February 2021 PUC Update
Clean Energy Action Board Member Marguerite Behringer works for E9 Insight and part of her work is to compile summaries of Colorado Public Utilities Commission activities. E9 Insight has given CEA permission to publish the items that we think our readers might find useful. If you have questions about the content, please contact hello@e9insight.com.
Note: Xcel Energy does business in Colorado as Public Service Company of Colorado (PSCo); references to both Xcel and PSCo will appear in the summaries below.
Note: PUC refers to the Colorado Public Utilities Commission.
21M-0061E Clean Energy Plan Review
On February 23, the PUC held an interagency workshop to discuss clean energy plans and goals with the Colorado Energy Office, Colorado Department of Public Health & Environment (CDPHE), and the Governor’s Office, Climate and Energy. The PUC filed a presentation titled, “Implementing Colorado’s Greenhouse Gas Pollution Reduction Roadmap,” referencing the roadmap that was published in December 2020. The presentation describes the main requirements of Colorado’s climate legislation, Colorado’s Climate Equity Principles, a summary of the near-term action plan, clean energy progress and goals for Colorado’s electric utilities, and the Clean Energy Plan (CEP) Emissions Verification process, which describes the role of the CDPHE in performing neutral verification of emissions reductions for presentation in PUC proceedings. The workshop also discussed utility CEP plans, with a separate portion reserved to discuss Xcel’s forthcoming CEP. The filing, expected on March 31, 2021, will comply with 2019 climate legislative direction, including examinations of high building and transportation electrification scenarios.
Slides from the PUC presentation:
21A-0096E Colorado Power Pathway Transmission Project
On March 2, a few weeks ahead of the Clean Energy Plan filing, PSCo filed a Certificate of Public Convenience and Necessity (CPCN) application for a $1.7 billion high-voltage transition system project: the Colorado Power Pathway. The project includes five segments of 345-kW transmission line covering over 560 miles. PSCo claims that the transmission project is necessary to meet the requirements of Colorado’s 2019 climate legislation and the upcoming Clean Energy Plan. Construction was anticipated to begin in 2023, with segments in-service in 2025-2027.
20M-0008E 10-Year Transmission Plans
On February 11, the Colorado Administrative Law Judge (ALJ) issued a recommended decision regarding the 2020 Joint Transmission Plan, filed by the Colorado utilities in June 2020. The ALJ expressed concerns that the transmission plans, filed under transmission planning rules, should not be used to streamline Certificate of Public Convenience and Necessity (CPCN) applications. The ALJ found that the current plan complies with requirements and is adequate to meet Colorado’s energy needs, though the ALJ recommended that the PUC open a rulemaking to modify the transmission planning rules.
Commenting on non-wires alternatives (NWAs), the ALJ stated that “the Utilities have presented scant evidence that they are even aware of, much less that they regularly evaluate these alternatives.” All filings mention the possible integration of energy storage as a NWA in the future as costs decline, but few other details were provided with regard to other NWAs. The ALJ directed the utilities to apply a more expansive definition of the word “alternative,” used in consideration of alternative paths, voltages, or conventional power mitigation solutions in order to consider technological advancements. If the decision is approved, utilities will need to file future plans with extensive NWA analyses and project descriptions.
20I-0437E Pueblo Unit 3 Investigation
On March 1, the PUC published its two-volume staff report on the history and continued operation of PSCo’s Pueblo Unit 3 (also known as Comanche 3) plant. The report reviewed the continued operations and equipment problems that “have plagued" Pueble Unit 3 since its operation in 2010, including boulder tube leaks; stack noise issued; reduced capacity factors due to planned outages; replacement of superheaters (the subject of a $11.7 million disallowance on investments); and the extended outage from January to December 2020 for repairs. Despite being the youngest unit in PSCo’s portfolio, Pueblo Unit 3 had the lowest availability of all units from 2010 to 2020, and actual levelized cost of energy (LCOE) was on average $66.25/MWh instead of the forecasted $45.70. High costs from the plant were associated with initial high capital costs; significant ongoing capital costs which were not included in the original projections; high O&M costs; lower availability and therefore lower production.
In addition to the unit review, staff recommended that the commission require quarterly status reports on Pueblo Unit 3 and relevant topics, and/or monthly reports documenting all unplanned outages for Pueblo Unit 3 in the prior month.
Demand-Side Management: Energy Efficiency Programming
20A-0287EG PSCo 2021-2022 DSM Plan
On February 12, the Colorado Administrative Law Judge issued a recommended decision accepting the settlement agreement in PSCo’s demand-side management (DSM, also known as energy efficiency) case. The ALJ summarized the settlement agreement as five key provisions: 1) energy efficiency goals and budgets ($90 million per year to exceed the 500 GWh PUC goal and 75 MW demand reduction); 2) increased income-qualified program funding and program expansion; 3) additional beneficial electrification analyses and programs (evaluation of heat pump offerings, tiered structures, on-bill financing options etc.); 4) modified social cost of carbon calculations; and 5) critical peak pricing pilot cap expansion from 30 MW to 65 MW. The ALJ recommended that all modifications be accepted as proposed.
Distribution: Technology for Energy Delivery
16A-0588E PSCo Advanced Grid Intelligence
On February 2, Trial Staff filed a response to a motion by Mission:data’s request to re-open PSCo’s distribution grid enhancement proceeding. Mission:data’s primary concerns involve Itron’s Distributed Intelligence (DI) meters, which the coalition claims represent anti-competitive technology beyond the initial scope approved in the proceeding. Trial Staff noted that it seeks transparency from the utility and while it does not advocate for the unnecessary delay in the rollout of AMI meters or relitigation of the AGIS and HAN proceedings, it recommends that the PUC examine the DI meter functionality and implications. The filing noted that the meters are behind schedule to achieve mandatory TOU rates system-wide by April 2022, due to the AGIS settlement. In late February, the PUC granted PSCo and Western Resource Advocates a “motion for leave to reply,” allowing the parties to respond to Trial Staff and Mission:data’s latest filing.