Repeal the Holy Cross Energy Rate Restructure

UPDATE: Holy Cross Energy has delayed its new rate structure until January 2024. In the meantime, a meeting with COSSA and state officials regarding the future of net metering will be held this month. READ MORE HERE.

The BIG Three Reasons HCE Must Repeal the Rate Restructure

1. This rate change is illegal. 

  • The new rate structure is against Colorado net metering laws that have been in place since 2008. 
  • One of the 2008 laws was HB08-1160 which mandates that all cooperatives in Colorado have to pay the full retail rate for all energy produced onsite by solar.
  • By breaking out the energy charge (kWh) and the demand charge (kW), Holy Cross is using an accounting trick to get around this well-established law.

Even if the rate change were legal;

2. This rate change is not sound policy.

  • Under a demand charge, a member who uses very little energy will see an 18% increase in their bills, whereas customers consuming substantial amounts of energy will see an 18% decrease.
  • The new rate design makes it more difficult for communities to achieve ambitious climate action goals by devaluing PV and making electrification of cars and buildings more expensive. 
  • The new rate structure increases fixed fees and devalues solar installations, making it harder for families to access the benefits of federal solar tax credits.
  • Utilities rarely use this demand rate for residential rates because it is confusing for customers and difficult to act on.
  • The new demand charge is based on your peak use during high-demand hours (4:00 – 9:00 pm). This means your whole month’s electricity bill will be based on your single-worst 15-minute block out of 600 similar windows throughout the month. That does not equate to customers only paying only for what they use.

Even if the rate change weren’t bad policy;

3. This rate change is not necessary right now.

  • Holy Cross Energy has low penetration of rooftop solar and is not overwhelmed by residential solar production. Only 4% of their members have on-site solar. 
  • Holy Cross does not have a revenue deficiency caused by lost revenues. While it states that its goal with the new rate design is to match costs with revenues, the co-op already has a strong balance sheet.
  • This significant rate change should never have been passed by the Holy Cross Energy Board of Directors before being publicly announced, let alone before accepting member feedback.  Holy Cross needs to adopt a better communication process with its members before making big changes.

Want to dig in further? Here’s the deep dive. 

Below you will find links to additional resources including the full case we sent to the Holy Cross Energy Board of Directors. The first two pages are an Executive Summary Letter by COSSA CEO Mike Kruger and can be downloaded individually.  

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