|
FEBRUARY 23, 2023 – We are excited to share news on NESP activities in 2023: The launch of a new project on distributional equity analysis (DEA), commission staff proposals to adopt a jurisdiction specific test after applying the National Standard Practice Manual (NSPM), a Public Utilities Fortnightly interview on benefit-cost analyses, and more. Enjoy this issue! We welcome your feedback.
— Julie Michals & Natalie Fortman
|
|
|
--MN Completes its NSPM Process
--LBNL and E4 to Develop DEA Guidance
--PUF Interviews E4 and SEPA
(and we'd like to interview you!)
| |
|
--DSP Tables Compare GHG and NEI Values
--Tips for Accessing NESP Resources
--Upcoming Events
| |
States using the NSPM: Minnesota and more… | |
|
Minnesota
Last fall, we described Minnesota's NSPM process through October -- applying NSPM Steps 1-5 to develop a new primary cost-effectiveness test for the utilities’ 2024-2026 Conservation Improvement Program (CIP) Triennial Plans. Since then, the Department of Commerce (DOC) held two workshops focused on identifying methodologies for quantifying various impacts (using NESP’s Methods, Tools and Resources Handbook).
The formal NSPM process, publication of white papers, and DOC’s recommendations, were completed in mid-December. On February 16, 2023, DOC Staff filed its Proposed Decision with a summary of the Cost-effectiveness Advisory Committee’s activities and Staff’s recommended cost-effectiveness methodology updates for the 2024-26 CIP Triennial Plan period. The issuance of Staff’s Proposed Decision – which includes adopting a Minnesota Cost Test (MCT) – marks the beginning of a formal regulatory process (Docket 23-46). A public comment period ends March 6, 2023. This process will conclude when the DOC issues the Deputy Commissioner’s Decision, expected by March 31, 2023.
To see how Minnesota applied the NSPM, visit MN NSPM workshop materials.
| |
|
Maryland
In past newsletters, we have provided updates on NSPM application in Maryland. Readers can see how a state has applied the NSPM to specific DERs in separate dockets, and then opened a docket to develop a “Unified BCA” to ensure consistency in the evaluation of all DERs. The Unified BCA docket (Case No. 9674) was opened in early 2022, followed by a commission order to convene a workgroup (Order 90212), which also directed the utilities to issue an RFP (on behalf of the Commission) for Workgroup facilitation services. An RFP was issued in early January 2023, with selection of the facilitator yet to be announced. Development of a Unified BCA test, using the NSPM process, will build on the two jurisdiction specific tests developed in 2021-22 – one for electric vehicles (Statewide EV BCA Methodology) and another for energy efficiency (EmPOWER Maryland JST). Stay tuned on next steps!
| |
|
Michigan
The Michigan Public Service Commission’s (MPSC) July 27, 2022 Order in Case No. 20898 requires that the utilities file proposed Michigan-specific BCA requirements to use in multiple types of dockets (pilot proposals, distribution planning, and rate cases), where the proposed BCAs should be informed by the NSPM and tailored to Michigan’s regulatory structure and requirements (pg. 20). The MPSC subsequently set forth a phased approach to the development of a Michigan specific uniform BCA, where Phase 1 addresses BCAs for pilots and Phase 2 will address more broadly applicable BCA.
As part of Phase 1, on February 1, 2023, DTE Electric Company and Consumers Energy (“the Companies”) submitted Proposed Requirements and Further Guidance on Benefit-Cost Analyses for Pilot Initiatives, where the proposal describes the Companies application of the NSPM 5-step process and consideration of the NSPM’s core principles to develop a JST that can be applied to pilot projects "at scale".
Separately, in the Commission’s Sept 2022 Order in Docket No. U-20147 on distribution system planning, the MPSC describes changes to its organizational structure, including the creation of a new distribution planning section (at pg. 71). It will be through this new section at the MPSC that a JST will be developed for use moving forward, as guided by the NSPM and also using the Staff’s reports filed in this docket. The Commission will provide more detail as part of a future order launching Phase 2 of the BCA effort once the new distribution planning section is adequately staffed.
| |
|
Washington
Since kicking off the NSPM process in Docket UE-210804 (May 2022), the Washington Utilities and Transportation Commission (UTC) convened intervenors in the docket for four workshops to bring cost-effectiveness testing practices into alignment with applicable policies — in particular, related to the state’s Clean Energy Transformation Act (CETA) and Climate Commitment Act – and to support clean energy rule requirements. The workshops culminated in a straw proposal developed by Synapse Energy Economics (technical advisor to UTC) recommending the adoption of a jurisdiction specific test (JST) – the Washington Test. See how the state followed the NSPM process, key BCA issues and topics addressed in the workshop series, and questions asked by the UTC to intervenors in its request for comments on the proposed test. Read more below.
