THE GLOBAL WARMING SOLUTIONS ACT A DECADES-LONG BURDEN ON VERMONT

The Vermont House overrode Governor Scott's veto of GWSA, and sent it to the Vermont Senate for an override vote

GSWA converts the aspirational goals of the CEP, into mandated goals, with penalties, taxes, fees and surcharges. 

GWSA had been called “must pass this Session”.

 

Capital Costs to Implement the Vermont Comprehensive Energy Plan

 

In 2015, Energy Action Network, EAN, an umbrella organization for RE businesses, etc., had estimated it would take at least $1.0 BILLION per year for 35 years to implement the CEP by 2050, not counting many $billions for 1) financing costs and 2) replacement costs of short-live systems (wind, solar, batteries, EVs, heat pumps) during these 35 years.

 

http://eanvt.org/wp-content/uploads/2016/04/EAN-2015-Annual-Report-... 

https://outside.vermont.gov/sov/webservices/Shared%20Documents/2016...

 

GWSA to Subsidize Job Creation in RE Sectors

 

Vermont has a very poor climate for traditional, private-enterprise job creation. Forbes, et al., rate Vermont near the bottom. There are too many onerous taxes, fees and surcharges, and rules and regulations, that have caused businesses to 1) not grow in Vermont, 2) leave Vermont, and 3) not even come to Vermont.

 

Vermont’s population is stagnant. Ambitious, younger people leave, older, more-needy people stay.

Well-paying, steady jobs, with decent benefits, are hard to come by in Vermont, except in government and education. 

 

GWSA would create an expensively subsidized, industrial development policy that would:

 

1) Require major increases in the current levels of various subsidies to all sorts of RE businesses for decades.

2) Produce expensive, mostly weather-dependent, unreliable, variable/intermittent, wind/solar electricity.

3) Very expensively “create jobs” that would not exist without the subsidies, the expense of other Vermonters.

 

The GWSA “industrial development policy” would be an expensive substitute for traditional, private-enterprise job creation, which has proven so difficult in Vermont, largely because of historic, socialistic mindsets within the Legislature, which prefer to protect/enlarge/perpetuate vote-getting pet projects, instead of creating the proper conditions for a vibrant private sector that produces hi-tech products, employs highly-skilled, tax-paying workers, in steady jobs, with good benefits.

 

GSWA Requires Major Annual Spending Increases

 

Annual spending on RE would have to increase from the current $210 million/y (includes $60+ million for Efficiency Vermont) to at least $1.0 billion per year, to implement the CEP.

 

If the RE subsidies were “freebie” federal subsidies, they would subsidize and grow RE businesses, and create jobs.

However, federal subsidies increase and decrease, and come and go.

 

If the subsidies were “state” subsidies, such as for 1) heat pumps, 2) electric vehicles, and 3) above-market, feed-in rates for solar, such as net-metering at 21.7 c/kWh and Standard Offer at 21.7 c/kWh, they would be extracted from Vermont ratepayers, taxpayers and tourists, which, as has been proven, would create jobs in the RE sectors, but would, as has been proven, eliminate jobs, or prevent jobs from being created, in almost all private-enterprise sectors.

 

That would further worsen the near-zero, real-growth Vermont economy, and prolong the adverse employment conditions of the “Virus economy”.

 

Brief Summary of GWSA

 

The Agency of Natural Resources, ANR, led by Peter Walke (who is a member of EAN), has to create the rules and regulations, and penalties for non-compliance, which would be subject for review by a “SUPREME COUNCIL”, i.e., mostly appointed RE profiteers with ties to RE companies.

 

GWSA states, if the ANR measures would not sufficiently reduce Vermont’s carbon dioxide, CO2, as scheduled per CEP, any entity, such as the Conservation Law Foundation, would be allowed to sue the state government, with lawyer’s fees reimbursed, if the suit is upheld in Court.

 

GWSA states, the legislature and any Governor’s administration would play no role other than the legislature voting to provide the money, extracted from more and more impoverished, already-struggling, Virus-unemployed Vermonters, to implement it all.

 

I foresee:

 

1)  A growing bureaucracy embroiled in one litigious brouhaha after another

2) Vermonters becoming more and more oppressed and impoverished in the pursuit of impossible climate goals

3) Vermont becoming less and less attractive as a place to do business, to visit, and to live.

4) GWSA inflicting decades of torture of Vermonters to achieve nothing regarding the climate, other than “feel-good/virtue-signaling”.

John McClaughry Commentary on GWSA

 

The GWSA bill would set up a “climate government” within the government, to direct state regulators to do whatever is necessary to achieve the emissions reductions needed to save the Planet from heat death, as if what Vermont does would make even the slightest bit of difference. See Note.

 

This counterfeit “climate government” would be chaired by the Secretary of Administration, but the Dem/Prog leaders of the House and Senate would appoint twice as many members as the Governor to make sure the Governor would always be outvoted.

 

Not only that, the Dem/Prog leaders thoughtfully provided a majority of their Climate Council’s membership may call meetings, if the Governor’s appointed chairman would not do it. 

 

And to top it off, the Council would invite the Conservation Law Foundation to sue the Governor’s cabinet officers whenever it believes the state government would not be moving fast enough to further wreck the already-weak, near-zero, real-growth Vermont economy, in the name of stamping out global warming.

            

The GWSA bill is purposely designed to lock up Phil Scott in a closet. He needs to stand up on his hind legs and tell the Senate he is ready with a veto.

 

NOTE: This URL, first table, shows Vermont is completely invisible.

https://wattsupwiththat.com/2020/06/23/update-global-man-made-co2-e...

EAN, VEIC, AND VELCO MAKING A SELF-SERVING JOINT ATTACK TO GAIN THEIR OBJECTIVES

 

All three entities want to build out solar from 438.84 MW dc, to at least 1000 MW dc, by 2025 (seven years sooner than required by the CEP), even though solar:

 

- Is, by far, the most expensive electricity in the portfolio of Vermont utilities. Table 3 shows some of solar costs shifted onto ratepayers, taxpayers and added to government debts. See Appendix.

- Imposes the greatest threat to the stability of the grid, due to ever-larger DUCK-curves, as has happened in southern Germany and southern California. The more solar, the larger the DUCK-curves.

- Would make the use of EVs and heat pumps much more costly.

