fuel that change by making their voices heard. Let the California Public Utilities Commission know that by updating service quality standards and enforcement mechanisms, it can help to ensure that all small businesses receive the baseline level of communications service quality they need to survive and thrive.

The California Public Utilities Commission has an ongoing proceeding called Order Instituting Rulemaking Proceeding to Consider Amendments to General Order 133 (Proceeding number R2203016) considering these issues. There are two ways you can share your thoughts with the Commission in this proceeding. 

Public Participation HearingsThe first is by participating in their upcoming Public Participation Hearings (PPHs) on December 6 starting at 6pm and on December 9 starting at 1pm. The following is the information to access the PPHs: Telephone number to comment publicly and/or listen during the PPHs:1-800-857-1917
English Passcode: 1767567#
Spanish Passcode: 3799627#
Press *1 to inform the operator that you want to comment

Online formThe second is by submitting Public Comments directly on the California Public Utilities Commission’s website. Go to the California Public Utilities Commission’s website and follow the instructions on how to Submit Comments via Online Form (you’ll need to search for the proceeding using the proceeding number: R2203016):https://www.cpuc.ca.gov/about-cpuc/divisions/news-and-public-information-office/public-advisors-office/providing-public-comments-at-the-cpucYou’re welcome to

use this sample letter below for inspiration.
====
SAMPLE LETTER
Dear California Public Utilities Commission,

My name is NAME and I am a small business owner. My business, BUSINESS NAME + BRIEF DESCRIPTION OF BUSINESS. [OPTIONAL: Add one brief sentence describing the specific essential business function VoIP, wireless, or broadband internet plays in your business.]

Small businesses like mine rely on high quality and reliable wireless, broadband, and Voice Over Internet Protocol service to survive.
[OPTIONAL PARAGRAPH – YOUR STORY: Include this paragraph if you’ve experienced low-quality and/or unreliable service] Unfortunately, that’s not always been my experience. INSERT YOUR EXPERIENCE(S). Even one experience like this can put small businesses like mine in jeopardy. ]

Currently, service providers can offer service that’s inferior to the service advertised and being paid for by their customers and that’s so substandard that it threatens the survival of small businesses—then pay the fines ordered by the Commission for doing so and continue to thrive financially. In other words, many providers lack the incentive needed to improve subpar service. This has to change. But it won’t without your leadership.

Collectively, small businesses are a major contributor to the California economy. But individually we are small and need sufficient regulatory oversight of service providers to ensure we receive the high quality, reliable services that we need to survive. So, please:

Update service quality standards and enforcement mechanisms to protect small business customers, improve service reliability, and ensure that all small businesses receive an adequate baseline level of communications service quality.

Thank you for accepting public comments on your website and for holding public participation hearings on this issue. If not for that, it’s likely that you may never have had the opportunity to hear the needs of small businesses like mine.

Sincerely,

YOUR NAME

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Introduction

As part of SDG&E’s solicitation schedule and to comply with D.18-01-004, SDG&E will be requesting abstracts for behavioral programs that will serve the Non-Residential market segment. This is the first stage of the solicitation process beginning on October 24th, 2022.

The purpose of this program is to increase customer awareness of their energy use and motivate them to take actions, which can include usage-based or equipment-based changes in behaviors, as well as increased participation in existing and future energy efficiency or demand response programs. 

This program seeks to leverage comparative energy use reports delivered to non-residential customers by U.S. Mail, email, web portal or any combination of the three channels to achieve greater customer awareness and energy savings. This program will also be leveraged to deliver energy efficiency and demand response program offers to the participating customers.

Stage 1 is a Request for Abstract (“RFA”), and Stage 2 is a Request for Proposal (“RFP”) for organizations selected from Stage 1. The RFA will enable bidders (“Bidder” or “Contractor”) to provide sufficient information for the California Investor-Owned Utilities (“IOUs”) to narrow down the selection to proceed to Stage 2, at which time we will issue a full RFP. It is not intended that Bidders prepare a detailed Abstract in Stage 1. Instead, it is important that Bidders should use the Abstract to provide enough information about the design, implementation and management of a proposed program, targeted market and customer segments, and overall program design and goals.

