5.5 ERMUSR 04-12-2011Elk River ^~-~
Municipal Utilities
13069 Orono Parkway • P.O. Box 430
Elk River, MN 55330-0430
UTILITIES COMMISSION MEETING
Phone: 763.441.2020
Pax: 763.441.8099
TO: FROM:
Elk River Municipal Utilities Commission Troy Adams, P.E. -Director of Operations
John Dietz, Chair
Daryl Thompson, Vice Chair
Al Nadeau, Trustee
MEETING DATE: AGENDA ITEM NUMBER:
A ril 12, 2011 5.5
SUBJECT:
2011 Minnesota Munici al Utilities Association Le islative Rall
DISCUSSION:
The MMUA Legislative Rally was held March 30`h -April 1 a`. The conference covered many timely
topics including: Transmission cost allocation, Utility performance indicators, Conservation Improvement
Program (CIP) tracking and reporting, Local Government Aid (LGA), and Legislative hot topics relating
to municipal utilities. The presenters included William Grant-Deputy Commissioner of the Dept. of
Commerce Energy Division, Gary Carlson -Director of Intergovernmental Relations with the League of
Minnesota Cities, and Joe Plummer from the Minnesota Office of Energy Security. Overall, the
conference portion of the rally provided a forum for much "round table" discussion amongst the utility
managers and commissioners in attendance.
The most important part of this rally is the unification of municipal utilities presenting positions on key
topics to our elected officials at the State Capitol. This year we spoke to our elected leadership about
three topics: CIP, evasion of water conservation rates, and coal and nuclear ban repeal. I was asked to be
a presenter for the evasion of water conservation rates topic.
The tone from the elected officials was that the current priority was the budget. Generally speaking, if it
didn't create non-government jobs or lower taxes then it wasn't a top priority. The legislators were
supportive of the municipal utilities' position statements because they are typically about providing
reliable services and lower costs. Overall, we were well received and it was a productive legislative rally.
Attached for your review are the 2011 MMUA State Position Statements.
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ACTION REQUESTED:
No action required.
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Table of Contents
Why Public Power? ........................................ 3
Conservation Improvement ..................4-5
Evasion of Water Rates ................................. 6
Coal and Nuclear Ban Repeat .................... 7
WAPA and RES ................................................ 8
The Cost of Clean Water .............................. 9
Service Territory .....................................10-11
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Why Public Power?
One hundred twenty-five Minnesota cities benefit from
having a locally owned and locally operated municipal
electric utility. Thirty-one cities have a municipal
natural gas system. Fifty of our eighty-seven county
seats are served by a municipal electric or gas system.
A not-for-profit municipal electric or gas utility is a
tremendous asset in these uncertain times. Here are
some of the reasons why:
• We have great service. We're part of the community
and our policy makers, managers and workers are part
of the community. Our crews are always on hand in
the event of emergency. You don't need to call an 800
number to talk to us.
• We're not in it for the money. Municipal utilities
are not-for-profit and operated in the public interest.
Our goal is long-term community benefit, not short-term
gain. We work hard to save you money.
• We're the yardstick for the industry. For
generations, public power systems have set standards
for rates and service that other utilities have had to
meet.
• We'll be there. Many of Minnesota's municipal
electric utilities have served their communities for more
than a hundred years. In an era when new competitors
come and go faster that we can learn their names, you
can count on ue. We will be there when you need us.
• We're locally regulated. Members of the community
who live in the community set rates and service • We're Public Power.
practices. If you have a problem, you know who to talk We're here for you!
to.
• We're owned by our customers. There is no tension
between the interests of customers and the interests of
stockholders. Our focus is Main Street, not Wall Street.
We work for you.
2011 State Position Statements / 3
photo courtesy afthe Ouwtarsrsa Peaplei Prers
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Conservation Improvement
Background
Minnesota's municipal utilities
support energy conservation. The
wise use of energy is in keeping with
the main goal of our electric and gas
services - to provide good service
at a reasonable price. Helping
customers improve their efficiency
helps the environment, helps the
utility defer the need to invest
in generating facilities and helps
consumers manage their energy
bills. Toward that end, Minnesota e
municipal utilities currently spend
about $12 million per year on
conservation improvement programs
(CIP).
