A guide for commenting on Xcel's 15 Year Plan: Racial Justice, Community Solar and Fossil Gas


Hey Xcel! No New Fossil Gas

Comment on Xcel's 15-Year Energy Resource Plan - Deadline Extended to February 11th !


We make it simple and easy to submit a comment to the MN Public Utilities Commission, who are the final decision makers who will approve, deny or modify Xcel's 15-year Plan. 

Gratefully, a group of dedicated volunteers with Saint Paul 350 has reviewed Xcel's 15-year plan has offered this list of messaging points you can use to help write your comments :

1: Stop Xcel's proposed billion-dollar new Sherco gas plant and pipeline 

2: Protest Xcel's inadequate modeling of our energy future, (which does not study or consider alternative scenarios without the new gas plant, earning Xcel a failing grade on their report card below)

3: Prioritize distributed renewable energy, storage, and efficiency

However, Xcel’s 15-year plan proposes to slash new rooftop & community solar by 90% from current levels !  

The Energy We Can't Afford Coalition has developed messaging points in this link here on community solar and making Firm Commitments to Prioritize Racial Justice. 


Click here to read about the strengths and weaknesses of Xcel's 15- year plan. 



Commenting is Easy! 4 Options 

MAIN POINT: you cannot submit anonymous comments
Send a comment directly to the MN Public Utility Commission via letter, direct comment, or video

1: MAIL  Write a letter. Make sure to include your name and Docket Number 19-368 and mail it to: Minnesota Public Utilities Commission, 121 7th Place East, Suite #350, Saint Paul, Minnesota, 55101

2: ONLINE DIRECTLY to the MN Public Utility Commission Submit a comment at this link and then reference docket number 19-368.

3: VIDEO COMMENT sent by EMAIL Submit comment by video: create video and send a Youtube link or wav file by email to [email protected]

4. THROUGH AN ORGANIZATION: MN350 and the Energy We Can’t Afford Coalition has provided a sample letter in this link, with space to type in your personal comments. These will be submitted as comments on Xcel’s 15 year plan.


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2020 Year in Review

This year has been unprecedented. On a global scale, a pandemic. On a national scale, a long overdue upheaval in protest to racial injustice to which Community Power posted an extensive historical reflection on. On a local scale we have seen changes in how we work, live, and take care of one another. Below are some highlights of what we accomplished in 2020 always alongside partners. 


  • Joint Letter to Xcel & the PUC on shut-offs and utility debt: As the COVID crisis hit, Community Power contributed to a joint letter to protect families from utility shut-offs and to demand utility debt cancellation by using Xcel’s historic profits made during the pandemic. As one among many voices from the Just Solar Coalition, we spoke up together to the Governor, the Public Utilities Commission (PUC), and the utilities themselves, and won a moratorium on utility shut-offs that extends as long as the crisis.


  • Groundbreaking Video Testimony Approved: We helped open the doors for ordinary folks to comment on the plans of energy utilities by winning a decision from a judge to allow short video testimony -- our first case saw a total of 72  Minnesotans take advantage of this option. That show of support played a key role in a recent encouraging decision, and the Judge cited this as an important precedent that captured the spirit of the law for participation, transparency, fairness, and process. Sincere thanks to the team at Sierra Club and CERTs for helping pull this off together, and to ILSR, CEF, and MN350 for co-signing our letter and adding key data points.
  • Building Power of Community in the "Superbowl" of Energy - Xcel's 15-Year Plan: We have kept Minnesotans regularly updated about improving Xcel’s 15-year Energy Plan and for that purpose over the long multi-year process with the multiple delay requests from Xcel. Over the course, of the fall we were invited to join a team of folks supporting grassroots groups to comment, intervene, and influence Xcel's IRP to better reflect the needs of community in the metro area, which have unequivocally oppose fossil fuel and Xcel's attempts to diminish community ownership of renewables.
  • Partnering with St. Paul 350 to support more bottom-up style climate fights in St. Paul. We provided technical and logistical support in outreach to district councils, St. Paul educators, and other community organizations around how to approach Xcel, and how to create change on behalf of community solar and other clean energy-friendly policies.


  • Inclusive Financing Is Almost Here: After years of conversations with community partners, technical experts, and City leaders, we had a whirlwind of progress and work on Inclusive Financing. On November 20th after a series of public hearings, comment periods, and letter-writing, the overseeing judge issued a recommendation that the PUC approve Minneapolis' pilot project for inclusive energy financing. The Judge also called to the PUC to take up the bold and necessary interpretation that the PUC should allow "a thousand flowers bloom" when it comes to energy efficiency.

*** Want to see the Judges recommendation (or read the comments which Community Power's submitted thus far)? Click here and in the row that says “Docket Number” choose 19 in the drop-down menu, and type in 524 as the number. Judge Lipman's Recommendation will be listed as the only document submitted on November 20th. You can find the 3 Comments which Community Power contributed to the discussion by scrolling to the dates of August 21st, October 7th, and December 7th. 