Purpose and Objectives

The purpose of this RFA is to evaluate abstracts for program design and implementation services for the Non-Residential Behavioral Program. Key elements to consider when bidding on the RFA:

  • Program Overview
  • Program Design
  • Program Operations
  • Innovation
  • Compliance
  • Savings Potential
  • Adherence to Requirements

If the abstract is successful, the bidder will be asked to submit a proposal at a later date that will include detailed information regarding information provided in the Abstract along with additional information to further validate the proposal.

PowerAdvocate Registration

SDG&E will manage this event through Power Advocate’s sourcing platform. Interested bidders will need to register in Power Advocate to access all future communications and, upon its release, the RFA for Non-Residential Behavioral program.

All Bidders are required to register in Power Advocate to access the RFA documents, submit questions, and submit a Non-Residential Behavioral Program Abstract. Bidders can register in Power Advocate using the following URL:

(https://www.poweradvocate.com). Apply to the event through the “Opportunities” portal, search for the SDG&E event, click the key to request access to the event.

Are you registering for a specific Event:* click the ‘Yes’ button Who referred you to this Event:* PEPMA Announcement

Name of that individual’s company:* San Diego Gas & Electric Company

Name or description of the Event: 136517 Non-Residential Behavioral Request for Abstract Click “Continue”

PowerAdvocate Support

Support@poweradvocate.com

(857)453-5800 M-F 8:00 AM to 8:00 PM Eastern Time

 

Third Party EE Solicitations Information

Further information regarding SDG&E’s current solicitations for Third-Party Energy Efficiency programs can be found at the following link:

https://www.sdge.com/more-information/doing-business-with-us/energy-efficiency-third-party-solicitations

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SBUA Summer Update on Oregon Advocacy

by admin on September 19, 2022

Small Business Utility Advocates (“SBUA”)Summer 2022 UpdateGreetings! Since our May 2022 newsletter, these are the SBUA updates of how we have advocated for Oregon’s small businesses seeking fair and reasonable utility rates & terms of service, provided a small business voice and perspectives on Oregon energy policy in local and state government, and in the business community. See below highlights from Summer ‘22.Finish your Summer SBUA and BESThq’s Mastermind for Purpose on September 20, 2022 !!
SBUA Oregon Advisory Committee:
If you would like to serve 4-6 hours a year in SBUA-focused meetings – always a virtual option available – with the purpose of providing guidance and input on ongoing SBUA activities, please reach out ASAP as we are arranging our first committee meeting very soon!Contact guillermo@utilityadvocates.org or diane@utilityadvocates.org for a draft charter & more info.It is a great way to give direct input and support small biz and keep informed in a short amount of time.

Annual meeting and Outreach
July 7th, 2022: SBUA Oregon held its annual Oregon membership meeting in person and by Zoom. Hector, the owner of Cafe Zamora, graciously provided their coffee shop for SBUA members to gather and discuss SBUA’s work and the Public Utility Commission (PUC) treatment of small commercial customers. The one-hour meeting included a discussion of energy rates, energy conservation, small business participation in solar and in electric vehicle charging, and small-scale energy projects.July 20th, 2022: SBUA presented to the East Portland Chamber of Commerce regarding our work and including the COVID-19 arrearage (unpaid utility bills) data and related costs and attended the EPCC happy hour. EPCC member participants asked several questions.  SBUA has been reaching out to local and state government to inform them of what we do and our concern that small business be treated fairly in implementing Oregon’s energy policy.

Northwest Natural Rate Case UG 435
SBUA has represented small businesses fully in this rate case – SBUA found an intra-class subsidy where a large percentage of the small business ratepayers were subsidizing other larger users in the same class. The Commission noted and appreciated this contribution. Also, we took the allocation of COVID-19 costs all the way to oral argument. We await the Commission’s decision in that rate case.

