March and April 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.
22M-0171ALL: Implementation of SB 21-272, Equity At the PUC
In April 2022, the Colorado PUC opened a new proceeding to hear from the public on how it can incorporate equity into its work. Senate Bill 21-272 requires the Commission to make rules in which it considers how best to provide equity, minimize impacts, prioritize benefits to disproportionately impacted communities and address historical inequalities. The docket will gather information on how to implement SB 21-272, including what kinds of rules it should create in the future and what other actions it should take. Initial comments are due June 13. The Commission will investigate the following topics:
How it should define equity for the industries it regulates, including electricity, gas, telecommunications, transportation, and other areas
How it can better engage disproportionately impacted communities
Whether changes to programs for income-qualified utility customers should be considered
What kinds of rules and practices would make it easier to participate in Commission proceedings
Experiences members of the public have had with utility services or Commission processes
Resource Planning: Your Power, Your Community
21A-0141E Xcel 2021 Clean Energy Plan
The Colorado PUC made several notable orders related to Xcel’s Clean Energy Plan, notably related to Xcel's attempt to keep Comanche 3 open through 2034. The PUC directed Xcel to file detailed modeling and cost comparisons between the 2034 and 2029 closure dates. An updated settlement agreement was filed in April, proposing to move the Comanche 3 retirement date to January 2031. Some stakeholders responded that the updated settlement should be rejected because the expedited schedule requested is “procedurally improper” and “ignores the due process rights of the non-settling parties.” The commission requested additional details on customer rate forecasts and re-opened the record for conferences and hearings specifically for non-settling parties to file comments and questions.
22A-0157EL Tri-State Early Rifle Retirement
In April 2020, Tri-State Generation and Transmission Association filed an application to retire its 85 MW "Rifle" gas-fired generation plant earlier than initially planned, in October 2022. Although Tri-State previously forecasted a retirement date of 2028 for Rifle, the facility is subject to a Colorado Discharge Permit System permit that will require certain major capital improvements at the facility in order to continue operations beyond the end of 2022. The facility has "operated very infrequently in recent years" and upgrades are not cost-effective. The facility was constructed in 1987 by an independent power producer as a cogeneration plant under the Public Utility Regulatory Policy Act of 1978. Tri-State purchased the facility in 2002.
22M-0156E: Consumer Advocate Petition to View Comanche Documents
In April 2022, the Office of the Utility Consumer Advocate (UCA) petitioned the Colorado PUC for access to the confidential documents filed by Xcel in Proceeding No. 22I-0086E, the Comanche Unit 3 Incident Investigatory Docket. This docket seeks to understand an incident at Unit 3 in January 2022 which resulted in the unit's uncertain return-to-service date. The UCA stated that Xcel's objections to disclosure run contrary to statute and the fundamental principle of transparency in Commission proceedings, and therefore should be rejected. "Moreover, the operational issues at Unit 3 are a matter of statewide importance with respect to the integrity of the electric grid and Colorado’s decarbonization efforts, and the public interest weighs heavily in favor of providing the UCA access."
20A-0528E Tri-State 2020 Electric Resource Plan
On March 28, the Colorado ALJ filed a recommended decision to approve the settlement filed in Tri-State’s Electric Resource Plan (ERP). Tri-State’s ERP as modified includes an assessment of a 0 MW capacity need prior to 2029 at earliest, with the expectation of further certainty related to resource need in its 2023 ERP. The Settlement Agreement thus commits Tri-State to evaluate the procurement of renewable, semi-dispatchable, and dispatchable resources with commercial operation dates no later than December 31, 2025, except for highly competitive 2026 Bids as described above, to meet carbon reduction (energy) needs.
Distribution: Technology for Energy Delivery
22I-0052EG: Climate Change & Extreme Weather Impacts
The Colorado PUC announced a Commissioner Information Meeting on wildfire mitigation plan activities, particularly to discuss utilities' data collection, grid hardening, and modeling of transmission and distribution circuits. The informational meeting is the first in the PUC's climate change and weather investigation, scoped to solicit information from experts, including information from climate and weather experts; studies performed or actions taken by other regulatory entities addressing changing climate and weather; and comments from utilities and other interested persons.
