2022-00152

Docket No. 2022-00152 before the Maine Public Utilities Commission concerns Central Maine Power Company's (CMP) request for approval of a distribution rate increase and associated rate design changes. The proceeding addresses several key areas:

- Sales Forecast: CMP predicts incremental increases in MWh sales through 2026, using an econometric model adjusted for load reductions from net energy billing and efficiency programs, as well as increases from electrification 1.
- Rate Design Changes: CMP proposes updated time-of-use (TOU) periods for various customer classes, re-design of residential TOU rates, elimination of certain legacy rate options, and expanded eligibility for beneficial electrification rates. The docket also considers broader availability of specific rates for electric vehicle (EV) charging and heat pumps, building on outcomes from prior dockets 1, 2.
- Stakeholder Participation: The docket involved multiple parties, including the Office of the Public Advocate, Efficiency Maine Trust, Governor’s Energy Office, and others. There were settlement discussions and technical conferences to review interventions and procedural matters 3, 4, 5.
- Advanced Rate Design: CMP expressed willingness to collaborate with interested parties on developing advanced rate design proposals and indicated openness to separate proceedings for further rate design innovation, such as non-firm customer rates 6.

Overall, this docket is a comprehensive review and update of CMP’s distribution rates and rate structures, with a focus on accommodating new technologies, electrification, and evolving customer needs.

The docket identifies several key areas of growth for Maine’s electric utilities, particularly Central Maine Power (CMP) and Versant. The main areas of growth and their associated considerations are:

1. Electric Vehicle (EV) Adoption and Electrification
- Growth: Increased EV adoption and broader electrification of transportation and heating.
- Key considerations:
- Advanced EV load forecasting is needed to assess impacts at the system and feeder level, accounting for rate structures, incentives, and control capabilities.
- Establishing a dedicated electrification team is recommended to own results and act as subject matter experts.
- Development and publication of electrification hosting capacity maps can help guide siting of high-capacity EV charging infrastructure and minimize upgrade costs.
- Continued reliability improvements are critical, as reliability concerns are a key barrier to EV and electrification programs.
- Expansion of EV pilot projects will help identify challenges and benefits specific to Maine, build stakeholder relationships, and improve public understanding 1.

2. Distributed Energy Resources (DERs) Integration
- Growth: Significant increases in DER penetration, including both renewable generation and storage.
- Key considerations:
- Improved communication, information availability, and consistency regarding DER interconnections, especially hosting capacity information.
- Publishing hosting capacity maps to inform stakeholders and developers about optimal locations for DER development.
- More visibility into distribution circuits and active resource management are required for successful DER integration.
- Making DERs dispatchable through aggregation, price signals, or automation is recommended for long-term integration 1, 1.
- Utilities should avoid simply overbuilding infrastructure and instead focus on targeted solutions for cost-effectiveness and flexibility 1.

3. Grid Modernization and Reliability/Resiliency
- Growth: Ongoing upgrades to create a modern grid that is reliable, resilient, flexible, and affordable.
- Key considerations:
- Stakeholder concerns focus on reliability, resiliency, and cost-effectiveness of grid improvements.
- Communication with ratepayers about improvement plans and cost-effectiveness is important to maintain trust and support technology adoption.
- Modern grid elements defined by the DOE (reliable, resilient, secure, affordable, flexible, sustainable) serve as guiding principles for evaluating growth and improvement opportunities 1, 1.

4. Energy Storage (specifically Battery Energy Storage Systems, BESS)
- Growth: CMP is piloting battery projects (Trap Corner microgrid and Woolwich peak shaving) to enhance reliability, defer infrastructure, and increase DER hosting capacity.
- Key considerations:
- These pilots aim to demonstrate how storage can optimize DER integration and improve resiliency but raise legal questions regarding utility ownership of generation assets.
- The benefit-cost analysis and demonstrated reliability need for these pilots remain under scrutiny by staff 2, 3.

In summary, the docket highlights growth in EV adoption/electrification, DER integration, grid modernization, and energy storage. The key considerations for each area revolve around forecasting and planning, stakeholder engagement and information transparency, targeted reliability/resiliency improvements, regulatory compliance, and careful assessment of costs and benefits.

The financial and timeline risks and concerns discussed in the docket for Central Maine Power Company’s (CMP) rate case (Docket No. 2022-00152) include:

Financial Risks and Concerns:
- The staff expressed concerns about the overall level of capital spending proposed by CMP and about pre-approving three years of rate increases without sufficient guardrails to ensure customers receive benefits from the increased spending. The staff requested quantitative reliability and customer service metrics, as well as quantifiable means to verify that CMP spends increased revenue in the proposed areas and on projects that maximize customer value. The staff also opposed the company’s requested capital adjustment mechanisms 1.
- There is a risk that if the multi-year rate plan is implemented without appropriate complementary elements, it may not incentivize cost containment, reliability, or innovation, and could have negative effects on ratepayers. The implementation of only part of a multi-year rate plan (MRP), without key complementary elements, may undermine its effectiveness 2.
- The Office of the Public Advocate (OPA) opposed the multi-year rate plan, advocating instead for calculation of the revenue requirement using a historical growth rate for plant additions, rather than CMP’s capital investment plan. The OPA also opposed the proposed capital adjustment mechanisms 1.
- Mechanisms such as capital trackers and reconciliation processes, which are sometimes used to address financial risk, can add administrative complexity and may not always be accepted by the commission 3.