 

NOTE: The CEP goal is 1000 MW dc, by 2032

 

1) Self-Serving, Impossible CO2 Reduction Dreams of EAN

 

“Meeting Paris”: In 2019, EAN made estimates of what it would take to “meet Paris”, i.e., reduce CO2 from 9.76 million metric ton, at end 2016, to 7.46 MMt, at end 2025, or 2.281 MMt. See URL

https://www.eanvt.org/wp-content/uploads/2020/03/EAN-report-2020-fi...

 

EAN proposed several measures to reduce CO2, including deploying, by end 2025:

 

Table 1/Item	Quantity/5y	Quantity/y	CO2	CO2
			Reduction	Reduction
			MMt	Mt/EV/y
EV	90000	18000	0.405	4.500
ASHP	90000	18000	0.370	4.111

 

Increase solar from 438.84 dc, at end 2019 to at least 1000 MW dc, at end 2025

See Note and pages 3, 4 and 5 of URL

 

Vermont had deployed, at end 2019:

 

3541 plug-in hybrids and pure EVs, increasing at about 750 per year

17,717 ASHPs, increasing at about 2850 per year

 

The totally unrealistic EAN goals, (increasing plug-ins from 750 to 18000 per year, increasing heat pumps from 2850 to 18000 per year) are beyond rational, even if 50% of the cost of EVs and heat pumps were donated by ratepayers, taxpayers, and added to government debt. This means “Meeting Paris” is beyond rational.

 

The above EAN CO2 reductions per EV, and per ASHP, are grossly overstated, because of flawed/deceptive analyses.

As a result, many more EVS and ASHPs would be required to achieve the EAN CO2 reductions.

See URL and below ASHP and EV articles

http://www.windtaskforce.org/profiles/blogs/response-to-energy-acti...

 

NOTE: All of Europe (550 million people, excl. Russia) is not “meeting Paris”, and neither are China (1.4 billion people), India (1.4 billion people), etc.

If those heavy hitters are absent, why should ultra-light-featherweight Vermont “meet Paris by 2025”?

Because GSWA mandates the VT CEP be implemented? Off-the-charts irrational!

NOTE: China and India are building coal plants and using more coal.

 

https://wattsupwiththat.com/2018/12/09/china-is-building-coal-power...

https://wattsupwiththat.com/2017/04/25/india-wont-be-able-to-meet-p...

https://wattsupwiththat.com/2021/01/18/surprise-china-coal-output-r...

2) Self-Serving, Impossible CO2 Reduction Dreams of VEIC

 

In 2016, VEIC published a 4-volume, Solar Pathways report, at a cost of about $740,365, paid for by the US Department of Energy

https://www.osti.gov/servlets/purl/1434651

 

In 2020, VEIC published an update of the Solar Pathways report, at a cost of about $50,000, courtesy of private donors.

Currently, only Volume One is available.

http://www.windtaskforce.org/profiles/blogs/vermont-solar-market-pa...

 

VEIC claims Vermont could reach 20% of electricity consumption from solar by 2025, if solar capacity would increase by about 19%/y, from 438.84 dc, at end 2019, to at least 1000 MW dc, at end 2025, 6 years.

VEIC did not provide a capital cost of increasing solar.

 

3) VELCO Claims Solar Requires Storage to Deal with DUCK-Curves

 

Vermont Electric Power Company, VELCO, proposed a $1.2 billion Fortress Vermont program, to be implemented by 2025, if solar were built-out from 438.84 dc, at end 2019 to at least 1000 MW dc, at end 2025, as proposed by EAN and VEIC

 

The $1.2 billion would be just a down-payment to end 2025, with more required in future years.

 

About $900 million would be for battery and other storage systems

About $300 million would be for curtailment payments to solar system owners for electricity they could have produced, but did not.

 

The DUCK-curves in future years would be a lot larger than in 2018.

 

The Fortress Vermont program would be needed solely because of the solar increase.

None of that cost would ever be charged to owners of solar, because that would make solar even more expensive; all part of coddling solar.

 

Capital Cost of Storage

Current capital costs for engineered, turnkey, 4-h duration, battery storage systems in New England are at least $500/kWh, HV ac to HV ac basis.

These are systems with a life of about 15 years, i.e., most of the capital cost would repeat every 15 years.

 

There are hopes capital costs of engineered, turnkey systems may decrease to, say $300/kWh in New England, but those prices likely would not happen anytime soon.

 

Connecting to Nearby Grids

The VELCO proposal is an “isolationist/Vermont is an island” approach, to be avoided like the plague.

 

European countries deal with wind/solar variations by interconnecting their grids with HVDC and HVAC lines.

Expensive battery storage, as proposed by “blinders-on” VELCO, et al., is not required. See URL.

http://www.windtaskforce.org/profiles/blogs/fortress-vermont-a-mult...

 

EAN, VEIC, and VELCO Goals of 1000 MW of Solar by 2025 are Self-Serving and Unrealistic

 

Their goals appear to be unattainable with:

 

1) The Federal EV tax credit having been cancelled

2) The solar Investment Tax Credit expiring in 2022

3) The multi-year recession and high unemployment due to the virus economy.

4) ASHPs Marginally Effective for Reducing CO2 in Average Vermont Houses. See ASHP URL 

5) EVs Minimally Reducing CO2 Compared with Efficient Gasoline Vehicles. See EV URL

6) The recent FERC PURPA update to ensure proper competition, i.e., no sweetheart deals.

Major increases of taxes, fees and surcharges on ratepayers, taxpayers, and adding to government debt to pay for their self-serving, dubious claims, likely would not be a palatable option. See table 2

 

Table 2/ Federal ITC	2019	2020	2021	2022, etc.
	%	%	%	%
Residential	30	26	22	0
Commercial	30	26	22	10

VERMONT CO2 REDUCTION OF ASHPs IS BASED ON MISREPRESENTATIONS

This article shows ASHPs are ineffective in average Vermont houses.

Owners lose money each year, and the CO2 percent reduction/ASHP is minor.

EAN/VT-DPS concocted an artificial/political value of 34 g CO2/kWh to “evaluate” ASHPs, about 8 times less than NE grid CO2/kWh, to make ASHPs look extra good!!! See Appendix and URL

http://www.windtaskforce.org/profiles/blogs/vermont-co2-reduction-o...

 

VERMONT CO2 REDUCTION OF EVs IS BASED ON MISREPRESENTATIONS

This article shows owners would have cost savings/mile, even if compared against a higher-mileage gasoline vehicle

The CO2 percent reduction/EV is minor, if compared to a higher-mileage gasoline vehicle, on a lifetime basis.

