In our work to democratize the electric grid, the Institute for Local Self-Reliance and partner organizations often submit comments to Public Utilities Commissions. These dockets decide on everything from overall grid modernization policies to pricing of net metering policies. Below are a few of the dockets we’ve participated in, and a copy of our comments for the year.
Below is a summary of Institute for Local Self-Reliance involvement in regulatory processes during 2017. ILSR regularly filed comments and tracks dockets that concern issues related to energy democracy, distributed generation, and otherwise improving access to clean energy.
In January, ILSR submitted comments for review by Minnesota’s Public Utilities Commission and Department of Commerce advocating for the Value of Solar Rate for use as a solar garden bill credit rate adjustments in favor of select criteria, including: siting on brownfields; locating the solar garden directly in the community it serves; having residential subscribers; and having low-income residential subscribers. In addition, our comments encouraged an averaged monthly bill credit for customers participating in Xcel Energy’s average monthly payment program.
- The Department of Commerce noted these comments in its own, requested by the Commission and filed in March.
In March, ILSR submitted recommendations for improving low-income access to community solar as part of the Commission’s review of Xcel Energy programming. We described in detail model rules for an inclusive community solar program, based heavily on research into effective programs in other markets. The Commission then solicited comments on the ILSR recommendations.
In April, ILSR submitted comments supporting incentives for community solar projects for residential subscribers in Minnesota. The state’s Public Utilities Commission had recently changed the base compensation rate for community solar to the value of solar (VOS) price, and the Department of Commerce recommended implementing a residential adder. In line with comments filed in January, ILSR supported the proposed residential adder worth $0.025/kWh, and called on the Commission to pursue regular review of any adders to ensure they reflect community solar development trends and market dynamics in Minnesota.
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In March, ILSR was granted a request for John Farrell, who leads the Energy Democracy Initiative, and Karlee Weinmann, the initiative’s research associate, to serve as observers of working group formed to develop interconnection standards for distributed generation in Minnesota..
Also in March, ILSR submitted comments in response to the Minnesota Public Utilities Commission’s request for feedback on updating these interconnection standards. The Institute advocated for evidence-based considerations that minimize unnecessary screening and provide consistency across the state.
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Basin Electric Power Cooperative
In February, ILSR signed on to FERC comments drafted by We Own It in opposition to a petition filed by Basin Electric Power Cooperative for a partial waiver of PURPA regulations, which aims to effectively pre-empt the use of locally relevant avoided cost pricing to undermine market access for smaller power providers that otherwise could compete with the avoided cost of distribution utilities. The comments highlighted an apparent lack of commitment to member engagement and member interests, and insufficient notice to members of the proposed change.
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Community Energy ACT/Red Lake Falls
In February, ILSR submitted comments in support of a fairer algorithm for calculating avoided cost under PURPA in support of a complaint filed by Red Lake Falls Community Hybrid LLC. We urged the Commission to conduct an expedited hearing process, and requested a separate docket to more adequately address the barriers to qualifying facilities delivering cost-effective electricity to Minnesota utilities and their customers.
- Allied signers included: North American Water Office, Cooperative Energy Futures, Minnesota Interfaith Power and Light, Clean Up the River Environment, Windustry, Rural Renewable Energy Alliance, Fresh Energy, ISAIAH, and We Own It
In April, ILSR submitted a letter urging both a timely complaint resolution process for the dispute between Red Lake Falls and Otter Tail Power and a deeper probe by the Commission with regard to the adequacy of existing methodology for calculating avoided cost.
- Allied signers include: Community Power, North American Water Office, Clean Up the River Environment, Windustry, ISAIAH, MPIRG, Clean Energy Economy Minnesota, Cooperative Energy Futures
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In April, ILSR submitted comments to the Minnesota Public Utilities Commission providing recommendations for improving a “hosting capacity” study produced by Xcel Energy examining how much new solar could be added to each of hundreds of distribution “feeders” delivering electricity to customers across the utility’s service territory. We proposed a series of pathways to plugging gaps in the study:
- By including impacts from existing distributed energy resources, which were not evaluated in estimating the capacity for new projects,
- By developing a draft model or process that considers the impact of proposed projects (that already have interconnection agreements)
- By displaying results visually–such as a map of available capacity–to help solar energy developers identify the best places to build new projects, and
- By factoring in the use of smart inverters to mitigate the grid impacts of existing or forthcoming projects.
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Performance Based Incentives
In December, ILSR submitted comments to the Minnesota Public Utilities Commission recommending adoption of performance based incentives for Xcel Energy for activities related to renewable energy, energy efficiency, and facilitation of distributed energy resources.