To: Montana Public Service Commission
Pay for Energy Efficient LED Street Lights With NorthWestern Energy Overcharge
Please eliminate NorthWestern Energy overcharges for street lighting and use refunded money to finance, without the need for tax or electricity rate increases, conversion to energy efficient LED street lighting.
Why is this important?
We asked the Montana Public Service Commission (PSC) to require NorthWestern Energy to update existing street lights with more efficient LEDs. We’ve provided a way to pay for the retrofit. That is, we want the PSC to eliminate an overcharge that is costing Montanan’s roughly $2.1 million a year and to claw back approximately $25 million in past overcharges. That’s more than enough money to pay for implementation of this energy-efficient technology. Further, we allege that Montana’s Constitutional right to a clean and healthful environment requires elimination of NorthWestern’s wasteful nighttime energy usage. Monopolies like NorthWestern should not be allowed to force customers to pay more than they should have to because there is no alternative to the energy-hog lights NorthWestern supplies. If you support the refund of past overcharges to fund additional ongoing savings coming from purchase of Dark Sky Association approved LED street lights please join our petition; send it to 10 of your friends, and ask them to do likewise. We will present the petition as part of the public comment portion of the case.
The city of Los Angeles has installed 150,000+ LEDs creating a 63.3% street lighting energy-use reduction and $7.7 million annual dollar savings (as of December 17, 2013). New York is replacing a quarter of a million of its lights with LEDs. Other cities are also moving to conserve energy.
More than 2180 local governments in 50 states (+Washington DC, Guam & Northern Mariana Is), and 84 (of 196) countries & all 13 Canadian provinces and territories have installed some LED street lights. In many towns, payment for energy to light streets consumes 37 to 50+% of the municipal budget. We can cut the energy component of that expense in half. It is estimated that the US has between 26 and 52 million street lights. The technology used in those is 90 years old and the average age of these lights is 25 years. Energy to illuminate streetlights in the US costs tax and ratepayers $2 billion a year and $4 to $6 billion a year to operate and maintain them. Conversion of 52 million luminaires would save enough energy to supply 500,000 US households.
At present, the PSC has decided to consider only the overcharge issue in the case. However, it has reserved consideration of other issues and we will be making offers of proof on issues not currently under consideration. Those issues include:
1) whether conversion to LEDs by NorthWestern should be mandated (as the conversion to high pressure sodium street lights from less efficient lighting was required by the PSC in 1982);
2) whether the overcharge ought to be used to fund energy efficient LED street lighting (which is saving communities worldwide money and reducing nighttime energy usage by more than 50%;
3) whether NorthWestern should be required to allow use of its poles that consumers have paid for to house LED lights if NorthWestern does not supply them (as has been done when Ottertail Power was required by the US Supreme Court to allow competitors to use its facilities);
4) whether a non-metered tariff for LED luminaires ought to be developed to eliminate the cost of metering LEDs (similar to the non-metered tariff now used to bill for current lights and non-metered tariffs offered by other utilities); and
5) whether future bills should reflect the amortization schedules of lights so cities will know when lights have been paid for and the portion of the charge used to defray infrastructure costs should drop out of the bill.
If we can eliminate the present overcharge and apply past, refunded overcharge to save energy, property owners in roughly 80% of the districts with NorthWestern-owned street lights, will see a reduction of approximately $70 to $120 a year per household in their individual property tax bills. For the other 20% of street lighting districts it will mean elimination of looming future overcharges. For Montana local governments it will mean revenue savings due to elimination of part of the overcharge they pay when they contribute to overcharged lighting districts encompassing city property. After the cost of the new LED luminaires are covered from the overcharge, we are requesting that money remaining after other expenses in the case be refunded to consumers.
Our testimony and exhibits have been posted (date of 3/21/14) on the Public Service Commission website at the link to docket # D2010.2.14 (incoming tab).
Seattle City Light’s Edward Smalley, former Director of DOE’s Municipal Solid-State Street Lighting Consortium, notes:
“LED technology has advanced to a point where it not only meets design standards for a plurality of applications where cobra head fixtures are used, but cost benefit analysis reveals the technology to also be cost effective. While many are seeing energy saving of greater than 50% over HPS, the driver for a large number of system owners is actually the operations and maintenance savings, both in manpower and resources. Furthermore, organizations like the Municipal Solid-State Street Lighting Consortium provide [online] tools and expertise to help simplify a transition to LED technology. We are at a point where it has become evident that there is a clear benefit of replacing HPS roadway lighting with LED.”