EAN/VT-DPS concocted an artificial/political value of 34 g CO2/kWh to “evaluate” EVs, about 8 times less than NE grid CO2/kWh, to make EVs look extra good!!! See Appendix and URL

http://www.windtaskforce.org/profiles/blogs/vermont-co2-reduction-o...

THE VAGARIES OF SOLAR IN NEW ENGLAND

https://www.windtaskforce.org/profiles/blogs/the-vagaries-of-solar-...

CONFLICT OF INTEREST

- The membership of EAN includes ten prominent members of Vermont Department of Public Service, VT-DPS: June Tierney, Riley Allen, Ed McNamara, TJ Poore, Anne Margolis, Andrew Perchlik, Maria Fischer, Phillip Picotte, Ed Delhagen, Kelly Launder.

- June Tierney is the Commissioner.

- Andrew Perchlik is on loan to the Legislature to shepherd the GWSA and $1.2 billion “Fortress Vermont” bills to ensure they contain all the bennies for EAN members.

- Perchlik manages the Clean Energy Development Fund that donates taxpayer money to renewable energy programs.

- No wonder VT-DPS resorts to artificial/political CO2 calculations regarding Vermont’s electrical sector, and EV and ASHP programs.

https://www.eanvt.org/about/people/network-members/

HOUSE BILL TO INCREASE IN-STATE SOLAR FROM 8.6% IN 2009 TO 20% IN 2032

 

Is not it amazing, after EAN, VEIC and VELCO advocated solar build-outs that are totally unrealistic, the VT House comes out with a bill to increase solar build-outs?

 

This section has information from this Seven-Days article, which contained some interesting information.

https://www.sevendaysvt.com/vermont/solar-flares-call-to-double-ver...

 

The bill mandates utilities buy 20% of their electricity supply, about 1.2 BILLION kWh/y, from in-state RE sources which effectively means solar, because the other RE sources are barely growing.

 

Solar:

 

- Is, by far, the most expensive electricity in the portfolio of VT utilities, such as GMP. See Appendix.

- Imposes the greatest threat to the stability of the grid, due to ever-larger DUCK-curves, as have happened in southern Germany and southern California

- Would make the use of EVs and heat pumps prohibitively expensive.

 

The bill appears uncomplicated to lay people, and some legislators eager to please Vermont solar businesses, but is far from it, according to energy systems analysts at VT-DPS and GMP, who oppose the solar expansion for various reasons.

 

- Vermont had installed 364.24 MW ac, or 438.84 MW dc, at end 2019, per ISO-NE/VT-DPS, which had a legacy capital cost of about $2 billion.

- In 2019, solar electricity generation was about 475,248 MWh, or 475.25/6000 = 7.9% of supply to utilities, or 475.25/5600 = 8.5% of consumption via wall sockets.

- Vermont installed solar would need to increase to about 20/8.5 x 438.84 = 1033 MW dc, at end 2032, per House bill. See Note.

- The additional capital cost would be about (1032 – 438.84) x $3 million/MW = $1.781 billion, or $137 million/y for 13 years, excluding:

 

1) Grid extension/augmentation to connect solar systems and deal with solar variability

2) Increased connections to nearby grids to minimize disturbances due to solar, as Germany did.

3) Any storage to deal with midday DUCK-curves

4) Any inverter replacements in about year 12 and O&M

  

Cost Shifting for Coddling Solar

Historically, items 1, 2 and 3 have been charged to ratepayers, taxpayers, and added to government debt.

If they had been charged to owners of solar systems, they would be a lot less eager to have solar.

 

NOTE: Legislators, and pro RE-entities, usually offer the “easy-talk/hand-waving” option of “we do this and that, by that date, and Vermonters will save lots of money, and save the climate”.

However, the experts at VT-DPS and GMP have no choice, but to evaluate the A to Z picture of cost and physical implications of increased solar on:

 

1) Electric rates, c/kWh

2) Stability of the grid

3) Expansion/reinforcement of the grid

4) Substations on grids with solar systems needing to be arranged to receive and send power.

 

If they did not, all hell may break loose, such as costs/kWh going through the roof, and the grid becoming unstable, especially on sunny days and variable-cloudy days, at some future date.

http://www.windtaskforce.org/profiles/blogs/vermont-solar-market-pa....

Wind/Solar Lulls

 

Some bill proponents likely do not realize, Vermont (and New England, and Germany and Denmark, etc.) often has wind/solar lulls (extended overcast periods, with rain or snow, and little or no wind) of up to 5 to 7 days, i.e., the combined wind/solar output that could have been expected, for that time of year, is, in fact, less than 15% of expectations. Sometimes, a second lull follows the first one a few days later.

Where would the shortfall come from?

Traditional generators in nearby states?

Storage?

https://www.windtaskforce.org/profiles/blogs/the-vagaries-of-solar-...

 

Subsidized Solar Profiteers Aided and Abetted by Legislators

 

SunCommon, politically well-connected, wants to build-out solar for solar’s sake, because it makes good money installing solar systems. It does not care about:

 

1) Net-Metered solar and Standard-Offer solar being charged to the utility rate base at up to 21.7 c/kWh, whereas such solar is worth to a utility about 8.5 c/kWh; N-M and S-O are the most expensive energy sources in the GMP electricity supply mix. See Appendix

2) The capital cost of expensive grid extension/augmentation to physically connect solar systems and expensive battery storage to subsequently deal with their output variations. See Solar Coddling Services.

3) Ratepayers, taxpayers, etc., paying through the nose, while they are being told various fables/fantasies about Vermont fighting climate change. See explanation of cost-shifting in Table 4.

4) Subsidy-fueled solar job creation causing increased costs, decreased job creation, and anemic growth in other sectors.

 

Free Solar Coddling Services: SunCommon does not care about midday, grid-disturbing, DUCK-curves, and grid-disturbing downward output spikes due to variable cloudy weather.

 

Owners of other generators, mostly gas turbine plants, are required to rapidly decrease their outputs to let his unruly, unreliable, expensive, solar onto the grid, starting around mid-morning, and then they are required to rapidly increase their outputs to fill the void, as solar nods off to go to sleep, starting late-afternoon/early-evening (a period with peak demands, mind you), until it wakes up about mid-morning the next day.

