Clean Energy-Related Formal Case Summaries

Working to meet aggressive climate goals
 
The Clean Energy Omnibus Amendment Act of 2018 included several goals and mandates that the DCPSC must fulfill. Listed below are summaries of Formal Cases before the Commission that are integral in addressing these goals and mandates, as well helping to achieve the District’s climate goals.
 
Formal Case No. 1017, RM41 — The Procurement of Renewable Energy through a long-term PPA for a Percentage of Standard Offer Service Load
Formal Case No. 1017
RM41

The DCPSC initiated a pilot project to procure renewable energy through a long-term power purchase agreement (“PPA”) for electricity for a target quantity of 5% of Standard Offer Service (SOS) load for delivery by June 1, 2024. Adopting a long-term PPA will help construct a new, large renewable generation facility (wind or solar) in the D.C. region that advances the District towards our clean energy goals. As of January 2021, Pepco, as the SOS Administrator, received bids in response to the PPA RFP. The Commission hired and independent evaluator to assure a just and reasonable bidding process and expects to issue a decision on approval of the contract in the near future.
 
Formal Case No. 1115, 1154 — Accelerated Pipeline Replacement (PROJECTpipes)
Formal Case No. 1115
Formal Case No. 1154

The DCPSC approved the first phase of a 40-year accelerated pipeline replacement program from Washington Gas (WGL) in August 2014 to modernize the 1,200-mile natural gas distribution system in the District and enhance overall system resiliency, reliability and safety for nearly 165,000 gas customers. This accelerated replacement program also helps the District meet its climate goals by reducing potential leaks and methane gas emissions on the distribution system. The Commission also approved a 3-year Phase 2 plan in December 2020 that allows WGL to advance six distribution replacement programs. Use WGL’s online activity map for PROJECTpipes work schedule info by ward and address.
 
Formal Case No. 1130 — Investigation into Modernizing the Energy Delivery System for Increased Sustainability
Formal Case No. 1130

The DCPSC opened a proceeding on June 12, 2015, to identify technologies and policies to modernize and improve the sustainability of the District’s energy delivery system. Under this proceeding, the Modernizing the Energy Delivery System for Increased Sustainability (MEDSIS) working groups were established in August 2018 and were comprised of industry stakeholders to form recommendations. The working group culminated in a final report in May 2019 with 32 recommendations and 10 learnings aimed to support the District’s grid modernization efforts. The Commission adopted, with modifications, several recommendations of the working group including, but not limited to:
  1. A Distribution System Planning (“DSP”) and Non-Wires Alternative (“NWA”) Process
  2. The creation of a secure web portal for data-sharing by Pepco and WGL
  3. The establishment of a rate design working group to propose best practices and develop residential dynamic pricing programs, and for Pepco to develop and file a pilot residential time- of- use rate proposal
  4. A new microgrids proceeding
  5. The establishment of a Pilot Projects Governance Board to review innovative ideas and recommend pilots with a clean grid in mind.
The DCPSC approved Pepco’s DSP and NWA Process, which includes Pepco’s roll-out of the District’s first Non-Wires Alternative RFP process to defer the need for a fifth transformer and instead develop and build behind-the-meter or in-front-of-the-meter projects comprising up to 9MW of electric power capacity. In response to a recommendation of the Pilot Projects Governance Board, the DCPSC moved forward with a value of distributed energy resources (DER) study to determine the most efficient and effective ways of accounting for DER in decision making. The Pilot Projects Governance Board also received submissions to a call for papers on topics ranging from battery storage and microgrids to sewer heat and smart inverters. 
 
Formal Case No. 1142 — WGL/Alta Gas Merger Commitment: Energy Efficiency program for low- and limited-income residents of multifamily housing
Formal Case No. 1142

WGL informed the DCPSC in February 2019 that Vermont Energy Investment Corporation was selected to run its energy efficiency program in compliance with the merger commitment. The Commission approved the Energy Efficiency Program Plan for Low and Limited-Income District of Columbia Residents in Affordable Multifamily Housing proposed by WGL in November 2019. WGL was directed to file quarterly reports detailing the implementation of the Term No. 3 Plan.  According to WGL’s most recent report, as of the end of calendar year 2020, 22 projects had been completed since the program was implemented.
 
Formal Case No. 1148 — Pepco/Exelon Merger Commitment: Energy Efficiency and Energy Conservation Program
Formal Case No. 1148

As part of the DCPSC’s efforts to reduce greenhouse gas emissions and help fight climate change in the District, the Commission has advanced a Whole Building Deep Energy Retrofit Program which is an energy efficiency and energy conservation program that assists affordable multifamily building owners with energy efficiency retrofit financing and helps them identify other energy programs that could minimize their buildings’ energy usage. More than $11 million has been allocated to fund this program which would allow building owners to replace lights with more efficient LEDs, upgrade to efficient HVAC systems, and, in some cases, even install rooftop solar panels.  
 
The Clean Energy Act established new minimum Building Energy Performance Standards (BEPS) for owners of private buildings in the District. By ensuring that affordable multifamily building owners have access to resources to comply with the BEPS, the Deep Energy Retrofit program will help achieve the District’s climate policy commitments. The Deep Energy Retrofit program also supports the Clean Energy DC plan goal to make equity and affordability central considerations when implementing climate policies. Clean and efficient household systems are not only good for the planet, but also for the families living in these buildings who otherwise face lower air quality at home and higher utility expenses. 
 
