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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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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