 

A rational person likely would think it is a true miracle, that solar, being such an expensive, troublesome, mostly absent “part-time worker”, is getting all these subsidies, plus free coddling services.

 

Table 3 shows the prices of solar, before and after subsidies, and before and after cost shifting, in sun-starved New England.

 

Table 3/Vermont & NE sources	Total	Grid support*	Subsidies	Paid to	GMP	Added to
	cost	cost	to owner	owner	adder	rate base
	c/kWh	c/kWh	c/kWh	c/kWh	c/kWh	c/kWh
Solar, residential rooftop, net-metered, new	24.7	2.1	5.2	17.4	3.4	20.8
Solar, residential rooftop, net-metered, legacy	25.5	2.1	5.4	18.0	3.7	21.7
Solar, com’l/ind’l, standard offer, new*	22.7	2.1	9.6	11.0	?	11.0
Solar, com’l/ind’l, standard offer, legacy	34.3	2.1	10.5	21.7	?	21.7
Wind, ridge line, new*	18.8	2.4	7.4	9.0	?	9.0

 

* Grid support includes Fortress Vermont grid extension/augmentation, storage to deal with DUCK-curves, curtailment payments to solar system owners, traditional generators (mostly gas turbines) counteracting solar output variations, etc.

* Competitive bidding reduced prices paid to owner from 24 – 30 c/kWh to about 11.0 c/kWh

http://www.windtaskforce.org/profiles/blogs/fortress-vermont-a-mult...

 

Observations by Castonguay, Chief Innovation Officer at Green Mountain Power

 

Castonguay stated, paraphrased:

  

- Storage would increase rates by 6 to 12%; that would be on top of any regular rate increases. Not good for promoting EVs and heat pumps.

- Solar has become too much of a good thing, and the grid upgrades needed to handle an intermittent power source have become an expensive problem. See Note.

- Other, lower-cost, in-state and out-of-state sources of renewable electricity need to be added to the utility mix.

 

NOTE: How can solar be a “good thing”, if it has midday DUCK-curves that disturb the grid and cost a lot of money to fix with storage and grid upgrades, plus owners of gas turbine plants incurring extra costs for counteracting the varying solar outputs, all adding up to a cost of  about 25 c/kWh, about five times NE wholesale grid prices?

 

Observations by McNamara, Planning Director at VT-DPS

 

McNamara claims a study is required to determine solar’s grid and rate impacts. He stated, paraphrased:

 

Economics:

- Prior net-metered rates were too high, because solar capital costs per kW had decreased, and the resulting excessive solar installation rates were unsustainable; a rate reduction was overdue

- Electric rates must be kept low to encourage people to use EVs and heat pumps

- Focusing on solar, regardless of costs, would further worsen the near-zero, real-growth Vermont economy, and prolong the adverse employment conditions of the “Virus economy”.

 

Grid Resiliency:

- Focusing on new in-state generation, mostly solar, is “isolationist”, which would lead to less resiliency.

- Massive storage to deploy “solar for solar’s sake” would be unwise regarding grid stability, and unnecessary.

- Vermont’s grid needs to be connected to nearby grids (Canada and New York) for maximum resiliency. See how European countries connect grids to counteract wind/solar fluctuations in this URL

http://www.windtaskforce.org/profiles/blogs/fortress-vermont-a-mult...

 

Revising the In-State 20% Bill

 

It looks like the Bill will be significantly revised to give utilities a lot more flexibility, such as lifting the cap on utility purchases from Hydro-Quebec to, say 50% of their supply.

 

That would help maintain Vermont electric rates at lower levels, than would heavily subsidized, expensive, solar build-outs, which would be good for:

 

1) Job creation in all sectors of the Vermont economy

2) Deployment of EVs and heat pumps

3) No expensive storage for ever-larger DUCK-curves

4) No expensive grid extension/augmentation to connect the solar systems

 

NOTE:

GMP has a 20-y contract with H-Q for 1.2 million MWh per year, at 5.549 c/kWh. See Appendix

Massachusetts has a 20-y contract with H-Q for 9.45 million MWh per year, at 5.9 c/kWh.

https://www.utilitydive.com/news/massachusetts-utilities-sign-contr...

COST SHIFTING THE NAME OF THE GAME IN VERMONT

 

In summer, highly subsidized, expensive, variable, intermittent solar dozes off in late afternoon/early evening, sleeps all night, and does not wake up until about mid-morning the next day, becomes very active around midday creating DUCK curves, especially on sunny days, then dozes off again in late afternoon/early evening.

 

In winter, solar dozes off in late afternoon, sleeps all night, and does not wake up until about mid-morning the next day, becomes very active around midday creating grid-disturbing DUCK curves, especially on sunny days, then dozes off again in late afternoon.

 

http://www.windtaskforce.org/profiles/blogs/cost-shifting-is-the-na...

http://www.windtaskforce.org/profiles/blogs/vermont-is-going-to-hel...

 

1) Net-Metered Solar Charged to Rate Base at a Legacy Cost of About 21.7 c/kWh

 

“GMP estimated the 263,515 MWh of net-metered generation (almost all of it solar, but also including minor quantities of small hydro, small wind, etc.) in its customer area will lead to $33 million in cost shifting, from solar system owners to non-owner ratepayers, in 2020, equivalent to 5% of its total annual cost of serving customers.”

https://vtdigger.org/2019/11/13/in-net-metering-talks-state-ideals-...

 

Vermont utilities net-metered solar was about 288,124 MWh at end 2019, likely about 10% greater at end 2020.

That means total solar cost shifting for 2020 would be about (288,124 x 1.1)/265,515 x 33 million – Other N-M systems = $38 million

https://www.windtaskforce.org/profiles/blogs/vermont-solar-market-p...

 

Net-Metered production cost, amortized at 3.5% for 25 y, is about 14.821 c/kWh

Net-Metered system owners get paid about 17.4 c/kWh, for a profit of 2.579 c/kWh.

Costs for inverter replacements in about year 12 and O&M are not included

See URLs

 

https://puc.vermont.gov/sites/psbnew/files/doc_library/PRESS-RELEAS...

https://www.myamortizationchart.com

 

2) Standard Offer Solar Charged to Rate Base at a Legacy Cost of About 21.7 c/kWh

Standard Offer likely would have about $11 million in cost shifting, including due to high subsidies and high feed-in tariffs.

Owners are paid up to 30 c/kWh (legacy projects).

