Pre-recorded video (very convenient!) or written comments were due on August 9th getting extended by 6 weeks). See link here for any potential updates!)

*** All public Comments submitted until June 28th at 4:30 PM in any form will be summarized by a neutral administrative law judge and sent to the MN Public Utilities Commission in a report by August 19th. ***   

Since Xcel also has to make the case for how they will meet our energy needs in coming years, this is where we get to see the mix of renewable versus nonrenewable energy sources the utility currently has in mind for their customers in Minnesota with big implications for climate. 

Along with this process came a series of public hearings for the general public to be able to hear each other weigh in. The public hearings on this docket happened between June 10th and June 20th. Community Power spoke at 5 out of 8 of them. Many thanks to the Office of Administrative Hearings and staff from the PUC, The Department of Commerce, Xcel Energy and the Office of the Attorney General for helping make these opportunities happen as well as the open house prior to each in-person public hearing. 

Top messaging points for why Xcel should minimize fossil gas plants: 

1. Minnesota’s climate goals say we must be carbon neutral by 2050 across all sectors. Bringing new gas generation online puts that into jeopardy.
2. Methane is around 80 times more potent than CO2 at trapping heat in Earth’s atmosphere, so even a small amount of unintentional methane leakage from pipes poses a climate risk.
3. New gas plants create a "lock-in" effect for greenhouse gas emissions. At a time when a rapid switch to renewables is crucial, constructing new gas plants and infrastructure, as a principle, will entrench our reliance on carbon-emitting fossil fuels for decades to come.
4. Minnesotans should instead be shielded from the volatile trends of the gas market, and be provided with clean, reliable, and secure energy at consistent and affordable prices.
5. The above reasons are why we should encourage Xcel to maximize the Energy Efficiency, Demand Response, Energy Storage components of their plan. 

(Photo Credit, Patty O'Keefe, Sierra Club)                           (Photo Credit Brian Krohnke, Community Power)

What is in Xcel's Plan? 

For a brief summary on what is at stake Xcel Energy announced in February that their preferred 15-year plan includes: 

• extending the 20-year operating extensions for the Prairie Island nuclear facility by 20 years (beyond 2033-34). 
• adding two new gas peaker plants, "2,200 megawatts of what Xcel called "always-available" power by 2030"
  • "Last week, the company proposed building a gas plant in Cass County in North Dakota and another in Minnesota's Lyon County; they would begin operating in 2027 and 2028" (both would be peakers. 
  • This will be heavily scrutinized by clean energy organizations in terms of Xcel’s ability to meet Minnesota's new carbon-free by 2040 law and likely settled in a different docket.  

On the renewable front Xcel's 15 year plan thus far also includes:

• By 2023, it would seek 3,200 megawatts of new wind, 400 megawatts of large-scale solar and 1,000 megawatts of solar from other sources, including small-scale community projects.
• Battery storage - 600 megawatts of battery storage by 2030, "aside from its plans for a novel 10 megawatt, 100-hour battery system at its Sherco energy complex in Becker"
• Expansion of the utility’s energy efficiency and demand response programs, although existing demand response aggregation docket suggests Xcel is not really using demand response resource.

For additional reference, see Xcel's own webpage about their own Upper Midwest Energy Plan here.  

Please click below for some more interesting messaging points & background !

Notes on prioritizing of distributed renewable energy, energy storage, and demand side management and minimizing costly new gas-plants: 

The following images are what Xcel is handing out about their next Upper Midwest Energy Plan. This is what Xcel wants the public to see and notice how it says nothing about adding new gas plants as the above Star Tribune Article clearly sites. In the bottom right corner of the first page, Xcel only refers to "continuing to use natural gas facilities to ensure the reliability and stability of the electric system..." without specifying whether they intend to continue to use existing natural gas facilities. The ambiguity caused by the absence of the word existing leaves open the possibility of it referring to new gas plants without having to explicitly directly state it on paper, if that is their intention.   

UPDATE! *** According to an Xcel spokesperson at one of the hearings the company is modeling what they call 'always available resources' as gas powered generation but does not know for sure what those always available resources will be whether is will be gas or something else. Specifically, Xcel is using the Encompass Model (a proprietary type of software that one has to purchase to be able to access) to model future energy scenarios. ***  

Background on Integrated Resource Plans - why the process is important: 

Every few years, Xcel Energy is required to submit a 15-year Energy Plan to the MN Public Utilities Commission (PUC) to make sure they are not overcharging customers for infrastructure that is not needed. 

Through the early to mid 20th century, electric utilities were incentivized to build more power plants and infrastructure with a goal of making electricity universally available at an affordable cost. As a result, utilities (still to this day!) are guaranteed profits on the infrastructure investments they make by those who determine how much we pay on our monthly utility bills. Because utilities have an incentive to build more infrastructure than might be necessary for our energy needs, state governments such as Minnesota's now require utilities to submit an Integrated Resource Plan (IRP) where the utility has to show how much energy customers will need and how they plan to meet it. The IRP process is intended to be a safeguard utilities against gold-plating and gouging  customers. Even though it is a 15-year plan, the state of Minnesota requires that utilities refresh and make updates to it every few years. The 15-year plan only sets the stage for about the next 5-years of utility action while the remaining 10 years sets a roadmap of where we expect the energy system to go which will inevitably be updated.

