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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 the pricing of net metering policies.
Below is a summary of ILSR involvement in regulatory dockets in 2020, including comments we’ve made and articles written, in order to increase the 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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Directing Utility Response to the COVID-19 Pandemic
Minnesota Public Utilities Commission Docket 20-375
At the end of October, ILSR submitted comments to the Minnesota Public Utilities Commission regarding utility response to the COVID-19 pandemic. In short, our comments express support for the comments made by Fresh Energy, National Housing Trust, and Natural Resources Defense Council on October 20, which highlight three specific needs: directing utilities to disaggregate their data by census tract or zip code, fully fund energy assistance programs, and to convene the stakeholder process with the input of BIPOC-led and community-based organizations.
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30 Times More Jobs from Rooftop Solar, Utility Filing Says
Minnesota Public Utilities Commission Docket No. 20-492
In early October, ILSR submitted comments to the Minnesota Public Utilities Commission regarding Minnesota’s Economic Recovery from the COVID‐19 Pandemic. The comments call attention to a portion of Xcel Energy’s recovery proposal, which compared two proposed solar projects: one, a giant solar array on the site of a closing coal plant; the other, a small collection of rooftop solar projects to serve low-income residents. In Xcel’s analysis, the company found that for every million the utility proposed spending on rooftop solar, it would create 30 times more jobs than by spending that same $1 million on utility-scale solar. The comments go on to address other proposals and raise issues that the Commission should consider before ruling on this matter.
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Updating Minnesota’s Dated Distributed Generation Tariff
Minnesota Public Utilities Commission Case Docket 16-521
In late September, ILSR submitted comments to the Minnesota Public Utilities Commission to encourage a fix for the distributed generation tariff.. As John Farrell illustrates with an excerpt taken from ILSR report Why Utilities in Minnesota and Other States Need to Plan for More Competition, Minnesota has a history of encouraging distributed generation. Further comments explain the missed opportunity to capture cost-effective solar projects sized 1 to 10 megawatts and opportunity to apply the state’s successful value of solar tariff to this form of distributed generation.
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Why it’s Short-Sighted to do Centralized Planning in a Decentralizing Energy Grid
Michigan Public Utilities Commission Case No. U-18232
In late April, ILSR submitted comments to the Michigan Public Utilities Commission regarding DTE’s 2020 Renewable Energy Plan. Found in full in this blog post, including images and charts, Farrell’s testimony strikes at the heart of utility resource planning in all 50 states. Using examples from the Is Bigger Best report, Farrell explains how utility resource planning must give adequate consideration to distributed energy resources. He also provides examples (from ILSR report Beyond Sharing) of why community solar is necessary to extend ownership of distributed energy to all. Finally, Farrell argues that it is time for antiquated top-down resource planning to adapt to the modern reality: customer-owned generation and a decreased demand for utility infrastructure.
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Utility Regulators Oversee Planning for a Robust, Inclusive Grid in Minnesota
Minnesota Public Utilities Commission Docket E002/M-19-666
In April, ILSR submitted comments to the Minnesota Public Utilities Commission regarding Xcel Energy’s 2019 Integrated Distribution Plan. This plan was to be a detailed report on the utility’s distribution network and how the utility will adapt to a changing energy landscape. In summary, ILSR’s comments reflect four beliefs. First, the proposed valuation method for non-wires projects (like solar, storage, and energy-efficiency) over-states their costs and does not not fully capture all of their benefits. Second, there must be a more robust grid hosting capacity analysis. Additionally, customers and third parties deserve greater data access, so that they have every opportunity to install distributed energy generation and cut their energy costs. Finally, ILSR asked that the commission deny certification of the Advanced Grid Intelligence and Security Initiative. All in all, ILSR seconds many of the comments made by the Citizens Utility Board, the City of Minneapolis, the Environmental Law and Policy Center, the Interstate Renewable Energy Council, Vote Solar, and Xcel Large Industrials.
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Designing a Rooftop Solar Alternative in Sacramento
California Energy Commission Docket 19-BSTD-08
In February, ILSR sent comments to the California Energy Commission regarding the Sacramento Municipal Utility District (SMUD) proposal for a SolarShares program. The program serves as an alternative for the California Energy Commission’s first-in-the-nation mandate requiring solar panels to be a part of all new residential construction. These comments express some concerns about the program, which could set a precedent for similar programs in the state of California. Mainly, ILSR is concerned that the program does not provide enough benefit to community solar subscribers. Additionally, our comments seek to reinforce the value of community solar installations that are located within the community. These comments fit into a broader discussion on the difference between on-site and remote solar power.
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