February 2022 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).

Note: PUC refers to the Colorado Public Utilities Commission.

Resource Planning: Your Power, Your Community

22I-0086E Xcel Comanche Unit 3 Incident

In February 2022, the Colorado PUC opened a non-judicatory proceeding to investigate an incident at Comanche Unit 3 which shut down the unit. The proceeding was opened in response to a letter filed by Xcel describing the issue. The PUC requested information on the estimated cost of the repairs, the estimated date the unit will be available to serve load, the impact on reliability, and the root cause of the accident. The Comanche 3 Unit has received criticism from advocates around the state for its intermittent service since commissioning, high cost, and continued use of fossil fuels. Xcel’s responses were filed confidentially, except a supplement to the filing which confirmed that it does not have an expected date as to when Comanche 3 will be returned to service.  

21A-0096E Xcel Power Pathway Transmission Project

The Colorado PUC met in February to discuss Xcel’s proposed $1.7 billion transmission loop around the Eastern plains of Colorado. The transmission line, called the “Power Pathway,” was framed as a key investment to facilitate the interconnection of 5.5 GW of renewable energy (outlined in Xcel’s Clean Energy Plan). Xcel intends to complete the first phase of investments by 2025.

A written order from the PUC is pending, but the Colorado Public Radio reports that the project was approved, and a separate article cites supportive quotes from commissioners.

Screenshot of Xcel’s Power Pathway project map, available on its Power Path website.

20A-0528E Tri-State 2020 Electric Resource Plan

In late January, stakeholders party to Tri-State’s Electric Resource Plan filed a comprehensive settlement agreement, which was signed by all but two parties (Vote Solar and Delta Montrose Electric Assn.). The settlement confirms Tri-State’s commitment to reducing its greenhouse gases by 80% in 2030 based on 2005 levels, with interim goals to reduce GHGs by 26% in 2025; 36% in 2026; and 46% in 2027. These targets are almost three times as aggressive as the targets initially proposed. Among the provisions in the settlement, Tri-State agreed to model a variety of scenarios for Phase II (resource selection process) of its resource plan, including high gas prices, early retirement of Craig Unit 3, the retirement of Burlington units, and others. Tri-State also agreed to create a Workforce Transition Plan with respect to the Craig Station by December 2022, which will accompany an Informational Community Assistance Plan. The settlement also addressed modeling inputs; Craig Unit 3 economic dispatch; resource solicitation processes, modeling inputs, and software; reliability considerations; resource procurement; ERP implementation reports; requirements for the next ERP; transmission; regional markets; renewable power purchase agreements; and other topics.

The PUC responded with a series of questions on the timing of the request for proposals and how Tri-State will incorporate extreme weather sensitivity analyses, reliability impacts, and other storm-related issues.

Demand-Side Management: Energy Efficiency Programming

21R-0449G Gas Clean Heat Proceeding

During the 2021 legislative session, SB 21-264 created new requirements for large Colorado gas utilities to develop comprehensive Clean Heat Plans designed to achieve GHG reductions. A separate 2021 bill, HB 21-1238, modified natural gas demand-side management programs. The Colorado PUC responded by opening an investigation to modify gas rules in line with these two bills. Initial Clean Heat Plans are due August 2023 and must include the following application components: the maximum amount of greenhouse gas reductions counting toward the CHP target that can be achieved through the use of recovered methane; projected annual greenhouse gas emissions and carbon dioxide and methane reductions; a program budget; priority for investments that ensure disproportionately impacted communities or income-qualified customers benefit from the investments; quantification of additional air quality, environmental, and health benefits; and a forecast of potential new customers or expansion of the utility’s gas system during the plan period and related projected greenhouse gas emissions.

Public hearings were held in February, and the PUC continues to explore the impacts of these changes on disproportionately impacted communities.

Transportation Electrification: Electric Vehicles, Charging Plans, and More

22D-0069E EVGo Petition for Order on Direct Current Fast Charging

In February 2022, the Colorado PUC opened a proceeding to discuss the Petition for Declaratory Order filed by EVgo Services on January 14, 2022 in Xcel’s Transportation Electrification Plan proceeding (20A-0204E). The Petition requested the Commission to enter an order to terminate a controversy regarding whether the Report on Process and Siting for Xcel Energy Direct Current Fast Charging (DCFC) Stations filed in December 2021 complies with Decision No. C21-0117 issued in March 2021. (NOTE: DCFC stations are of importance to transportation electrification because they can enable quick public charging along highway corridors) EVgo claimed that the DCFC Siting Report did not comply with the commission’s Decision in three ways:

-      First, EVgo claimed that the report “erroneously” relies on the Commission’s alleged approval of the “market” and “connector” station concept and claims that the report ignores the Commission’s clarifications through its RRR Decision.

-      Second, EVgo further claims that the Company’s proposal of “a mere half-mile distance metric between Company-owned and third-party-owned DCFCs is not aligned” with the Commission’s directives in the RRR Decision.

-      Third, EVgo claims that “[b]y pressing forward with a half-mile metric after multiple parties expressed significant concerns that such a metric was inadequate to achieve an appropriate balance between the regulated monopoly and competitive market,” the Company did not follow the Commission’s direction to “proceed cautiously and thoughtfully in siting the Company’s stations.”

EVGo requested that the commission reject the half-mile minimum distance metric proposed and instead use a 10-mile metric and clarify that in no case will Xcel site a utility-owned station closer than ten miles from existing or proposed privately-owned DCFC.

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March and April 2022 PUC Update

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Equity at the Public Utility Commissions: Recent Research and Lessons