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YouTube transcript (ahkWsK5gGgo) — Transcript

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1:34hello hello we can hear you um it won't
1:38start until 1 pm um but since you're
1:44calling yeah
1:47we right we started so everyone can get
1:50online um since you're calling from a
1:52phone if you could change your Zoom name
1:55to your first and last name are you able
1:58to do that
2:00I I wouldn't know how to do that okay um
2:03that's if you I'm trying to join the
2:04zoom just with the join button okay and
2:08it won't let me do that okay I can
2:10change um I can change this and you're
2:12calling from 303 and ends in 013 is that
2:17right uh
2:19303564
2:217013 okay perfect and if you can just
2:23tell me your first and last name I can
2:25change that just so it shows who you are
2:27on the
2:28screen uh Tim
2:30Jordan j o r d
2:32n and then are you with a a company or
2:37you just um appearing on your
2:39own you I'm with a residential community
2:43in lower downtown Denver okay which one
2:46is
2:47that I'm sorry are you appearing on
2:50behalf of them or just for yourself yes
2:54which I'm
2:57sorry are you appearing behalf of on
3:00behalf of
3:02them I'm having a hard time hearing you
3:04I apologize are you appearing on behalf
3:07of of the agency or just as
3:10yourself I'm on the board of the uh
3:13residential community so I'm on the
3:15homeowners association board okay and
3:18what is the name of that board just so I
3:20can put it on there on the screen the
3:22titanium
3:25LS titanium lofs l FTS
3:30uhhuh and you said that was
3:33HOA uhhuh okay so Tim Jordan with
3:38titanium LS HOA is that
3:41correct yep okay I'm gonna just change
3:44the screen so it shows that hold
3:57on right thank you so much and then if
3:59you can just mute until we start and
4:01then until you're called on to talk to
4:03speak if you're going to speak
4:06today okay I'll just hang on okay thank
4:09you okay
4:28thanks
21:27all
27:47hey it's our reporter and ready to
27:53go excellent
27:56thanks
28:00okay with that uh we are now on the
28:02record this is a public comment Hearing
28:05in proceeding number
28:0723m
28:11d464 in this proceeding the commission
28:13is implementing aspects of Senate Bill
28:1723291 including consideration of
28:20customer connections to and
28:22disconnections from investor owned
28:24Utility Systems and the study of
28:27potential barriers to beneficial
28:29electrication and distributed energy
28:31resources the
28:53purpose let me just step are you on
28:58yes it sounded like um the audio your
29:01audio was buffering and then we lost you
29:03for a second okay sorry my entire Zoom
29:07restarted
29:09so I want to make sure we didn't lose
29:11everyone it seems like we just lost me
29:14so no
29:16wores I'll uh I'll rewind just a little
29:19bit since I'm not 100% sure where I lost
29:21you um but this is a
29:25comment in seting 23 m-
29:300464
29:32EG um and let me know Stephanie if I'm
29:34not coming through uh clear enough I
29:36could turn my video off in the future
29:39that's a problem okay in this meeting
29:42the commission is implementing aspects
29:44of Senate Bill
29:46239 including consideration of customer
29:50connections to and disconnections from
29:53investor owned Utility Systems and the
29:55study of potential barriers to
29:58beneficial electrification and
30:00distributed energy resources the purpose
30:03of today's hearing is to collect
30:05information regarding current
30:07stakeholder experiences in securing new
30:11electric service upgrading electric
30:13service to allow for beneficial
30:16electrification sometimes referred to as
30:18be or implementing distributed energy
30:22resources often known as deers
30:24particularly from utility customers
30:27Builders and housing developers local
30:31government officials and utility
30:33Representatives regarding electric
30:36utility policies and practices related
30:39to requests for new or upgraded electric
30:41service or interconnection of
30:43deers including the costs and timing of
30:47service upgrades for necessary system
30:51interconnection today is October 4th
30:552023 I am commissioner Megan Gilman the
30:58hearing commissioner for this proceeding
31:01I have been designated by a vote of
31:03three Commissioners to hear this matter
31:05and issue a recommended decision for
31:07consideration to the full
31:09commission I'm just going to talk uh
31:11about some brief Logistics and then
31:13we'll open it up for comments first this
31:16hearing is being webcast on the internet
31:19it will be live at all times during the
31:21hearing including during any breaks we
31:23may take so please be mindful of your
31:25video and microphone at all time if it's
31:28not your turn to speak please leave
31:30those off so we can focus on comments
31:33being provided until your signal to
31:35speak a court reporter is listening
31:38remotely to this proceeding live
31:41transcribing all oral comments for the
31:44record commenters should please State
31:47and spell their full name before giving
31:50their comments speak clearly and at a
31:53conversational Pace the court reporter
31:56May interject and ask you to slow down
31:58if she's a to transcribe effectively at
32:01your speaking Pace I'll note from prayer
32:04experience this is particularly an issue
32:07if you're reading prepared remarks or
32:09maybe a bit nervous um Can to speed
32:13people up so please just be mindful of
32:15your speaking pace so we can ensure we
32:17get all of your comments down um next I
32:22plan to organize groups of commenters
32:24today efficiency um in the following
32:28order first I'd like to ask members of
32:31the general public to provide comments
32:34perhaps members of the public who are
32:35just relaying individual thoughts or
32:38experiences followed by Builders and
32:42developers then representatives from
32:45kosa or solar interests then from other
32:48deer vendors followed by utilities I
32:52plan to announce a category and ask for
32:55those present on the descrip group or
32:57category or virtual hand and I will call
33:01on you in the recorder that you appear
33:04on my screen um if you're calling in by
33:07phone you can unmute your phone and that
33:09will also signal that you wish to speak
33:12uh may call on speakers out of order
33:15from time to time um if we need to stay
33:18on a certain topic but I'll certainly
33:20trying to do my t uh to barely get
33:22everyone in more or less the order that
33:25I see you uh I don't fact that will be
33:27pressed for time today we have this
33:29schedule from 1 p.m. to
33:313M um so I don't anticipate in posing
33:35any strict limits on comments terms of
33:38timing however if the need arises I may
33:41ask you to wind up your comments for the
33:43purpose of staying within a lotted time
33:46uh and getting um to a point of fairness
33:49with all the
33:50participants next if you have written
33:53comments prepared there's no need to
33:55read them verbatim as oral comments um
33:58instead you can provide oral comments
34:01that are a summary of the key points of
34:04any written comments full written
34:06comments can be filed directly into this
34:09proceeding again that proceeding number
34:12is 23 m-
34:140464 EG through the commission's E fil
34:19website written comments also be
34:22submitted through the commission's main
34:24web page especially for those who are
34:26unfamiliar with filings you can go to
34:28our main web page at
34:31P.C
34:34colorado.gov um and then click on the
34:37file comment or complaint link and you
34:40can put it in there it's very helpful if
34:42you do identify the proceeding number
34:44that I provided um so we are still early
34:48in this proceeding um if hear something
34:51today you'd like to comment on further
34:54please take the opportunity to file a
34:56post during written comments we aim to
34:59understand your experiences and
35:00priorities and want to aim to make it
35:02easy for you to contact us um to best
35:05understand and consider your perspective
35:07so um perhaps you've already spoken but
35:10here's something um that shers a thought
35:13and you can certainly feel free to
35:14provide those written comments after the
35:16hearing um finally I ask the commenters
35:19today are mindful to avoid speaking on
35:22topics concerning other cases and
35:24particularly to avoid repeating in this
35:27proceeding positions they're advocating
35:29for uh in ongoing litigated cases this
35:32is important to ensure that the ad
35:35advocacy of these issues occurs within a
35:39litigated
35:40proceeding notice parties opportunity to
35:44respond if your comments to too close to
35:48a litigated case um I or Council will
35:51likely interject and ask you to move on
35:54to another topic um or another point an
35:58example of this would be a commenter uh
36:00advocating in this hearing specific or
36:05that they have already RA in public
36:06services ongoing interconnection
36:09proceeding proceeding
36:1223-01 188b which is currently before an
36:16alj will later come to the full
36:18commission I understand not all
36:20commenters may be familiar with all of
36:22the different proceedings in front of
36:24the commission um so myself or Council
36:27will uh give you a nudge if you Veer
36:29into one of these
36:30issues um and we would encourage you to
36:33file com in that appropriate proceeding
36:36on topic that's too close um so with
36:39that i' like to thank you all for taking
36:42the time to be here today and share your
36:44comments um it means a lot to us to get
36:47to hear um from you all and your
36:49experiences and uh uh really look
36:52forward to to your time and appreciate
36:54your attendance so um
36:57now I'd like to move on to taking the
36:59comments so the first um category that I
37:03had mentioned before I'll go through
37:05those categories just one more time for
37:07those of you listening kind of hearing
37:09for the first time first i' like to
37:11focus on any individual um comments from
37:15the general public be relaying
37:16individual experiences or perspectives
37:20then I'd like to move to builders and
37:22developers or those kind of within the
37:24building Community um subcons
37:26contractors electricians mechanical
37:28whatever it might be then move on to
37:31representatives of kosa and solar
37:34Representatives after that any other de
37:38vendors um and then follow that by
37:41utilities so um within those categories
37:44I'll have folks just hit the raise hand
37:46button if you can if you can't make that
37:49work you could on your video and wait
37:51until I get to your name um so with that
37:55if we have any members of the the
37:56general public here relay uh individual
37:59thoughts and
38:01experiences be happy to see if you all
38:04could raise your hand right now um or go