22A-0189E: Xcel 2022 Distribution System Plan Phase I
Public Service Co. of Colorado filed Phase I of its first Distribution System Plan in May 2022, submitted alongside a non-wires alternatives (NWAs) service agreement and model RFP to fulfill five potential NWA needs (upgrades estimated to exceed $2 million). While the NWA RFP is technology-agnostic, anticipated projects include demand response programs, energy efficiency programs, energy storage services, distributed generation, or some combination thereof. Xcel requested a new proposed shared savings performance incentive mechanism for NWAs. The DSP also proposed a Feeder Relay and Protection Improvement Plan pilot to proactively upgrade substation equipment to integrate additional distributed solar capacity at lower interconnection costs; a Demand Response Management System (DRMS) pilot to control and aggregate distributed energy resources (DER); more granular and frequent hosting capacity analysis to help inform customers’ siting of DER; and a Secure Web Portal to allow stakeholders to access more granular information to help better inform DER siting and interconnection-related decisions.
The DSP also discussed the value of the company's pre-existing AMI and distributed intelligence investments, ADMS implementation, the Parasonic and Community Resiliency Initiative microgrid projects, storage pilots, Voltage Supervisory Reclosing technology, and vehicle-to-grid transportation electrification projects.
Business Models: Moneymaking, Programs, and Regional Impacts
21AL-0317E Xcel 2022 Rate Case
On March 24, the Colorado PUC accepted the proposed settlement in Xcel's rate case. The settlement proposed a rate increase of $298 million (estimated to equal $182 million after adjustments), down from the initial request of $469.7 million. The settlement removed “Distributed Intelligence” advanced metering expenses, $4.8 million, and related expenses associated with the Advanced Grid Intelligence and Security (AGIS) proposal. Xcel agreed to estimate "the potential opportunity for AGIS-related incremental MWh and/or MW load management targets/benefits" in relevant proceedings (i.e. energy efficiency, beneficial and transportation electrification plans). Xcel will also redesign its customer bills through customer surveys, redesign its Rate Advisor Tool (to reflect customer behavior), and estimate MWh/MW savings attributable to IVVO in its next Distribution System Plan. Xcel will implement its base rate increase through a modified General Rate Schedule Adjustment rider and will file a Phase II rate case no later than September 2022. The commission deferred a decision related to the retirement of the Craig and Hayden coal units to a later proceeding.
Distributed Energy: Local and Customer-Owned Power
22AL-0130E: Xcel Resiliency Service Program Tariff (applicable to microgrids!)
In March 2022, Xcel filed an application and testimony to implement a new Resiliency Service Program Tariff for Small Commercial or Commercial and Industrial Secondary, Primary or Transmission Service customers that have a need for higher than standard service reliability through use of battery energy storage or on-site generation assets. Resiliency service assets can consist of battery energy storage systems, generation assets, switching and control equipment, or some combination of these. Resiliency assets will be hosted behind the meter but owned and operated by Xcel. Customers installing a back-up generator will pay $80 per month, while customers installing resiliency projects beyond back-up generation, such as solar and storage or full microgrid installations, will pay $450 per month. The difference in pricing is due to the additional design work and vendor management required for resiliency assets that include multiple technologies.
Transportation Electrification: Electric Vehicles, Charging Plans, and More
21AL-0494E Xcel Electric Vehicle Rates (TOU, CPP, DCFC)
On April 11, Xcel filed a corrected settlement agreement. The settlement was organized by three components: a Secondary Voltage S-EV optional rates, a Direct Current Fast Charging (DCFC) rate at company-owned DCFC stations, and an equity performance incentive mechanism (PIM). The S-EV rate provides charging fleets and public charging operators with two choices: a critical peak pricing rate option and a non-critical peak pricing option. The new S-EV, non-critical peak pricing rate adjustments include a demand charge that is 84% lower than the current S-EV rate, removal of a 50% demand ratchet applicable to both S-EV rates, and reduction of the on-peak window by 1 hour, and more. The equity performance PIM will provide Xcel will award per-port installation and rebates provided, up to $1.5 million.
22D-0069E: EVGo Declaratory Order for DCFC EV Siting
On April 13, the Colorado PUC denied EVGo's petition related to Xcel's Direct Current Fast Charging (DCFC) Siting Report. While the commission found that EVGo's proposed 10 mile buffer between utility-owned and third-party charging stations was not reasonable, the decision reviewed various concerns about the stakeholder process used to inform the report. The PUC tasked PUC staff, the Colorado Energy Office, and theOffice of the Consumer Advocate with responsibilities in future stakeholder discussions. Additionally, "given these concerns, and our recognition throughout this process that the regulated monopoly and competitive market sit in a critical and vulnerable balance, we find it appropriate to limit the company to developing no more than five “market” stations prior to approval of its next-filed transportation electrification plan," down from Xcel's proposed 20-25 stations.