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Iowa Utilities Board - Distributed Generation Letter of SupportMasterpiece on the Mississippi February 12, 2014 Iowa Utilities Board 1375 E. Court Avenue, Room 69 Des Moines, Iowa 50319 -0069 To Members of the Iowa Utilities Board: Dubuque tied All- America City 11111. 2007 • 2012 • 2013 Office of the Mayor City Hall 50 West 13`" Street Dubuque, IA 52001 -4864 www.cityofdubuque.org ..cityofdubuque.org As Mayor and on behalf of my City Council colleagues and City staff, I am pleased to submit these comments regarding distributed generation in response to Docket NOI 2014 -0001. In 2006 and every year since, the City Council has identified becoming a more Sustainable Dubuque as one of its top priorities. The Sustainable Dubuque vision statement, which was developed by a diverse community task force that represented residents, small and large business, utility providers, and non - profits, states that, "Dubuque is a viable, livable and equitable community. We embrace economic prosperity, environmental integrity, and social /cultural vibrancy in order to create a sustainable legacy for generations to come." This vision and 12 sustainability principles, which include Smart Energy Use, Resource Management, and a Regional Economy, have become the lens through which we view all projects and initiatives at the City. I am proud to say that the City had implemented many projects since then that improve the energy efficiency of our municipal buildings and the community as a whole, including the Smarter Sustainable Dubuque partnership with IBM Watson Research Center and local utility providers. Along with Alliant Energy and with support from the Iowa Office of Energy Independence, we implemented an award - winning Smarter Electricity pilot in which 1,000 volunteers decreased their electricity use by an average of 3 to 11 %. Since 2009, the City of Dubuque has filed Alliant rebates that document 2.7 million kWh /year in energy savings. The residential energy efficiency savings in the same time frame is 6.2 million kWh /year. We strongly believe that this unused energy is the most efficient type of energy "use ". However, once these efficiencies have been achieved, we support the use of distributed, renewable energy sources as a way to reduce one's negative impact on the environment, increase resiliency and energy independence, and support local job creation in Iowa. In 2011, the City installed a solar array on the Municipal Services Center. This array, installed by one of (currently) three Dubuque -based companies, provides approximately one third of that facility's power needs. It is one piece of our strategic plan to meet our goal of reducing community greenhouse gasses 50% by 2030, and is an opportunity to reduce our utility bills and provide on -site energy generation to a critical municipal service facility in the event of grid failure. Iowa has a strong history of including wind and solar in our Renewable Portfolio Standard. The state has one of the best wind resources in the country, although today it is estimated we are only harnessing about 1% of the potential. Iowa ranks 16th among U.S. states in the potential for solar energy production, and we have tremendous opportunity here as well. Iowa's leadership on renewable energy has already meant billions of dollars of investment in local manufacturing and installation jobs, thanks in part to incentives supported by the IUB. We urge you to consider additional policies that support the further development of distributed generation. The benefits of distributed generation for residents, commercial and industrial users, municipalities, schools and non - profits are many: • Private dollars investing in energy generation. That investment creates Iowa jobs. Additionally, investment in distributed energy has been proven to help utility customers, particularly large users, in meeting energy demands and offsetting investments that the general public would otherwise have to make in new generation and operations and maintenance costs. • Diversification of utility generation resources. Diversification helps with grid reliability and serves as a hedge against potential future increases in the cost of natural gas or pricing of carbon; solar and wind are supportive and complementary energy resources. • Environmental benefits. Renewable generation is clean energy that keeps our air and water clean and reduces greenhouse gas emissions. • Economic benefits. Renewable energy creates local jobs for installers, distributers and suppliers. Market trends show that residents, businesses, municipalities and schools in Iowa want to invest in distributed generation. • Reductions in peak demand. Solar is a particularly effective resource during peak periods and will help reduce the need for some of the dirtiest, most expensive energy we use and provide relief when the electric grid is stressed. • Reductions in line losses that make our energy system more efficient. When distributed renewable systems put energy back on the grid that energy is frequently used nearby, saving energy losses on the distribution lines and making our energy production more efficient. • Distributed generation can reduce the dollars spent importing fossil fuels. Investment in distributed energy infrastructure in an investment that keeps dollars circulating in Iowa. The City of Dubuque supports the IUB's efforts to increase distributed generation of energy for all utility customers in the state. This includes support of increased renewable portfolio standards; net metering policies that apply to all utilities and customers; updated, standardized interconnection standards that reflect national best practices; and the support of policies that make investment in distributed generation for local governments and non - profits an economically viable option. Dubuque is proud to be a partner with the IEDA and IAMU as a pilot community in the upcoming Rooftop Solar Challenge. We look forward to addressing state and local government barriers to the installation of solar through that process, and appreciate this opportunity to provide comment to address some of the barriers that have already been identified through that process. We look forward to continuing to partner with the IUB, state officials, and our own utility providers to increase the state's economic prosperity, environmental integrity, and quality of life through the improvement of distributed generation policies and standards. Thank you. Respectfully, Mayor Roy D. Buol City of Dubuque STATE OF IOWA DEPARTMENT OF COMMERCE UTILITIES BOARD IN RE: DOCKET NO. NOI- 2014 -0001 DISTRIBUTED GENERATION ORDER OPENING INQUIRY ON DISTRIBUTED