Formal Case No. 1156 — Electric Utility Multiyear Rate Plan
Formal Case No. 1156

Pepco filed a Multi-Year Rate Plan (MRP) Application in May 2019 for approval to increase rates for its electric distribution service in the District. Traditional cost of service rate cases generally reviews costs and investments through a historical approach or partially forecasted test year (which provides for six months historical data and six months of forecasted data). Under this ratemaking paradigm, Pepco has been filing rate cases approximately every two years to recover the costs of their investments in the electric distribution system. The expenses they incurred in litigating each rate case cost ratepayers an average of $3 million each. The DCPSC has long recognized that other forms of regulation may help the District’s meet its aggressive goals regarding greenhouse gas emission reductions, transportation electrification, renewable energy development, grid modernization, and others.
 
With the Commission’s grid modernization efforts solidly off the ground in mid-2017, the Commission indicated that it would allow Pepco to include in its next rate case a request for a fully forecasted test year and/or a multiyear rate proposal. The Commission recognized in its decision that the District is in a period of growth and change, with increasing distributed energy resource (DER) deployment. Future rate design questions will need to complement the city’s development of appropriate mechanisms to help us to achieve the goals outline in PowerPath DC

The Commission has authority to consider alternative forms of regulation (“AFORs”) under D.C. Code § 34-1504 (d) if the AFOR protects consumers, ensures quality, availability and reliability of regulated services, and is in the public interest of ratepayers and shareholders. In furtherance of the District’s clean energy goals and the Commission’s PowerPath DC objectives, the Commission established the framework for AFORs in the District in December 2019 to explore new tools to achieve those objectives, while also preserving a high standard of energy delivery system reliability and fostering grid modernization.
 
The Commission is expected to render a decision on Pepco’s MRP soon.
 
Formal Case No. 1160 — Development of Metrics for Energy Efficiency and Demand Response Programs
Formal Case No. 1160

The DCPSC established a working group to develop long-term energy saving metrics, performance indicators, and cost-effectiveness standards. These standards will become embedded in the decision-making process for electric and gas energy efficiency programs and demand response programs. The Commission adopted recommendations from the working group in October 2020 that established metrics for electric energy efficiency programs. The Commission also directed Pepco and WGL to open a solicitation for a contractor to complete an Energy Efficiency Demand Response (EEDR) Potential Study. The Commission also directed  the EEDR working group to reconvene to consider unresolved issues such as the governance structure to coordinate the planning, delivery, reporting, and evaluation of EEDR programs administered by the utilities including cost allocation and recovery, filing requirements, income verification, data sharing, and additional reporting requirements, if any, and the design and recommended list of EEDR PIMs. The working group’s report is due by April 28, 2021. 
 
Formal Case No. 1167 — Implementation of Electric and Natural Gas Climate Change Proposals
Formal Case No. 1167

To ensure the District’s utility companies are considering the effects of climate change in their business decisions, the DCPSC opened this case to review any new proposals filed by the Commission’s regulated utility or energy companies for Commission approval to implement the District of Columbia’s climate business plans.
 
RM 9-2020-03 — Net Energy Metering
RM 9-2020-03

The DCPSC increased the threshold for Net Energy Metering (NEM) systems beyond the 100% of customer usage originally in the rules to further promote the development of renewable energy facilities. Renewable energy generators may now increase production by 20% per year, culminating in a threshold of 200% in 2024. This means that customers will eventually be able to export to the grid an amount equivalent to 100% of their native usage. The Commission also took several steps to increase the use of CREFs, including eliminating the requirement that they be directly connected to the electric distribution system. This could eventually facilitate the implementation of a “virtual” CREF and increase renewable energy production in the District.
 
RM 29-2020-02 — Renewable Energy Portfolio Standard Rules
RM 29-2020-02

The DCPSC adopted final revisions to its Renewable Energy Portfolio Standard rules (15 DCMR §2900, et. seq.) in January 2020 to conform with certain provisions of the Clean Energy Act. The Commission has been working to make the certification of renewable energy facilities easier, including by streamlining the RPS application process as well as making filing and processing RPS applications faster by developing an online application system. The District has more than 7,900 solar facilities comprising nearly 118 MW of power as of December 31, 2020.
 
RM 40-2020-01/Formal Case No. 1050 — District of Columbia Small Generator Interconnection Rules
RM 40-2020-01
Formal Case No. 1050

The Council of DC passed the Community Renewable Energy Amendment Act in 2013 which created Community Renewable Energy Facilities, or CREFs. CREFs allow those not able to put solar panels on their own roofs to participate in renewable project sponsored by someone else, often a community organization or church. The District has 137 CREFs registered for RPS that comprise over 13 MW of power as of Dec. 31, 2020.  The Commission has also proposed changes to its rules to address system upgrade costs related to the interconnection of community renewable energy facilities, small generator interconnection timelines, and small generator interconnection costs, as well as incorporate a definition of Advanced Inverter. The Commission expects to finalize these rules soon. The Commission also issued a rulemaking that would address system upgrade costs related to the interconnection of CREFs.
 
GD 2019-04 — Implementation of the 2019 Clean Energy DC Omnibus Act Compliance Requirements
GD 2019-04

The DCPSC opened this docket in 2019 to develop a framework of accounting for the effects on global climate change and the District’s clean energy commitments when reviewing utility proposals. This effort includes discussion on whether to implement greenhouse gas (GHG) emissions reporting requirements, metrics for GHG reduction, and carbon footprint metrics. This undertaking relies on working groups comprise of more than 35 participants, including the Sierra Club, the Environmental Defense Fund, DC SUN, Washington Gas, Pepco, the D.C. Department of Energy & Environment, and Office of the People’s Counsel. The Commission hosted two technical conferences before re-designating the conferences as working group meetings. The working group, which is divided into three committees (Benefit-Cost Analysis Framework, Metrics, and Reporting), meets regularly, focusing primarily on BCA frameworks and metrics. The group has approved a work plan setting April 2021 as the date of the final working group report that will outline all findings and recommendations to the Commission.