PacifiCorp dba Pacific Power Rate Case UE 399
SBUA is building on information we learned in a Pacific Power rate case two years ago and are advocating for:Fairer rates than what the utility has offered in its proposal to the CommissionMore information about small businesses energy use patterns to develop better rate designBetter outreach to make it easier for small businesses to learn about and choose energy rate plans, and accessing solar, electric vehicle chargingFairer treatment of COVID-19 costs.Strengthening Protections for Utility Customers AR 653
SBUA provided input to the Commission reviewing Division 21 rules regarding customer protections for disconnections, late fees, and payment options. This was an offshoot of the PUC focus on COVID-19 pandemic impact on utility customers. The inclusion of small commercial language in several rules demonstrtes a positive direction for the PUC.

Oregon Department of Energy Small-Scale Renewable Energy Study
SBUA participated as a member of this Study workgroup and contributed thanks to your input. The report is due at the State Legislature on September 30th, 2022 and will be considered at the Oregon House Energy and Environment Committee meeting during Legislative Days on September 22, 2022 @ 9:25 a.m. – access the meeting here via livestream: https://olis.oregonlegislature.gov/liz/2021I1/Committees/HENVNR/Overview.

SBUA is helping Oregon small businesses have their voices heard as the state of Oregon transitions and decarbonizes its energy supply. Here is an example of the state taking a step toward this new future through the demolition of the Boardman Coal Plant: https://youtu.be/yB90dFKZiYw (fast forward to 24:20).Diane Henkels,
Attorney, Small Business Utility Advocates
541-270-6001
admin@utilityadvocates.org

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Contract Opportunity Announcement Type: RFA – Request for Abstract

Title: Residential Equity Energy Efficiency and Electrification Program

Estimated Contract Value:  $9 million for a 3-year contract

NAICS Code / Size Threshold: 541613 –Marketing Consulting / $16.5M

Work Location: PG&E Service Territory

Deadlines:   Registration Due Date in PowerAdvocate: November 4, 2022, 3:00 p.m. PT

                                                    RFA Response Due Date: November 4, 2022, 3:00 p.m. PT

COA Website: Upcoming PG&E Bid Opportunities  

Description:

In February 2019 the California Public Utilities Commission (CPUC) adopted Version 1.0 of an Environmental and Social Justice (ESJ) Action Plan to serve as a roadmap for implementing their vision to “advance equity in ESJ programs and policies. On May 20, 2021, the CPUC approved D. 21-05-031 on the “Assessment of Energy Efficiency Potential and Goals and Modification of Portfolio Approval and Oversight Process”. This Decision directs PG&E to segment its portfolios based on the primary program purpose, into three sections: Resource Acquisition, Market Support, and Equity.

As required in CPUC D. 18-01-004, PG&E is seeking abstracts from prospective Third-Party (3P) Implementers (Bidder(s)) to design and propose a new equity energy savings program that will deliver the benefits of energy efficiency and building electrification (Equity Program) to residential customers in disadvantaged communities and to customers in regions that have not historically received it. This Equity Program will be required to focus on effective implementation activities and customer engagement, in contrast to past resource programs with a focus on claimable energy savings.

This Request for Abstract (RFA) is the first stage of a two-stage Equity Program solicitation. Selected Bidders from the RFA will be invited to participate in a subsequent Request For Proposal (RFP). PG&E selected RFP Bidder(s) will be invited to negotiate a contract with PG&E to implement this new Equity Program. 

See attached COA document for detailed requirements, deadlines and documentation instructions.

Respond To:

PowerAdvocate – event link: https://www.poweradvocate.com/pR.do?okey=136113&pubEvent=true

Additional Questions Contact:

            Paula Paschal via Wood Mackenzie PowerAdvocate event 136113.