| |
|
Other State Updates and NSPM References
While some states are formally applying the NSPM, others are learning about the NSPM through recommendations for its use in regulatory dockets. Below are recent examples of the latter.
| |
|
|
Connecticut (Docket 22-08-05): In their response to the Public Utilities Regulatory Authority’s (PURA) Notice of Request for Briefs regarding the Annual Energy Storage Solutions Program Review, the Northeast Clean Energy Council (NECEC) expresses concern about the risk of counting the costs from charging but not the benefits from discharging. They recommend PURA work with stakeholders to create a rate design that reflects the benefits and costs of energy storage systems on the distribution system and to consider the BCA principles in the NSPM for distributed storage (pg. 2).
Florida (Docket 20200181): In their comments on the proposed amendments to Goals for Electric Utilities, Southface Energy Institute recommends the Commission replace the current cost-effectiveness manual with the NSPM as it is a more modern and flexible guide to properly evaluate the costs and benefits of DERs (pg 12).
North Carolina (Docket E-100 Sub 180): In their Brief to the Commission, the Environmental Working Group, NC WARN, North Carolina Climate Solutions Coalition, Sunrise Movement Durham Hub, 350 Triangle, 350 Charlotte, and the North Carolina Alliance to Protect Our People and the Places We Live (Joint Intervenors) recommend using the NSPM as it represents the standard of care for conducting BCA of DERs, including net energy metering. Joint intervenors note the NSPM was adopted by eleven public utility commissions and is recommended for adoption in 31 additional states (pgs 19-24).
| |
New Project to Develop Guidance on DEA | |
|
In 2022, NESP outlined a conceptual framework for conducting a distributional equity analysis (DEA) in Chapter 9 of the Methods, Tools & Resources Handbook for Quantifying DER Impacts. Early last fall, Lawrence Berkeley National Lab (LBNL) and E4TheFuture prepared a proposal to US DOE to fund (with leveraged E4 funds) development of a guidance document on how to evaluate the distribution of benefits and costs across all customers when making decisions about utility investments in DERs. This work builds on industry research such as LBNL’s recent work Assessing the Current State of U.S. Energy Equity Regulation and Legislation.
Synapse Energy Economics is the lead consultant developing DEA guidance and conducting the supporting research. The project is guided by an Advisory Committee with representatives from across the energy industry.
An initial outline, informed by the Advisory Committee, covers:
- Stakeholder input and engagement processes to inform DEA
- Limitations of BCA, and how DEA can be used with BCA
- Defining priority populations and communities
- Identifying relevant distributional equity metrics
- Conducting a DEA
- Using BCA and DEA to make decisions about resource investments
The Committee provided important feedback on the document’s issues, content, and scope. Final guidance is scheduled for publication in Fall 2023. See the LBNL DEA project website for details.
| |
PUF Interviews E4 and SEPA | |
|
What BCA Use Cases Do you Care About? Take a Short Survey!
NESP invites your feedback on the BCA Case Studies report to inform more case study development. The 2022 report illustrates how NSPM guidance can be applied to BCAs for three use cases:
- Residential EV managed charging
- Commercial solar + storage
- Residential grid-interactive efficient buildings
Have you used or referenced these case studies in your work? Can you suggest other examples that would be helpful to the industry? All responses are anonymous and will help to improve future NESP resources. We appreciate your response by COB March 3. Thank you!
| |
DSP: NEI and GHG Impact Comparisons | |
The Database of Screening Practices (DSP) is an open-source tool for looking at cost-effectiveness screening practices in ratepayer-funded energy efficiency programs (50 states, Washington, D.C., Puerto Rico). To simplify how users compare values for certain impacts using sources cited in the DSP, we created two new tables that provide a snapshot of values used for host customer non-energy impacts (NEIs) and carbon emissions across states. Read more for a comparison of host customer NEI and carbon emission impact values and methodologies across states and to access the DSP and the new tables. | |
Tips for Accessing NESP Resources | |
A note to frequent NESP website visitors: to avoid entering your name and affiliation each time you view resources, you can bookmark the resource after accessing it for the first time. | |
|
March 1, 2023. AESP Annual Conference, New Orleans, LA. Shifting Tomorrow’s Regulation: Performance-Based Regulation and Evaluation for DERs. Julie Michals (E4TheFuture), and David Pudleiner (ICF). More information and registration here.
Stay tuned for other events!
| |
|
E4TheFuture serves as coordinator of the National Energy Screening Project, and manages its publications.
Contact us at [email protected]
Please follow NESP on Twitter!
| | | | |