To purchase 2000 LED streetlights in 2009, Seattle spent $369/luminaire. Today a better performing unit costs near $150 to replace luminaires in residential areas. As of the end of 2013, Seattle City Light has saved its street lighting customer $2.6 million per year in energy and maintenance costs by the conversion to LED street lighting, 75% of this savings going to the citizens of Seattle. It is anticipated that the savings will approach between $4-5 million a year once all 86,000 Seattle streetlights are converted to LED. At that point municipal energy use will have been reduced by 24%. Seattle City Light’s estimated simple payback is 7.6 years. Seattle’s RFP requires a 10 ye...
The city of Los Angeles has installed 150,000+ LEDs creating a 63.3% street lighting energy-use reduction and $7.7 million annual dollar savings (as of December 17, 2013). New York is replacing a quarter of a million of its lights with LEDs. Other cities are also moving to conserve energy.
More than 2180 local governments in 50 states (+Washington DC, Guam & Northern Mariana Is), and 84 (of 196) countries & all 13 Canadian provinces and territories have installed some LED street lights. In many towns, payment for energy to light streets consumes 37 to 50+% of the municipal budget. We can cut the energy component of that expense in half. It is estimated that the US has between 26 and 52 million street lights. The technology used in those is 90 years old and the average age of these lights is 25 years. Energy to illuminate streetlights in the US costs tax and ratepayers $2 billion a year and $4 to $6 billion a year to operate and maintain them. Conversion of 52 million luminaires would save enough energy to supply 500,000 US households.
At present, the PSC has decided to consider only the overcharge issue in the case. However, it has reserved consideration of other issues and we will be making offers of proof on issues not currently under consideration. Those issues include:
1) whether conversion to LEDs by NorthWestern should be mandated (as the conversion to high pressure sodium street lights from less efficient lighting was required by the PSC in 1982);
2) whether the overcharge ought to be used to fund energy efficient LED street lighting (which is saving communities worldwide money and reducing nighttime energy usage by more than 50%;
3) whether NorthWestern should be required to allow use of its poles that consumers have paid for to house LED lights if NorthWestern does not supply them (as has been done when Ottertail Power was required by the US Supreme Court to allow competitors to use its facilities);
4) whether a non-metered tariff for LED luminaires ought to be developed to eliminate the cost of metering LEDs (similar to the non-metered tariff now used to bill for current lights and non-metered tariffs offered by other utilities); and
5) whether future bills should reflect the amortization schedules of lights so cities will know when lights have been paid for and the portion of the charge used to defray infrastructure costs should drop out of the bill.
If we can eliminate the present overcharge and apply past, refunded overcharge to save energy, property owners in roughly 80% of the districts with NorthWestern-owned street lights, will see a reduction of approximately $70 to $120 a year per household in their individual property tax bills. For the other 20% of street lighting districts it will mean elimination of looming future overcharges. For Montana local governments it will mean revenue savings due to elimination of part of the overcharge they pay when they contribute to overcharged lighting districts encompassing city property. After the cost of the new LED luminaires are covered from the overcharge, we are requesting that money remaining after other expenses in the case be refunded to consumers.
Our testimony and exhibits have been posted (date of 3/21/14) on the Public Service Commission website at the link to docket # D2010.2.14 (incoming tab).
Seattle City Light’s Edward Smalley, former Director of DOE’s Municipal Solid-State Street Lighting Consortium, notes:
“LED technology has advanced to a point where it not only meets design standards for a plurality of applications where cobra head fixtures are used, but cost benefit analysis reveals the technology to also be cost effective. While many are seeing energy saving of greater than 50% over HPS, the driver for a large number of system owners is actually the operations and maintenance savings, both in manpower and resources. Furthermore, organizations like the Municipal Solid-State Street Lighting Consortium provide [online] tools and expertise to help simplify a transition to LED technology. We are at a point where it has become evident that there is a clear benefit of replacing HPS roadway lighting with LED.”
To purchase 2000 LED streetlights in 2009, Seattle spent $369/luminaire. Today a better performing unit costs near $150 to replace luminaires in residential areas. As of the end of 2013, Seattle City Light has saved its street lighting customer $2.6 million per year in energy and maintenance costs by the conversion to LED street lighting, 75% of this savings going to the citizens of Seattle. It is anticipated that the savings will approach between $4-5 million a year once all 86,000 Seattle streetlights are converted to LED. At that point municipal energy use will have been reduced by 24%. Seattle City Light’s estimated simple payback is 7.6 years. Seattle’s RFP requires a 10 ye...