38:07ahead and turn on your video and I will
38:09come to you in the order I
38:13see
38:15okay um first on my list is Anita seeps
38:22from CC
38:254ca
38:28hi there um my name is actually Anita
38:30sites and I have a a quick question um
38:34one of the groups at the um pu's email
38:37asked to participate today was local
38:39governments and you didn't list that um
38:41bucket would you like local governments
38:43to participate in this portion or yes
38:47sorry for that oversight I recognize on
38:50our list yeah I think this is
38:52appropriate time for local governments
38:54as well um Nita i' happy to you if
38:58you're okay starting um and maybe can um
39:01and spell your name for the record I
39:03think I got it
39:04wrong that's fine um hello Commissioners
39:08my name is Anita sites that's spelled a
39:11ni T SEI TZ um I'm the advocacy director
39:17of Colorado communities for climate
39:19action cc4 ca for short um and prior to
39:24that I served on the Westminster city
39:25council for eight years um cc forca is a
39:29coalition of 42 diverse local
39:32governments that have come together to
39:33work on strong and effective State
39:35climate action this hearing um in the
39:38issue improve of improving distribution
39:40planning and connecting new electric
39:42service is critically important um if
39:45the state of Colorado is to meet our ghg
39:48reduction goals um as a side note CC 4ca
39:52did support and help work to pass Senate
39:54Bill 291 so we are very happy to have
39:57this hearing um going on today
40:00distributed energy Generation Um
40:03resources beneficial electrification of
40:05buildings and of Transportation are
40:08fundamental components of an effective
40:11um greenhouse gas emission reduction
40:13strategy and the status quo threatens to
40:16delay those efforts our members and
40:18other local governments have
40:20communicated their concerns to CC 4ca on
40:23this topic and I'd like to share a
40:25highlevel overview of some of the things
40:27we're hearing which fall generally into
40:29three
40:30buckets the first are concerns with
40:32distri uh distributed energy Generation
40:36Um resources specifically solar
40:38interconnection issues the second is
40:41individual homeowners having to pay for
40:43Excel infrastructure upgrades when their
40:45project triggers a capacity issue for
40:47the
40:49utility three new development oftentimes
40:53the types of development we really need
40:55like Transit oriented multifam or
40:57affordable H um housing developments
40:59finding out at a very late stage that
41:02the utility do not does not have the
41:04capacity to serve um and that they have
41:07both um additional millions of dollars
41:11and years of delays um we find this
41:13particularly unacceptable as these
41:15developments help to address two of the
41:17state's most pressing challenges the
41:20housing and climate
41:22crisis as the Pu is no doubt aware there
41:25have been um issues with the cost of
41:28interconnection of new distributed solar
41:30resources um to the Excel Energy grid
41:33and these fall on the com customers who
41:36installation happens to exce exceed
41:38excel's hosting capacity for that
41:41area Grand Junction rifle and Boulder
41:44County are some of the Colorado
41:46communities that show up with the most
41:48limited hosting capacity on Excel
41:50energies um map their hosting capacity
41:53map and they are very affected by this
41:55issue
41:57um first it's great that these maps are
42:00available at the local planning level um
42:04however they provide very little benefit
42:06since the details are blurred we do not
42:09believe that providing transparent
42:11hosting capacity all the way down to the
42:13neighborhood level of compromises
42:15customer privacy or creates any kind of
42:17infrastructure risk therefore we'd
42:20recommend the commission at a minimum
42:21require the maps to be fully detailed
42:24publicly available and accurately
42:27maintained second it's unreasonable for
42:30a single customer to Bear the full brunt
42:32of the interconnection costs we've seen
42:35the cost causer pays principle for
42:37distributed generation hosting capacity
42:40present homers homeowners with price TS
42:43as high as
42:45$60,000 not only is that inequitable to
42:48the customer who happen to be beaten to
42:50interconnection by their neighbors it
42:53has a chilling effect on energy code
42:55adoption around this
42:56State we do understand that solar is
42:59complex in terms of who benefits and who
43:02pays what we advocate for is one to
43:06reassess the cost model so that upgrades
43:08that provide benefit Beyond simply
43:10allowing the interconnection to occur
43:11are appropriately born by the utility
43:14not the individual customer two that
43:17standardizing cost so that they are more
43:20transparent and predictable for
43:22customers three developing a tariff
43:25mechanism by which cost can be
43:26distributed in a way that is more
43:30Equitable third the internet connection
43:33application could also be simplified by
43:36narrowing the scope of what the utility
43:38should be reviewing um for example
43:41utilities are not in charge or have any
43:43jurisdiction over Electrical Codes um
43:46reviewing electrical drawings and other
43:48elements that are already subject to
43:50review at the local jurisdiction are not
43:52within the utilities perview um what the
43:56utility should be reviewing is their own
43:58infrastructure and whether it can
43:59support interconnection of the system
44:01being
44:02proposed fourth recognizing that
44:04jurisdictions are adopting Progressive
44:06building codes and beneficial
44:08electrification in solar has a place
44:11among these codes utilities must
44:13proactively address areas where there
44:15are hosting capacity concerns and they
44:18need to do this before the problem
44:20surfaces not
44:21after communities like the City of
44:24Lewisville should be able to implement
44:26the national level codes that are
44:28adopted with a reasonable Assurance of
44:30success not be faced with decisions as
44:32to whether or not they need to roll back
44:34the codes because excel's infrastructure
44:36in their Community lacks the hosting
44:38capacity that other communities benefit
44:41from between state and local building
44:44and transportation electrification goals
44:47we know that we can be
44:48certain there will be significant
44:50electric load growth local governments
44:54can't meet their adopted GH G reduction
44:56codes without very high levels of
44:59electrification so it is important we
45:01work out these issues now in a way that
45:04recognizes the urgency and the pace of
45:06load growth and is Equitable to rate
45:08payers and how it contemplates cost
45:10recovery for the utilities again thank
45:13you for the hear for the hearing for
45:15listening to our comments um we really
45:17appreciate your work on this issue and
45:19we look forward to being um involved in
45:22the future um of this uh exploration
45:27thank you so much for that I appreciate
45:30it um and I did get word that I think
45:33it's my audio is a little glitchy so if
45:36when you're giving your comment I take
45:38off my video don't worry I'm still here
45:41just trying to make sure that I catch
45:43every word and can can see you at the
45:45same time um so thank you very much for
45:48those comments next on the list I have
45:51Claire Valentine from Denver and just a
45:53reminder anyone who's joining as a
45:56member of the general public or
45:58representing a government uh
46:00governmental entity um go ahead and
46:02raise your hand if you would like to be
46:04placed in line to speak uh go ahead Miss
46:07Valentine thank you commissioner Gilman
46:10um at at the outset would you prefer The
46:12Abridged version or the unabridged
46:14version the difference is five versus 10
46:17minutes um five is closer I think to our
46:21Target given the number of attendees and
46:23uh please do feel free to file uh
46:26written comments in the unabridged
46:28version that's great and we will file
46:30our full written comments then in
46:32addition um yes so thank you good
46:35afternoon um really appreciate the
46:37opportunity to speak today on this topic
46:39my name is Claire Valentine which is
46:41spelled c l a r e last name v l n t i n
46:48um and I am a senior energy policy
46:50adviser with the City and County of
46:52Denver within the office of climate
46:54action sustainability and resiliency
46:56um today I bring to you the perspective
46:58and experiences of the City and County
47:00of Denver um but my comments also come
47:02through the lens of experience with
47:04distribution system planning in Colorado
47:06and Beyond I've been involved with the
47:08distribution system planning process at
47:10this commission since its Inception I
47:12provided technical comments in the rul
47:13making initiated in 2020 and I testified
47:16in public services inaugural DSP in
47:192022 and what I can tell you through the
47:21lens of uh this experience and after the
47:24year that I've spent working with the
47:26City and County of Denver is that we
47:28have only scratched the surface of
47:29distribution system planning and
47:31preparing the grid for Rapid beneficial
47:33electrification there are significant
47:35challenges that the city its community
47:37members and local developers are facing
47:39to advancing not only transportation and
47:41building electrification but also
47:43sustainable Urban Development more
47:45generally at a time when Denver's new
47:48mayor Mike Johnston has declared an
47:50emergency around homelessness the Denver
47:52metro area is short almost 70,000 homes
47:55this is one of the widest housing gaps
47:57in the country and we urgently require
48:00additional Housing Development
48:01particularly affordable housing
48:03unfortunately as you will continue to
48:05hear on this call I'm sure uh the city
48:08increasingly hears from builders that it
48:10works with that in the pursuit of
48:12electric service connections for new
48:13developments public service has quoted
48:15them millions of dollars for grid
48:17upgrades and has stated that due to a
48:19lack of electric of electric capacity it
48:22will take years to add infrastructure to
48:24support these new buildings I emphasize
48:26that this is not necessarily caused by
48:28electrification the issues that Denver
48:30has encountered include mixed fuel as
48:31well as all electric buildings rather at
48:34least within the City and County of
48:35Denver we're already experiencing
48:37electric capacity Contra constraints and
48:39our office anticipates that these con
48:41constraints will significantly hinder
48:43beneficial electrification in
48:44transportation and buildings in addition
48:47to the development of affordable housing
