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2020 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 the pricing of net metering policies.
Below is a summary of ILSR involvement in regulatory dockets in 2021, 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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Minor Corrections to Xcel Energy’s 2022 Value of Solar Calculation
Minnesota Public Utilities Commission Docket No. 13-867
On December 9th, the Institute for Local Self-Reliance submitted comments to the Minnesota Public Utilities Commission Xcel Energy’s 2022 vintage Value of Solar calculation. ILSR asks that Xcel Energy make a few corrections to its 2022 value of solar calculation, including those suggested by Dr. Gabriel Chan and updating its calculation with more recent gas prices.
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Protecting Tenant Rights in Minnesota’s Community Solar Program
Minnesota Public Utilities Commission Docket No. 21-695, 13-867
On December 6th, the Institute for Local Self-Reliance and the Energy Equity and Access Parties submitted reply comments to the Minnesota Public Utilities Commission on customer protections in Xcel Energy’s community solar garden tariff. The parties are concerned for the rights of tenants and support of a solar industry in Minnesota that centers justice and community access.
In these comments, ILSR and the Energy Equity and Access Parties respond to other intervenors and provide seven recommendations regarding strengthening tenant safeguards, securing access to community solar for tenants, streamlining subscription processes for tenant subscribers, and further stakeholder dialogue.
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Uncompetitive Bidding Process Results in Unreasonably Expensive Sherburne County Solar Project
Minnesota Public Utilities Commission Docket No. 20-891
On November 16th, the Institute for Local Self-Reliance submitted reply comments to the Minnesota Public Utilities Commission on Xcel Energy’s proposed Sherburne County solar project. These comments reiterate the concerns raised by ILSR and others on the proposed Sherco solar project: the bidding process was poorly structured, the projected cost was unreasonable, and the Sherco project would result in a disproportionate benefit for utility shareholders. ILSR asks that Xcel Energy restarts the bidding process to collect more competitive and reasonable project bids.
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Free Access to Utility Resource Modeling Software Is in the Public Interest
Minnesota Public Utilities Commission Dockets 21-33, 19-368, 21-339
On November 2nd, the Institute for Local Self-Reliance and Vote Solar submitted comments to the Minnesota Public Utilities Commission on modeling software costs and utility integrated resource plans. In these comments, ILSR and Vote Solar explain how electric utility resource modeling software can be prohibitively expensive for organizations that hope to intervene in utility resource plans.
Whereas utility companies may pay for the software with funds from captive customers, nonprofit organizations rely on public donations or other philanthropy to secure the software — often for a limited time. The cost for the software can be tens or hundreds of thousands of dollars for a single proceeding. Some public utility commissions, including those in Michigan and South Carolina, have found it in the public interest to provide free software licenses for intervenors. Transparency and access to modeling software would allow for greater stakeholder input and the best outcome for customers.
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Xcel Energy’s Revised Integrated Resource Plan Still Lacks a Consideration of Distributed Generation Resources
Minnesota Public Utilities Commission Docket 19-368
On October 15th, the Institute for Local Self-Reliance and the Distributed Solar Parties (Vote Solar, Cooperative Energy Futures, and the Environmental Law & Policy Center) submitted supplemental comments to the Minnesota Public Utilities Commission on Xcel Energy’s 2020 Integrated Resource Plan. The comments acknowledge that, while Xcel Energy’s revised plan has appropriately abandoned the Sherco Combined Cycle gas plant, accelerated the retirement of coal plants, and expanded renewable energy and efficiency, the Company’s plan still ignores the benefits of distributed generation. The groups suggest that the Commission should require Xcel to model distributed generation resources, as was done in the Sierra Club’s CEFA plan. The groups also ask that the commission not approve the combustion turbines in Xcel Energy’s alternative plan.
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Utility Conflict of Interest is at the Heart of Minnesota’s Solar Interconnection Frustration
Minnesota Public Utilities Commission Dockets 16-521, 01-1023
On September 30th, ILSR submitted reply comments to the Minnesota Public Utilities Commission regarding issues in the distributed solar interconnection process. In these comments, ILSR supports several interim solutions to the queue backlog put forth by other parties, but points out that these are all band-aid solutions to a deeper problem. As long as the utility’s interest is earning a rate of return on new generation assets, it will not successfully manage grid access for third parties. At the heart of the interconnection frustration is the state continuing to set distributed generation policy as though this resource is ancillary to, rather than central to, the future clean energy system.
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Cluster Studies Could Reduce Distributed Solar Interconnection Backlog
Minnesota Public Utilities Commission Docket No. 16-521
In August, ILSR submitted comments to the Minnesota Public Utilities Commission regarding the distributed solar interconnection process and the possibility of cluster studies. Under the law, the interconnection process must be constructed to best serve distributed generation – in the interest of the public. In the comments, ILSR raises the importance of community solar and its value to Minnesotans. Minnesota’s community solar growth has been held back by interconnection delays and many distributed solar advocates believe that cluster studies may speed up the process. ILSR’s comments support the non-utility participants in the docket who are calling for these cluster studies.
