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Consumer counsel urges detailed forecasts, benefit‑cost tests and external review for IDSP
Summary
The Office of Consumer Counsel, supported by RMI, told PURA an IDSP should be a comprehensive decision framework with granular, multi‑scenario forecasts, consistent cost categories, benefit‑cost analyses for major investments, transparent stakeholder engagement, and options for external evaluation such as a technical advisory group.
The Office of Consumer Counsel told the Public Utilities Regulatory Authority that an Integrated Distribution System Plan (IDSP) should function as a centralized decision framework that helps stakeholders and the regulator evaluate long‑term grid investment strategies, potential impacts on consumers and how those investments support state policy goals.
"We view an IDSP document, and the overall planning process as a decision framework that can enable the formulation of long term grid investment strategies," said Stephanie Beeler, senior associate at RMI presenting on behalf of the Office of Consumer Counsel. Beeler said an IDSP should present a comprehensive grid needs assessment, location‑specific multi‑scenario forecasts, resilience threat assessments, a clear methodology for selecting "least‑regret" solutions, and a prioritized action plan with forecasted spending and rate‑impact implications.
On cost assessment, OCC recommended including benefit‑cost analyses and rate‑impact assessments for investments that materially affect ratepayers, while acknowledging it is impractical to require full BCA for every minor line item. OCC suggested setting thresholds (drawing on national standards of practice) to determine when comprehensive BCAs and rate‑impact analyses are warranted and urged the inclusion of explicit cost categories so stakeholders can compare investments consistently.
OCC also proposed external evaluation mechanisms, such as a technical advisory group, to review methodologies and provide independent feedback on forecasts and scenario assumptions. During questioning, PURA staff and commissioners emphasized that the IDSP should be readable to multiple audiences — PURA bureaus, state energy offices, advocacy groups and ratepayers — and that key information should be made accessible through dashboards or executive summaries.
OCC reiterated that while the IDSP should inform other dockets, it should not be read as preapproval of spending or as a substitute for prudency review; rather, participants suggested the IDSP could be used as an anchor for subsequent prudency discussions and retrospective review.
PURA commissioners and staff indicated they will continue to refine the document requirements, thresholds for BCA, and engagement mechanisms through subsequent technical meetings and a forthcoming revised concept paper.