48:48for our community members um I'm aware
48:51that several builders that Denver works
48:53with are are here providing public
48:54comment today or through another Channel
48:56um so accordingly I will not share every
48:58example that the city has encountered of
49:00these issues but rather highlight a
49:02select few with particularly problematic
49:04costs and timelines um and then I will
49:07provide through our WR through our
49:08written comment five recommendations for
49:11how the commission can continue to
49:12investigate these issues through
49:14additional questions that it poses to
49:16the utility through this miscellaneous
49:19proceeding um so to begin with some
49:21background Denver's office of climate
49:23action sustainability and resiliency has
49:25extensively engaged with the Builder and
49:27de developer Community through its all-
49:29electric new buildings program Denver
49:31offers design and Equipment incentives
49:33for commercial development of all
49:35electric new buildings and homes and is
49:36partnering with the building buildings
49:38community on four commercial
49:39demonstration projects and six multif
49:42family demonstration projects for all
49:43electric new buildings in particular the
49:46demonstration projects have an equity
49:48Focus 76% of the pilot funds have been
49:50allocated for affordable housing or
49:52other projects serving underresourced
49:54communities and Denver through this
49:57program Denver has worked with um a
49:59developer on a multif family housing
50:00project that is designed to provide over
50:02100 affordable housing units the
50:05developer told us however that the
50:06project is on hold until 2027 four years
50:09from now due to inadequate capacity in
50:11the area another example the city has
50:13been in discussion with another another
50:15developer on a multif family building
50:17this developer sought a conceptual
50:19capacity check for the development and
50:21public service stated that the project
50:22would trigger the need for an additional
50:24feeder due to capacity constraints in
50:26the area the company stated that the
50:28projected cost would be between $3 to5
50:30million and take two or three years
50:32similarly the city has worked with
50:34another multif family developer um
50:37affordable housing developer aiming to
50:38construct 50 units and public service
50:40again stated that the project would
50:42trigger the need for an additional
50:43feeder at a cost of$ four to5 million
50:47one final example um another multif
50:49family affordable housing project
50:51according to the developer Public
50:53Service stated that they cannot provide
50:54a feeder exess exension to the site
50:56until 2026 unless the project P have it
50:59installed for 2 and a half million in
51:01all of these cases the developer had no
51:03insight into whether their project will
51:05trigger the need for grid reinforcements
51:06until the 11th Hour when the developer
51:09submits its electric load calculations
51:10and construction documents to the
51:12company based on my conversations with
51:14Builders and developers it is not always
51:16even the sheer cost of the grid upgrades
51:18that is the problem it's the timing and
51:20it's the uncertainty of the capacity at
51:22this point implementing the required
51:24distri distrib ution system upgrades
51:26delays the project and it becomes
51:28challenging for developers to access
51:30financing to pay for the grid upgrades
51:32particularly affordable housing has
51:34unique funding sources that are
51:36incompatible with these last minute
51:37costs further we have heard that
51:39developers are not told how much they're
51:41exceeding the available load capacity or
51:43if there are ways to mitigate the cost
51:44of grid reinforcements through load
51:46reduction below some threshold to
51:49successfully support transportation and
51:50building electrification as well as
51:53development more generally there must be
51:54a better way Denver sees the need for
51:56several changes to policies and
51:58processes including modifications to
52:00assumptions in distribution system
52:01planning forecasting better
52:03collaboration between utilities and
52:05Community Planning and Development
52:06departments and local governments new
52:09processes for developers to align their
52:10design process with infrastructure
52:12upgrades to ensure timely deployment
52:15cost support mechanisms for service
52:16level upgrades and potentially
52:18modifications to line extension policies
52:21I'm pleased that the commission has
52:22launched this proceeding to investigate
52:24these issues I expect that the
52:26commission will continue to Grapple with
52:27them in the coming months and years um
52:29this issue is very complex and in the
52:31scope of this miscellaneous proceeding
52:33um we do have several suggestions for
52:35for questions that the commission could
52:37pose to utilities um to be able to
52:39gather more information that's currently
52:40obscured to the City and County of
52:42Denver when we raised some of these
52:44issues to Public Service you know I
52:45think there's this perception that uh
52:48it's it's either hearsay or it's
52:49potentially exaggerated and I think we
52:51need to see more data on what's really
52:53happening with um these conceptual
52:56capacity checks and the costs associated
52:58with grid upgrades so we'll provide
53:00additional details through written
53:01comment on some of the questions that we
53:03think would be valuable um but for now
53:05this concludes my initial public comment
53:07on behalf of Denver and thank you again
53:08commissioner Gil Gilman for taking the
53:10time to hear our concerns and
53:13suggestions excellent thank you and I'll
53:16look forward to your written comments um
53:19I will point out to we did Issue a first
53:21round of questions to utilities to get
53:24some base level understanding of the
53:25policies and practices around some of
53:27this um just to mention that but thank
53:30you so much for your comments um next
53:33I'll move to Edward
53:36Stafford good afternoon thank you my
53:38name is Edward Stafford
53:41edwd St FF oard I'm with the city of
53:44Boulder as a senior manager in our
53:46planning and development services
53:47department pleased to be able to speak
53:49with you a little bit today and I will
53:50start by saying Echo many of the
53:53comments that Clare Valentine from the
53:55City and County of Denver just shared
53:57and I'll share a few of our experiences
53:59that align with that and some of our
54:00challenges that we've seen as we try to
54:02support the development in our community
54:04here one of the things we see frequently
54:06is the need for early coordination on
54:08both sides we recognize this is not a
54:10one-sided issue but is a challenge
54:12between both the development community
54:14and the energy providers we've had
54:16multiple projects and have examples
54:18where assumptions are made early in
54:20projects because they're unable to have
54:22the coordinated effort with the electric
54:24utility or they haven't been able to
54:26find a contact or process to do such
54:28which results in projects having
54:30incorrect assumptions on placement of
54:32cabinets on grid capacity on a variety
54:34of things that ultimately impacts design
54:36that may be multiple years in the
54:38process the process is not clear for
54:40many and the ability to engage early in
54:42the planning process is at best limited
54:45and developers therefore tend to take
54:47other sources outside of the electric
54:49utility to attempt to make these
54:52determinations that results in those
54:55that are less knowledgeable about
54:56specific issues about the system itself
54:59or are not necessarily reliable in the
55:01work to make determinations or
55:03recommendations that then cause projects
55:05to go in a direction that is ultimately
55:07not acceptable or feasible for the
55:09electric utility or the electric
55:12facilities that creates a really strong
55:14need for early contacts and coordination
55:17efforts and a responsiveness to those
55:19questions and comments that it needs to
55:21occur long before an application for
55:23connection to the system occurs to
55:25support these developments that are
55:26working towards meeting our Greenhouse
55:29house gas emission goals and building
55:33electrification we also see a challenge
55:35within the process of generic comments
55:37being issued that are not necessarily
55:39specific to the Project Specific to
55:41needs an example of these come out of
55:44plats where we'll receive very generic
55:45letters asking for exclusive easements
55:48that have a negative impact to the
55:49development and may not necessarily be
55:52appropriate or necessary for the
55:53distribution system
55:57further on in projects we see frequent
55:59challenges with just obtaining things
56:01such as meter releases so that the
56:03connections can be made be it for the
56:05brand new connection to the facility or
56:06for connection of the solar and find out
56:09that there are minor administrative
56:10issues that have created holds on these
56:12meter releases and these meter connects
56:14but the reasons are not necessarily
56:16clear they haven't been shared or
56:17communicated and in fact frequently the
56:20blame is pointed back at the city that
56:22we didn't do something that we actually
56:24did this creates delays to projects and
56:26frustration for our customers it becomes
56:28a challenge for us as we become that
56:30point of contact and that blame because
56:32they don't have another point of contact
56:34they can actually get specific
56:36information or ask about this those are
56:39examples of some of the challenges that
56:40we see again recognizing this is a joint
56:44effort that involves Cooperative effort
56:46between the development Community the
56:47local regulatory Community such as the
56:49city of Boulder and the private utility
56:52that need to be worked on and improved
56:54so that the processes work
56:56electrification can occur and people are
56:58able to move forward and meet the goals
57:00of our communities thank you for your
57:02time we appreciate the opportunity I and
57:05if there are follow-ups we are certainly
57:07willing and able to provide future
57:10testimony thank you Mr Stafford
57:13appreciate it and um if you do have
57:15those comments written or have specific
57:16examples you'd like um to provide us
57:19feel free to submit in writing um
57:21through our website or through e filings
57:24just as reminder we are getting to any
57:26members of the general public to relate
57:29individual experiences or to
57:31governmental entities or Representatives
57:34um in this phase of the public hearing
57:36so please do go ahead and raise your
57:37virtual hand if you're in that group and
