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An Open Letter on Energy Justice and a San Antonio COVID-19 Recovery

To: Mayor Ron Nirenberg, San Antonio City Council, CPS Energy Board of Trustees

San Antonio is one of the fastest growing cities in the United States and celebrates a rich cultural heritage and diverse population. We are also one of the most economically and racially segregated large cities in the country. The impact of COVID-19 has only further laid bare glaring income and health disparities between white residents and people of color -- disparities that have complicated justice-based pandemic recovery efforts. We have long known that Northside residents of certain ZIP Codes live decades longer than some on the Southside(1), for instance, and therefore should have predicted that Latinx residents would die at disproportionately higher numbers with the onset of COVID-19. A raft of factors are behind these grim inequities: exposure to air pollution from fossil-fueled car and truck traffic; lack of access to greenspace and healthy food; redlining and racist development patterns and policing; rising temperatures driven by the engines of climate change and dirty power plants; and zoning that permits industrial operations near schools and neighborhoods.

San Antonio’s elected leadership has taken steps to begin tackling some of these challenges. In 2017, our City Council voted to support the goals of the Paris Agreement, an international accord with a goal of limiting the rise of global temperatures. The Climate Action and Adaptation Plan—adopted a year ago, the product of two years of work and involving nearly 100 volunteers from across the City—requires stepped reductions in health-threatening climate pollution from power production and transportation. It also encourages reforms across many other sectors. In spite of this, City leaders have largely ignored the values and goals of this ambitious undertaking in the COVID recovery work to date.

While the City Council recently declared racism a public health threat, there has been no attention given to the largest polluter in the city that disproportionately impacts people of color in the form of asthma attacks, heart attacks, early mortality, and rising temperatures. As thousands upon thousands of lower-income residents saddled with inequitable utility burdens struggle to keep ahead of rising debt, there has been no creative dialogue around the possibility of making the source of that burden—CPS Energy, the largest contributor to the City's General Fund—an engine for an integrated, justice-based recovery.

With a suite of new energy efficiency programs coming to Council for approval, and CPS CEO Paula Gold-Williams discussing a possible utility rate increase, the time to prepare is now. Just as we've never had a public conversation about the utility's contribution to maintaining structural racism in San Antonio—neither have we explored how the power and wealth of the utility could assist us in reversing these many ills. Healthy sustainable jobs, housing security, improved public health, all of these should flow from thoughtful policy setting around our utility. In fact, energy reform represents a tremendous and overlooked opportunity for jobs for San Antonians struggling to move through this punishing pandemic and the toll it continues to take on our economy and public health—most critically among our low-income residents and communities of color. Therefore, the members of Climate Action SA make the following recommendations and demands:

1. End the Policy of Utility Disconnections for Most Vulnerable Families Until the novel coronavirus appeared in San Antonio, CPS Energy was cutting power to roughly 100,000 households and businesses every year for non-payment. While disconnections are currently paused in response to the economic crisis that has followed the COVID-19 pandemic, other city-owned utilities have begun returning to disconnecting power to the most vulnerable households for non-payment, and it’s just a matter of time before CPS Energy returns to their former behavior. To give ratepayers more security than a 30-day warning, we call on CPS Energy to publicly commit to ending disconnections until, at least, February 2021. CPS must eliminate completely the policy of disconnections for nonpayment for all households at or below 200% of the poverty level. Additionally, we call for a third-party audit of existing payment assistance programs and a study of the potential impacts of rate-structure changes that could significantly reduce the costs to overburdened lower-income neighborhoods. We note that CPS Energy enacted a temporary pause on disconnections in the early days of this pandemic--the same day Councilmembers called for such a pause. While Council members have historically resisted engagement with CPS Energy because of power distinctions set in the Charter agreement, the Mayor and Council have a tremendous amount of political authority to set our energy agenda when they choose to use it.

2. Elevate FlexSTEP as an Essential Element of a Just COVID-19 Recovery CPS Energy’s Save for Tomorrow Energy Program (STEP) has been an innovative tool to reduce the energy burden on low-income ratepayers in San Antonio. In the last 10 years, STEP has reduced total energy use in the city by roughly 800 megawatts of electricity through first-of-its-kind solar offerings, energy efficiency, and demand response measures—including a free weatherization program that reduces bills for customers across the city. CPS Energy and San Antonio should take that innovative and pioneering approach and apply it to San Antonio’s most urgent challenge: charting a just and equitable COVID-19 recovery.

As CPS Energy begins to review market proposals for energy conservation technologies for the next STEP round, our Mayor and Council must insist the utility increases energy reduction targets while taking maximum advantage of these programs as tools for a justice-based COVID-19 recovery. We must expand our overall goal to at least 940 MW of coincident peak reduction and 1.5% annual energy saving 2 , but also prioritize weatherization and home improvement programs, as well as dramatically increasing rooftop solar in historically neglected communities. We must also work with other agencies, including social services, to include the homes most in need, those previously disqualified for substandard roofs and foundations, and homes most frequently disconnected for nonpayment.

Texas is second only to California in the realm of clean energy, according to E2 statistics, with San Antonio already boasting more than 21,000 clean energy jobs(2). Yet while San Antonio is poised to lose funding for its greenways program, it is Austin that is exploring how to utilize federal COVID funds to create jobs in habitat restoration and trail and greenways maintenance(3). In a city where energy efficiency jobs exceed those of the oil and gas sector, and are expected to increase dramatically in the years to come, we should leverage FlexSTEP as a skills- and jobs-training program for people struggling under the highest energy burdens and prioritize clean jobs within the Mayor's proposed workers training program.