Owners are paid about 10 - 12 c/kWh for newer, competitively bid projects

The amortized cost, at 3.5% for 25 y, of S-O systems is about 14.418 c/kWh, which means the net effect of subsidies is about 4.418 c/kWh, due:

 

1) Federal and state subsidies

2) Interest and depreciation write offs

3) Return on investment at 9%

4) Inverter replacements in about year 12 and O&M.

3) Utility-Owned and Privately-Owned Solar Charged to Rate base at a Legacy Cost of About 21.7 c/kWh

 

This category of solar systems, installed capacity of about 78 MW ac, or 94.3 MW dc, at end 2019, is about 33% larger than Standard Offer, i.e., not trivial.

 

This category is least written about, likely because utilities, such as GMP, are joining up with multi-millionaire, private investors, to build large-scale solar systems.

 

Those investors may be part of the pro-RE elite in Vermont, i.e., affiliated with EAN, VEIC, VELCO, VPIRG, etc., who loudly and frequently require more subsidies to "save the world".

Why not get in on a good deal for decades, and do some virtue signaling regarding “fighting climate change”, or whatever?

 

All is strictly business, i.e., milking subsidies to the maximum extent, pay the least state and federal taxes, and have a great, guaranteed, return on investment for decades.

 

It is assumed, for analysis purposes, Net-Metered numbers are valid for Utility-owned systems, and privately-owned, in-state systems, who sell all their production to a Vermont utility under a PPA. See Note.

 

A cost of 21.7 c/kWh was assumed, because no published value is available to the public, due to not revealing “proprietary business information”, even though high levels of federal and state subsidies were involved.

 

What is the cost/kWh of legacy systems?

What is the cost/kWh of new systems?

Who are these private, multi-millionaire owners riding the Utility-solar-subsidy gravy train for decades?

Legislator family, friends and political campaign supporters quietly getting in on good deals, as part of "fighting climate change"?

Vermont ratepayers and taxpayers are paying through the nose, i.e., higher electric rates than they would have been, but are kept in the dark!

 

NOTE: I was not even aware of this large category, until I saw the VELCO graph. See page 24 of URL

https://www.velco.com/assets/documents/2018%20LRTP%20Final%20_asfil...

 

NOTE: NE wholesale prices have averaged about 5 c/kWh starting in 2009, i.e., 11 years, courtesy of low-cost, near-zero-CO2 nuclear, and low-cost, low-CO2 natural gas.

This is the price at which utilities buy electricity on the wholesale market.

http://www.windtaskforce.org/profiles/blogs/cost-shifting-is-the-na...

 

NOTE: All this cost shifting is on top of the $60 + million/y added to electric bills for the utter-boondoggle, called Efficiency Vermont.

About 90% of what EV does would have happened anyway, because Vermonters are not stupid, when it comes to saving money.

 

NOTE: All this cost shifting does not include NE grid extension/augmentation, and the costs of the up and down ramping of gas turbines connected to the NE grid to counteract the wind/solar variations, 24/7/365. See table 3

http://www.windtaskforce.org/profiles/blogs/cost-shifting-is-the-na...

 

NOTE: It is assumed, solar has a value to utilities of about 8.5 c/kWh, due to local generation, etc.

In the future, that value likely would decrease, as more solar is built-out on a distribution grid, because:

- Duck-curves would increase

- Expensive storage would be required

- Curtailment payments to owners would be required

- More up/down ramping by gas turbines would be required.

- More grid expansion/augmentation/MW would be required

Heavily subsidized, coddled, unreliable, weather-dependent solar appears to be a gift that keeps on taking.

 

Table 4 shows a summary of all three solar categories.

Table 4/ Solar cost shifting		Large Systems	Large Systems	Small Systems
		Standard Offer	Utility + Other	Net-Metered
Capital cost, turnkey	$/kW	3000	3000	4000
Production	kWh/y	1250	1250	1200
Amortized at 3.5%, 25 y	$/y	180.22	180.22	240.30
Fed Tax Credit, 26%	$			1040
FTC amortized	$/y			62.48
Net capital cost	$/y			177.82
		c/kWh	c/kWh	c/kWh
Amortized cost of turnkey cap cost	c/kWh	14.418	14.418	14.821
Bonus effect of Subsidies + ROI @ 9%	c/kWh	4.418	4.418
Bonus effect of FTC	c/kWh			2.579
Paid to owner	c/kWh	10.000	10.000	17.400
Utility costs	c/kWh	3.000	3.000	3.000
Charged to rate base, new	c/kWh	13.000	13.000	20.400
Charged to rate base, legacy	c/kWh	21.700	21.700	21.700
.
Value of solar claimed by utility	c/kWh	8.500	8.500	8.500
.
2019					Total
Production	MWh	83270	110816	288124	482,210
Charged to rate base/ratepayers	$/y	18,069,590	24,047,072	62,522,908	104,639,570
Value of solar claimed by utility	$/y	7,077,950	9,419,360	24,490,540	40,987,850
Value shortfall	$/y	10,991,640	14,627,712	38,032,368	63,651,720

APPENDIX 1

Wind and Solar Conditions in New England are Mediocre 

New England has highly variable weather and low-medium quality wind and solar conditions. See NREL wind map and NREL solar map.

https://www.nrel.gov/gis/images/100m_wind/awstwspd100onoff3-1.jpg

https://www.nrel.gov/gis/images/solar/national_photovoltaic_2009-01...

 

Wind:

- Wind electricity is zero about 30% of the hours of the year (it takes a wind speed of about 7 mph to start the rotors)

- Wind is minimal most early mornings and most late afternoons/early evenings (peak demand hours), especially during summer

- Wind often is minimal 5 - 7 days in a row in summer and winter, as proven by ISO-NE real-time generation data.

http://www.windtaskforce.org/profiles/blogs/daily-shifting-of-wind-...

- About 60% is generated at night, when demand is much less than during the late afternoons/early evenings

- About 60% is generated in winter.

- During winter, the best wind month is up to 2.5 times the worst summer month

- New England has the lowest capacity factor (about 0.262) of any US region, except the US South. See URL.

https://www.eia.gov/todayinenergy/detail.php?id=20112

 

Solar:

- Solar electricity is strictly a midday affair.

- It is zero about 65% of the hours of the year, mostly at night.

- It often is minimal 5 - 7 days in a row in summer and in winter, as proven by ISO-NE real-time generation data.

http://www.windtaskforce.org/profiles/blogs/daily-shifting-of-wind-...

