July 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).
Note: PUC refers to the Colorado Public Utilities Commission.
Resource Planning: Your Power, Your Community
21A-0141E Xcel 2021 Clean Energy Plan
On July 2, the Colorado PUC issued an interim decision directing Xcel to file certain information in its supplemental direct testimony. The PUC requested incorporation of a week-long extreme heat event, doubling the rate of growth of the “high gas price,” a thorough qualitative analysis of high penetration of EVs by 2030 with strategic implications, an analysis of changes from shifting system peak by 2 hours, and analysis of up to 200 MW of more community solar gardens through 2027 and up to 200 MW of demand response. New modeling must consider modified natural gas scenarios (no new PPAs beyond 2050 and using a 20-year life for new gas) and potential 400 MW capacity from “Pacificorp East” (Nevada).
Xcel was also directed to present the eight resource plan portfolios with modified operational input assumptions for the Comanche 3 unit “that more closely reflect that unit’s actual historical experience,” including outage rates and high costs.
On July 12, the Colorado PUC published the Phase I Electric Resource Plan (ERP) schedule and discovery provisions. Evidentiary hearings were scheduled for November 15-18, and parties were directed to file briefs regarding whether or not the PUC should hold evidentiary hearings in Phase II of the ERP, especially because the ERP contains Xcel’s first Clean Energy Plan.
Additionally, the PUC issued several decisions granting party status, including a rejection of the “Coalition of Ratepayers,” which filed a vague application for intervention.
ERP Background
In accordance with SB 19-236, the Company’s ERP filing contains a Clean Energy Plan designed to meet the mandatory clean energy target of achieving by 2030, an 80% reduction in CO2 emissions using a 2005 baseline. The ERP will be judged in two phases: In Phase I, the Commission reviews and may approve, or approve with modifications, the utility’s plan to acquire new utility resources. In Phase II, the utility brings forward actual portfolios assembled from bids provided during the competitive acquisition process, and the Commission determines whether the utility should be granted a presumption of prudence for pursuing the acquisition of particular resources.
Distributed Energy: Local and Customer-Owned Power
21I-0321E Interconnection of Distributed Energy Resources (DER)
In reaction to discussion from other PUC proceedings, the Colorado PUC established a docket to investigate the DER interconnection practices of Colorado's regulated electric utilities. The opening notice stated that the proceeding was necessary, "particularly given the significant amount of DER capacity likely to be proposed in ongoing and future proceedings." The PUC requested that staff establish an anonymous comment procedure to learn from customers, and also noted that performance incentive mechanisms and performance based regulation may support the interconnection process. Other topics of interest were hosting capacity analysis coordination, a comparison of non-wires alternatives and distribution system equipment impacts, issues faced by specific sub-sets of DER, and other issues.
Business Models: Moneymaking, Programs, and Regional Impacts
20AL-0432E Xcel 2020 Phase II Rate Case
On July 12, the Colorado Administrative Law Judge (ALJ) issued a recommended decision accepting the settlement agreement in PSCo's 2020 rate case. The settlement largely addresses PSCo's Class Cost of Service Study and various rate design principles, including Time of Use (TOU) and demand rate issues. The ALJ agreed to eliminate the existing Inverted Block Rate (IBR) primary residential rate, Schedule R, in support of the transition to TOU rates for customers receiving AMI meters. The ALJ rejected the proposed Flat Bill Option because its design would provide too much incentive for customers to self-select into a tariff that does not limit consumption.
The decision also denied the Residential Demand-Time Differentiated Rate (RD-TDR) due to over-complicated rate design; approved small commercial TOU rates as the default for small commercial class; created a new SG-TOU pilot design as proposed by staff; rejected the proposal to convert the Schedule SG rate from demand-based to energy-based rates; and addressed other demand charge issues (i.e. reducing the summer differential from 70% to 60%). PSCo asserted that it will investigate time-differentiated demand charges as AMI meters are rolled out.
Parties filed responses and exceptions to the decision through the rest of the month.
Distribution: Technology for Energy Delivery
20R-0516E Proposed Rules for Distribution System Planning
On July 8, the PUC issued a recommended decision to amend and adopt rules regulating Colorado’s Distribution System Plans (DSPs). The ruling satisfies the requirements of SB 19-236, which directed the PUC to promulgate rules for new DSPs and the evaluation of non-wires alternatives (NWA). The DSPs will provide a transparent review of utility investments in the distribution grid and support diversification of energy supply through DERs and NWA. DSPs were designed to complement the DSM planning process, as well as distributed generation acquired through the Renewable Energy Standard or Transportation Electrification Plans. PSCo’s DSP will be submitted in January 2022 and every two years thereafter for large utilities, while smaller utilities will file in 2023. The DSPs will also evaluate the implementation of a web portal and “how the utility has incorporated community climate, equity and resilience goals and priorities.” Hosting capacity analyses, grid needs assessments, “innovative” DSP pilots, NWA screening and solicitation, data access, and other sections will be required. “Energy efficiency measures” were defined as those that target consumer behavior, equipment, or devices that result in the decrease in electricity usage of customers without detriment to end-use services.
21A-0279E Xcel Petition to Amend AGIS CPCN
On July 28 at its weekly public meeting, the Colorado PUC deemed Xcel’s AGIS CPCN application complete and referred the matter to an ALJ, who will address interventions and motions for extraordinary protection. During the hearing, Commissioner Gilman said she looks forward to the proceeding developing a roadmap as to who will pay and who will benefit from the capabilities of the advanced meters and Distributed Intelligence. Commissioner Gavan stated the importance of “drilling into details and getting things right,” and noted that this is a very important proceeding involving edge computing, home automation, DER enablement, and the home energy application ecosystem – as well as the importance that “open architectures prevail,” as shown over the last 30 years. Chairman Blank echoed the importance of getting things right.