  • Drawing a Line in the Sand on Energy We Can't Afford: We are active coalition partners in the Energy We Can’t Afford Coalition that focuses on removing fossil gas from the conversation in Xcel's IRP. The Coalition has now submitted at least 3000 comments contesting Xcel’s plans to build a new fossil gas plant in Becker, MN!


  • Cooperatively-Owned Solar takes off: We supported Southern Minnesotans connect with a member-owned solar cooperative to lower their electric bills and share in the any profits, including 30+ residents, an ice cream shop, a library, a Buddhist meditation center, a Catholic church, and a prairie-restoration non-profit. (Shout-outs to partners CEF + MNIPL!)
  • Energy Efficiency Cohort: We co-facilitated the first year-long Energy Efficiency Cohort that supported 10 community-based organizations to build a shared analysis on how to transform efficiency programs to center renters, households with low-income, and BIPOC communities. (Shout out to CEED, CUB, & Neighborhood Hub!)


  • Mr. Monopoly Speaks Again: We partnered with members of the Energy We Can’t Afford coalition to host a satirical interview on Xcel's 15-year plan with Mr. Monopoly-- also known as Mr. Moneybags, playing the role of a self-appointed spokesman for investor-owned utilities. Click below to watch and hear what he says about Xcel's preferred plan...!


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Coalition Partners Launch "Energy We Can't Afford" Campaign to Challenge New Fossil Gas Plants

Quick Action: Sign the petition here to help Xcel fix its "F" grade on gas.

Across Minnesota, utilities are rushing to replace coal with fossil gas (or “natural gas” as the industry has called).

A key example is Xcel Energy's 15-Year Plan on where to source our energy from. It has yet been approved by the state, so there is time to make a difference!

 Energy Democracy coalition partners have given Xcel a Report Card on how their revised plan stacks up with important goals. 


While the report card shows a mixed bag, check out this article on what an "A+" energy plan might look like for Minnesota's energy users. Xcel’s Plan received one failing grade because the company did not model any energy future scenario that did not include a $1 billion new fossil gas plant + new pipeline facility in Becker, MN at the site of their soon-to-be-retired Sherco Coal plant.

Coalition partners launch the #EnergyWeCantAfford campaign (https://energywecantafford.org/)

The socially distanced action in front of Xcel’s HQ on September 10th began with a singalong to a rendition of the song "Electric Avenue" with special lyrics calling for transparency and accountability in utility planning. See the video !


Why is Xcel's plan a new fossil gas plant #EnergyWeCantAfford?

For decades, the industry has promoted fossil gas a “clean” and a “bridge fuel”. But most fossil gas now comes from fracking, a process which emits methane, a greenhouse gas eighty four times more potent than carbon dioxide. The fracking techniques used to extract fossil gas involve numerous hazardous chemicals which poison nearby community members.

It also places shareholders over customers. Even if Xcel shuts this proposed fossil gas plant down many years earlier than its 40-year expected lifespan, Xcel customers (rather than Xcel shareholders) will still be on the hook to pay off the costs of building it because Xcel stockholders are legally guaranteed to receive a return on infrastructure investments (like this power plant). 


This is not Energy Democracy. Is there a better way?

The new coalition effort called Energy We Can't Afford offers

* A quick fact sheet of what's at stake- There are not one but three proposed new fossil gas plants in MN which would set us back decades in the transition to 100% clean, renewable energy if built. But it's not too late to stop them!

* A powerful in-depth report on how investing in clean energy instead of new fossil gas infrastructure is expected to save Minnesotans and Wisconsinites around $600 million over the next 30 years.

Even back in 2018, when Xcel was still drafting its 15-year energy plan, the Minnesota’s “Smarter Grid” study was released and showed that distributed renewables and efficiency together could save $1,200 per Minnesota household per year. Meanwhile, Xcel’s preferred plan costs Minnesotans at least 1% more per year.

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Xcel's Shockingly Low Forecasts for Community & Distributed Solar

Undercounting customer-sited and non-utility solar energy in Minnesota has significant financial and economic consequences and utilities need to instead plan for more competition.  

Why do we see utilities push back against customer- and community-owned energy? "The bottom line: 500 megawatts of community-owned solar represents a missed opportunity for Xcel shareholder profits."

    A core existing pillar holding up some degree of Energy Democracy in the U.S. is that so many utilities, including Xcel Energy, are required to present “Integrated Resource Plans” to identify their plans for power generation for the next 10, 15, or 20 years, which state regulators who oversee the utilities have to approve.

The oddest and most noticeable problem with Xcel’s revised 2020-2034 Integrated Resource Plan is that it assumes a dubiously low estimate for future Community, Distributed and Rooftop Solar. It forecasts only 21 Mega Watts per year of new Distributed/ Rooftop & Community Solar from 2021 through 2034. That amounts to only 273 MW total in that timeframe).

(SUPPLEMENT 2020-2034 Upper Midwest Integrated Resource Plan (Docket No. E002/RP-19-368). https://bit.ly/3guwYUX)

 For comparison, we had more than 200 MW of distributed and community solar added in 2018 alone and program capacity reached 688 MW of capacity in May 2020, nearly six years ahead of Xcel’s 2019 forecast.

