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.