In order to increase the transparency and accessibility of the regulatory process, ILSR’s involvement in 2022 regulatory dockets is summarized below. ILSR regularly files comments and tracks dockets that concern issues related to energy democracy, distributed generation, and otherwise improving access to clean energy.
< 2023 Docket Submissions 2021 Docket Submissions >
Minnesota Needs a Collective Solution to Get Off Gas
Minnesota Public Utilities Commission Docket No. G-999/CI-21-565
In October, John Farrell submitted comments to the Minnesota Public Utilities Commission in its landmark “Future of Gas” docket. In these comments, Farrell argues that there is no future for gas in Minnesota. Continued use of fossil gas exposes customers to financial volatility, fatal explosions, and adverse climate impacts. Still, addressing these problems at the individual household is impractical and inequitable. Farrell emphasizes the need for a collective solution to the collective problem of natural gas use in Minnesota and makes some recommendations for the scope of the docket.
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Xcel Energy’s Proposed Resiliency Program Threatens a Competitive Market
Minnesota Public Utilities Commission Docket No. E002/M-22-170
In August, John Farrell submitted a letter to the Minnesota Public Utilities Commission responding to Xcel Energy’s petition to create a resiliency service program. The letter expresses a wariness toward giving an incumbent too much power in a burgeoning market. Even though the scale of Xcel Energy’s proposal is small, the company’s incumbency and name recognition provide a competitive advantage that the Commission must evaluate carefully. If Xcel Energy has correctly identified barriers in current market conditions, the Commission should work to improve market conditions and remove these barriers, rather than allowing Xcel Energy to distort a competitive market.
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Arizona Community Solar Advocates Answer Many Questions
Arizona Corporation Commission Docket No. E-00000A-22-0103
In July, ILSR was one of many signatories on a letter to the Arizona Corporation Commission. The letter defines key elements of competitive community solar, describes how the state can protect consumers, and answers other questions that have been raised in working group sessions. The letter includes definitions and a community solar diagram. Advocates also attached a summary of the successful elements in other state community solar programs and sample disclosure forms.
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ILSR Asks Arizona Commissioners to Consider Community Solar
Arizona Corporation Commission Dockets E-01345A-21-0240 and E-00000A-22-0103
In May, ILSR wrote a letter to the Arizona Corporation Commission supporting the development of a community solar program. In the letter, ILSR supports Commissioner Kennedy’s amendment (docket E-01345A-21-0240) to create a community solar program for customers of Arizona Public Service (the largest electric utility in Arizona). As proven in Minnesota, a single-utility community solar program is a pathway to building distributed solar capacity and extending the benefits of solar to more residents, businesses, and public entities. ILSR also supports the simultaneous discussion of community solar in a separate docket, as brought forth by Arizona Corporation Commission Chairwoman Márquez Peterson.
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Xcel’s Hosting Capacity Map Is Better, but Still Needs Improvement Before It’s Useful for Distributed Generation Interconnection
Minnesota Public Utilities Commission Docket No. E002/M-21-767
In early April, ILSR submitted comments to the Minnesota Public Utilities Commission regarding Xcel Energy’s 2021 Hosting Capacity Report. Xcel presents the results of its quarterly hosting capacity analysis (HCA) in an online Hosting Capacity Map. Publicly shared hosting capacity data helps solar developers, electric customers, and others make more informed decisions. If the analysis is done well, customers can use HCA as an indication of available generation hosting capacity. The Commission has also set a long-term goal to use HCA in the distributed generation interconnection process’s fast track screens.
In these comments, ILSR notes several ways Xcel Energy has improved the Hosting Capacity Map. The comments then call attention to some outstanding issues from the Company’s 2020 report, which ILSR commented on in April 2021. Finally, ILSR asks that the Commission hold stakeholder workshops with Xcel Energy and industry experts to develop the methodology for a load hosting capacity analysis, which Xcel must complete by November 2022.
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Implemented Correctly, Community Choice Energy Can Support Colorado Communities in Their Goals
Colorado Public Utilities Commission Proceeding No. 22I-0027E
On March 1st, ILSR submitted comments to the Colorado Public Utilities Commission for its Study of Community Choice for Wholesale Electricity Supply (Proceeding No. 22I-0027E). The comments largely draw from ILSR’s 2020 report on community choice energy. ILSR describes how a community choice agency, as a public entity, can better manage energy efficiency programs, support the expansion of distributed energy resources, and align with local interests. ILSR’s comments also list several crucial powers a community choice entity must have and make recommendations on transition fees.
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ILSR Asks Regulators to Protect Customers From Unjust Utility Spending
Federal Energy Regulatory Commission Docket No. RM22–5–000
In February 2022, the Institute for Local Self-Reliance submitted comments to the Federal Energy Regulatory Commission on utility rate recovery and industry association dues. ILSR also signed on to a correlating petition with the Center for Biological Diversity and 311 other organizations.
The rules of the Federal Energy Regulatory Commission presume that electric utility spending, even when spent in anti-consumer lobbying, can be recovered by utilities from their customers. In the comments and the Petition, ILSR asks that utility trade association dues be treated as non-recoverable by default — unless the utilities can provide sufficient evidence that their benefits to consumers ought to allow them to be recovered.
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Xcel Energy Should Consider Customer-Owned Solar, Load Flexibility, and Incentivized Demand Response in Future Resource Planning
Minnesota Public Utilities Commission Dockets 19-368
On January 24th, the Institute for Local Self-Reliance and the Distributed Solar Parties (Vote Solar, Cooperative Energy Futures, and the Environmental Law and Policy Center) submitted decision options to the Minnesota Public Utilities Commission. The Commission issued these decision options on Xcel Energy’s 2020 Integrated Resource Plan. The decision option proposed by ILSR and the Distributed Solar Parties would require Xcel Energy to include a model of distributed solar development in the company’s next integrated resource plan. The groups also propose that Xcel Energy considers load flexibility and incentivized demand response in its resource planning.
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ILSR Issues its Preferred Decision Options on Minnesota’s Distributed Solar Interconnection Proceeding
Minnesota Public Utilities Commission Dockets 16-521, 01-1023
On January 18th, the Institute for Local Self-Reliance submitted preferred decision options to the Minnesota Public Utilities Commission. The Commission issues these decision options on the distributed solar interconnection process.
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Further Discussion Is Needed on the Issue of Modeling Software Costs and Utility Integrated Resource Plans
Minnesota Public Utilities Commission Dockets 21-33, 19-368, 21-339
On January 10th, the Institute for Local Self-Reliance and Vote Solar submitted reply comments to the Minnesota Public Utilities Commission on the issue of modeling software costs and utility integrated resource plans. These comments support the proposed approach of the Citizens Utility Board: opening a new docket for the joint petition regarding modeling software costs.