- It is minimal early mornings and late afternoons/early evenings

- It is minimal much of the winter months

- It is minimal for several days with snow and ice on most of the panels.

- It varies with variable cloudiness, which would excessively disturb distribution grids with many solar systems, as happens in southern California and southern Germany on a daily basis. Utilities use batteries to stabilize their grids.

- During summer, the best solar month is up to 4 times the worst winter month; that ratio is 6 in Germany.

- New England has the lowest capacity factor (about 0.145, under ideal conditions) of any region in the US, except some parts of the US Northwest.

 

NOTE: Even if the NE grid had large capacity connections with Canada and New York, any major NE wind lull and any major NE snowfall likely would affect the entire US northeast, i.e., relying on neighboring grids to "help-out" likely would not be prudent strategy.

 

Wind Plus Solar: 

ISO-NE publishes the minute-by-minute outputs off various energy sources contributing their electricity to the grid.

All one has to do is add the wind and solar and one comes rapidly to the conclusion both are minimal many hours of the year, at any time during the year.

 

Wind plus solar production could be minimal for 5 - 7 days in summer and in winter, especially with snow and ice on most of the panels, as frequently happens during December, January and February, as proven by ISO-NE real-time generation data.

http://www.windtaskforce.org/profiles/blogs/daily-shifting-of-wind-...

 

If we were to rely on wind and solar for most of our electricity, massive energy storage systems (a few hundred GWh-scale for Vermont, multiple TWh-scale for NE) would be required to cover multi-day wind lulls, multi-day overcast/snowy periods, and seasonal variations. See URLs.

 

Wind and solar cannot ever be expected to charge New England’s EVs, so people can get to work the next day, unless backed up by several TWh of storage, because wind/solar lulls can occur for 5 - 7 days in a row, in summer and in winter. BTW, the turnkey capital cost of one TWh of storage (delivered as AC to the grid) is about $400 billion.

 

http://www.windtaskforce.org/profiles/blogs/wind-and-solar-energy-l...

http://www.windtaskforce.org/profiles/blogs/vermont-example-of-elec...

http://www.windtaskforce.org/profiles/blogs/seasonal-pumped-hydro-s...

http://www.windtaskforce.org/profiles/blogs/electricity-storage-to-...

http://www.windtaskforce.org/profiles/blogs/pumped-storage-hydro-in...

http://www.windtaskforce.org/profiles/blogs/wind-and-solar-hype-ver...

 

Shortcomings of Wind and Solar

 

Variable and intermittent wind and solar electricity cannot exist on any electric grid without the traditional, dispatchable generators performing the peaking, filling-in and balancing. Battery systems could be used, but the battery system turnkey capital cost would be about $400/kWh, based on AC electricity delivered to the high voltage grid. See Note.

http://www.windtaskforce.org/profiles/blogs/wind-and-solar-hype-ver...

 

APPENDIX 2

Highly Sealed, Highly Insulated House

In 2008, Transformations Inc., Townsend, MA, was chosen among six builders to participate in the state’s investor-owned utilities Zero Energy Challenge, a competition to encourage builders to plan and develop a home with a HERS Index below 35 before December 2009.

 

Carter Scott, President of Transformations, Inc. brought together a team of design and energy experts to not only meet the challenge, but to figure out how to get all the way to zero, while still building an affordable, new house. The team designed a three-bedroom 1,232-sq ft house, called the “Needham," which has a “- 4” HERS rating, i.e., the house produces more energy than it is using. Sales price: $195,200 in 2009

https://www.buildingscience.com/sites/default/files/2011-03-08%20NE...

 

Major Design Features:

 

Roof (R75): 5 inches of high-density polyurethane foam, HDF, and 13 inches of high-density cellulose all along the slope of the second-floor roof rafters; 2 x 12s and a 2 x 4s held off by 3 inches for a thermal break separation 
Walls (R49): 2 x 4 outside wall; added a second 2 x 4 wall for a total depth of 12 inches; filled 3 inches with HDF and 9 inches with cellulose 
Basement Ceiling: 3 inches of HDF and a layer of R-30 fiberglass batts 
Windows: Paradigm triple-pane model with Low-E and krypton gas 
Heating/Cooling: Two Mitsubishi Mr. Slim mini-split, ductless, ASHPs

Ventilation: Lifebreath 155 ECM Energy Recovery Ventilator 

Leakage: About 175 cfm at 50 pascal, per blower door test (or 284 cfm for a 2000 sq ft house. See table 8)
Solar: Evergreen Solar’s 30 Spruce Line 190-watt PV panels to create a 6.4-kW system;

Hot Water: SunDrum Solar’s DHW heating system

Heat Loss: About 10,500 Btu/h, at 70F indoor, 6F outdoor (or 2000/1232 x 75 delta T/64 delta T x 10500 = 19,975 Btu/h for a 2000 sq ft house, at 65F indoor and -10F outdoor, in Vermont)

 

APPENDIX 3

Standard Weatherizing of Housing not Sufficient for ASHPs

 

In 2017, about 2012 housing units were weatherized, for about $20 million, about $10,000/unit.

CO2 reduction about 6 million lb/y, or 2716 Mt/y.

 

Assuming the older houses would last another 30 years, the CO2 reduction cost would be $19.75 million/(2716 Mt/y x 30y) = $242/Mt, which is high. See URL, page 30

https://legislature.vermont.gov/assets/Legislative-Reports/Annual-2...

  

Because these units had an average fuel use reduction of 23%, does not mean they are out of energy-hog territory, i.e., they likely would still not be sufficiently energy-efficient for 100% space heating with ASHPs.

 

The rate of weatherizing is far too slow, and not "deep" enough, for the CEP 63% goal of space heating of all buildings using only ASHPs. See table 5

 

A new approach, hopefully not involving government and Efficiency Vermont, is needed.

 

1) Entire neighborhoods, with old houses, would need to be leveled for replacement with modern Passivhaus buildings.

2) A new statewide, enforced, building code is required. See URL.

http://www.windtaskforce.org/profiles/blogs/cost-savings-of-air-sou...

 

Table 5/Weatherized housing units	2012
Average fuel use reduction, %	23
Cost, subsidies, $	11,083,404
Cost, owners, $	8,666,786
Total cost, $	19,750,190
Cost/unit, $	9816
.
CO2 reduction, lb	5,988,367
CO2 reduction, Mt/y	2716
CO2 reduction, $/Mt, based on 30-y life	242

 

APPENDIX 4

Table 6 shows space heat energy sources of Vermont houses, per CEP.