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Southern California Edison (SCE) is hosting a virtual Clean Energy Summit for business customers.
2022 Clean Energy Summit:Learn How to Accelerate Your Clean Energy Transition
Thursday, Aug. 25, 2022

Main Sessions: 9-11 a.m.Session 1: The Integrated Path to Greenhouse Gas ReductionSession 2: Clean Energy Transformation from a Business and Public Sector Perspective
Breakout Sessions: 11 a.m.-Noon
Option 1: Small Business/Economic Development
Option 2: Water & Agricultural
This special event will provide a forum to hear about California’s greenhouse gas goals and regulations, learn from subject matter experts about innovative programs and technologies, and gather best practices from customers.
Learn more about the topics and speakers, and register for the summit, by using one of the registration options below.

RegistrationGo to https://on.sce.com/cleanenergysummit or scan here with your mobile phone camera.

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The Energy Efficiency Third-Party Solicitations Semi-Annual Stakeholder Forum will be hosted at the SoCalGas Energy Resource Center, July 11, 2022, from 10:00am to 3:00pm. The session will also be available online, by selecting the link below:

Energy Efficiency Third Party Solicitations Semi-Annual Stakeholder Forum

SoCalGas Energy Resource Center

9240 Firestone Blvd.

Downey, CA 90241

This public hybrid in-person and remote meeting will include presentations from the Investor-Owned Utilities (IOUs) on the solicitations process for third-party implemented energy efficiency programs, presentations by the Independent Evaluators (IEs) on the June 2022 Semi-Annual Reports, opportunities for stakeholder feedback, and other topics.

The agenda, presentations, and meeting minutes will be available at the CAEECC website: California Energy Efficiency Coordinating Committee (caeecc.org)

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As part of San Diego Gas & Electric Company (SDG&E)’s energy efficiency solicitations, SDG&E is requesting abstracts for a Small Business Outreach Program. This is the first stage of the solicitation process beginning in July 2022. The Small Business Outreach program will serve small commercial customers in SDG&E service territory, the majority of whom are classified as Hard-to Reach (HTR) or located in Disadvantaged Communities (DAC). This program will be classified as an Equity program to specifically target these customers who are typically underserved through traditional energy efficiency interventions. The Small Business Outreach sector includes two main market segments: Wholesale/Retail/Offices and Hospitality/Services. This request will remain open until June 30, 2022.

For more information and to participate, please see SDG&E’s Small Business Outreach Request for Abstract here:

PEPMA – Public Events (pepma-ca.com)

Energy Efficiency Third-Party Solicitations | San Diego Gas & Electric (sdge.com)

Small Business Outreach: Request for Abstract

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RATE CASES +++++++COVID-19 & RULEMAKING +++++++ENERGY TRUST+++++++SBUA OREGON ANNUAL MTG

Remember that our state legislators passed huge energy bills in 2021 that will result in ratepayers paying in their power and natural gas bills the costs of decarbonizing Oregon’s energy supply. SBUA is advocating that these costs be vetted well and allocated FAIRLY and REASONABLY for all small business and especially small biz customers of Pacific Power, PGE, Northwest Natural Gas, Avista Utilities, Cascade Natural Gas & Idaho Power.

Please send comments to the Public Utility Commission and also to your state legislators with your input! Information and talking points are included here below in the Pacific Power Rate Case, treatment of COVID-19 costs, and rule revisions regarding disconnections and late fees.

RATE CASES   May 24, 2022 6 pm PacifiCorp dba General Rate Case–UE 399 Public Utility Commission (“PUC”) PUBLIC COMMENT HEARING Make comments  by Zoom or Phone:  1 971 247 1195 Meeting ID: 823 8399 1218 Passcode: 4884093995 Zoom Link: https://opuc-state-or-us.zoom.us/j/82383991218?pwd=WUlWTGxZUVVuZGZhbXc0WU90SWpsZz09#success     Northwest Natural General Rate Revision Case – UG 435–a good Public Comment time re COVID-19 costs (see below)

PACIFICORP DBA PACIFIC POWER RATE CASE (“UE 399”):

Here are the numbers per the utility’s proposed changes:

–Small commercial would have a base change of 10.3% and a net change of 9.5%, more than any other customer  except large agricultural  pumping. Residential would have a base change of 12.6% but  a net change of 9.1%—LESS than small commercial. 

