IRP Talking Points and Resources
CEDI's guest column in The Des Moines Register is a good place to start.
Why is IRP needed?
- Alliant rates are out of control, hurting customers and communities throughout Alliant territory. Integrated Resource Planning is one of the most important tools regulators need but do not have to get utility spending - and rates - under control.
- MidAmerican Energy rates are lower but still have been steadily rising for a decade in a process hidden from the Iowa Utility Board. IRP would allow regulators to also address those hidden fees, and whether Iowa ratepayers are unjustly subsidizing investor profits from the export of Iowa wind.
- The 2023 legislature ordered the Iowa Utilities Board to conduct a study on Iowa rate-making procedures. The final report of this study, conducted by London Economics International, recommended IRP as one of the most important reforms to Iowa ratemaking to assist regulators in ensuring ratepayers are getting affordable energy and a reliable grid.
- The foundation of IRP is “only pay for what you need." Right now without IRP, as the LEI study identified, regulators are not in a position to ensure Iowa ratepayers are actually only paying for what they need, rather than paying for unnecessary investments that only benefit the bottom line of investors/shareholders.
What are IRP key principles?
- IRP needs to be a process that sets the foundation for other rate-related dockets such as “advanced ratemaking principles” and regular rate dockets. As such, it needs to be mandatory and set on a regular 3-year cycle. Currently the House bill makes it an optional, discretionary, irregular process, which would be entirely ineffective.
- IRP needs to be comprehensive in scope, including all modeling/predictive capabilities of the utility for defining future needs, and all potential resource solutions at all levels - transmission, generation, and distribution system assets.
- The IRP dockets must maximize transparency and stakeholder engagement, because that is how ratepayers have a voice in the process.
Integrated Resource Planning Bills in the 2024 Session
Senate File 2244, introduced by Senator Klimesh, is a very strong bill that makes IRP comprehensive, participatory, and requires that it be conducted on a regular cycle. Key improvements should include clarifying that a full IRP docket is required every three years (including within one year of passage), and ensuring that the energy efficiency programs continue in parallel. The main message to Senators is to work with colleagues and leadership in support of SF 2244.
House File 2551 is a much broader energy bill that includes a short section on IRP. It needs improvement, as it currently leaves an IRP docket to the discretion of the IUB and only in certain circumstances. This would make it a relatively useless exercise if the goal is to help regulators ensure that ratepayers are only paying for what they need, because IRP needs to be the foundational process upon which all other rate regulation is built.
The main message to House members (and Senators too, if the House bill reaches them) is that for IRP to help utility customers and communities across Iowa, it must be a robust, foundational planning process as it is in virtually all states, and as explained in the London Economics report,
including:
- Comprehensive in scope – including all distribution, generation, and transmission assets and investments under consideration by a utility
- Transparent and participatory – conducted as a contested case allowing stakeholders and ratepayers (who are captive customers of the monopoly utilities) to be a part of the process
- Required to be completed on a regular, ideally 3 year cycle
IRP Resources
- The Final Report from the study docket, by London Economics International, including a strong recommendation for the establishment of Integrated Resource Planning in Iowa.
- London Economics International presentation of the study docket final report to the Senate Commerce Committee
- Video of CEDI’s energy lunch from February 6 on IRP, featuring Bob Rafferty of Iowa Business for Clean Energy
- The CEDI page on the rate-making study docket, which includes:
- First Round and Third Round of comments submitted by CEDI
- Study docket final report
Helpful websites and resources if you want to really dive in, or to share with policymakers who might want more information.
- National Association of Regulatory Utility Commissioners (good because it is the “official” professional group for IUB members, and serves state regulators everywhere)
- Task Force on Comprehensive Electricity Planning - NARUC
- Blueprint for State Action - report from the NARUC/NASEO Task Force on Comprehensive Electricity Planning
- Midwest Energy Efficiency Alliance IRP overview
- Rocky Mountain Institute excellent report, Reimagining Resource Planning
- Excellent IRP best practices from Synapse and RAP
- Excellent slide show from Berkeley Lab on distribution system planning, which has not traditionally been included in IRP but increasingly needs to be.
In each legislative session, energy policy may be addressed by elected Iowa officials. CEDI also follows the rulings of the Iowa Utilities Board, the three-person panel of appointed officials that “regulates utilities to ensure that reasonably priced, reliable, environmentally responsible, and safe utility services are available to all Iowans.”
CEDI provides background on relevant issues, publishes comments in news outlets and on this site, and may file comments or petition to intervene in formal policy dockets. CEDI activity and policy advocacy is nonpartisan.