 

The CEP goal of 63% of buildings having ASHPs for space heat and DHW could be achieved, if buildings were highly sealed and highly insulated. Such buildings would have very low energy use that could be economically provided 100% by ASHPs, even with the cost of amortizing the ASHPs over 15 years.

 

An average Vermont free-standing house is nowhere near where it needs to be regarding economic heating 100% with ASHPs, even after standardized weatherizing.

 

An average Vermont free-standing house, with an ASHP, would displace only 27.6% of the traditional fuel, per CADMUS report. Standardized weatherizing might increase that percentage to about 35%.

 

Table 6/Housing units	Existing		Future, per CEP
Source	Description	Units	Source	%	Units
Cordwood/pellets	Primary fuel for space heat	65,000	Cordwood/pellets/biofuels	34	90,100
No. 2 fuel oil, propane or natural gas	Primary fuel for space heat	190,000	ASHPs	63	166,950
Electricity	Primary energy for space heat	10,000	Fossil	3	7,950
Total		265,000		100	265,000

 

About 88,000 of Vermont's 100,000 free-standing houses, and about 59,000 of Vermont’s 66,950 apartments, condos, etc., are economically unsuitable for 100% space heat from ASHPs.

 

Only well-sealed/well-insulated, highly sealed/highly insulated and Passivhaus-style houses are economically suitable for 100% space heat from ASHPs

http://www.windtaskforce.org/profiles/blogs/air-source-heat-pumps-a...

See table 7, and example of energy-efficient house in Appendix.

  

Table 5/Vermont	Built		Area	Htg. Demand	Pk. Demand *	Times	Air Leak	ACH
Unsuitable for ASHPs		%	ft2	(Btu/h)/ft2	Btu/h at -10F	Passiv	ft3/min	@ -50 pascal
Typical older house	1750 - 1990	68.4	2000	40.0	80,000	12.6	2667	10.0
Newer house	1990 - 2000	10.0	2000	24.0	48,000	7.6	1600	6.0
Newer house	2000 - 2012	10.0	2000	20.0	40,000	6.3	1867	7.0
Suitable for ASHPs
WS/WI house *	2012 - 2021	10.0	2000	15.0	30,000	4.7	800	<3.0
HS/HI house *	2000 - present	1.5	2000	10.0	20,000	3.0	400	<1.5
Passivhaus*	1985 - present	0.1	2000	3.2	6,348	1.0	160	<0.6
		100.0

*

- WS/WI = well-sealed/well-insulated

- HS/Hi = highly sealed/highly insulated

- Winter 99% design temperature: The outdoor air where you live will be colder than this temperature for 1% of the hours of a year (88 h), based on a 30-year average; that temperature is -10F in Vermont. See URL, page 112

https://www.energystar.gov/ia/partners/bldrs_lenders_raters/downloa...

- These leakage rates would be significantly less at lesser pressures. A whole-house ventilation system with heat-recovery ventilator, HRV, would be required.

 

APPENDIX 5

GMP Cost of Electricity in 2016 (latest numbers available to me) 

Table 8 shows the GMP cost of electricity charged to the rate base. Column 4

Standard Offer and Net-Metered solar are off-the-charts expensive.

 

James Moore of SunCommon, et al., and some legislators want more solar

EAN, VEIC, and VELCO want more solar

http://www.windtaskforce.org/profiles/blogs/green-mountain-power-co...

 

In 2016, the PUC began competitive bidding of SO solar systems.

Some recent SO solar bids were as low as 11 c/kWh.

More such SO systems would slowly reduce SO solar to less than 21.793 c/kWh, in future years.

http://www.windtaskforce.org/profiles/blogs/cost-shifting-is-the-na...

 

Table 8/GMP costs	1	2	3	4	5
GMP purchases, 2016	MWh	% of purchases	Cost, $	c/kWh	% of Cost
HQUS (Hydro-Quebec)	919312	22.13	51013678	5.549	20.34
Standard Offer	78920	1.90	17199202	21.793	6.86
Net-metered	71970	1.73	15699137	21.813	6.26
Ryegate (wood)	126707	3.05	12710175	10.031	5.07
ISO wholesale	575553	13.85	18645214	3.240	7.43
Misc. sources	1772462	42.66	115267406	6.503	45.96
Other sources	2382075	57.34	135516232	5.689	54.04
Total GMP purchases	4154537	100.00	250783638	6.036	100.00
ISO midday wholesale				6.000

APPENDIX 6

1) VT-DPS Concocting an ArtificialPolitical CO2/kWh for Vermont, based on PPAs

 

VT-DPS concocted an artificial/political CO2 emission for the Vermont grid of 34 g/kWh, based on paper power purchase agreements, PPAs, utilities have with in-state and out-of-state electricity producers.

This concocted value, which has no physical basis, is about 8 times less than the NE grid CO2 value, as determined by ISO-NE.

 

GMP, et al., merely signs some papers, and presto, its electricity is certified green, and has low CO2. 

Break out the champaign. The system has been gamed.

 

All other Vermonters have to bust their chops, and save hard-earned money, because they are mandated to buy heat pumps, EVs, insulate their homes to be "net zero", etc., to be certified green

 

Physically, almost all Vermont electricity is drawn by utilities from high voltage grids. There is absolutely no reason for not using the NE grid CO2 value, other than deliberate deception. See below explanation.

 

2) NE Electric Grid CO2 in 2018, based on Primary Energy

 

ISO-NE uses fuel/energy fed to power plants to calculate CO2/kWh; primary energy basis.

Page 13 of URL shows 658 lb CO2/MWh, or 658 x 454/1000 = 299 g/kWh; PE basis

 

ISO-NE does not include CO2 of upstream energy

Upstream is about 10.2% of PE CO2

https://www.iso-ne.com/static-assets/documents/2020/01/draft_2018_e... 

 

Fed to grid becomes 299 x 1.102 = 329 g CO2/kWh; source energy basis.

Fed to wall meter becomes 323 x 1.102 = 356 g CO2/kWh, SE basis.

 

Imports from Nearby Grids: Imports were 17% of total electricity fed to the NE grid.

