*** Example Commentary on Xcel's 15 Year Plan - Opinions expressed are my own, Delivered in the October 21st, 2019 public hearing. Since that time, we have learned that Xcel will refile its plan on April 1st, 2020, opening up another round of public commentary on that date. ***
Thank You for giving me the opportunity to speak today on this important issue of Xcel’s plans for our energy future.
The part about Xcel’s Integrated Resource Plan (IRP) that I can’t quite get beyond is that it estimates such an alarmingly low amount of new additional distributed rooftop and community solar, flatlining at just 20-25 MW per year from 2021 through 2034. For comparison, we had more than 200 MW of distributed and community solar added in 2018 alone.
In Xcel’s May 20th stakeholder meeting, the company explained that this steep drop-off was due to “market conditions”. But that can’t be true because the actual market is a monopoly with trade secrets that shelter their assumptions.
Last Thursday (Oct 17th), I asked this same question to one of Xcel’s lobbyists who is active at the state capitol about why Xcel’s IPR predicted such a steep drop-off. He responded that Xcel is legally obligated to add on new community solar projects. But he evaded my question by not acknowledging how Xcel’s IRP projects quashing this current momentum by between 90%- 97% in coming years and how that doesn’t reflect continuation of Xcel having to accept new Community Solar.
Given that response, these low estimates can only make sense to me if Xcel privately assumes that future lobbying efforts at the state Capitol to end Minnesota’s Community Solar program will actually be successful.
The PUC should instead both expect and support an accelerated scale-up of community-based clean energy because it has strong consumer interest with organized groups committed to making it happen.
But instead of more people or communities owning their own solar panels, Xcel appears to be presenting us with a future where the right to profit from renewables is overwhelmingly controlled by monopoly utilities.
Xcel’s IRP does estimate between 3000 MW and 4000 MW of solar power coming from large, utility-owned solar farms, which may be appropriate in areas where there is already the grid infrastructure, but quite often appears to be designed in a way that enables Xcel to maximize its market share and to rate base the assets.
A more balanced IRP would include an approach of strategically sizing and locating new renewable power generation to fit within the capacity that each corresponding substation can accommodate. The goal of this approach is to avoid having to construct new million-dollar-per-mile high voltage transmission lines (HVT) that would saddle Xcel Customers with preventable expenses. I also worry that adding new HVT lines could become controversial political bottlenecks which can delay the clean energy transition to be slower than what Xcel expects in the IRP.
In addition, community-scaled power is more energy efficient and loses less voltage than the standard approach of moving bulk power from remote sites to distant loads. Furthermore, if too many megawatts of solar capacity is concentrated in too few geographic areas, it will cause big disruptions in power supply when it happens to be cloudy over that one area than it would if the solar were more distributed. When Xcel intends new solar capacity to mimic the model of central station power plants, it creates the expectation of sharp intermittency in energy supply. That expectation is a big part of Xcel’s justification behind claiming a new Becker gas plant to be necessary.
For the above reasons, I’d strongly encourage that Xcel be obligated in its IRP, or in its Integrated Distribution Plan, include energy modeling at the distribution level. It would be dishonest for Xcel to publicly downplay the potential for distributed renewable power in its IRP if the company didn’t even do the modeling necessary that would reveal the possibility.
I applaud seeing Xcel treat energy efficiency as a supply side resource, which I heard is new for utility IRPs. But it would be great to hear more specifics on how the company offers to accomplish saved energy at an exponential rather than incremental rate. For that purpose, it would be great to see Xcel make a commitment to adopt a tariff-based on-bill inclusive financing to make energy efficiency improvements and rooftop solar more accessible to customers.
Thank You again for taking the time for me to share just some of my thought and I hope you will consider them as you make decisions.
Lee Samelson from South Minneapolis, energy education organizer with the non-profit Community Power.