IRPs, IDPs, and rate cases -- Oh my!
Published September 8, 2021
It will be a busy fall at the Minnesota Public Utilities Commission. This blog post provides a brief overview of the policy and regulatory work CUB expects to be involved in over the next several months.
There are already numerous complex dockets underway before the Commission, including several unique dockets arising in relation to the COVID-19 pandemic, an ongoing review of historic, extraordinary costs Minnesota’s natural gas utilities incurred last February, and regulatory reviews of Xcel Energy’s and Minnesota Power’s most recent integrated resource plan (“IRP”) filings. CUB has been actively involved in many of these dockets, and we plan to continue this work in the weeks and months ahead.
On top of these existing dockets, we are aware of at least two utilities (Xcel and Minnesota Power) that plan to file integrated distribution plans (“IDPs”) by November 1, 2021. An IDP outlines a utility’s plan for how it will distribute energy across the distribution grid in the coming years. The IDP process allows stakeholders to review the utility’s plan and ask questions or make recommendations designed to ensure the final plan serves the public interest in the most cost-effective manner reasonably possible. Informed by this process, the Commission will ultimately either authorize the utility to proceed with its IDP as proposed or require the utility to make modifications that account for any identified deficiencies in the plan.
Finally, on top of that, we are aware of at least three utilities (Xcel, Minnesota Power, and CenterPoint) that intend to file general rate cases this November. Rate case proceedings allow utilities to present a “snap-shot in time” of all aspects involved in the services the utility provides to its customers. For example, the utility will provide information on the utility’s financial health, sales forecasts, rate design, costs of capital, costs associated with legally-mandated conservation efforts, and other factors affecting the utilities' costs and/or revenue. Once the utility makes all of that information available, the Commission will evaluate whether the utility’s rates are, on one hand, low enough to be “just and reasonable” to consumers and, on the other hand, high enough to permit the utility to recover its costs plus a “fair and reasonable return.” This can be a complex balancing act. Our role, as consumer advocates, will be to also review the information the utilities make available in the rate case proceeding and when appropriate, challenge costs and rates we believe would be unjust and unreasonable if passed through to customers.
We look forward to playing a role in these dockets to advocate on behalf of Minnesota’s consumers. Please keep an eye on our blog for updates on these processes. If you are interested in filing your own public comments in any of the proceedings discussed above, you can do so by following the instructions on the Commission website, here.