Municipal utilities were early
leaders in developing programs to
manage and control customers' peak.
Many municipal utilities have been
operating energy efficiency programs
for 20 years or more. Many others have become
increasingly engaged in developing and implementing
conservation programs. Municipal utilities' support for
energy conservation has been demonstrated by their
continuing efforts to meet state energy conservation
mandates, which have been evolving over the course of
the last 20 years
The legal state mandate for CIP began in 1993, when
Minnesota law required municipal electric utilities to
spend 1% of their gross revenues on CIP programs.
In 2001 the Minnesota State Legislature expanded
municipal involvement in these programs by increasing
CIP spending on electric operations to 1.5% of gross
revenues, while gradually reducing the amount of
spending on load management that could be used to
meet municipal CIP spending requirements.
In 2007, the Minnesota legislature changed the
statewide CIP goal from a spending requirement to a
1.5% annual energy savings goal. The new requirement
is very difficult to meet and may be virtually impossible
to meet for some small systems with little load growth.
In order to meet or even approach the goal, a utility
must spend substantially more than the 1.5°~ of revenue
required prior to 2007. Some utilities have picked all the
low-hanging fruit and are finding it incmasingly
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Position Statement
difficult to maintain cost-effective conservation
programs.
Legislative Action
Proposals are being discussed in both houses of the
Minnesota legislature that could alter the current State-
mandated CIP program.
MMUA Position
Minnesota's municipal utilities are serious about
conservation, but we are also serious about spending our
ratepayers' dollars wisely and about not raising rates
to pay for CIP efforts that are not tailored to the needs
of many of our utilities. We have detailed a number of
concerns.
Not Sustainable -The Conservation Improvement
Program in its current form ie not sustainable over
the long term. The legislative intent was to compel
cost-effective measures, but the coat-effectiveness of
measures going into the future will decline quickly.
The legislature should consider ways to clarify the coat-
effectiveneas provisions of the statute.
Legitimate Saviags -The current program does not
recognize much of the legitimate energy savings that do
or could occur from utility efforts.
Energy savings from adopting certain technologies will
4 / 2011 State Position Statements
Position Statement
accrue over the period of time that the measure is in
use. But the CIP law recognizes the energy savings of a
given measure only in the year in which it is installed or
adopted. For measures with useful lives of more than
one year, the energy savings accruing during those years
should be recognized rather than ignored.
Current law provides a greater incentive for utilities
to create energy savings from measures affecting the
amount of energy consumed by the customer than from
measures that could be taken to prevent energy waste
from generation, transmission and distribution to the
customer's location. Savings such as these should be
valued and recognized right along with other types of
energy savings.
Energy audits identify potential energy savings. The
value of this step in the efficiency and conservation
process should not be underestimated and should
continue to be recognized under the savings program.
The use of shade trees to reduce the amount of air
conditioning used at a residential, commercial or
industrial electric customer can produce
quantifiable energy savings and should be
recognized in the program.
Educational efforts -Much of the
potential energy savings from utility efforts
could come from the changing behaviors
of customers. Utilities cannot make those
changes happen without communicating
the benefits of making energy-conscious decisions to
customers. These educational efforts are some of the
moat effective means of creating energy savings, but
they are the hardest to quantify in terms of how much
energy savings ultimately result from them. If the CIP
program could better recognize these savings on paper,
the state would better realize the improvement in energy
consumption the program is actually creating and
promote more of the same.
Work Group - It may be possible to address some of the
CIP program's problems by tweaking certain aspects of
it. However, some of the deeper problems that prevent
the CIP program from realizing its true potential and
future suetainability require more comprehensive
reforms. Solutions may require regulatory or legislative
changes. With a clear focus on fixing those limitations
outlined above, a working group of people from the
utility industry could determine what those solutions
might be.
