Setting Your City Up for Success at the Public Utilities Commission

November 12, 2018 | Kelly Crandall
This post is the third in a three-part series that helps local governments understand why working with utility regulators matters, what they can achieve, and how to set themselves up for success. Read part one here and part two here.

In my last post, I talked about Montgomery County, Maryland, which engages at Maryland Public Service Commission as part of a comprehensive clean energy strategy. Montgomery County is a shining example of how any local government can build a successful approach to achieve its goals by working with utilities and regulators. Public utility commission (PUC) proceedings can be lengthy and complex, however, by creating a proactive plan for what you want to achieve at the state level you can use resources wisely and take control over what is possible for your community’s energy future.

Here are six steps I’ve found to be invaluable both as a former city staffer myself, and in the process of helping staff at other cities. (Click here to download this tip sheet).

  1. Know your priorities. Look to your master plans and other documents to help you identify your goals and high-impact ways to achieve them. You may have to decide, for example, if you still want to purchase green power for city facilities if the program is designed such that the power is not generated locally.
  2. Ensure executive buy-in. Participating in PUC proceedings may be viewed as political or contentious, although it doesn’t have to be. Strong executive leadership can help ensure you have the staff resources you need to participate actively.
  3. Know who should be involved. Whether it is vegetation management, planning and development, construction permitting, sustainability, or facilities—many city departments interact with utility staff. That’s why it is important to know who within the city to contact when an issue comes up. For example, should facilities management be involved if there is a question about LED street lighting? Are permitting staff prepared to enforce an “electric vehicle-ready” code provision where a utility has projected EV uptake based on it?
  4. Foster meaningful partnerships. Many advocates participate at PUCs, representing interests from large businesses, to environmental quality, to low-income customers, to renewable energy trade associations. These entities can help you stay on top of what has happened and what is to come at the PUC. Therefore, you will want to work with them to develop meaningful and well-rounded recommendations. In some of the examples listed above, cities worked with groups of advocates or other cities to raise their issues, and in many cases, they also worked directly with utilities to develop settlement agreements.
  5. Bring in experts when you need them. Many PUC proceedings require legal or technical expertise, and some cities hire outside counsel or experts. Others may lean on the partners they’ve been fostering to provide certain types of expertise, such as rate design or power supply planning. Coalitions of cities in California, Michigan, and North Carolina have been able to jointly sponsor expert assistance. However, local governments like Chicago, Boulder, the District of Columbia, and Montgomery County maintain in-house legal or technical expertise.
  6. Be strategic about engagement. You don’t have to do everything at once. Generally speaking, it’s important to make specific, actionable recommendations that are backed up by evidence the commissioners can use to make decisions. If you can do that well, you will create a track record of success and build your credibility.

Taking the Next Steps

Many cities have already started down an engagement path with their PUCs, and seen successes, but room remains to make cities’ recommendations more robust and comprehensive. Networks like the Urban Sustainability Directors Network and the City Energy Project, both of which IMT supports, provide peer-to-peer exchange and technical guidance to help cities on utility engagement.

With the help of a facilitator like IMT, you can put together a strategy that will enable you to:

  • Define and prioritize your regulatory goals;
  • Understand your utility’s existing programs, initiatives, and requirements;
  • Formulate clear and reasonable asks to your utility and PUC that put you on course to meet your goals; and
  • Identify and coordinate with knowledgeable local stakeholders.

Do you work for a local government that wants to build a regulatory strategy or take its engagement at PUCs to the next level in pursuit of local and state goals? IMT is here to help. Contact me at kelly.crandall@imt.org.

This post is intended to be informational and should not be construed as legal advice.

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This post is the second in a three-part series that helps local governments understand why working with utility...