This year Renewable Energy Advocates including IndianaDG are encouraging everyone to participate in
We are also seeking sponsors for this event. Please complete this form no later than Feb. 1st!
IndianaDG is working with other groups to organize teams to talk to state legislators.
Reply Briefs and Exceptions were filed on Friday, January 15, 2021, by all parties in Vectren Excess Distributed Generation (EDG) Tariff case (Cause No. 45378) to replace net metering before the Indiana Utility Regulatory Commission (IURC).
45378--JP Responsive Brief--1-15-2021FINAL 10 pages
45378--JP Selective Comments and Exceptions to Vectren PO--1-15-2021FINAL 37 pages
Solarize Indiana (SI) Reply Brief Filed 12/23/2020 in Appeal of IURC Order Approving Vectren PURPA 30-Day Filings Nos. 50331 & 50332
Solarize Indiana, Inc. (“Solarize Indiana”) submits this reply to address arguments in the appellee briefs filed by Southern Indiana Gas and Electric Company, d/b/a Vectren Energy Delivery of Indiana, Inc. (“Vectren”) and Indiana Utility Regulatory Commission (“Commission”). The appellees have failed to demonstrate that federal statutory and regulatory requirements under the Public Utilities Regulatory Policies Act (“PURPA”), as amended, do not count as “applicable law” with respect to the two Vectren 30-day filings at issue, or that the Commission could approve those rate submissions as noncontroversial, without a hearing, despite Solarize Indiana’s objections.
ARGUMENT
A. The Commission Erred by Finding PURPA Objections
Insufficient to Make the Vectren Filings Controversial
B. The Objections Based on PURPA Were Specific
C. Solarize Indiana Properly Raised Valid Objections
1. Vectren unlawfully imposed a 1MW threshold
2. Vectren failed to provide a long-term option
for predetermined pricing
3. Vectren’s avoided cost computation was deficient
in several respects
4. Vectren’s proposals are discriminatory
D. Solarize Indiana Is Properly Appealing a Final Order
E. Efforts to Shift the Controversy Elsewhere Cannot Justify
the Refusal to Address the PURPA Violations
CONCLUSION
The Commission erred by granting summary approval, without a hearing, on the ground that the Vectren 30-day filings were noncontroversial, notwithstanding Solarize Indiana’s express, written objections alleging PURPA violations. The Order should be
reversed and the matter remanded with instructions to deny summary approval on the grounds that the filings are controversial.
Download and read the brief HERE>
Reply Brief of Appellant Solarize Indiana Inc.-12-23-2020 Accepted
INDIANA OFFICE OF UTILITY CONSUMER COUNSELOR’S AND THE JOINT PARTIES’ BRIEF IN SUPPORT OF PROPOSED ORDER
The Indiana Office of Utility Consumer Counselor (“OUCC”), Citizens Action Coalition of Indiana, Inc., Environmental Law & Policy Center, Indiana Distributed Energy Alliance, Solar United Neighbors, Solarize Indiana, and Vote Solar, by counsel, submit this brief in support of its proposed order recommending that the Indiana Utility Regulatory Commission (“Commission”) deny the proposal by Southern Indiana Gas and Electric Company d/b/a Vectren Energy Delivery of Indiana, Inc. (“Vectren”) for an Excess Distributed Generation (“EDG”) Tariff, as the proposal does not comply with the statutory requirements of Ind. Code ch. 8-1-40 et seq. Click links below to read both the Proposed Order and Legal Brief.
45378--Proposed Order of Joint Parties--12-18-2020FINAL
45378--Submission of Proposed Order and Brief of Joint Parties--12-18-20FINAL
SUBMISSION OF AND BRIEF IN SUPPORT
OF FINDINGS RELATING TO DETERMINATION OF
“EXCESS DISTRIBUTED GENERATION” IN PROPOSED ORDER
Southern Indiana Gas and Electric Company d/b/a Vectren Energy Delivery of Indiana, Inc., a CenterPoint Energy Company (“Vectren South” or “Petitioner”), by counsel, respectfully submits for the Commission’s consideration and use the form of proposed Order attached hereto. The principal issue in this proceeding is whether Vectren South’s proposal to instantaneously net the two components of “excess distributed generation” set forth in Ind. Code § 8-1-40-5 is consistent with that statute and in the public interest.
The next filing is January 15, 2021, when all parties will file their Reply Briefs and Exceptions with the IURC.