 

New York State electric grid CO2 was 464 lb/MWh, in 2018, or 211 g/kWh

https://www.eia.gov/electricity/state/newyork/

 

Quebec electric grid CO2 was 500 g/MWh, in 2018, or 0.5 g/kWh

https://www.hydroquebec.com/data/developpement-durable/pdf/co2-emis...

 

I assumed imports have zero g CO2/kWh, which likely understates the real-world conditions.

 

Adjusted for imports 323/1.17 = 276 g/kWh, PE basis

Adjusted for imports 356/1.17 = 304 g/kWh, SE basis

Table 9/NE grid for 2018	Grid CO2	Grid CO2
	PE basis	SE basis
	g/kWh	g/kWh
Source energy
Upstream for extract, process, transport, 10.2%
Primary energy = Fed to power plants
Conversion loss
Gross generation
Plant self-use loss
Net generation = Fed to grid	299	329
T&D loss, 7.5%
Fed to wall meters	323	356
Fed to wall meters, adjusted for imports	276	304

 

3) Vermont Electricity Sector CO2 in 2018

 

Based on Physics, per ISO-NE: Electricity, via a wall socket, would have the NE electricity mix; CO2 of 276 g/kWh, PE basis, in 2018. See table A

  

Fed to Vermont High Voltage Grid: Electricity fed by generators (in-state and out-of-state) into the Vermont high voltage grid is about 6 billion kWh/y

 

Consumption via Wall Sockets: Consumption is about 6 x (1 – 0.075, T&D losses) = 5.55 billion kWh/y

 

Solar: Almost all Standard-Offer solar and Utility solar is fed into high voltage grids and instantly becomes part of the NE mix.

Almost all Net-Metered solar, such as rooftop solar, is fed into distribution grids.

 

Wind: The output of all in-state wind plants is fed into high voltage grids

 

McNeal, Ryegate: The output of both plants is fed into high voltage grids and instantly becomes part of the NE mix.

The CO2 of both plants is not counted, because it is from burning trees, which has been ordained by the EPA to be “renewable”.

 

Hydro Plants: Almost all in-state hydro plant output is fed into high voltage grids and instantly becomes part of the NE mix.

 

ISO-NE Values in Table 1A, at outlet: Vermont CO2 would be about 5.55 billion kWh x 276 g/kWh x 1 lb/454 g x 1 Mt/2204.62 lb = 1,530,426 Mt/y, PE basis, in 2018

 

VT-DPS Using PPAs, at outlet: CO2 of the “PPA Vermont electricity mix” yields an artificial/political value of 190,000 Mt/y in 2018, or 190000/1530426 x 276 = 34 g/kWh, PE basis, in 2018 

   

See page 18 of Agency of Natural Resources URL for GHG estimates for 2017 and 2018.

The rapid GHG reduction from 2015 to 2018 is miraculous.

It may have to do with GMP buying more nuclear and hydro. See table F

https://dec.vermont.gov/sites/dec/files/aqc/climate-change/document...

 

4) Vermont Utilities and VT-DPS "Reduce" CO2

 

No CO2 is reduced by GMP and other Vermont utilities signing paper PPAs with electricity generators, in-state or out-of-state.

 

It is unscientific, chicanery for:

 

1) VT-DPS to calculate CO2 of the Vermont electrical sector and CO2/kWh, based on paper PPAs

2) EAN to use those artificial/political numbers to evaluate the CO2 reduction of ASHPs and EVs

https://www.eanvt.org/wp-content/uploads/2020/03/EAN-report-2020-fi...

   

VT-DPS calculates CO2 of the Vermont electrical sector at 32 g/kWh for 2018, fed to grid basis

ISO-NE calculates CO2 at 299 g/kWh for 2018, fed to grid basis. See URL page 18

 

https://dec.vermont.gov/sites/dec/files/aqc/climate-change/document...

https://www.iso-ne.com/static-assets/documents/2019/04/2017_emissio...

 

Table 10/Grid CO2/Year	1990	2000	2015	2016	2017, est.	2018, est.
VT-DPS, PE basis
Electricity fed to VT grid, GWh	6,000	6,000	6,000	6,000	6,000	6,000
Vermont electrical sector CO2, million Mt	1.09	0.43	1.00	0.81	0.49	0.19
Total CO2, all sectors	8.65	9.70	10.19	9.76	9.41	9.02
CO2, g CO2/kWh, Fed to grid basis		72	167	135	82	32
CO2, g CO2/kWh, WM basis		78	180	146	88	34
ISO-NE, PE basis
NE generation, fed to grid, GWh		110,199	107,916	105,570	102,562	103,740
NE grid CO2, lb//MWh, Fed to grid basis		726	747	710	682	658
NE grid CO2, g/kWh, Fed to grid basis		330	339	322	310	299
NE grid CO2, g/kWh, WM basis		357	366	348	335	323

* Table CO2 values not adjusted for imports

APPENDIX 7

Who are the 23 members of the Vermont Climate Council?

http://www.truenorthreports.com/climate-council-appointed-with-acti...

 

The Speaker of the House, Rep. Mitzi Johnson, chose 8 members of the Council:

• Catherine Dimitruk, Fairfax, Northwest Regional Planning Commission
• Chris Campany, Newfane, Windham Regional Commission
• Liz Miller, Burlington, Green Mountain Power
• Johannah Miller, Montpelier, lobbyist for the Vermont Natural Resources Council
• Michael Schmell, South Pomfret, Chief Operating Officer for Stone Road Energy
• Lesley-Ann Dupigny-Giroux, South Burlington, Vermont State Climatologist
• Adam Knudsen, Shelburne, Dynapower
• Richard Cowart, Calais, Regulatory Assistance Project

 

Senate leaders chose 7 members of the Council:

• Kelly Klein, Greenbell Meadery, St. Albans
• Chad Farrell, Encore Renewables
• Sue Minter, Capstone
• Abby Corse, farmer, Windham County
• Lauren Oates, The Nature Conservancy
• Sarah Evans, youth member from Stowe
• Jared Duval, Energy Action Network

 

The Climate Council also includes 8 members of the Governor’s cabinet:

• Susanne Young, Secretary of Administration
• Julie Moore, Secretary of Natural Resources
• Anson Tebbetts, Secretary of Agriculture
• Lindsay Kurrle, Secretary of Commerce
• Michael Smith, Secretary of Human Services
• Joe Flynn, Secretary of Transportation
• Michael Schirling, Commissioner of Public Safety
• June Tierney, Commissioner of Public Service