–Large commercial and industrial customers would pay only 5.9% more. See this link to see who these customers are: https://edocs.puc.state.or.us/efdocs/HAP/um2033hap155454.pdf

Did you know that small commercial customers in several PacifiCorp’s service territory zip codes are facing

COVID-19 arrearages (unpaid bills) ranging from $1,000-$3,000 apiece ?!!

After extensive work in the last rate case 2020 to identify possible rate designs that could be made for small commercial customers, Pacific Power  proposes NOTHING new for small business. Rather the utility wants the small businesses to pay MORE than other customers for the transition from coal. And the small businesses will be asked to pay MORE than the residential customers (& much more than the industrial or large commercial) even though the small businesses received NOTHING during COVID. Disappointing.

The PUC is having a public meeting Tuesday 5/24 6 pm by Zoom.

Tell the Commission the utility should do more for small business and to incorporate the tools learned from the last rate case such as worthwhile time of use rates.

AND LET YOUR LEGISLATOR KNOW that you are a small business utility customer and tell them you are concerned that small business are treated fairly in Oregon’s transition from fossil fuel based energy supply.

NORTHWEST NATURAL RATE CASE  (“UG 435”):

Northwest Natural Gas Company known as “NW Natural” has asked the Oregon Public Utility Commission (PUC) permission to raise NW Natural’s rates 9.7% for its small commercial customers.

SBUA notes this about this NWW Natural Gas rate case:

—The utility proposes small commercial customers to receive the highest increase in rates of all ratepayer consumers.

—A portion of the small commercial, the largest users,  is being subsidized by the rest of the class, so SBUA recommends the utility change that by creating a different class.

–The PUC Staff is asking that  small commercial pay part of the costs of the COVID-19 relief provided to residential customers. That is approximately $20 million that the PUC Staff  would have small business help pay even though small business were not included in any of the programs paid for by those funds AND the PUC Staff thinks the utility should benefit by receiving all the LATE fees even if there was no cost incurred, and that small businesses should have to pay a portion of those late payment fees that residential customers would otherwise pay. This is NOT FAIR because standard ratemaking principles would have each ratepayer class bear their own expenses, AND the utility should not charge  a late fee where there is no cost associated. See this article  that cites our expert: Food or power: Energy bill late fees force tough choices – ABC News (go.com)

Washington and California did not treat their small businesses as unfairly.

–PUC Staff does not bother to differentiate between large commercial and small commercial in the analysis so essentially treating Safeway and a community hardware store or a dry cleaners similarly.

—SBUA is successful in seeking permission to obtain intervenor funding but the Commission placed significant  limitations on this which continues to create difficult conditions to work.

INVESTIGATION INTO THE EFFECTS OF THE COVID-19 PANDEMIC ON UTILITY CUSTOMERS (UM 2114 Update): the Commission must treat small commercial customers fairly!   SUPPORT SMALL BUSINESS at the 6/9/22 Public Meeting re the PUC Division 21 Rules dealing with late fees, disconnections, deposits and reconnections.  

Contact your legislator and tell them to send a public comment asking them to support send public comment to support small business and SBUA. Tell the Commission that small commercial customers should not be having to pay the costs of the COVID-19 of residential ratepayers ! Tell them small businesses are also part of the environmental justice communities that have suffered disproportionately in the pandemic. Tell the Commissioners that you support what SBUA is doing to support small business and get fair and reasonable rates for the small commercial ratepayers and the Commission should welcome that.