GENERATION AND SOLICITING COMMENTS (Issued January 7, 2014) I. INTRODUCTION Energy efficiency plan proceedings were recently concluded by the Utilities Board (Board) with final orders issued for Interstate Power and Light Company (Docket No. EEP- 2012 -0001) and MidAmerican Energy Company (Docket No. EEP- 2012- 0002). In the energy efficiency plan orders, the Board recognized that the debate over whether rate - regulated utilities should have an incentive -based renewable energy program is part of a larger debate regarding distributed generation in general. The Board announced its intent to commence an inquiry into the broader subject of distributed generation to consider the policy and technical issues associated with its potential widespread use, including consumer protection, interconnection, and safety. II. INITIATING INQUIRY The Board is initiating this inquiry to gather information regarding distributed generation. The Board has not previously conducted an inquiry related to distributed generation policy. Information obtained in this inquiry will be useful to the Board and DOCKET NO. NOI- 2014 -0001 PAGE 2 other agencies involved in energy, environmental, and economic policy. The Board will commence the inquiry by inviting participants to comment on broad general questions related to the benefits and challenges of distributed generation, both for utilities and their ratepayers, on policies that should be examined with respect to distributed generation, and to identify the technical, financial, regulatory, and safety aspects of distributed generation that should be examined in this docket. While the questions are broad, the Board also invites participants to comment on other issues that they believe are relevant to the discussion regarding distributed generation. Those issues could include, but are not limited to, the potential rate ramifications of distributed generation to participating and non - participating ratepayers, the impacts of distributed generation on the reliability of the electric transmission and distribution systems and the need for future transmission expansion (including any issues that may impact regional transmission system operations), the economic impacts of widespread distributed generation, and whether the existing consumer protection laws are adequate with respect to the sale and installation of distributed generation equipment. Participants may also comment on whether there are any technical hurdles to the implementation of distributed generation (whether customer -owned or utility - owned), such as whether the current interconnection standards (199 IAC 45) are appropriate. In addition, participants may wish to comment on whether they believe widespread customer -owned distributed generation might be economic for DOCKET NO. NOI- 2014 -0001 PAGE 3 residential, commercial, and industrial customers.1 Comments may include policy recommendations to the Board or other state agencies or suggested legislative changes that the participants believe are necessary or appropriate. The Board invites state agencies, environmental groups, renewable energy trade associations, renewable energy groups, local government entities, industrials, and any others with an interest in these issues to participate in this inquiry. The Board asks that the investor -owned utilities, municipal utilities, and electric cooperatives participate, either individually or through their respective associations, or both. Participants with similar interests are encouraged to file joint comments. Following receipt of the initial information and comments, the Board will determine what additional steps, if any, should be taken to continue or conclude this inquiry. The Board will review the comments to determine what topics warrant further discussion and may request that participants respond to more specific questions on some topics. As the inquiry progresses, the Board might schedule one or more workshops to address some of the issues. Participants must submit their responses electronically through the Board's Electronic Filing System (EFS). Instructions for making an electronic filing can be found on the Board's EFS Web site at https: /lefs.iowa.gov. The Board is appointing Brenda Biddle, Utility Specialist in the Board's Policy Section, as the Inquiry Manager for this docket. Questions regarding this docket 1 The Board recognizes that legal issues associated with certain types of third -party financing for distributed generation are currently at issue before the Iowa Supreme Court in S.Z. Enterprises, LLC v. Iowa Utilities Board, No. 13 -0642. Oral argument is scheduled for January 22, 2014. DOCKET NO. NOI- 2014 -0001 PAGE 4 should be addressed to Ms. Biddle, (515) 725 -7305, or via e-mail at Brenda.Biddle@iub.iowa.gov. III. INQUIRY QUESTIONS Participants are invited to respond to some or all of the questions. Participants may also provide any additional comments or information that they believe are relevant to this inquiry. The Board recognizes that the comments by various participants could be extensive. To facilitate review of the information, participants who file comments that exceed 20 pages are asked to include an executive summary that does not exceed two pages. Also, in order to frame the issues for further discussion, all participants who file comments are asked to list what they view as the most significant issues related to distributed generation. Participants are asked to keep this list to five issues or less. Responses to the following questions and other comments from participants will assist the Board in determining the next steps for this inquiry: 1. What are the potential benefits and challenges of distributed generation for utilities and ratepayers? Are these different for utility -owned distributed generation versus customer -owned distributed generation? 2. Are there policies the Board, other state agencies, or the General Assembly should examine related to distributed generation? 3. What other topics (i.e., technological, financial, regulatory, safety, or others) should be examined in this docket? DOCKET NO. NOI- 2014 -0001 PAGE 5 IV. ORDERING CLAUSES IT IS THEREFORE ORDERED: 1. A notice of inquiry is opened to address distributed generation. The inquiry is identified as Docket No. NOI- 2014 -0001. Participants are invited to provide the information identified in this order on or before February 25, 2014. 2. All filings in this docket shall be made using the Board's electronic filing system. The rules for filing are in 199 IAC 14. UTILITIES BOARD /s/Elizabeth S. Jacobs /s/Nick Wapner ATTEST: /s/Joan Conrad /s/Sheila K. Tipton Executive Secretary Dated at Des Moines, Iowa, this 7th day of January 2014.