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The concerns that Mr. Spitzer, who currently practices energy law representing energy companies, states in his Opinion published Nov. 7 are rational, although clearly biased to Tucson Electric Power Company (TEP).

Mr. Spitzer fails to recognize that ratepayers-stakeholders, AZ Residential Consumer Office (RUCO), have been very active in stating their concerns to TEP and the Arizona Corporation Commission (ACC). The reason that the Municipal Electric Utility Study was initiated is that Tucson Electric Power Company doesn’t listen, act effectively and promptly to address captive Ratepayer concerns. TEP prioritizes paying huge executive compensation and shareholder dividends.

Chronic compounded rate increases during a time when lower fixed cost Arizona Solar-Energy Storage (BESS) are available and being deployed by other Arizona utilities like Salt River Project that have much lower rates than TEP is irresponsible and regressive.

Ratepayers currently provide TEP with about $200 million in profit each year. Just eliminating the profit would recover the possible $800M implementation expense in just four years. And that doesn’t include the avoided costs of the 30-40% rate increases TEP is now pursuing.

As current ACC policy holds captive ratepayers responsible for all expenditures consequent to TEP Management decisions that take decades to pay, TEP has no risk, and are guaranteed profit for decades. The current 9.5% “Return-on-Rate” is excessive, unearned, and should be no more than the 3-4% Federal interest rate.

In addition to their excessive profit, TEP continues to make decisions that increase other costs that could be avoided by simply increasing Utility-Residential-Commercial Scale Solar-BESS generation.

Those cost reduction opportunities include, and are not limited to:

Aquifer water depletion and Tucson Water costs to acquire a new water supply (TEP pays nothing for the water they withdraw from our common aquifer);

Heat-trapping emissions that create greater electricity usage/TEP revenues and exacerbate extreme weather events, wildfires, transmission pole damages, health care, private/public insurance costs.

Non-competitive wages per the ADEQ average $118,000/year, the highest of all AZ Industries.

Generation via lower fixed cost solar-BESS closer to demand points, within/adjacent to the distribution grid, reduces the need for incremental expensive transmission infrastructure that is vulnerable and loses 8% of the electricity during transmission.

Generating 86% of their electricity utilizing expensive fossil fuels, and AC Turbines that require avoidable operating-maintenance labor costs.

In closing, with a slight but significant modification, I concur with Mr. Spitzer’s conclusion that:

“The lesson of Boulder is the road to success is stakeholder engagement and consensus followed by transparent negotiations with the incumbent utility. I would expect Tucson [Electric Power Company] to follow that path.”

Solutions are available. TEP management needs to collaborate with ratepayers, stakeholders, to quickly increase Solar-BESS, avoid chronic rate increases and depletion of our precious aquifer water that constrain our local economy and standards of living.