57:39care to offer a comment um next hand I
57:43see up is Don
57:47coup hi commissioner Gilman uh thanks
57:50for uh giving an opportunity to speak I
57:52don't have any prepared comments but
57:54I'll uh
57:55I'm speaking as a resident of lower
57:58downtown um my name is Don coup first
58:01name is do last name is spelled KU uh
58:04I'm a resident of lower downtown and I
58:07wear a couple hats um I'm on the HOA
58:11board for larer place which is a 31
58:14story highrise Condo building right next
58:17to larer square and I'm also on the
58:20board for the lower downtown
58:21neighborhood
58:22association and we rep represent mostly
58:25the residents in the L downtown area
58:28which uh is composed of rough roughly 50
58:31condo buildings and and countless number
58:34of apartment buildings and I wanted to
58:37just talk about kind of my experience my
58:40experiences in both uh with lmer place
58:43and the neighborhood uh around working
58:46with Excel and um and trying in
58:49particular to meet a couple of other
58:50drivers that are hitting a lot of the
58:52residents uh in lower downtown one is uh
58:56you may have heard of the energized
58:58Denver ordinance that was passed last
59:00year so that's driving a lot of activity
59:04around uh trying to Electrify move off
59:07of natural gas uh and also you know
59:10reduce our energy consumption across a
59:13lot of buildings to meet uh you know
59:15certain targets that the city has set
59:18for various buildings uh the second
59:21driver is um you know kind of the the um
59:25the Advent of electron electric vehicles
59:28and the goal I think there's a Statewide
59:30goal to to uh you know vastly increase
59:34the adoption of electric vehicles
59:36manufacturers have started to just just
59:39manufacture those solely and have plans
59:41to do so and so those two things in
59:44particular are
59:45driving the need for many build
59:48buildings in in lower downtown and in
59:50our place at lur place especially to to
59:53try to add more electricity to our
59:55building and uh and what I've
59:57encountered for larl is that while we
1:00:00have some capacity now uh EXL has told
1:00:04us that we will run out of capacity uh
1:00:07when we U add you about 20 more uh
1:00:12Chargers and we have 100 we have
1:00:15170 units at lar replace and uh we we're
1:00:20currently working with Excel to add
1:00:22eight uh EV Chargers
1:00:25I mean if the if the projections are are
1:00:28from the state are um are accurate and
1:00:31that we think we're going to get to you
1:00:32know half of the people adopting EV cars
1:00:36you know by the year 2030 or so uh
1:00:38that's going to mean needing you know 80
1:00:41or more uh spots uh Chargers in our in
1:00:45our building and that's going to clearly
1:00:47exceed our current
1:00:49capacity and um and I've tried to get
1:00:52with Excel to figure out well how much
1:00:53capacity
1:00:55how how can we add more capacity and um
1:00:58haven't been able to get a great answer
1:01:00uh from them um so that that's uh my
1:01:04experience particularly at lmer Place uh
1:01:08secondarily uh with respect to the
1:01:10neighborhood I've heard anecdotally that
1:01:12there are a few other buildings that
1:01:14have also tried to uh bring electricity
1:01:17to their building and have been told by
1:01:20Excel that there's no capacity and so uh
1:01:23so their full already and um uh in fact
1:01:27one building Franklin LS had a plan in
1:01:30place to add a transformer into the
1:01:33alley uh behind their building and then
1:01:36at the last minute they were told that
1:01:38Exel wouldn't do that uh I think maybe
1:01:40for RightWay reasons or or what have you
1:01:43I'm not sure uh but um so so they're
1:01:47stuck as well um and I know Tim Jordan
1:01:50is on he spoke earlier as he's a he's an
1:01:53HOA board for for titanium lofs and he's
1:01:56had trouble getting electricity to his
1:01:58building as well uh and there's many
1:02:01other examples uh because everybody's
1:02:03trying to do this right everybody's
1:02:04trying to to add EV Chargers they're
1:02:07trying to move off of gas they're trying
1:02:10to do all sorts of things and and my
1:02:12overall concern is that we don't know
1:02:15kind of what the situation is with EXL
1:02:18being able to provide uh capacity to all
1:02:22of these buildings in the lower downtown
1:02:24area
1:02:25and and without any kind of plans you
1:02:28know we don't know how much might cost
1:02:30us we'd have to potentially try to pass
1:02:34assessments for homeowners in our condo
1:02:37buildings to try to pay for this we
1:02:39don't know what that might look like we
1:02:41don't know if there are federal or state
1:02:44grants that might apply to offset some
1:02:46of the infrastructure costs uh
1:02:49so we kind of feel like there's a lot of
1:02:52unknowns and it's hard to plan uh for
1:02:55what we need to do uh and what uh what
1:02:58we need to um you know plan to pay for
1:03:01or fund over the next 10 years uh so
1:03:06that's that's I want just to relay that
1:03:08and I think that there's it feels like
1:03:10that there is uh at least some capacity
1:03:14issues in parts of downtown and and
1:03:16exactly where it's hard hard to say and
1:03:18I'm I'm not sure how we can get more
1:03:20transparency into what the situation is
1:03:25those are all the comments I have thank
1:03:28you Mr coup very much appreciate it uh
1:03:30appreciate your insights and and
1:03:32expertise uh in the buildings you're
1:03:34working with
1:03:35there um let's see I had formerly seen
1:03:38another hand up in this group I don't
1:03:41see one right now so just offer anyone
1:03:43else from the general public or uh
1:03:46representing a local government or
1:03:48entity feel free to raise your hand now
1:03:51and I'll get to you in the order I see
1:03:53you um um now I see Allison
1:03:58Jones hi there sorry I'm trying to start
1:04:01my video um yeah I I am glad that I
1:04:06joined this call we are a multif family
1:04:08developer we're working on a project in
1:04:11wheat rdge right now um our civil
1:04:14engineer is HKS um engineering and
1:04:18they've joined the call as well they do
1:04:20a lot of work with private multif family
1:04:22developers here in the Denver area
1:04:25um we had an early capacity check or
1:04:28multiple early capacity checks from XL
1:04:32Energy that stated no issue with
1:04:35capacity for a project that we're
1:04:36working on in wheat rdge um if you guys
1:04:39are familiar with the American
1:04:41Motel um motel that's on I uh I70 that's
1:04:46the um project that we're working on um
1:04:49just last week this is you know almost
1:04:52to the point at which we're 100% uh
1:04:55complete with our project design and and
1:04:58electrical design for the for the
1:05:00project we got word from Excel that
1:05:02there's a capacity issue in the area um
1:05:06and that it's going to take 24 to 36
1:05:09months um for the design and for the um
1:05:13routing um of the or I'm sorry the
1:05:16construction of the feeder to the
1:05:18project so that so that we can get power
1:05:21to the new building um this puts the
1:05:24project at risk um not just from a
1:05:27Redevelopment perspective but puts um
1:05:30financing at risk um that we were hoping
1:05:33to get from the urban renewal Authority
1:05:35in wheat rdge which has to be um spent
1:05:39by November of next year so it's it's
1:05:42put a you know stop on that project and
1:05:45I you know we've had several
1:05:47conversations um with XL Energy and you
1:05:50know it's it's um been pretty much the
1:05:53same same result every time that um
1:05:57sorry get in line and nothing we can do
1:06:00to speed up the process and we're sorry
1:06:02we didn't catch this issue you know nine
1:06:05months ago before you spent you know a
1:06:07million dollars on plans and
1:06:09entitlements um which is a huge huge
1:06:11issue that we're spending that kind of
1:06:14money to get these projects entitled and
1:06:17then finding out so late in the process
1:06:19that there's a capacity issue so I just
1:06:22wanted to voice my opinion on that and
1:06:25I'm glad I joined this call and um I do
1:06:28think that our civil engineer HKS um
1:06:31they've got about 10 other projects in
1:06:33the metro area that are having this same
1:06:35issue and um it's it's really impacting
1:06:38our ability to get housing built so I
1:06:41don't know what the solution is but it's
1:06:43a big problem for us that's all I have
1:06:46thank
1:06:47you thank you Miss Jones I appreciate it
1:06:51um so I I will move um I kind of have
1:06:54these broad categories um we'll move on
1:06:57to builders and developers next that
1:07:00that was very helpful um so right now
1:07:03focusing on any members of the general
1:07:05public or those representing any
1:07:07governmental entity or or interest um
1:07:11after that I plan to open it up to
1:07:13builders or developers then uh solar
1:07:16interests and kosa then any de providers
1:07:21outside of just solar and then to
1:07:24utilities after that just to kind of
1:07:26organize Us in some categories so if I
1:07:29do have on any other members of the
1:07:31general public toay individual
1:07:33experiences or governmental entities uh
1:07:36I will take you next and I see Mr Jeff
1:07:41fer hi yeah apologies for dropping
1:07:44signal there earlier this is Jeff
1:07:49feed sorry M Lake County Commissioner um
1:07:54and I just wanted to say maybe in the of
1:07:55time I just the testimony and examples
1:07:59from cc4c from Denver from Boulder from
1:08:02other previous commenters all ring so
1:08:05true up here in our Mountain Community
1:08:08uh in Lake County and just time and time
1:08:10again this kind of incremental reactive
1:08:14approach to being able to serve uh
1:08:17whether it's rooftop solar or putting in
1:08:19an EV charger um you know or trying to
1:08:23go all electric as a large Municipal
1:08:25Building you know it just
1:08:27comes uh you know that that um large
1:08:31incremental cost if you're unlucky to
1:08:34exceed the grid
1:08:35capacity um on the distribution grid
1:08:38just puts a hole to trying to do the
1:08:40right thing and be aligned with the
1:08:43state's climate and clean energy goals
1:08:45um and I wanted to add one other thing
1:08:48having been through this both as an
1:08:50individual uh trying to build a new
1:08:53County building previously on
1:08:56Schoolboard there's a real lack of
1:08:58information so all these examples
1:09:01someone knows to ask about going all
1:09:04electric or do beneficial
1:09:06electrification or put an EV charger but
1:09:08if you don't even know to ask that
1:09:10question or consider it the point of
1:09:14contact with Excel is not asking you to
1:09:17consider that option it's just not being
1:09:19raised
1:09:21proactively to undertake beneficial
