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What's Happening in Energy - Oct 3
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What's Happening in Energy highlights the most interesting findings from public utility commission filings.

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What's Happening in Energy — Oct 3
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In Connecticut, there is significant controversy surrounding the recent resignation of Public Utility Regulatory Agency (PURA) Commissioner Marissa Gillett. Utility Avangrid has stated that Gillett “must not have anything further to do with any matter pending before PURA related to the Avangrid Companies, from now through her departure on October 10th. Doing otherwise will not only compound existing legal challenges to PURA’s conduct but will result in new, unnecessary litigation.”

The letter goes on to highlight allegations of bias from PURA General Counsel, Scott Muska, including accusations of his attempts to conceal the true authorship of an op-ed published in Connecticut Mirror in December 2024, titled “Don’t believe the utility company propaganda.” Avangrid claims that Gillett had “substantial participation” in drafting this piece.

The letter was submitted as part of an ongoing rate case proceeding for United Illuminating Company (UI), one of Avangrid’s subsidiaries. Furthermore, the companies intend to “enter this letter in every open docket at PURA involving the Avangrid Companies.”

In connection with this case, several UI employees have submitted letters expressing their concerns about the draft rate case filed by PURA staff, including this letter from an early career employee:

“I am emailing you regarding the current rate case draft with PURA, and my growing concerns about it. To give you a quick back story, I was so fortunate to be able to come as an intern for 10 weeks over the 2024 summer and learn about power distribution and all of the things that go with it. Not only did UI give me a great summer, but they offered me a full-time job as a "Rotational Utility Worker". In short, my position rotates to a new department related to linework and power distribution every 6 months. They have given me the opportunity to learn so much and figure out what department fits me best. 

Unfortunately, with the recent rate case draft with PURA, we weren't given nearly enough to even support our current workforce. Approximately 10% of our workforce won't be funded if this current draft of the rate case goes into effect. Not only could I be out of a future lifelong career, but our customers would suffer as well. The current rate case draft would give us the equivalent funding that we received in 2013. Unfortunately, inflation is real, and this draft would detrimentally affect our customers, outage response time, and our workforce. If there is anything in your power that you could do to prevent/alter this current draft, I couldn't be more grateful for you to do so. The final draft will go into effect on October 25th, 2025.”

Read more comments submitted in the docket profile linked below.

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In Minnesota, Xcel shared materials from their Integrated Distribution Plan Preview (IDP) stakeholder workshop held on August 19th. The workshop covered various topics, including planning, forecasts, capital budgets, and more related to the distribution system.

There is an entire slide deck worth viewing, which included three utility scenarios: base case, high adoption, and expanded non-residential demand.

MN_Xcel_Forecast_Scenarios

 

 

 

 

 

 

 

In the Capital Budget section of the materials, Xcel outlined investment trends by category.  The investment in Asset Health & Reliability remains consistently high, ranging from $300m-$350 million each year. Notably, investments in Capacity and Wildfire are projected to increase significantly in 2026 and 2027, with Capacity investments continuing to rise and approaching nearly $300 million by 2029. In 2026, spending on wildfire will exceed that on capacity investment!

MN_Xcel_Cap_Budget_Breakdown

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In Texas, discussions continue regarding the integration of large loads into the electrical grid. In a presentation on September 24th, ERCOT highlighted large load growth in relation to the emerging system risks and the continuing expansion of its renewable fleet.

One significant risk associated with large loads is rapid demand fluctuations, which can lead to issues with voltage ride-through. The following visual illustrates a load that experienced rapid fluctuations of 25 megawatts (MW) “peak to peak” before decreasing from 350 MW to 0 MW in just 24.3 seconds. “ERCOT is concerned that AI data centers may exhibit similar oscillations.”

ERCOT_System_Fluctuations

An ERCOT presentation wouldn’t be complete without some astonishing load forecasts. The following displays ERCOT’s “Adjusted” load forecast, along with breakdowns by type. In the background, shown in gray, is the much larger load forecast provided by the Transmission Service Providers (the utilities), which include MWs that may not actually be realized. This is a concern that the Public Utility Commission of Texas and ERCOT are seeking to address, as highlighted in last week’s WHiE.

ERCOT_Adjusted_Load_Forecast_by_Type

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In Wisconsin, the Public Service Commission has filed a memorandum regarding the application from Northern States Power Company-Wisconsin to acquire and construct the Elk Creek utility-scale solar and battery project. The memorandum invites public comments until October 7, 2025. The total acquisition cost is projected to be $656.7 million, excluding an additional $68.5 million in allowance for funds during construction. The estimate is based on a cost of $1,817 per kW for the 300 MW solar facility and $1,456 per kW for the 4-hour 76.6 MW BESS. The Commission’s memorandum determined that these capital costs are reasonable when compared to similar projects from past dockets.