Timeline Risks and Concerns:
- CMP indicated that to implement time-of-use pricing for supply rates by January 2024, they would need commission guidance as much as 15 months in advance. This highlights concerns about the feasibility of meeting regulatory deadlines and the need for timely commission orders to enable proper implementation 4.
- If guidance or orders are delayed, it may not be possible to implement new rate designs or pricing changes within the desired timeline, causing further delays in achieving regulatory or policy objectives 4.

In summary, key risks discussed in the docket relate to approving large capital investments without sufficient oversight, the need for clear metrics and verification on spending, potential negative effects of partial implementation of multi-year rate plans, administrative complexity from financial mechanisms, and potential timeline delays due to the need for advance regulatory guidance 4, 2, 3, 1.

Stakeholders in this Central Maine Power rate case (docket 2022-00152) include:

- Central Maine Power Company and its representatives
- Efficiency Maine Trust
- Competitive Energy Services (CES)
- Maine Renewable Energy Association (MREA)
- Coalition for Community Solar Access (CCSA)
- Conservation Law Foundation
- Industrial Energy Consumers Group (IECG)
- Governor’s Energy Office
- Office of the Public Advocate (OPA)
- Walmart, Inc.
- AARP
- Acadia Center

These stakeholders' representatives are explicitly listed in technical conference appearances 1, 2. Stakeholder engagement is also discussed as an ongoing process, with a history of involvement from these groups in similar dockets and in relation to proposals such as energy storage and rate design changes 1, 1, 3.

Positions for or against specific proposals vary and are not always unanimous:

- Some stakeholders, including Efficiency Maine Trust and CES, have provided feedback leading to the withdrawal or modification of certain battery storage proposals, preferring alternative solutions like rate design over direct battery investments 3.
- There is general concern among many stakeholders about high electric rates, skepticism about the value of further utility investments, and a desire for utilities to consider alternative strategies rather than relying exclusively on familiar methods 4, 4.
- In rate design, several stakeholders and the commission have previously opposed increases in residential service charges and have questioned whether the costs of new TOU (Time-of-Use) and demand charge proposals are sufficiently justified compared to their benefits 5, 5.
- Stakeholders have called for advanced rate design proceedings, consideration of net load in TOU period selection, and harmonization of new programs with existing Efficiency Maine efforts 5, 5, 6.

Positions are not always clear-cut or static, as stakeholder engagement is ongoing, and feedback is incorporated into evolving proposals. No single proposal has unanimous support or opposition among all stakeholders 4, 4.

Timeline of key events and submissions in the Central Maine Power (CMP) rate case proceeding (Docket No. 2022-00152):

- May 26, 2022: CMP filed a notice of intent to file for an increase in distribution rates, identifying a proposed rate effective date of July 30, 2023 1, 2.
- June 27, 2022: Industrial Energy Consumer Group (IECG) filed a petition to intervene 2.
- August 5, 2022: Commission issued a notice of proceeding and opportunity to intervene, stating CMP's intent for a three-year rate plan and specifying deadlines for intervention 1.
- September 2, 2022: Deadline for intervention requests in the docket 3.
- September 15, 2022: Deadline for data requests on initial testimony 3.
- October 14, 2022: Deadline for data responses on initial testimony 3.
- November 1–10, 2022: Technical conferences scheduled for witness questioning on initial testimony 3, 4.
- January 5–13, 2023: Technical conferences on intervenor testimony and staff bench analysis 3.
- March 7–16, 2023: Technical conferences on rebuttal testimony and surrebuttal testimony; reply bench analysis scheduled 3.
- May 3–4, 2023: Additional technical conferences scheduled for witness cross-examination and questioning 5.
- June 6, 2023: Commission approved stipulation in the case, setting the stage for a follow-on proceeding on rate design issues 6.
- July 5–7, 2023: Notices and letters issued to commence the follow-on rate design proceeding as agreed in the stipulation 6, 7.
- August 1–8, 2023: Interventions by generator customers, including ReEnergy, granted for participation in the follow-on proceeding, with CMP to schedule initial stakeholder discussions 8.

Additional scheduled steps included the filing of a final proposal from CMP resulting from the collaborative follow-on proceeding, expected on or about December 1, 2023 7.