1:09:23certification and there's a huge missed
1:09:26opportunity for Education um and helping
1:09:29people think through those pros and cons
1:09:33um and I really encourage along with
1:09:35that bigger issue of how to upgrade the
1:09:38distribution grid is getting the
1:09:41utilities um to proactively work with
1:09:44consumers to consider these options
1:09:46because right now that is just not
1:09:48happening and specifically we're about
1:09:50to replace our largest single municipal
1:09:53building our
1:09:54courthouse and if I hadn't asked about
1:09:58an all electric option and rais $50,000
1:10:01of our own money to do the energy
1:10:04modeling it wouldn't be on the table and
1:10:06that's just again just a huge missed
1:10:09opportunity for these large municipal
1:10:11buildings um and more broadly you know
1:10:14consumers to uh try to pursue beneficial
1:10:18artification so thank you for taking the
1:10:21time I really appreciate it thank you
1:10:23thank you so
1:10:24much question Megan I didn't he said how
1:10:28much money did he raise I heard it two
1:10:30or 3,000 to do the electrification I
1:10:32didn't get that
1:10:34number I uh we we got a DOA grant for a
1:10:38total of $50,000 five z00 Z that was my
1:10:44question sorry kind of got
1:10:47thanks thank you and thank you Harry we
1:10:50want to be sure we properly record uh
1:10:53anyone remarks we got thank you so much
1:10:55for adding that um next I see Jacqueline
1:11:03kikio thank you so much commissioner
1:11:05Gilman this is Jackie Kiki on behalf of
1:11:07Colorado energy office I feel like we
1:11:09probably fit in this particular bucket
1:11:11of governmental entities so thank you so
1:11:13much for for letting me speak um I just
1:11:15wanted to ask if it is okay that we go
1:11:18out of order from your buckets given
1:11:19that Mr Haye wanted to speak today and
1:11:21he is at a conference in another time
1:11:23Zone um and he will be joining a little
1:11:26bit later in this window of time that
1:11:28you all have scheduled for public
1:11:29comment yeah surely not not a problem
1:11:31thanks for the heads up this was just to
1:11:33kind of roughly organize us and keep us
1:11:35uh in certain topics and groups but um
1:11:38when Mr haye's available he can pop on
1:11:41and raise his hand when he thinks it's
1:11:42appropriate as we're going much
1:11:44appreciated commissioner Gilman thank
1:11:46you thank
1:11:48you all right um probably one last call
1:11:51for anyone joining uh from the general
1:11:54public to relate individual experiences
1:11:56or anyone representing a governmental
1:11:59entity or
1:12:01group um if and if not if someone joins
1:12:04later just over with Miss Kio would be
1:12:07fine for folks to raise their hands um
1:12:10whenever they are
1:12:13available yeah Mr
1:12:16Jordan yeah hi I sorry I didn't raise my
1:12:20hand electronically but I I wanted to
1:12:22Echo what Don cou earlier ADV voiced
1:12:24just in on behalf of a residential
1:12:27Community here in Denver it's we're
1:12:29being faced with conflicting demands
1:12:31energized gender is telling us we need
1:12:33to reduce our energy usage and much of
1:12:35that would require converting from
1:12:37natural gas to electricity but on the
1:12:40flip side we're being told by Exile that
1:12:42we have no
1:12:43capacity and energized Denver has some
1:12:46huge fines if we don't meet their
1:12:47standards but on the other hand we can't
1:12:49do it because of that limitation and we
1:12:52also really want to get on board the EV
1:12:55um transition but we also can't do that
1:12:57because there's zero capacity for that
1:12:59and so we're really in a very awkward
1:13:01spot and just don't know where to go or
1:13:03who to help help mediate the situation
1:13:06so really like I say I'm really echoing
1:13:08what Don has said earlier but uh it's a
1:13:10really critical issue down in uh lower
1:13:13downtown Denver Thank
1:13:16you thank you Mr Jordan uh appreciate it
1:13:21um and and thank you for joining on your
1:13:23phone I know it's a little more
1:13:24difficult but you came through loud and
1:13:26clear um next I see Mr David lad
1:13:32ladic good choice I'm just uh gonna Echo
1:13:36Don and Tim's points about the downtown
1:13:38stuff I think that the legislature needs
1:13:41to see this not just in Denver but in
1:13:42other cities um as well as being a good
1:13:46um way to push people out of living in
1:13:48cities if they want to do that because I
1:13:51think that these kinds of conflicting
1:13:53Dem demands will continue to drive
1:13:55Builders and developers as well as those
1:13:57of us who are residents in these areas
1:13:59to look for other opportunities if we
1:14:01can't find these needs being met and
1:14:04find a good way to have some sort of
1:14:06balance so just want to as a third
1:14:09person just Echo those comments again
1:14:11and make sure that they're heard
1:14:12multiple
1:14:15times I appreciate that thank you um Mr
1:14:19ladic um anyone else representing um
1:14:23individual experiences or governmental
1:14:27entities okay next I'd like to move on
1:14:29to any Builders development or kind of
1:14:33construction professionals outside of I
1:14:36say save solar and deers which we will
1:14:39get to after this so more General
1:14:42construction um experience for
1:14:45practitioners um go ahead and raise your
1:14:46hands I'll get to you in the order I see
1:14:49you first I see Molina
1:14:52Saunders
1:14:53yes good afternoon I'll get my camera
1:14:55going here thank you for the opportunity
1:14:58to speak I'm Molina Saunders me i n a s
1:15:02u n d RS um I am a senior project
1:15:06manager at AE design here in Denver um
1:15:09we are an electrical technology and
1:15:11lighting design firm um so we work on
1:15:14electrical engineering projects locally
1:15:15and across the us us um recently we've
1:15:19been working on multiple electrification
1:15:21projects within the Denver area driven
1:15:24largely by the sustainability goals of
1:15:26our firm our clients and you know our
1:15:29state um and local jurisdictions um our
1:15:33process has always been to coordinate
1:15:35with the utility companies early in an
1:15:37effort to make sure the capability and
1:15:39the capacities there and also limit
1:15:41unexpected costs for our customers as
1:15:43early as possible um on coordination the
1:15:47early timing has always been a challenge
1:15:49with Excel but has grown increasingly
1:15:51challenging given their expectation is
1:15:53that our design is complete 100% CDs um
1:15:57for construction documents before they
1:15:59even start their engineering um this is
1:16:01Impractical given the large equipment
1:16:03elements that we have to coordinate
1:16:05around in design um both on site as well
1:16:09as capacity um as well as permit and
1:16:13calculation requirements that we as
1:16:15design Engineers have to coordinate and
1:16:16evaluate um before we even get to that
1:16:19construction document stage um now with
1:16:22the electrification go
1:16:23uh there are greater impl implications
1:16:26for operating conditions um that impact
1:16:29the Utility side regarding a shift in
1:16:31the peak timing throughout the year and
1:16:33overall increased electrical load um so
1:16:36even if we're doing working on a
1:16:38renovation project as an example um the
1:16:42actual uh functionality of that
1:16:44electrical system that um profile
1:16:47changes so on a typical project where we
1:16:50may not have even reached out to excel
1:16:52because we're still within the capacity
1:16:54of that Transformer um now we're needing
1:16:57to do that because with the profile
1:17:00change we are concerned about the
1:17:02capacity issues that have been expressed
1:17:05um so while we continue to push for
1:17:08earlier coordination with them um and do
1:17:10try and have those conversations still
1:17:12in an early manner a more concerning
1:17:14issue um that recently arose with one of
1:17:17our larger clients they're they have a
1:17:19multi-building system on on a large
1:17:23medium voltage Loop um they were hit
1:17:26with the infrastructure Improvement
1:17:27charges as part of these early
1:17:29coordination discussions um that looked
1:17:32like we shared very very early
1:17:34information for our you know on behalf
1:17:36of our client um and after months of
1:17:39trying to get the right people in the
1:17:41room for this Excel conversation um we
1:17:44shared the plan for their first three
1:17:47buildings that they're looking to
1:17:49Electrify um Coming online that are
1:17:51currently early in design we're in
1:17:53schematic design and design development
1:17:55phases um Excel communicated at that
1:17:58point that the customer would have to
1:17:59pay over $1 million a sixf figure number
1:18:02um for improvement charges um because
1:18:05they were the client that pushed the
1:18:07forecasting over the allocated capacity
1:18:10on set infrastructure um it was
1:18:13resulting in the need to replace a
1:18:15feeder um so similar to some another
1:18:18commenter earlier um when we asked about
1:18:21cost sharing opportunities because there
1:18:23not the only customer on that feeder um
1:18:26they were we were told that cost sharing
1:18:27was not an option uh sixf figureure
1:18:30number well exceeds anything that our
1:18:33client had planned for these projects
1:18:35and they are a large client so um while
1:18:38they may have better financial means to
1:18:40potentially find the funding for that um
1:18:45it it's a large number and they are very
1:18:47concerned about being able to get that
1:18:49funding in place in order to continue
1:18:51with our construction project
1:18:53uh Excel also noted that this needed to
1:18:55be paid before the Improvement can be
1:18:57made and that that process um could hold
1:19:00up our timeline overall and ultimately
1:19:03that there's no guarantee that once that
1:19:06Improvement is made capacity will remain
1:19:09for the second building planned in this
1:19:12project to come online given that the
1:19:14construction schedule is a few years out
1:19:17um Excel did note that they offer a
1:19:19discount in anticipation of the other
1:19:21users but only at a rate of about
1:19:2435% um this sixf figure cost will land
1:19:28many other project Types on hold and
1:19:31even put some at Full Stop um we in the
1:19:34industry sometimes call this a project
1:19:36killer um it's a challenge that many
1:19:39projects may not be able to overcome the
1:19:42financial burdening is unclear project
1:19:44owners have no means to anticipate it
1:19:47and the format feels as though larger
1:19:49clients are also unfairly carrying the
1:19:52weight of Improvement shared by others
1:19:54when they are able to find a means to
1:19:56afford these costs um overall we'd like
1:19:59more transparency regarding regarding