3. No Rate Increases Until Our Utility Rate Structure is Fair Low-income people pay the same rate as profitable businesses and have a disproportionately high energy burden—the percentage of household income spent on energy bills. Twenty-seven percent of Latinx residents suffer a high energy burden, defined by the American Council for an Energy Efficient Economy as energy bills greater than 6 percent of total disposable income. Additionally, the median energy burden of low-income multifamily households in San Antonio is 83% higher than medium- and high-income multifamily households. No pathway exists to allow the community to meaningfully participate in the decision-making process concerning rates—even as critical public health decisions must be made about energy generation.

Likewise, the current rate structure does not encourage energy conservation. Conservation is well-established as the most affordable way to reduce greenhouse gas emissions and other pollution. Thus, adjusting rates to encourage conservation is aligned with the goals of the Climate Action and Adaptation Plan. Climate Action SA has long advocated for the creation of a community-represented Rate Advisory Committee (RAC) at CPS Energy with strong community engagement to ensure that all residents’ basic needs are met, regardless of their ability to pay. We are excited to see CPS Energy moving forward with the concept since Mayor Ron Nirenberg brought it to the CPS Board of Trustees in January.

We call on our City Council to resist any attempt to raise utility rates until this RAC has formed and been able to restructure utility rates in a fair and just manner. If San Antonio is going to avoid a return to the same inequitable economic structure of the pre-pandemic world, our elected leaders must insist on equitable rate reform before any additional rate hikes.

4. Develop Community-Driven Resource Planning CPS Energy does not engage in any sort of public resource planning process that is visible to the community, including our elected representatives to City Council. Instead, CPS Energy offers proposals in silos, without a clear path connecting the decisions to community needs. For example, CPS Energy drops hints about the future of the largest carbon polluter in the county, San Antonio’s Spruce coal plant—but provides no analysis or concrete timeline. Despite years of engagement with CPS, key demands by the CPS Energy Environmental Quarterly Stakeholders for this and related efforts remain unsatisfied.

Recently, CPS Energy issued an Request for Information (RFI) for a set of resources (solar, battery, and “firming” capacity) without sharing any technical or economic analysis of what specific existing resources may be replaced by these new resources and when. CPS Energy discusses a FlexSTEP proposal but doesn’t share how the energy efficiency and demand savings fit in with the rest of the power generation assets. CPS Energy needs to open up these processes in a comprehensive way to openly vet input from the communities that are most impacted by their decisions.

5. Shut Down the Spruce Coal Plant by 2030 San Antonio releases 17.5 million metric tons of CO2 equivalent per year, according to the Climate Action and Adaptation Plan. To avoid the worst manifestations of global warming in this climate crisis requires cutting that number in half (or better) by 2030. Our own climate plan requires us to cut our emissions by 41 percent by 2030. We know that reforming the transportation sector—with remarkably scant funding and millions of miles of roads—is a multi-decadal prospect. The only way to hit our target is by retiring Spruce, which is responsible for roughly 8 million metric tons per year (MMT/yr) on a 10-year average.

While CPS is working to replace their aging, rarely used, gas power plants, which collectively contribute just a fraction of Spruce’s pollution, CPS’s leadership refuses to even share possible retirement scenarios for Spruce after years of requests—including during the CAAP-development process. We expect our Mayor and City Council to call on CPS to commit to a Spruce retirement by 2030 at the latest. CPS Energy—with the strong encouragement of the Mayor and Council—must make this commitment immediately as part of a community-centered, transparent generation resource planning process (4, above). Our early retirement of “Dirty” Deely proves that we can retire a major polluting asset far ahead of schedule while safely transitioning workers and expanding cleaner energy sources.

COVID-19, climate crisis, structural racism, economic recession: In the coming weeks, our members will be finishing a COVID-19-Climate Recovery Proposal, detailing a collection of policy proposals that will help our city navigate these punishing intersecting forces. However, with several siloed processes already underway--the languishing Rate Advisory Committee; the future of FlexSTEP; and the FlexPowerBundle RFI--we present this letter today for your urgent consideration and community discussion. For a detailed assessment and suite of recommendations on FlexSTEP, please see the Optimal Energy report provided to your office earlier this year(4).

You collectively have the authority to set the direction for our utility and must approve or reject any proposal that would impact rates for San Antonians. We must now live up to the values repeatedly expressed by CPS Energy’s own slogan of People First a nd by o ur Mayor and Council in the fight against structural inequity. We look forward to continuing the conversation with you personally in the spirit of collaboration exploring specific, actionable steps. Signed,

● Alliance of Nurses for Healthy Environments

● Sierra Club, Lone Star Chapter

● Public Citizen

● Southwest Workers Union

● Esperanza Peace & Justice Center

● Yanawana Herbolarios

● Texas Drought Project


● Charles Roundtree Bloom Project

● Energia Mia

● San Antonio Progressive Alliance ● MOVE Texas ● Carrizo/Comecrudo Tribe of Texas ● Domestica Unidas ● Indivisible 21 ● Sierra Club, Alamo Group ● Texas Organizing Project ● Bexar County Green Party ● Deceleration ● Environment Texas ● Greater Edwards Aquifer Alliance ● Citizens Climate Lobby, SA Chapter ● Society of Native Nations

Media Contacts Diana Lopez Southwest Workers Union


Greg Harman Sierra Club 210.323.9834 Citations

  1. Life Expectancy at Birth in Communities Across Texas: 2005-2014 (

  2. Clean Jobs America 2020: Repowering America’s Economy in the Wake of COVID-19 , E2 (

  3. “Council seeks plan to form conservation corps using federal Covid-19 aid” ( -federal-covid-19-aid)

  4. CPS Energy Save For Tomorrow Energy Plan Phase 1 Review and Recommendations for Phase 2 (“FlexSTEP”) ( t.pdf)

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