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2011 State Position Statements / 5
Position Statement
Evasion of Water Conservation Rates
Background
In 2008 the Minnesota Legislature passed a bill
requiring water utilities serving more than 1,000 people
to implement conservation rates. The "conservation rate
structure" is defined ae "a rate structure that encourages
conservation and may include increasing block rates,
seasonal rates, time of use rates, individualized goal
rates, or excess use rates." Minn. Stat. §103G.291 Subd.
4(a). In many cases, cities will use a tiered water rate
structure that makes water use increasingly expensive
ae customers use more of it. The intent of this legislation
was to cause the biggest users to curtail their use of
water.
As a result of the effort by cities to implement this
mandate, water costa for large users have been driven
higher by the state-mandated water conservation rates.
Private well-drillers, which have increasingly been
seeking business within city limits as development
of housing outside of city service areas has dwindled
over recent years, are using the implementation of
conservation rates to convince large water uaera to get
free water by sinking their own wells.
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or restrict the operation of private wells within
the urban service area. The two state agencies that
regulate wells-the departments of Health and Natural
Resources-have indicated that they do not have
adequate authority under existing statutes (Chapters
103G, 103H and 103I) to fully consider the impacts
associated with a new well on the public water system.
Allowing large uaera to circumvent the conservation rate
by drilling their own wells defeats the purpose of the
law. And those uaera that are large enough to consider
drilling their own wells are precisely the users that the
law was intended to impact. With price signals removed,
the well owner has no incentive to use water wisely.
Not only is this practice contrary to the intent of the law,
it has led to a serious strain on the financial viability of
some public water systems. If one or more large water
uaera suddenly atop paying, the capital debt and system
operations and maintenance expenses must be paid by
the remaining customers. In moat communities the loss
of a major water user would have a very serious impact
on the finances of the municipal water utility, potentially
requiring rate increases.
Private wells can also pose risks to drinking water
quality, and cause localized over-drafting of aquifers
and capture-zone interference, especially during drought
periods when high capacity irrigation wells would be
operated extensively. Public water systems need to be
able to protect the resources they draw upon to provide
water to their communities.
Cities have responded to these challenges by asserting
their authority under existing state law to prevent
Legislative Action
Legislation has been introduced that would exacerbate
this problem by rescinding the authority of city councils
to regulate private wells within city limits. HF 135,
(Rep. Tom Hackbarth, R-Cedar) along with its Senate
companion, SF 64, (Sen. Mike Jungbauer, R- Eaet
Bethel), limits city authority to only public wells, which
would allow property owners to construct and operate
their own wells to circumvent paying for public water.
The bill has had several hearings in the House.
MMUA Position
MMUA opposes HF135/SF64. If passed into law,
this legislation could lead to a serious strain on the
financial viability of public water systems and could
also result in large increases in essentially unregulated
water use through new private wells, affecting water
sustainability, wellhead protection, efficient operation
and security of the public water supply. Municipal
utilities have invested millions of dollars in sewer and
water extensions, and cost-sharing the sealing of private
wells to protect ground-water resources. MMUA strongly
opposes any legislation that compromises those efforts
and investments.
6 / 2011 State Position Statements
Position Statement
Coal and Nuclear Ban Repeal
Background
Electric utilities will need a full range of energy supply
options if they are to affordably and reliably meet the
needs of Minnesota's economy as it recovers from the
recent recession. Each electric generation technology
has advantages and disadvantages. The best approach
will be a balanced portfolio that avoids over-reliance on
a few resource options. Clean coal and nuclear power
may prove to be an important part of the resource mix
that will power Minnesota's economy into the next
generation.
One of the provisions of "The Next Generation Energy
Act," passed by the Minnesota Legislature in 2007,
effectively prevents Minnesota electric utilities from
constructing new coal-fired plants or importing
electricity from such plants in other states unless they
either reduce emissions of carbon dioxide (COZ) at a
different plant, or find some other way to compensate
for the increased COa emissions. The current language
for emissions and offsets severely limits the options
available to utility planners in meeting Minnesota's
future energy needs. As new technologies emerge,
we need to be able to consider all available options,
including clean coal technology.