1:20:01cost distribution to customers um we
1:20:04would ask how can Excel as an
1:20:06engineering partner help to provide more
1:20:07clarity consistency and how their these
1:20:10costs are applied um how do we help the
1:20:12owners uh to identify these costs before
1:20:15we as a design team may even be involved
1:20:18for both establishing a budget and
1:20:20raising funds we feel strongly that the
1:20:23lack of clarity and large Financial asks
1:20:25for these improvements will continue to
1:20:27be problematic until changes are made
1:20:29and the clients re represent for their
1:20:31sustainability plans for their
1:20:34projects uh we need proactive action by
1:20:37Excel Energy to support the
1:20:39electrification goals and requirements
1:20:40of adopted codes and Community
1:20:42sustainability initiatives that us as
1:20:44engineers and designers are required to
1:20:46designed to and our clients are expected
1:20:48to develop to um and as was mentioned
1:20:51some of these expect expectations may
1:20:53come with fines if they're not meeting
1:20:55these so um that's that's my summary I
1:20:58appreciate the opportunity um to speak
1:21:01and thank you for the time and
1:21:03consideration Miss Saunders thank you so
1:21:05much for your time and for your comments
1:21:07appreciate it um next I have Daryl
1:21:10Shriner shriner I'm just trying to be
1:21:13equal opportunity and mess up everyone's
1:21:15name that's great my name is Daryl
1:21:17Shriner I am a um director of
1:21:19construction for a big company we do d r
1:21:22re l l s c re i n e r and we do a very a
1:21:28lot of affordable housing we are in the
1:21:30process right now of a 250 unit project
1:21:34uh and we've started it and we have had
1:21:36issues with EXL energy especially on
1:21:39electrification and especially getting
1:21:41the um you know all the P the the power
1:21:45to us which is three or four miles away
1:21:47and it is a six and seven figure number
1:21:50that that is really hard to work with
1:21:51but I have found
1:21:53uh that once they give you the numbers
1:21:55and they work with you a little bit some
1:21:57of those numbers do come down when
1:21:58you're on site but we are dealing with
1:22:01those issues they're incredibly hard to
1:22:03deal with um we're worried about making
1:22:06sure that we're going to get our
1:22:08closings on time making sure that people
1:22:10can rent and you know in the affordable
1:22:12area you have to start leasing way in
1:22:14advance and start working with people to
1:22:17get them involved and get them into your
1:22:19units and this is something that um is a
1:22:23little scary for us we're pushing hard
1:22:24we have decided to have weekly meetings
1:22:28with the EXL people that we're working
1:22:30with and they have been good to meet
1:22:32with us and help us understand some
1:22:34things and and we help them understand
1:22:37some things that we need done uh to get
1:22:40people moved in so I agree with
1:22:42everything that everybody has said
1:22:44everyone has brought up some great
1:22:45things that need to happen I think the
1:22:48biggest thing is
1:22:50communication and um sometimes people
1:22:52are afraid to talk to each other or
1:22:54visit with them and everyone wants to do
1:22:56it on zoom and doesn't want to do it
1:22:57face to face you can tell I'm an old guy
1:23:00I like meeting face to face I like
1:23:02talking to people and I I think if we
1:23:05can help Excel and everybody understand
1:23:07that which we're working to do and get
1:23:10people to get started on communicating
1:23:12on why we're having these problems what
1:23:14we need to do to solve it because I
1:23:16don't I think everybody is talking about
1:23:18the problem uh I think what we need to
1:23:20do is figure out how do we solve solve
1:23:22these issues how do we sit down together
1:23:26and make these things work because we
1:23:28have to compel those events to happen we
1:23:31can't just watch them happen and and so
1:23:33those are the things that we're dealing
1:23:35with like I say we're right in the
1:23:37middle of a 250 unit Apartment project
1:23:40all affordable that's what we mostly
1:23:42build and it's a struggle and it's a
1:23:44little nerve-wracking but thank you uh
1:23:48Megan for having this meeting and and
1:23:49listening to all the things I won't say
1:23:52everything is going to say almost the
1:23:53same thing about what we're saying but I
1:23:56just want to thank you guys for uh
1:23:57letting us come in and talk and be a
1:23:59part of this because it is a big problem
1:24:02and we need to all reach out and figure
1:24:03out how to solve it so thank you very
1:24:05much thank you so much really appreciate
1:24:08your comments um and next I have Kyle
1:24:16sundman uh good afternoon commissioner
1:24:18Gilman uh thank you for hosting this
1:24:20meeting uh the name my name is spelled k
1:24:23y l s u n d m an um I representing uh
1:24:27pivot energy we're a national Community
1:24:29solar developer with a strong Focus um
1:24:31and actually headquartered here in
1:24:33Colorado as the senior director for
1:24:35project development um obviously we've
1:24:38heard a number of of challenges that
1:24:39various stakeholders have experienced
1:24:41and uh we have a number of our own to
1:24:43share as well um we will submit written
1:24:46comments in addition so I I'll keep my
1:24:48comments brief and Broad and focused on
1:24:51a few key points which which uh would be
1:24:53data quality transparency and cost
1:24:56sharing so you know just as a broad
1:24:59point I'd like to I'd like to start by
1:25:02saying that we do think that you know
1:25:03Public Service Company can and should
1:25:04conduct sort of internal reviews to
1:25:07improve processes and adequately
1:25:09resource their teams and we also
1:25:11recognize that you know they may not be
1:25:13empowered to make all of those changes
1:25:15without some support from the commission
1:25:16so certainly we'll uh hope that that
1:25:19they do receive that support through
1:25:20this proceeding and in many cases just
1:25:23to acknowledge we we have found Excel to
1:25:25be a willing and collaborative partner
1:25:27especially on the indiv you know
1:25:29individual contributor
1:25:30level um with that said we we do
1:25:33continue to experience systematic data
1:25:35quality issues throughout the entire
1:25:36interconnection process and and by the
1:25:39way I'm speaking mostly on the community
1:25:40solar side of of Solar Development here
1:25:43um but this can present as inaccurate
1:25:46system impact study results with the
1:25:48Quantum of error between system impact
1:25:50and facility study being literally
1:25:52millions of dollarss um all the way down
1:25:55to sort of simple but meaningful
1:25:57clerical errors on the delivery of final
1:26:00executable documents where inaccuracies
1:26:03are are found throughout the
1:26:04interconnection agreements which we
1:26:06believe just sort of demonstrates a lack
1:26:08of qaqc um at the program level on the
1:26:12issue of transparency when some of these
1:26:14aforementioned issues in the system
1:26:15impact studies present we're looking to
1:26:17further understand the calculus the
1:26:20inputs and the rationale uh we often
1:26:22receive few and and vague answers and uh
1:26:26have also been told very directly that
1:26:29we don't need that information and Excel
1:26:32will not be providing it uh which is you
1:26:34know unfortunate and lacks sort of good
1:26:37faith and collaboration in our minds you
1:26:39know most markets there is transparency
1:26:41in the study results processed through
1:26:42the interconnection and you know a far
1:26:44more detailed interconnection agreement
1:26:46is provided with a facility study
1:26:49whereas in Colorado the interconnection
1:26:51agre agreement itself has a single line
1:26:55of the overall cost estimate for the
1:26:57upgrades with no further information
1:26:59about how that number was reached uh
1:27:01what what you know was considered how
1:27:03procurement Works
1:27:05Etc um lastly as renewable energy
1:27:08generation continues to to increase in a
1:27:10penetration sense uh we'd like the
1:27:12commission to consider directing the
1:27:13company to investigate cost sharing
1:27:16strateg strategies that support general
1:27:19grid infrastructure upgrades uh may also
1:27:21align with planned improvements in
1:27:23various areas in the state um you know
1:27:26we're we as developers are more than
1:27:27willing to pay our fair share to upgrade
1:27:30the utility grd on behalf of our
1:27:31projects but much as much like you've
1:27:33heard with some of the residential
1:27:35issues where whoever is unlucky enough
1:27:37to get hit with the major upgrade will
1:27:39need to pay it for everybody else you
1:27:41know we think on the kind of community
1:27:43solar level that creates inequities and
1:27:45unnecessary roadblocks to development um
1:27:49you know there's a great opportunity
1:27:50here for the company to Bear a portion
1:27:52of the upgrades um where the you know
1:27:56created but unused capacity can be then
1:27:59used by another developer and the
1:28:01company can be reimbursed you know
1:28:02perhaps there's a nominal carry fee for
1:28:04doing so but a way that allows projects
1:28:07to to move forward without you know
1:28:09always being in Long uh you know cluster
1:28:12studies that require collaboration not
1:28:14with not only with everybody in q but
1:28:16also you know the utility itself um so
1:28:19like I said we'll follow up with some
1:28:20additional written comments as well but
1:28:22want to thank you for your time um and I
1:28:25guess a quick question for you is is
1:28:26there a deadline for when you want those
1:28:28written comments to be
1:28:31submitted no I do um you this better
1:28:35with we um kind of first condu the study
1:28:39portion as a response to 291 looking at
1:28:41barriers to and Dr deployment um and
1:28:46then there will be some other phases of
1:28:47this proceeding that outlive that study
1:28:50um so I think as as soon as you are uh
1:28:54able are you able to hear
1:28:57me it's a little choppy but my the
1:29:00takeaway was as soon as possible so
1:29:02understood I turn my video off sure uh
1:29:05so the sooner you get comments in
1:29:07obviously the more of this proceeding
1:29:09and the more of the study will be able
1:29:11to take into consideration what you've
1:29:14provided um vers the alternative it
1:29:16comes in later so um we don't have a
1:29:20hard but the sooner the the more we'll
1:29:23be able to consider
1:29:24it okay thank you for your
1:29:27time and apologies again for my internet
1:29:31um of course as luck would have it it's
1:29:33on its Worst Behavior today um so just a
1:29:36reminder you can hear from Builders
1:29:38developers other building professionals
