Utility IRPs

Utility IRPs

Participating in state regulatory processes to advance renewables

State regulatory agencies responsibilities for overseeing generation expansion vary from state to state. Most states require their utilities to file Integrated Resource Plans (IRPs) forecasting their generation expansion over the next five to 20 years. The IRP process encourages utilities to model least-cost options for supplying energy, while also accounting for energy efficiencies, policy objectives, and desires of the public in a transparent manner.

One state has multiple agencies prepare and approve a plan for procuring energy, capacity, renewable energy credits and solar renewable energy credits, and expanding the use of energy efficiency for its utilities.

Although the specific requirements of resource planning varies state-by-state, most allow the public to submit comments and interested parties to file testimony or comments on the utility’s plan through a docket that is managed by a regulatory agency like a state public utilities commission. Typically, the resource planning includes a review of its forecasted annual energy demand, plans for reserves, an analysis of the potential futures and policies that may occur over the planning period. After reviewing this information, the utility or state agency prepares a mix of resources that meet the state standard. Since utilities have an obligation to minimize costs to the consumer, the IRP process is a desirable and effective mechanism to encourage the use of cost-effective renewables.

Planning for the Future

Traditional utility resource planning involves evaluating the expected demand for electricity and any applicable governmental policies or regulations and balancing that with maintaining reliability and cost-effectiveness. The Integrated Resource Plan expands this basic analysis and includes: 

  • Evaluating existing resource options and their ability to meet demand and policy objectives in a fair and consistent manner
  • Forecasting future loads
  • Identifying potential resource options (including efficiencies) to meet future loads, policy objectives, compliance with environmental regulations, and overall market conditions
  •  Assessing the costs and risks associated with each load forecast and resource option
  • Determining the optimal mix of resources, receiving and responding to public participation (where applicable)
  • Minimizing total costs
  • Presenting a flexible resource plan that allows for uncertainty and adjustments in response to changing circumstances to the appropriate state regulatory agency.
Below is a summary of the process utilities in MISO states follow with their resource planning.  
  • Illinois                  Illinois does not use an IRP process.  The Illinois Power Agency (IPA) annually develops a plan to procure renewable energy credits for its utilities. The plan does not apply to small utilities, alternative retail electric suppliers, and municipal or cooperative energy providers. The utility procurement plan is approved by the Illinois Commerce Commission. Alternative Retail Electric Providers make alternative compliance payments to the IPA for the procurement of renewable energy products. That money is placed into a renewable energy resources fund (RERF) to be used to procure renewable energy products comparable to what the IPA procures for Illinois utilities. There is no oversight and approval of the IPA's decision to use money from its RERF to procure renewable energy credits.

  • Indiana                 Utilities submit an IRP bi-annually.   
    • Duke Energy Indiana, Indiana Municipal Power Agency, Indiana & Michigan Power Co., and Wabash Valley Power submit IRPs in even years
    • NIPSCO, Indianapolis Power & Light, Vectren, and Hoosier Energy Rural Electric Cooperative, Inc. submit in odd years.
  • Iowa                      Iowa does not have an IRP process. The Iowa Utilities Board requires utilities to file an annual report, which includes the utility’s financial information.
  • Michigan             Utilities must submit an IRP any time they file a petition for a certificate of necessity.
  • Minnesota          Investor-owned utilities shall file a resource plan “periodically” with the Minnesota Public Utilities Commission. This is traditionally submitted every 2-3 years in Minnesota. This does not apply to individual municipal utilities or individual rural electric cooperatives, but does apply to their wholesale power providers. Interested parties may provide input on a utility’s plan through a contested case proceeding. The Commission will make its determination on the utility’s plan, based on the facts in the record.  Click here for more information on this Administrative rule
  • Missouri              Utilities file IRPs every three years; each utility files in a separate year, they also file annual updates noting any significant changes and actions taken in conformance with the plan. 
    • Ameren MO will file its IRP in October  2017
    • Empire District submitted its plan in April 2016
    • Kansas City Power & Light, and Kansas City Power & Light Greater Missouri Operations filed in March 2015
  • North Dakota     Utilities that own or operate any facility in North Dakota shall submit a 10-year plan in July of every even-numbered year. This includes information on the size, type, and location of their facilities (including potential retirements), preliminary information on proposed generation and transmission facilities, information on regional coordination efforts, environmental factors, demand forecast, and any other information deemed relevant by the commission.
  • South Dakota         Utilities are required to submit 10-year plans focused on facilities, load forecasts, and regional efforts. The full list of requirements can be found here.
  • Wisconsin           Wisconsin does not have a traditional IRP process, but does require utilities to submit their financial information in an annual report. The Public Service Commission of Wisconsin also prepares a biennial Strategic Energy Assessment, which evaluates the adequacy and reliability of the state’s current and future electrical supply. Wisconsin statute includes a variety of other requirements for this report and also allows the public to comment on the content of this assessment.