Recall that the devastating economic & social impacts of the COVID-19 pandemic led the PUC  to conduct a rigorous investigation process with utility companies, customer groups, & other stakeholders. SBUA continues to fight to prevent unfair rate increases due COVID-19.

The COVID-19 work has caused the Commission to proceed with a revision of  Division 21 rules. This rule revision is highly critical to our small commercial customers as rules define utility regulation impacts through disconnections, protections, late fees, reconnection fees, utility programs eligibility, etc. SBUA remains involved in this rules revision process filing comments to ensure  the new rules include more protections for small commercial customers. SBUA reminds the Commission that late fees are considered regressive and not based on standard utility ratemaking where costs should serve as the basis for rate increases, and late fees just for the sake of late fees, or to induce customer payments are regressive.

We see some positive results in the Commission Staff favoring more wildfire and extreme weather protections for small commercial customers, and also equal payment plans for small commercial customers too.

See Staff’s Draft Rules from 5/11/22 here: https://edocs.puc.state.or.us/efdocs/HAH/ar653hah165752.pdf

Of big concern to SBUA are zip codes with the highest and longest arrearages from COVID-19 reporting:

SBUA has taken advantage of these monthly reports and has analyzed the persistent arrearage balances for small commercial customers and arranged them by the top zip codes with highest arrearage balances. Using this data SBUA used further government sources such as the Environmental Protection Agency’s EJ Screen tool to help illustrate the environmental justice aspects of these zip codes. Our research has shows correlation between the gathered zip codes and their relationship to environmental stressors.

SBUA is shedding light on small business customers in this zip codes to OPUC staff, utility companies, & stakeholders  to demonstrate how environmental justice communities with a small commercial customers are important members of environmental justice communities and as  ratepayer they must be treated fairly with many of the same protections as residential ratepayers within these communities.

See certain SBUA Small Commercial Zip Code observations here—go to page 3: https://edocs.puc.state.or.us/efdocs/HAC/um2114hac162646.pdf

Energy Trust of Oregon Energy Conservation Updates for Small Commercial Customers

The purpose of the Energy Trust of Oregon (ETO) has been to provide utility customers with incentives and support on energy saving and renewable energy projects. Noticeable program updates from the Conservation Advisory council include a a departure from staff historically focusing on agricultural and industrial programs to increase service to rural small businesses onto a shift for a diversity requirement onto program management contractors to ensure at least 20% of the contract dollars are spent on firms that are certified by the Certification Office for Business Inclusion & Diversity (minority & women owned businesses).

The success of incentive & budget limitations implemented in 2021 has allowed the ETO to increase incentive & active project limits for select programs so small commercial customers may better promote their businesses. Programs such as Business Lighting, Existing Building, & Production Efficiency have had noticeable increases of $250,000 incentive project limits.

ETO is offering standard & custom bonus incentives for select gas-saving equipment for existing commercial, industrial, & multifamily properties in Oregon. To qualify for this offer equipment must be purchased on or after March 1st and installed on or before September 30, 2022. The ETO has recently announced its roundup of spring 2022 commercial & industrial incentive increases which includes new upgrades to their business lighting, existing buildings, & industry and agriculture incentives programs. Click the links below for more information to qualify any questions you may have!

​​https://insider.energytrust.org/roundup-of-spring-2022-commercial-and-industrial-incentive-increases/?the-program=existing-buildings

SBUA Oregon Member Meeting June 24 at noon or June 25 at 9. TBD Please join us for a one hour update! We’ll be calling you soon.   CONTACT SBUA OREGON AT GUILLERMO@UTILITYADVOCATES.ORG  OR DIANE@UTILITYADVOCATES.ORG
   

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SBUA is fighting to ensure fair and reasonable energy costs for small business ratepayers in Avista’s service territory. We want your input! Avista is asking to raise gas and electricity rates by over 2.7% and 2.6%, respectively, for small commercial customers. How will this impact your business and what concerns do you have?

Please let us know by commenting below or sending comments to britt@utilityadvocates.org!

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