Minnesota also has had a ban on new nuclear power
plants since 1994, when a moratorium on new nuclear
power plants was included in the legislative package
that provided authority for storing nuclear waste above
ground at the Prairie Island plant. Despite the severe
problems that have occurred at nuclear power plants in
Japan following the recent earthquake and tsunami, the
next generation of nuclear technology will be required to
be safe, reliable, and areasonably-priced source of power.
As new technologies emerge, we believe that it is unwise
to artificially circumscribe the range of options available
to utility planners. Each technology should be allowed
to compete for a place in our energy future. The best will
earn their place in our portfolio.
Legislative Action
HF 72 (Rep. Mike Beard, R-Shakopee) and SF 86
(Sen. Julie Rosen, RrFairmont), which would eliminate
the moratorium on new coal construction, has been
introduced and passed by committees in both houses.
Specifically, the bill would remove the coal prohibition
from the 2007 Next Generation Energy Act and allow
the importation of newer, cleaner and more efficient coal-
generated electric power and the replacement of older,
leas efficient electric generation facilities.
HF 9 (Rep. Joyce Peppin, R-Red Wing) and SF 4 (Sen.
Amy Koch, R-Buffalo), which would eliminate the
moratorium on the construction of new nucleaz power
plants, has been passed by committees in both houses
and is currently in conference committee. The Governor
has stated that he will not support the legislation unless
it contains provisions that protect future ratepayers
against up-front coats and later cost overruns, provide a
cleaz plan for radioactive waste storage, and prevent the
production of weapons grade plutonium.
We should also point out that removing the ban on new
coal or nuclear plants will not mean that the regulatory
skids will be greased for new projects using these fuel
sources. All of the existing regulatory mechanisms
that govern the development of new electric generation
resources will remain in effect. Power suppliers will still
have to develop integrated resource plans, and those
plane will have to demonstrate that any proposed project
is the leasbcost option. Proponents of a project will
still have to obtain a site permit and certificate of need.
MMUA Position
MMUA supports the passage of HF 72/SF 86, repealing
the ban on new coal-fired generation, and HF9 /SF4,
repealing the ban on new nuclear generation. Support
for this legislation should not be interpreted as a
retreat from our commitment to renewable energy and
conservation. Municipal utilities will need the ability to
use all energy options to protect Minnesota's economy
and quality of life.
2071 State Position Statements / 7
Eliminating the ban will not put new coal or nuclear
projects at an advantage over other technologies; it will
merely put them on an equal regulatory footing with
other technologies.
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WAPA and the RES
Background
The 2007 `Next Generation Act" established a renewable
energy standard (RES) that requires investor-owned
utilities, generation & transmission (G&T) cooperatives
and municipal power agencies
to produce electricity from
renewable resources in the
following percentages:
7 percent by 2010,
12 percent by 2012,
17 percent by 2016,
20 percent by 2020, and
25 percent by 2025.
The Minnesota Office of
Energy Security (OES) has
allowed the reduction of total
retail sales used to calculate
the RES requirement for
wholesale systems by the
amount of power sold directly
to distribution municipal
utilities by the Western Area
Power Administration (WAPA).
This reduction is based on the concept that hydropower
provided by WAPA already met the renewable
requirement and the power is sold separately, before the
agency provides supplemental power.
The Northern Municipal Power Agency (NMPA) is
comprised of ten Minnesota municipal utilities and
two North Dakota municipal utilitiee. Some years ago
NMPA entered into an agreement to pool resources
for rate making purposes with Minnkota Power
Cooperative, a G&T cooperative serving rural electric
cooperatives in both Minnesota and North Dakota. This
"Joint System" agreement provides that the municipal
utility members of NMPA and the cooperative members
of Minnkota also contribute their WAPA allocations
to the combined system pool of resources. Staff of the
OES has taken the position that the renewable energy
requirement of the joint system could not be reduced
by the amount of the WAPA allocation to its members
because the allocation was pooled.