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The Best Plan for Minnesota, According to Many Intervenors, Is to Retire Coal, Deploy More Renewables, and Halt Gas Buildout
Minnesota Public Utilities Commission Docket No. 19-368
On June 25th, the Institute for Local Self-Reliance and the other Distributed Solar Parties (Vote Solar, Cooperative Energy Futures, and the Environmental Law & Policy Center) submitted reply comments to the Minnesota Public Utilities Commission on Xcel Energy’s 2020 Integrated Resource Plan. These comments highlight the points made by the Citizens Utility Board, the City of Minneapolis, and the Energy Efficiency for All partners.
The Distributed Solar Parties believe the comments by other intervenors reinforce the importance of increasing the distributed solar component of Xcel Energy’s resource plan. The comments highlight the alignment of the Sierra Club’s Clean Energy for All Plan and the Citizens Utility Board’s Consumers Plan: the early retirement of coal plants, no new natural gas plant, and increased deployment of renewable energy together provide the most cost-effective and reliable plan for Xcel Energy customers. The Distributed Solar Parties ask that the Commission considers the impact of Xcel’s plans on Minneapolis’s climate and equity goals, adopts additional environmental justice and equity considerations, and weighs the benefits of including distributed energy resources in the utility resource planning process.
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Targeting Subscriber Inequities in Minnesota’s Community Solar Program
Minnesota Public Utilities Commission Docket No. 13-867
On June 21st, ILSR submitted its latest comments to the Minnesota Public Utilities Commission regarding Xcel Energy’s community solar program. In the comments, ILSR asks that the Commision extends the residential adder: a program designed to increase residential participation in community solar gardens. In particular, the comments address the importance of the community solar program in supporting residential and low-income subscribers, share a variety of approaches used by other states to achieve similar aims, and highlight why affordable distributed community solar has significant economic benefits beyond its participants.
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Xcel Energy’s Proposed Sherco Solar Project Is Overly Expensive and Its Comparison to Community Solar Is Disingenuous
Minnesota Public Utilities Commission Docket No. 20-891
At the end of April, the Institute for Local Self-Reliance submitted initial comments to the Minnesota Public Utilities Commission on Xcel Energy’s proposed Sherburne County solar project. In these comments, ILSR expresses its support for the replacement of coal-powered generation with utility-scale solar in a way that reuses existing transmission resources, uses union labor, and supports the tax base of the communities surrounding the Sherco coal plant. However, ILSR also flags a few issues that the Commission should consider in evaluating the proposed project, including the project cost, ownership, and the inane comparison to the costs and benefits of distributed generation.
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Hosting Capacity Analysis Could Simplify Grid Interconnection for Distributed Energy Resources
Minnesota Public Utilities Commission Docket No. E002/M-20-812
In early April, ILSR submitted comments to the Minnesota Public Utilities Commission regarding Xcel Energy’s 2020 Hosting Capacity Report. The comments underline the value Xcel Energy’s hosting capacity analysis could have as part of the interconnection process.
Xcel Energy is required to conduct annual hosting capacity analysis reports. These reports identify where the grid can accommodate additional distributed generation capacity (including rooftop and community solar) and the results are displayed on the company’s Hosting Capacity Map. If improved, the hosting capacity analysis could also be used to streamline the “interconnection” process of plugging solar into the electric grid — the Minnesota Public Utilities Commission has set this as the long-term goal.
In the comments, ILSR recommends that the Commission accept Xcel Energy’s 2020 Hosting Capacity Analysis Report, recognizing a few caveats: 1) Xcel slows the adoption of cost-effective distributed generation, 2) Xcel has not fulfilled the requirements outlined in the Public Utility Commission’s July 2020 Order, and 3) Xcel could do more to advance toward the ultimate goal: delivering its customers more cost-effective clean energy by integrating hosting capacity analysis with the interconnection process.
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Much More Rooftop Solar from an Alternative to Monopoly Utility Models
Minnesota Public Utilities Commission Docket No. E002/RP-19-368
In February, Vote Solar, the Institute for Local Self-Reliance, the Environmental Law & Policy Center, and Cooperative Energy Futures filed joint comments to the Minnesota Public Utilities Commission. The comments, summarized in this blog post, respond to a 2021 resource plan created by utility Xcel Energy.
The filed comments introduce a new modeling approach from Vote Solar and ILSR that could finally put distributed solar on the same footing in grid planning as the large power plants that utilities prefer. The proposed method showed that Xcel Energy could cost-effectively add nearly 2,000 megawatts more distributed solar than it plans to, saving customers billions of dollars. Expanded to other regions and utilities, these findings underline the importance of accurately assessing the potential of customer-sited solar in utility planning.
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ILSR Issues its Preferred Decision Options on Minnesota’s 2021 Value of Solar Proceeding
Minnesota Public Utilities Commission Docket No. 13-867
On January 27th, the Institute for Local Self-Reliance submitted preferred decision options to the Minneapolis Public Utilities Commission. The Commission issued these decision options on Xcel Energy’s 2021 Value of Solar calculation.
This page originally posted at ilsr.org. For timely updates, follow John Farrell on Twitter, our energy work on Facebook, or sign up to get the Energy Democracy weekly update.