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Detailed Comments In re: Distributed Generation before the Iowa Utilities Board

Valuation, Analysis, BCA   
Iowa Utilities Board Docket No. NOI-2014-0001. Clean distributed generation ("DG") is the most exciting development in electric service and technology since the negawatt. It offers a host of advantages, but also has been perceived as a threat by utilities. While industry experts and many in the utility business have moved on beyond initial reactions to impose fixed charges and demand charges in an effort to undermine DG economics, there are still important issues, such as data-driven issues, that need to be addressed. Data-driven issues are issues associated with actual measured costs and impacts, analysis of maximum demands, coincident and non-coincident peaks, and cost and benefit analysis, cost-causation, and fair cost allocation. All of the issues occur before rate design. These issues are some reasons why utilities must be careful to change rates. The author suggests the Iowa Utilities Board begin data collection and develop study methodologies to ensure data-driven issues are properly addressed.