(Farrell, John. Why Minnesota’s Community Solar Program is the Best. (Institute for Local Self-Reliance, updated monthly). https://ilsr.org/minnesotas-community-solar-program/)

When you take Xcel forecasting this current momentum will be quashed by 90%- 97% in coming years, and compare that decline with its recent growth trends plus the number of projects are already in the existing queue, we can realistically expect that new Community Solar added to Xcel’s system will far outstrip Xcel’s projections *** barring legislative action to curtail the program***. By 2013 State Law, Xcel is legally obligated to accept new Community Solar project proposals.

I personally asked this same question to one of Xcel's lobbyists who devoted an evening last October to presenting and taking questions about Xcel's IRP.    I started asking the question this video (~ minute 22:26). The Xcel representative appeared to quickly pivot to general facts on a related but different topic (until ~ minute 27:09) and offered platitudes along the lines of "we can't predict the future, and there are a lot of things to look at". https://www.youtube.com/watch?v=APXfAbWE6AA But he avoided acknowledging the basic premise behind my question which was that the forecast for community & distributed solar was low by perhaps a factor of ten. It is his job to paint Xcel in a good light, which suggests this question touched a nerve. Note that he was eager to volunteer to put an earlier audience member in touch with someone who could talk about Xcel battery technology, but with the question on lowballed community/ distributed solar forecasts he seemed all too eager to move on  to another topic. Overall, I could have obtained a forecast from a recognized entity such as NREL or MISO and asked a question like "I noticed that the community distributed solar forecast from MISO Energy zone 1 differs from the number in the latest IRP -  why are you using a different estimate?" or "If Distributed solar ends up being two to three times more than Xcel has forecasted, then does that mean Xcel has unnecessarily invested in energy from fossil gas?"


Xcel also has had a track record of lowballing estimates for Community Solar and has been wrong on a similar forecast before. Shortly after the law passed in 2013 requiring them to take on Community Solar Project, Xcel proposed allowing just 20 megawatts of development over the first two years.

(Shaffer, David. Xcel Energy opens way for solar gardens. (Star Tribune, 10/1/13). http://strib.mn/3732vd7)

What is so valuable about distributed renewable energy?

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Take Action for Inclusive Financing and Against Regressive Rate Increases

CenterPoint Energy, which provides natural gas to Minneapolis and many of the western suburbs, has had public hearings for an unpopular rate hike proposal which very refreshingly included a long-awaited remedy for preventably high natural gas bills to speak in favor of, called Inclusive Financing.   

Centerpoint - in the middle of the ongoing COVID crisis - is proposing a 8.7% rate increase for residential customers, (with a smaller rate increase for commercial and industrial customers) a percentage which concerningly includes a 26% increase in the fixed charge

Community Members were offered a chance to weigh in on both Inclusive Financing AND Centerpoint's proposed Rate Hike at 4 different hearings in Late July which were held via WebEx with Telephone for audio. Having attended all 4 hearings myself, each of these only resulted in 8 Public commenters participating (including myself).

In Contrast, an effort led by Community Power and coalition partners like Sierra Club Northstar was able to collect a total of 72 pre-recorded video comments in support of Inclusive Financing and against the rate hike proposal. 

See https://flipgrid.com/55c254d1 or Click the image below to see this new, innovative and much more convenient way for Community Members to weigh in!


(Students in the Youth N' Power summer training program shared video comments)   



Interesting Findings on Centerpoint's Rate Increase Proposal

The City of Minneapolis submitted its Inclusive Financing proposal as an intervention into Centerpoint’s Rate Case so that is why Centerpoint's Rate Increase was the main topic among the comments. 

To this date, there has not been a single commenter who spoke in support of Centerpoint Energy raising our rates during a historic pandemic in any of the 4 Public Hearings and online written comments.  

Even Centerpoint's spokesperson admitted at the July 28th hearing that they fully expect the final ruling to be different from their initial rate increase request. 

There is a routine norm for rate cases. First utility companies request a far greater rate hike that they could justify. Second, the Public Utilities Commission approves about half of their requested rate increase. So that way the decision can be publicly spun in the media as “a win for the people”. In this particular rate case, the MN Department of Commerce Division of Energy Resources concluded at the hearings that exactly half of Centerpoint’s current proposed rate hike was unjustified. 

In response to a question during the July 28th hearing, the Office of the Attorney General disclosed that a portion of Centerpoint’s proposed rate increase was for marketing & ads promoting increased natural gas use. Because the intent behind increased sales is to drive up shareholder profits, that is a cost which utility customers should not have to pay for. 

Centerpoint first filed this particular rate increase request back on October 28th, 2019. At the time, the Company had a $300 million capital spending plan of projects and system Infrastructure improvements. Many of these public improvement projects have since gotten postponed with the impact COVID has had on City Budgets. However, Centerpoint’s rate increase request is still the same amount as it was in October. In contrast, utility peer Minnesota Power has reduced its rate hike request to respond to the economic challenges during this historic Pandemic.  


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