WI_Elk_Creek_Solar_BESS_Comps

Check out the filing below.

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In South Carolina, Charles River Associates (CRA) filed its post-solicitation report regarding Duke Energy’s 2024 Solar and Solar Paired-with-Storage Procurement Program request for proposals.

Duke Energy ultimately solicited bids and procured resources through two tracks. The first track, the Utility Ownership Track, accounted for 64% of the portfolio (967 MW), while the second track comprised the remaining 36% through Power Purchase Agreements (PPA). Notably, there was a significant drop in proposals between the initial submissions and those remaining at the end of Step 1. This decline was attributed to uncertainties surrounding tax credit policies and tariffs. To mitigate this uncertainty, CRA made the following recommendations:

“To address potential federal law changes affecting solar or energy storage tax credits occurring between bid close and the bid refresh date during Step 2 of the 2025 RFP, a limited upward bid price refresh opportunity may become available. This mechanism is designed to discourage inflated initial bids (since it is not certain it will be used), reduce the risk of proposal withdrawals, and address uncertainty surrounding tax credit implementation and potential federal tariff changes. Recognizing that PPA proposals are particularly sensitive to shifts in tax credit policy, the 2025 RFP will also include PPA renegotiation provisions with clearly defined triggering events for mutually agreed price adjustments. These provisions aim to maintain project viability after contract execution, enabling projects to move forward under materially different policy conditions. Renegotiation opportunities can also protect customers from cost increases driven by suppliers hedging against tax credit or tariff risks in their proposals.”

The filing included charts that compared the originally submitted projects (see page 19) with those remaining at the end of Step 1 (see page 22). The first chart focuses on solar standalone projects that were initially submitted.

SC_Duke_RFP_Solar_Only_Submitted

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In West Virginia, the Committee from the Gas and Oil Association of West Virginia expressed concerns regarding Hope Gas’s ongoing base rate case and its application to fund its 2025 Pipeline Replacement and Expansion Program (PREP). The conventional natural gas producers worry that the funds, most of which will be raised through charges to producers, could harm industry competitiveness.

WV_Hope_Gas_PIC_Comments_1

WV_Hope_Gas_PIC_Comments_2

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In Arizona, Arizona Public Service (APS) recently shared mid-year updates on its Transportation Electrification Implementation Plan. Two charts illustrate a compelling trend: APS’s service territory is a significant and growing source of electric vehicle (EV) adoption in the state.

According to the Electric Power Research Institute (EPRI), 45% of Arizona's 157,000 EVs are located in APS’s territory.

AZ_APS_EVs_Operational

E3 predicts that by 2045, there will be over 1,000,000 EVs in operation within the APS territory according to the core scenario. In the high scenario, this number is expected to exceed 2.5 million EVs during the same period!

AZ_APS_EV_Forecast

The materials were shared during the recent Demand Side Management (DSM) and Transportation Electrification (TE) Collaborative meeting — materials below.

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In Missouri, Evergy Missouri Metro and Evergy Missouri West are seeking approval of new and modified tariffs for large load customers.

Evergy has submitted a table detailing the changes to its Large Load Power Service (LLPS) tariff in testimony supporting a settlement reached among Ameren, Google, the Data Center Coalition, Renew Missouri, Velvet Tech Services, Nucor Steel Sedalia, and the Sierra Club. Notably, the non-unanimous agreement did not include the Missouri Public Service Commission, which raised objections to the stipulation and agreement.

MO_Evergy_LLPS_Changes_1

(To view the continuation of the three-page table, see the document, page 13.)

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In California, the CPUC has approved Southern California Edison’s 2023 petition to raise the maximum prudent cost of the Eldorado–Lugo–Mohave Series Capacitor from $239 million to $295 million. This increase is partly due to the inflexibility of approving bodies and their extended timelines (as well as supply chain and weather-related cost increases, and schedule delays pushing completion).

CA_SCE_Capacitor

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In New England, ISO New England’s Evolving Grid presentation highlights the significant changes in the network interconnection queue over the past eight years. In June 2015, natural gas-fired capacity made up 48% of the queue; by April 2025, that percentage dropped to less than 1%. It’s worth considering the impact that batteries have had during this same period.

ISONE_GenerationInterconnectionQueue

ISO-NE anticipates a return to an increase in net energy demand. The expected annual net energy use over the next decade is projected to rise by 11.4%, although it will still remain below the peak experienced in 2005 due to the impacts of behind-the-meter solar PV and energy efficiency measures.

ISONE_GrowthInEnergyUse

The 10-year forecast for summer and winter peak demand, including components such as electric vehicles (EVs), heat, behind the meter photovoltaic (BTM PV), presents new challenges.

ISONE_10-YrForecast