- Earlier this month, PSC staff issued a report on emerging issues in utility regulation, focused on distributed energy resources. The report recommends utilities collect certain information, including aggregate information characterizing the distribution circuits where retail-scale distributed energy resources are connected, and aggregate capacity of retail-scale DER for each feeder or load.
- Missouri utilities are still digesting the report, but cautioned staff of the Public Service Commission that there were potential procedural issues involved.
- Kansas City Power & Light said it had concerns about the requests, as written, saying for some resources "the utility’s ability to track this information at the circuit level is doubtful."
Missouri PSC staff have suggested utilities begin collecting a range of data in order to better integrate DERs into the planning process, as part of the state's investigation into new utility regulation issues. This investigation builds upon many taking place around the nation, the most notable of these in New York and California. As expected, utilities have concerns.
Rather than focusing on a value of solar or value of DER study at this time, staff recommended that regulators "focus stakeholder efforts on Chapter 22 revisions related to distribution system planning, as these efforts may also provide a framework for valuing DER." Chapter 22 includes integrated resource planning rules. As to rate designs that could enhance distributed resources, staff said that would likely occur within individual utility rate cases.
"Because appropriate rate structures and rate designs are unique to each utility and that utility’s costs, movement toward specific rate design objectives must occur within that utility’s rate cases," the report said.
Staff also recommended certain steps that should be taken to inform those rate cases. For instance, before a residential rate design is set, the report recommends improvements in customer education, a review of rates on an unbundled basis, implementation of a low-differential time-of-use rate design; and a study to examine the implementation of on-peak demand charges.
Staff also recommended the commission direct utilities to file an evaluation of the impacts, including distribution system impacts of raising standard offer contract for generation to 1 MW, 2.5 MW and 5 MW.
KCP&L questioned some of staff's data requests, but it may be an issue of wording. The utility said that "due to the many forms energy efficiency may take, the utility’s ability to track this information at the circuit level is doubtful."
The utility noted that in past discussions of distributed resources, energy efficiency was included "but only with respect to dispatchable forms of energy efficiency." KCP&L requested additional information on staff's data request.
Ameren also raised concerns with the data requests, noting they are "not trivial" and cover information the utility is not currently collecting.
"Maintaining such information (in fact, to maintain it would require creating it) would entail the commitment significant resources and costs," Ameren said.
Ameren also said portions of staff's report appeared to take the form of an order, which it said would be unlawful. Ameren said it was not addressing the substance of the report's suggestions, but "objects to ... the idea that workshops can be held, that the Staff can then recommend the issuance of certain orders, and that those orders could be effective ... Such a process would be unlawful, and to the extent the Staff’s report suggests it, that suggestion is unlawful as well."