This interpretation, which disallows the WAPA
allocation reduction because it was pooled, unfairly
penalizes one group of WAPA customers. Aggregated
WAPA allocations should carry the same weight in
Position Statement
establishing RES retail sales levels for a municipal
power agency or a G&T cooperative as allocations given
to individual distribution utility members.
Legislative Action
Bills have been introduced in both houses of the
Minnesota Legislature that clarify the RES law. HF 220
(Rep. David Hancock, R-Bemidji) and SF 113 (Sen. John
Carlson, R•Bemidji) allow wholesale power euppliers
to use aggregated WAPA allocations for the purpose of
establishing total retail sales under the RES mandate.
MMUA Position
MMUA supports the passage of HF 220/SF113.
The electricity allocation from WAPA, however it is
ultimately distributed, is still a renewable resource
originally allocated to municipal members of NMPA
and cooperative members of Minnkota, and should be
included in the process of establishing the retail sales
level for RES compliance.
8 / 2071 State Position Statements
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Position Statement
The Cost of Clean Water
Background
Despite the tremendous investment by local government,
the U.S. Environmental Protection Agency estimates
that there still is a $500 billion "needs gap" to meet
water and wastewater infrastructure needs and to
comply with current environmental mandates. This
is borne out by a recent report by the U.S. Conference
of Mayors, which states that cities are spending more
dollars on water and wastewater each year, but the
need for investment for sewer and water facilities far
outweigh local government's ability to keep up with an
aging infrastructure.
MMUA members, who have made very heavy
investments in sewer and water facilities over the years,
are experiencing first-hand the need for much greater
investment, particularly regarding the construction,
operation and maintenance of water and wastewater
treatment facilities. One of the greatest sources of these
coat increases comes from the expanding number of
regulations and the growing list of contaminants that
must be dealt with under state and federal law.
There is an economic component to the discussion of
this issue ae well. Expanded investment in water
and wastewater facilities is not only important for
public health, but has become an essential ingredient
for economic development. The heavy cost increases
for water and wastewater facility investment, if not
addressed, are sure to adversely impact the economic
viability of our Minnesota cities as well.
At present, there seems to be a lack of appreciation by
both state and federal legislators of the tremendous
burden that this situation has imposed on local
communities, which must bear moat of the burden
from the increased costa of new water and wastewater
treatment facilities. We believe that public policy
makers on all levels should be in a position to review
and understand the increase costs brought about by this
increased regulation.
Legislative Activity
HF 182 (1Zep. Mike Beard, R-Shakopee) and SF 196
(Sen. John Pederson, R-St. Cloud), would place atwo-
year moratorium on new water testing rules from the
Minnesota Pollution Control Agency and would require
several state agencies to conduct studies identifying
and analyzing the coat impact of rnlemaking related to
various types of water use. The bill also would require
agencies to report the results of these studies to the
environment committee of both houses by January 15,
2012.
MMUA Position
MMUA strongly favors a study, such as that called for
in HF 1S2/SF 196, which would chart historic costs of
conatruction,operation and maintenance for water and
wastewater treatment facilities. We envision a study
that would also establish a standard for comparing
costa based on plant output. MMUA also supports a
requirement that a specific agency in state government
be charged with keeping track of these coats on a go
forward basis and reporting the results of these studies
at the beginning of each biennial session.
It is not the intent of MMUA or its members to argue
for or against the inclusion of particular substances in
the list of contaminants established by State or Federal
authorities that must be removed from drinking water
or from wastewater. It is, rather, our intent that elected
and appointed policy makers be provided information
that will help focus attention on the dramatically
increasing costa of clean water, which will, hopefully
produce policy decisions that will address what has
become a quiet crisis in local government services.