1:29:41I'll plan to have kosa and some solar
1:29:43focused interests go after that then
1:29:46other de providers and then utilities um
1:29:50just keep us organized a bit if if folks
1:29:52are able so next I see on my list um
1:29:55Miss Miss Melissa St and uh I'll see how
1:30:00it's going hope I turn my camera back on
1:30:02if it seems like the internet can handle
1:30:05it hello I'm Alissa stuie uh m l i
1:30:11SSA last name
1:30:13stube with Urban Ventures development
1:30:16services um I Echo what everybody else
1:30:18has said thanks so much for inviting us
1:30:20here to uh
1:30:22um talk through our recent experiences
1:30:24in getting electrical service for new
1:30:26Housing Development um in the context of
1:30:31uh the development that I'm talking
1:30:32about we're dealing with challenges of
1:30:35bearing the financial responsibility of
1:30:37existing grid limitations as well as um
1:30:41challenges around the lack of
1:30:43availability of accurate and timely
1:30:45information about the available existing
1:30:47service so the project that I'm talking
1:30:50about um
1:30:52is 89 units serving single parent
1:30:54families exiting homelessness it's in
1:30:56the heart of Denver it's it's on Alama
1:30:59it's about a third of a mile from the
1:31:00south Plat River so we're right smack in
1:31:03the middle of town um it is a low-income
1:31:06housing tax credit project um so major
1:31:09source of the funding is the federal tax
1:31:11credit program so there's really strict
1:31:13um timing Milestones uh with associated
1:31:17with that funding source as well as the
1:31:19support that we're receiving from the
1:31:21city and the state to uh to provide this
1:31:24housing um and this project does align
1:31:27with the city's homelessness state of
1:31:29emergency since those are the uh
1:31:31families that we're going to be serving
1:31:33at this at this property so um just a
1:31:36quick little outline of um of what we've
1:31:39experienced with this project um in
1:31:42March of 2022 we submitted um our city
1:31:47concept and that went to excel as well
1:31:49and no comments were returned um fast
1:31:52forward we submitted our liag
1:31:54application and right after that um we
1:31:58sent a message out to excel to request
1:32:00the level of existing Gas and Electric
1:32:02Service um having heard some some
1:32:05murmurs of stories of projects not not
1:32:07having appropriate and adequate service
1:32:10service levels uh wanted to reach out
1:32:13early very early on and um that was
1:32:16September of 2022 didn't really hear
1:32:19anything back substantial back um from
1:32:22them and until December and we found out
1:32:25in December that we would need
1:32:27reinforcement for the electricity
1:32:28portion um but they weren't able to
1:32:31provide a ballpark estimate and we also
1:32:33didn't understand that the project would
1:32:35be um on the hook for the cost of that
1:32:39so we continued to reach out and um
1:32:41trying to get more details and a project
1:32:44budget um and then in May so this is
1:32:48over a year after it was our concept
1:32:51submitt was sent to excel from the city
1:32:55um we were able to get get some time on
1:32:58the phone to chat with some folks have a
1:33:00casual conversation about the project
1:33:02and that was only the first time that we
1:33:05really understood the scope of the
1:33:07reinforcement um that the existing power
1:33:10at the site was enough to maybe power
1:33:12two small single family homes and um you
1:33:16know we are headed towards the Finish
1:33:17Line to to break ground on 89 units um
1:33:22so we found out we would need a feeder
1:33:24run from about a mile and a half away
1:33:26and through this process our the
1:33:28designer that was assigned to our
1:33:30project has been very pleasant and very
1:33:32responsive and so we've been really
1:33:34grateful to have have him on our team um
1:33:37we did not have a final um final budget
1:33:42for it or design and we had to push
1:33:45through our litec closing so that we
1:33:47could break ground and um get some
1:33:49housing built for homeless families so
1:33:52um beginning of August this year we
1:33:54closed and we received our design and
1:33:57cost for the offsite reinforcement the
1:34:00end of August so it came in at a little
1:34:03under $400,000 it's less than what we
1:34:05heard through the Great Vine that it
1:34:06would be but it's still Way Beyond what
1:34:09this project has a budget for so um and
1:34:13I think that one of the key points is as
1:34:16developers we're used to paying for
1:34:18Transformers and on-site distribution so
1:34:21Urban ins has been around for 25 years
1:34:23and we've never had to pay to bring
1:34:25power to the site within the city so
1:34:27it's especially troubling when it's an
1:34:29affordable housing development um so we
1:34:32all can understand that it really it's
1:34:35really apparent that Excel is running
1:34:37out of capacity to deliver electricity
1:34:39within the city and it's very
1:34:41frustrating that the last development to
1:34:43go over the grid capacity in an area
1:34:45seems to be the one that is on the hook
1:34:48to Bear the brunt of the cost of the
1:34:50infrastructure Improvement
1:34:52um seems to be a um pretty flawed policy
1:34:56that is is not does not provide equality
1:34:59and particularly when we're all working
1:35:01collaboratively to meet all electric
1:35:03goals and the role the dice just happens
1:35:06to land on an affordable housing
1:35:07development that already has a tight
1:35:08budget to provide social benefits to our
1:35:11community so um really grateful that
1:35:14you've invited us here to to share our
1:35:17experiences and hopefully work towards a
1:35:20solution
1:35:23thank so much really appreciate it and I
1:35:26apologize for having my video off but
1:35:29I'm I'm on the edge of good enough
1:35:31internet so I don't want to blow it um
1:35:34next I have on my list Austina REM
1:35:41remedios hello um thank you and
1:35:44hopefully the background noise isn't too
1:35:46much um my name is Austina ridos I am
1:35:50with the neighborhood Development Club
1:35:51collaborative we're a coalition of 22
1:35:53affordable housing providers working
1:35:54across the Front Range primarily in the
1:35:56Denver metro area with some of our
1:35:58members in um serving across
1:36:01Colorado uh my comments today are
1:36:04regarding the ability of EXL energy to
1:36:06support the housing need in Colorado
1:36:08it's no exaggeration to say that the
1:36:10current XL policy represents one of the
1:36:12most acute barriers standing in the way
1:36:14of creating critically needed affordable
1:36:16housing we are specifically focused on
1:36:18the importance of transparency in
1:36:20service capacity and substation sighting
1:36:22as well as the overall cost of AFF cost
1:36:24to affordable housing developers
1:36:26electricity provision is a crucial
1:36:28component to our community's
1:36:29infrastructure and understanding cost
1:36:31implications and operational details is
1:36:34essential to us for as affordable
1:36:36housing developers to improve the
1:36:38situation we have three specific apps um
1:36:42with regards to impact on affordable
1:36:43housing since 2019 the cost for
1:36:46substation capacity has been split
1:36:48between developers in XL into 6535
1:36:51division this flat rate applicable to
1:36:53all developers needing capacity upgrades
1:36:56serves as a regressive cost that
1:36:58affordable housing developers must bear
1:37:00the margins for building affordable
1:37:02housing are much Slimmer than those of
1:37:04market rate housing thus the cost of
1:37:06major infrastructure upgrades can easily
1:37:08exceed the funding available through the
1:37:10revenue and subsidies millions in
1:37:12unforeseen costs and years of delays are
1:37:15not just an inconvenience they stop
1:37:17affordable housing development tracks um
1:37:20and actually with that I wanted to Echo
1:37:21some of what other folks had said and
1:37:23what Claire had mentioned earlier some
1:37:25of those examples are um almost exactly
1:37:28to a te of what some of our members have
1:37:30been facing so with this we ask that
1:37:33other members uh or we ask that other
1:37:35means of offsetting these costs to be
1:37:37explored for Community serving
1:37:39development especially affordable
1:37:40housing development this could be in the
1:37:42form of a cost split that puts less
1:37:44burden on the developer waivers for
1:37:47infrastructure Investments or private
1:37:49Public Partnerships that can offer
1:37:51subsidies for affordable housing
1:37:53development um with regards to
1:37:55collaboration for transparent service
1:37:58capacity in recent years our members
1:38:00have received will serve letters which
1:38:02have previously been understood to mean
1:38:04that the provider has adequate capacity
1:38:06to serve the new development more recent
1:38:08letters have been clarified to mean we
1:38:10are willing to serve you if you bear the
1:38:12cost of new infrastructure needed to
1:38:13generate electricity for this life this
1:38:16results in a very late in the game
1:38:18unplanned expenditure that is impossible
1:38:20to budget for during the development
1:38:23planning Early Access to accurate
1:38:26information about the capacity of exist
1:38:28existing substations is critical for our
1:38:30plan with this we asked Excel should
1:38:34clarify capacity earlier in the review
1:38:36process being able to provide a
1:38:37likelihood that service will be
1:38:39available during the concept review
1:38:41phase of building permit process with
1:38:43Aid affordable housing developers in
1:38:45assessing the financial viability of
1:38:46their plans before sinking millions of
1:38:49dollars into predevelopment expenses
1:38:51and then lastly citing transparency it
1:38:54is critical to implement transparent and
1:38:56Community engaged processes for
1:38:58substation sighting ensure that
1:39:00communities especially low to moderate
1:39:02income communities who have historically
1:39:04borne the brunch of infrastructure
1:39:06externalities have a voice in the
1:39:07decision-making process a lack of
1:39:10transparency and substation sighting can
1:39:12only benefit the service provider or the
1:39:14market rate developer with resources to
1:39:15push new substations offsite allowing
1:39:18the community we have to ask more of a
1:39:21voice in these decisions is absolutely
1:39:24crucial we ask for the development of a
1:39:27public process to coordinate input from
1:39:29Community developers and affected
1:39:31jurisdictions to determine Equitable
1:39:33sighting selection for new substs ensure
1:39:36that this process is not just informing
1:39:38the public of decisions already made but
1:39:40that it allows for Meaningful feedback
