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Direct Testimony of Karl R. Rábago (Rabago) for RENEW Wisconsin and Environmental Law and Policy Center

Net Energy Metering   
Wisc Public Service Commission Docket 6690-UR-123. The purpose of this testimony is to demonstrate many significant errors underpinning the wholesale attack by Wisconsin Electric Power Company (the “Company”) on customer generators. The testimony points out the deficiencies in and adverse consequences of the proposals by the Company to: 1. raise fixed customer “facilities” charges; 2. impose standby/demand charges on distributed generators; 3. impose a new requirement for monthly netting on net metering customers; 4. set a de facto avoided cost rate for purchased or credited energy from customer generators; 5. and to impose a new facilities charge for metering, customer accounting, and customer charges. The testimony recommends the Public Service Commission of Wisconsin disapprove of all the Company's proposals to increase so-called facilities charges and to increase or create new charges and conditions on customer generators because the proposals are not adequately justified and are contratary to public policy of sound ratemaking. This testimony was developed exclusively for the role of Rabago Energy LLC.