2017 State Position Statements / 9
Position Statement
Service Territory
Background
Minnesota municipal electric utilities have had the
right to nerve their entire communities since they were
formed, many more than 100 years ago. Municipal
utilities grow with their cities for a number of reasons,
including:
• To treat all electric ratepayers and taxpayers in the
city equally.
• To preserve the financial stability and fiscal integrity
of the city's overall financial structure and credit ratings.
• To provide for greater efficiency of the city and
municipal utility through economies of scale.
• To facilitate intermediate and long range planning
for electric generation, transmission, and distribution
facilities-for the municipal utility and neighboring
utilities.
• To provide electric service to residents and users in the
city at terms and conditions subject to the control and
regulation of the city.
Cities grow because families and businesses want city
services. City services drive development. It is proper
that cities provide these services (including electric
service) throughout the city, including new areas ae
growth occurs.
Prior to 1974, there was no state regulation
of utilities in Minnesota. The regulation
that did exist was through the granting or
withholding of city franchises. Investor-
owned utilities wanted state regulation so
they could deal with one state entity rather
than each individual city. The cooperatives
wanted service territories to prove to their
banker-the federal Rural Electrification
Administration-that they would have
customers to pay for new power plants
and transmission lines. Municipal utilities
wanted only to preserve their existing right
to grow with the cities they serve. The
cooperatives testified in support of preserving
thin well-established right and practice.
The landmark service territory law of 1974 has allowed
Minnesota's electric cooperatives to protect their power
plant investments, to greatly expand their business,
and to secure generous compensation from municipal
acquisitions. The co-ops have attempted to use disputes
to derail the intent of the territory law by obstructing
the municipal electric utilities right to grow with their
cities.
The 19741aw has worked very well for the electric
cooperatives. Co-opa are growing faster than other
utilities. In fact, the co-opa' customer base has virtually
doubled since the enactment of the service territory law
in 1974.
Minnesota Public Utilities Commission decisions
concerning compensation for service territory acquired
by a municipal utility have increasingly resulted in
financial windfalls to co-ops. Cooperatives receive
reimbursement for facilities, payment for any
reintegration coats, and payment for lost revenue
from existing customers, along with compensation for
future customers not in existence at the time that the
municipal utility begins serving the area. Compensation
paid to cooperatives now amounts to more than $16
million.
A number of co-opa have pursued increasingly extreme
positions in negotiations, demanding ever higher levels
of compensation. Several cooperatives have forced
70 / 2011 State Position Statements
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Position Statement
municipals to `freeze' service territories, or resort to
lengthy, expensive action before the Minnesota Public
Utflitiea Commission or before the district courts.
There is growing evidence that this is a coordinated
attempt not only to obstruct municipal growth, but to
enable cooperative acquisition of municipal utilities.
We estimate that, over the peat few years, Minnesota
cooperatives received at least $2 million from the
"service territory integrity fund" of the National Rural
Cooperative Finance Corporation (CFC), a national fund
expressly created to prevent municipal utilities from
growing with their cities.
Efforts to Negotiate
Municipal electric utilities have made three recent
efforts to find a compromise with electric cooperatives
on the service territory issue-as part of discussions
concerning industry restructuring in 1998, an effort at
mediation in 2001 and a joint task force that met in the
Spring and Summer of 2008.
The moat recent attempt nearly bore fruit. The
two aides reached agreement on 18 of 20 issues
identified by MMUA, with only two minor issues
remaining. Unfortunately, the cooperatives suspended
the negotiations before complete agreement was
reached. Since the negotiations concluded, a number
of municipals and co-ope have entered into service
territory agreements that follow the "template" that was
developed through the negotiation process.
MMUA Position
Municipal utilities cannot forego the essential right to
grow with our cities, which has been recognized since the
inception of the industry more than one hundred years
ago. We remain willing to work with others to make
the law easier to administer for all parties, by adding a
formula, based on the 2008 negotiations, to state law Aa
custodians of our citizens' rights, cities and municipal
utilities insist that the right to grow with our cities
be affirmed. If necessary, this affirmation should be
established by legislative action.
2011 State Position Statements / 11
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