September 21, 2018
ESA Comments on Colorado PUC’s Implementation of House Bill 18-1270
ESA will file comments today in response to the Colorado Public Utilities Commission’s Notice of Proposed Rulemaking to implement House Bill 18-1270, which passed the state legislature this year. In our comments, ESA calls for additional revisions to the Electric Resource Planning (ERP) rules to facilitate effective consideration of energy storage in procurement, including use of up-to-date cost estimates and forecasts, modeling tools that employ sub-hourly intervals, and instituting a “net cost” analysis to better capture flexibility benefits. Additionally, ESA submits that in addition to updating the ERP rules, additional rules governing Certificate of Public Convenience and Necessity and Distribution Resource Planning require updating to reflect the full guidance of the legislation.