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2018 Docket Submissions > |
In our work to democratize the electric grid, the Institute for Local Self-Reliance and partner organizations often submit comments to Public Utilities Commissions, regulatory bodies that provide oversight of electricity markets in many states across the U.S. As part of the regulatory process, these commissions and the dockets they manage decide on everything from overall grid modernization policies to pricing of net metering policies.
Below is a summary of ILSR involvement in regulatory dockets in 2019, including comments we’ve made and articles written, in order to increase transparency and accessibility of the regulatory process. ILSR regularly files comments and tracks dockets that concern issues related to energy democracy, distributed generation, and otherwise improving access to clean energy.
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Calculating an Accurate Value of Solar
Kentucky Public Service Commission Case Number 2019-00256
In November, ILSR sent a letter to the Kentucky Public Service Commission regarding their consideration of the value of solar. As a key author in Minnesota’s 2013 value of solar concept, Director of Energy Democracy John Farrell provides his insights on the concept. As more states consider adopting value of solar legislation, regulators ought to look at the lessons learned by others that have gone through this process. In the letter, Farrell outlines what has made the Minnesota value of solar process a success and what could be improved. He concludes the letter with 5 recommendations to construct an accurate value of solar. A report “Minnesota’s Value of Solar” gives a comprehensive account of the value of solar proceedings in Minnesota.
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Designing the Utility Electric Vehicle Home Service Program
Minnesota Public Utilities Commission Docket 19-559
In late October, ILSR submitted comments to the Minnesota Public Utilities Commission on Xcel Energy’s Electric Vehicle Home Service Program. In the comments, ILSR congratulates Xcel Energy on creating a pilot program that will benefit vehicle owners and all customers. However, ILSR suggests Xcel makes changes to the charger fee and “bring your own device” portions of the program. Xcel has designed the pilot so that the customer pays a monthly fee, indefinitely, for the electric vehicle charger. This would mean that in many cases, the customer is overpaying. ILSR believes that the charger fee should be a separate fee that no longer applies when the charger is paid off. Additionally, Xcel has designed the program so that the customer cannot buy their own charger. ILSR believes customers should be able to use their own compatible devices.
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Using Accurate Figures for an Adequate Value of Solar
Minnesota Public Utilities Commission Docket 13-867
In October, ILSR joined groups Cooperative Energy Futures and Vote Solar to submit comments to the Minnesota Public Utilities Commission on Xcel Energy’s proposed Value of Solar rate for 2020. Specifically, the comments are in response to three components of the proposed rate: how Xcel Energy will calculate the Solar PV Fleet Production, what Xcel Energy will use for Heat Rate data, and what values Xcel Energy will use for Avoided Power Plant O&M Costs and Avoided Generation Capacity Costs. Using the most accurate values in each of these three categories is essential for creating an adequate Value of Solar rate.
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Defending the Interests of Ratepayers in a Proposed Gas Plant Purchase
Minnesota Public Utilities Commission Docket 18-702
In late September, ILSR testified at the Minnesota Public Utilities Commission over Xcel Energy’s proposed acquisition of the Mankato Energy Center. ILSR’s testimony outlined the many risks of utility investment in gas, giving special attention to the risks a gas plant purchase puts on ratepayers. After hours of testimony and questions, the Minnesota Public Utilities Commission delivered a unanimous rejection of Xcel’s proposal. All in all, commissioners agreed that there was not enough evidence to prove that this purchase would benefit ratepayers. Xcel has stated that it still plans to buy the gas plant through an affiliate company, which would place the risk on shareholders.
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Maintaining a Factual Record of Events and Comments
Minnesota Public Utilities Commission Docket 18-702
In June, ILSR and Cooperative Energy Futures submitted reply comments to the Minnesota Public Utilities Commission about Xcel Energy’s proposed purchase of a natural gas plant. These comments support the inclusion of comments by the Sierra Club on the docket as part of the factual record. The comments go on to highlight the exclusion of many groups from the “Settlement Agreement.” Finally, the comments agree with and others who have said that the proposed gas plant purchase of Xcel Energy will put all of the risk on customers, with no sure reward.
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Addressing Interconnection Challenges of Distributed Generation through Revised Utility Tariffs
Minnesota Public Utilities Commission Docket 18-714
In late-February, ILSR submitted reply comments to the Minnesota Public Utilities Commission to support revisions to Xcel Energy’s tariff for distributed generation, while providing additional considerations to protect customers during the revision process. Agreeing with comments provided by the City of Minneapolis, ILSR highlighted related barriers for connecting rooftop solar or electric vehicle charging infrastructure projects to the grid. The comments note several challenges distributed generation and customers face including identifying areas of the grid with likely available capacity, anticipating costs of interconnection due to an opaque process managed by utility companies, and bearing excessive costs when billed for the full cost of utility-scale power generation. Given these challenges, ILSR recommends that the Commission clarify distributed generation tariff rules so that customers not be charged the full, undepreciated cost for existing or upgraded equipment by incumbent utilities like Xcel Energy.
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Risks of New Utility Investments in Natural Gas Power Plants
Minnesota Public Utilities Commission Docket 18-702
In February, ILSR submitted comments to the Minnesota Public Utilities Commission about a proposed acquisition of a natural gas plant by the shareholder-owned utility Xcel Energy. The comments discuss how new investments in fossil fuel power plants are likely a bad bet for electricity customers. The widespread availability of affordable energy storage in the coming years will impact electricity markets and upend traditional resource planning by utilities, making large investments in natural gas plants risky. These comments offer a candid assessment to state regulators that call into question motives and timing of the proposed investment and recommend the Commission require sufficient financial safeguards for customers, at a minimum, should the deal move forward. An article “Should Utilities Be Buying New Gas Plants?” takes a closer look at these detailed comments and the issues at stake.
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Ensuring Transparency of Utility Avoided Cost Data under PURPA
Minnesota Public Utilities Commission Docket E999/PR-19-9
In late-January, the Environmental Law and Policy Center and ILSR submitted comments to the Minnesota Public Utilities Commission about data transparency practices of the state’s shareholder-owned electric utilities. Under the federal Public Utilities Regulatory Policies Act of 1978, Congress required utilities to offer contracts to cost-effective, non-utility projects at the utility’s avoided cost to facilitate a newly competitive market for local, renewable energy resources. To meet this requirement, utilities need provide information about their avoided costs, but many have failed to do so under a veil of “trade secrets.” The filing submitted in Minnesota argues failure to provide these data is illegal and more enforcement is needed to ensure utilities comply and make these data available. The filing that could apply to markets in dozens of other states and illustrates how federal and state laws require utilities to share their cost data publicly. We summarize these comments in our article “Electric Utilities Must Stop Illegally Concealing Public Cost Data.”
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Electric Vehicles and Charging Infrastructure
Minnesota Public Utilities Commission Docket 18-643
In January, ILSR submitted comments to the Minnesota Public Utilities Commission about two new pilot programs being rolled out by Xcel Energy that influence the utility’s electric vehicle charging rates and infrastructure investments. These comments applaud the programs’ goals and outreach, while still pushing the utility to develop ways for users to provide feedback on the new programs. The comments also highlight several areas for additional consideration: time-of-use pricing as a tool to motivate a shift to off-peak charging, infrastructure proposals that incorporate distributed energy resources as well as traditional concepts like transformer upgrades, and a push to have Xcel Energy finance not just chargers but also the incremental cost of bus batteries for school and transit fleets, which are often operated by cash-strapped public entities. An article “Minnesota Utility Tees Up Programs to Support an Electric Vehicle Future” that summarizes our detailed comments is available here.
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