Brief history of Xcel's Previous Integrated Resource Plan Process: 

After Xcel finally committed to a timetable to phase out their Sherco Coal Plants in 2015, Xcel was so intent on refurbishing some of the units as a billion-dollar new gas plant + pipeline project, that they:

1. Successfully lobbied the state legislature back in 2017 to do a regulatory workaround and give state approval for the proposed gas plant. This overrode the usual Public Utilities Commission process which would have required Xcel to do some degree of cost-comparison studies on whether combinations of renewable energy and energy storage can be a reasonable and prudent alternatives.
2. Crafted a whole 2020-2034 15-year energy plan that did not even consider any scenarios without the planned Sherco gas plant (aka "gaslighting") which delayed the regulatory process for an additional year. The delay worked in our favor as it provided extra time for energy storage to get cheaper.   

But in 2021, Xcel withdrew the plans for this Sherco gas plant when Xcel realized they had lost the ability to win arguments on it and could no longer “gaslight” those of us who are watching. 

That is because Community Power, along with organizations like Sierra Club, St. Paul 350 & COPAL used this extra time to do a diverse collaborative outreach effort to get community members to speak out citing intelligent studies. 

Several organizations did the cost comparison studies and modeled scenarios without the Sherco gas plan which Xcel did not want to be obligated to do at the time. They are still online and the conclusions are still worthy of citing for this resource plan.  These studies showed how Xcel customers would also save hundreds of millions of dollars if the utility scaled up local clean energy enough as opposed to Xcel’s usual business model of expensive back-up power plants and new long-distance transmission lines. Earlier in Xcel's previous resource plan process back in 2019, Xcel drastically underestimated the potential for how much local distributed solar energy on the grid would be on the grid by 2034 (at being only barely above the amount they had already committed to for 2021). 

Notes about Nuclear Energy & Removing Radioactive Waste from the Prairie Island Indian Community

While Xcel may frames extending the lives of either of its MN nuclear facilities as if they involve almost no extra cost, we can't overlook the risk of storing dangerous nuclear waste in the Mississippi River floodplain. In addition, as Xcel’s most recent nuclear plant extensions show, repairing and maintaining nuclear power plants beyond their original operating life typical costs Minnesotans hundreds of millions of dollars. These are essentially public funds that could otherwise be spent on cheaper, clean, and safe energy solutions. 

Only ~8% of uranium mined to use in making nuclear energy comes from inside the US. Both in the US and globally, indigenous communities bear the disproportionate burden of that mining - from the Cree nation in current-day Canada; to the Havasupai and Dine nations in current-day southwestern US and the Oceti Sakowin nations near the Black Hills of the US; to the multiple Aboriginal tribes in current-day Australia. Once its brought to Minnesota and used up in the making of electricity at the two nuclear plants - in Monticello and Red Wing, Minnesota - the radioactive waste is brought to be stored 600 yards from one of the smallest Dakota reservations in Minnesota, Prairie Island Indian Community. This has been un-consensual since the arrangement was proposed in the 1970s.

On April 9th, 2024, Community Power Board Member George Crocker got the following Op-Ed published in the Star Tribune about Nuclear Power "An ill-advised path"

"Certain Minnesota legislators are interested in new nuclear power plants to address problems resulting from climate change.

Perhaps these politicians have recent and exciting new information about how to overcome the multitude of economic problems that cause new commercial reactors to be much too expensive. It would be good to find that out, because back in July 2018, for one example, Proceedings of the National Academy of Sciences concluded that fission power is just too expensive relative to the competition. A new reactor would start out costing about $13.61 million per megawatt and go up from there. New solar costs about $1 million per megawatt, with wind at about $2 million per megawatt, and wind and solar costs continue dropping.

Perhaps these politicians have also figured out how to manage high-level nuclear waste for the required 240,000 years, now that Yucca Mountain, the nation's only proposed high-level nuclear waste repository has been shut down and abandoned for years, and U.S. federal courts recently stopped the nuclear industry from developing a dump to hold 100,000 metric tons of spent fuel on top of the Ogallala Aquifer in eastern New Mexico. These politicians probably also have a time machine to manage the fact that climate chaos is upon us as you read these words, but even in Nuclear Magic Land, if history teaches anything, new reactors will take upward of 10 years to construct. There's also the CO2 from burning the coal to boil the uranium to refine nuclear fuel to acceptable levels of U235.

If the Legislature were actually interested in combating climate chaos, it could pass legislation that enables the development of more than 8,000 megawatts in Minnesota of new renewable energy capacity, plus energy storage, that can be immediately installed and commissioned on the low-voltage side of virtually every load-serving substation in the state. Strategically sizing this new renewable energy capacity will allow it to come online immediately, because all the electricity will get consumed within the footprint of the substation and no new transmission would be needed."

George Crocker, Lake Elmo

The writer is executive director North American Water Office.

For a study the reinforces George's Points about how we can save money, dramatically decrease emissions and avoid any more nuclear:

• "Clean Energy For All Plan" from Sierra Club Saves $2.2 Billion and Reduces Carbon Emissions 90% by 2030 without nuclear