In early April, ILSR submitted comments to the Minnesota Public Utilities Commission regarding electric utility Xcel Energy’s 2021 Hosting Capacity Report. Minnesota is one of seven states that require utilities to conduct hosting capacity analysis and present their results in a map resource. The six other states requiring hosting capacity analysis are California, Connecticut, Nevada, New Jersey, New York, and Maryland.
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 about where to put new solar generation on the electric grid.
If the analysis is done well, customers can use it as an indication of available generation hosting capacity in a particular area of the grid, allowing a solar project developer to know if there’s room to add their project there. The Minnesota Commission has also set a long-term goal for hosting capacity analysis to simplify 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 would help to factor in new electric uses, such as electric vehicles), which Xcel must complete by November 2022.
Read ILSR’s comments to the Minnesota Public Utilities Commission in full below.
April 4, 2022
RE: Docket E002/M-21-767 In the Matter of Xcel Energy’s 2021 Hosting Capacity Report
Dear Mr. Seuffert:
The Institute for Local Self-Reliance (ILSR) respectfully submits the following comments on Xcel Energy’s 2021 Hosting Capacity Report.
The Commission should accept Xcel Energy’s 2021 Hosting Capacity Analysis Report. On the whole, the Report achieves the requirements outlined in the Commission’s July 31, 2020 Order, the Commission’s November 9, 2021 Order, and Minn. Stat. §216B.2425, Subd. 8. Xcel has completed most of the improvements to its online hosting capacity map, the data is presented in a way that serves Xcel customers and grid stakeholders, and the quarterly update cadence is an improvement — though monthly updates and other improvements are needed before integrating HCA with the interconnection process.
Lastly, the Commission should replicate the stakeholder engagement opportunities surrounding Xcel Energy’s Hosting Capacity Analysis Report in Xcel’s upcoming load hosting capacity analysis, which the Commission required in its November 9, 2021 Order.
- Xcel’s online Hosting Capacity Map is a functional and useful representation of the Hosting Capacity Analysis Report.
Xcel’s compliance with the Commission’s July 2020 order to include all criteria threshold violations in the hosting capacity map pop-ups is a significant improvement to the map.
Xcel, the Commission, and intervenors are addressing the Company’s noncompliance with Order Point 12 of the Commission’s July 2020 order in Docket E999/M-20-800 (In the Matter of a Commission Investigation on Grid and Customer Security Issues Related to Public Display or Access to Electric Distribution Grid Data).
- The Hosting Capacity Analysis methodology needs many improvements before it is integrated with the interconnection process.
The Commission has a long-term goal to use the Hosting Capacity Analysis in the interconnection process’s fast track screens. If Hosting Capacity Analysis is to integrate with the interconnection process, the two must operate under the same assumptions.
In this year’s Hosting Capacity Analysis Report, Xcel changed the power factor for DER sites from 98 to 95 percent to be in alignment with the interconnection study process. That change is a step in the right direction. However, there is a more significant discrepancy in how the two processes treat distributed energy projects in the queue.
The interconnection process assumes that queued projects are operational. Xcel’s Hosting Capacity Analysis, on the other hand, does not include projects that are in the interconnection queue. As the Interstate Renewable Energy Council (IREC) positioned in previous comments, in order for customers to use HCA as an indication of available hosting capacity and for Xcel to use HCA as a first step in the interconnection process, queued projects should be treated as operational in the HCA. This inclusion would be consistent with the methodology of other utilities that have integrated hosting capacity analysis with the interconnection process, according to IREC.
The Company’s rationale for excluding queued DER projects is that to include them “would create too much variability as many projects enter and exit the queue during the [hosting capacity] analysis period.” Xcel could mitigate this problem by conducting a monthly hosting capacity analysis update cadence — which is another change necessary for integrating HCA with the interconnection process.
- Xcel’s projected costs to perform monthly updates need further examination.
Many intervenors have asked that Xcel perform monthly updates to its hosting capacity analysis. Monthly updates would be more useful for the several hosting capacity analysis purposes envisioned by the Commission, including its ultimate integration with the interconnection process.
Since Xcel has not done a more detailed analysis of the costs for a monthly HCA update, the Company’s conceptual estimate should be treated with caution. IREC has detailed several ways in which the methods and resulting costs of Xcel’s conceptual proposal were excessive. IREC has a forthcoming report with the National Renewable Energy Laboratory on HCA data validation plans which may be a useful resource for The Commission and the upcoming stakeholder workshops on integrating HCA with interconnection.
- The commission should hold stakeholder workshops with Xcel Energy and industry experts to develop the load hosting capacity analysis methodology.
As Minnesota electric customers increasingly electrify their vehicles and buildings, electric load hosting capacity data becomes a necessary resource. The Commission has asked Xcel Energy to conduct a separate hosting capacity analysis for load by November 2022. As was done with the generation Hosting Capacity Analysis, the Commission should hold stakeholder meetings to establish a methodology, including inputs, limiting criteria, and thresholds. Additionally, ILSR echoes IREC’s comment that a load hosting capacity analysis is not complete without including existing distributed generation.
Thank you for the opportunity to comment and for taking up this important conversation; we appreciate that there has not been any legislative preemption of this regulatory process.
Maria McCoy, Institute for Local Self-Reliance
Featured photo credit: Xcel Energy Hosting Capacity Map.