1:39:42Creative Solutions and the elimination
1:39:44of externalizing impacts on the lowest
1:39:46income residents um in conclusion the
1:39:50cost and transfarency transparency of
1:39:52substations and line extension
1:39:54infrastructure management plays a
1:39:56significant role in our ability to
1:39:57provide affordable housing options for
1:39:59our community the less Equitable this
1:40:02system is the less empowered we are to
1:40:04meet cral affordable housing and other
1:40:07community we urge all stakeholders to
1:40:09work collaboratively to find Innovative
1:40:11and costeffective solutions that allow
1:40:13us to continue our mission and offering
1:40:15affordable and safe housing to those who
1:40:17most need it um and there was one more
1:40:19thing that I wanted to had to um the
1:40:22impact on affordable housing in the 6535
1:40:25division split that was enforced in 2019
1:40:28is that prior to that we've learned that
1:40:31um the cost of the substation was born
1:40:35uh uh the person who first initiated the
1:40:38cost of a new substation would bear the
1:40:39brunt of that cost and then other
1:40:41developments to follow who would benefit
1:40:43from that substation would then pay back
1:40:46um that original person I think
1:40:49something along those lines would also
1:40:51be beneficial or bring back some system
1:40:54in that way in addition to the comments
1:40:55that I gave her that before um thank you
1:40:58so much time for your time and
1:40:59perspective on this and we really
1:41:01appreciate all the work that you're
1:41:04doing thank you Mr medo appreciate your
1:41:08comments um next I have missman Miss
1:41:11Herman before I go to you a reminder any
1:41:14build developers those kind of outside
1:41:17of specifically solar and deers who wish
1:41:20to comment
1:41:21um please go ahead and raise your hand
1:41:23and I will get to you as soon as we're
1:41:25done with Miss Harmon go
1:41:27ahead great thank you very much
1:41:30commissioner Gilman and thank you for
1:41:31this hearing I'm Sarah Harmon senior
1:41:34vice president at Urban Land Conservancy
1:41:37my name is spelled s a r a h a r m an
1:41:42Urban Land Conservancy is a 20-year-old
1:41:45nonprofit real estate company working
1:41:47across metro Denver we ensure affordable
1:41:50housing affordable nonprofit space and
1:41:52other amenities are built and preserved
1:41:54in historically underinvested and
1:41:56gentrifying communities we don't work on
1:41:59market rate development we are focused
1:42:01entirely on meeting the needs of
1:42:03underserved communities in the housing
1:42:05and real estate crises our neighbors and
1:42:07neighborhoods are facing we also put
1:42:10high priority on um environmental
1:42:13sustainability on electrification solar
1:42:16and we've invested also in geothermal
1:42:19for 20 years we've worked effec ly with
1:42:21EXL energy as our local power utility we
1:42:24have trusted EXL for our power just as
1:42:26they've relied on us as consumers I
1:42:29would like to share with you a specific
1:42:31development experience um we are in the
1:42:33midst of right now and before I get into
1:42:35that I would like to say that Excel has
1:42:37some exceptionally talented people on
1:42:40the ground in middle management and
1:42:42design engineering and in leadership so
1:42:44ulc would like to see that Colorado
1:42:47talent and Colorado Workforce is
1:42:49preserved grown and strengthened
1:42:51we are concerned that we must ease the
1:42:54impossible situations and inherent
1:42:56conflicts that many of these Excel staff
1:42:59today seem to be working
1:43:01on so to a specific development ulc is
1:43:04currently in pre-development for the
1:43:06Irving at Mile High Vista this is 102
1:43:09affordable Apartment Homes being
1:43:11developed on West kfax affordable
1:43:13housing Finance is complex and highly
1:43:16competitive last year on the basis of no
1:43:19objections being raised in our proposed
1:43:22developments concept review for which
1:43:24Excel is a reviewer we then competed for
1:43:27and successfully won a coveted lowincome
1:43:30housing tax credit Award with M matching
1:43:32State credits this was both an honor to
1:43:34the development and enabled a financing
1:43:37tool necessary to build this housing
1:43:39that was last year this summer our
1:43:42development team was noticed uh was
1:43:44given notice through one sentence in an
1:43:47otherwise normal email that no power
1:43:50would be available to our site to our
1:43:53apartment building until
1:43:552027 this unexplained statement stood to
1:43:58derail 10 years of ulc investment of the
1:44:01site in land acquisition in brownfields
1:44:04remediation entitlements Community
1:44:07engagement phase development and our
1:44:09current current building design and site
1:44:11planning not to mention disrupt our
1:44:14financing um we had been positioned to
1:44:17house 102 families and individuals with
1:44:20income spanning 20% area median income
1:44:23to 80% area median income these are the
1:44:25very people who keep our city our
1:44:28schools our hospitals and our utilities
1:44:30operating so we quickly mobilized
1:44:33response to work through every channel
1:44:35we could find um this was a crisis it
1:44:37felt desperate and our development has
1:44:40hung in the balance we needed to
1:44:42understand the facts of the situation
1:44:43which are um have not been that easy uh
1:44:46to determine at the start we sought to
1:44:48turn over every stone to bring new and
1:44:50creative resources to the problem and to
1:44:53identify any possible solutions we know
1:44:56that making housing people can afford in
1:44:58Denver is a high priority it's Civic
1:45:00it's Humane and it's necessary we are on
1:45:02a mission to do this it has not yet been
1:45:05confirmed by Excel Engineering but it is
1:45:08possible that a combination of political
1:45:10advocacy and creative thinking including
1:45:12by their system staff may give us a
1:45:15sliver of a chance to get this
1:45:17development built this 102 affordable um
1:45:20Apartments to say that we are on a
1:45:23couple week countdown in survival of
1:45:25this development is not an exaggeration
1:45:27it's painfully accurate as we're trying
1:45:29to balance the pressures of Housing
1:45:31Development with our financing Awards
1:45:34where market rate developers may be able
1:45:36to adjust their budgets and pass on um
1:45:39sudden unexpected costs including the
1:45:41costs of delay because delay is very
1:45:44expensive um affordable housing cannot
1:45:47do that as I think you've just heard
1:45:49we're restricted in the uptick of our
1:45:51rents um our operational budgets are
1:45:54constrained and we have hard uh
1:45:57deadlines uh to meet for our Federal
1:46:00Financing so if we can by excel's Graces
1:46:03creativity and everyone coming together
1:46:06just squeak through to build the Irving
1:46:08at Mile High then we have to ask what's
1:46:11next Urban Land Conservancy owns other
1:46:13property in the metro area that we have
1:46:15expected to develop as affordable
1:46:17housing yet we've been told that pocket
1:46:20of utility underresourced areas exist
1:46:23all across the metro and two we're told
1:46:27that those exact areas and the capacity
1:46:30limitations can't be shared with us so
1:46:33how in the world do people plan ahead we
1:46:35cannot afford again to front $2 million
1:46:39in predevelopment costs just to get into
1:46:42the conversation because it's at the
1:46:45point of detailed load and subpanel
1:46:47drawings where Excel once to start the
1:46:51conversation about capacity facts
1:46:54somehow the power utility needs to
1:46:57become able to discuss at least rough
1:47:00borders of magnitude earlier in the
1:47:02process to discuss these Geographic
1:47:05based capacity limitations with
1:47:08transparency that is timely to the onth
1:47:10ground facts of multif family housing
1:47:13development I'd like to summarize three
1:47:16reasons why affordable housing in
1:47:18particular is uh especially vulnerable
1:47:21to the recent capacity connection and
1:47:23especially the 65% um upgrade cost
1:47:26burden one affordable housing does not
1:47:28have the ability to make up unexpected
1:47:31costs by increasing cost of rent or the
1:47:34list price two affordable housing
1:47:36Finance is much more complex and slower
1:47:39moving than market rate development
1:47:40Finance so that when there is a first
1:47:42mover advantage in getting power
1:47:45capacity allocated affordable housing
1:47:47will lose we're not fast where there is
1:47:49a first first mover cost burden
1:47:52affordable housing will lose because we
1:47:54may not be able to make up those cost
1:47:56through margin and three housing of any
1:48:00kind is now competing with all other
1:48:02development types for utility capacity
1:48:04multif Family Housing Development will
1:48:06typically move more slowly than
1:48:08Transportation
1:48:10infrastructure Urban Land Conservancy
1:48:12appreciates any prioritization and
1:48:15affordable housing prioritization um as
1:48:17much as can be possible by the Denver
1:48:20mayor's office by Excel Colorado um it
1:48:23is our hope and our understanding that
1:48:25the Irvings needs for temporary
1:48:27construction power and permanent power
1:48:29might yet be met so we are just one of a
1:48:33number as you're hearing today of
1:48:35developments hanging in the balance of
1:48:37immediate decision
1:48:39making it's important that we speak not
1:48:41just for these immediate points of
1:48:43decision but also for the affordable
1:48:44housing pipeline that will start
1:48:46tomorrow next week next month next year
1:48:50we know people need housing we look
1:48:52forward to utility capacity appropriate
1:48:54power resources and trusted timely
1:48:57Communications to house all of our
1:48:59community's peoples today and into the
1:49:01future so ulc we want to be optimistic
1:49:06we want to be an ally to the Pu an ally
1:49:09to excel where policy needs to change
1:49:12we'd love to participate where trust
1:49:14needs to be rebuilt transparency needs
1:49:16to be added or um relationships need to
1:49:19be reinforced
1:49:20we do look forward to joining you in the
1:49:22hard conversations that will follow this
1:49:24hearing to bring solutions for
1:49:26affordable attainable and available
1:49:28housing so thank you very much for your
1:49:30time and
1:49:33attention thank you Miss Haron I
1:49:35appreciate it um I don't see any other
1:49:38current hands up in our developer or
1:49:41Builder area um or category if there's
1:49:45anyone else working in the construction
1:49:47field apart from solar de
1:49:51um please go ahead and raise your hand
1:49:52I'll get you now um otherwise not seeing
1:49:56anyone we'll move on to um solar
1:50:00interest so uh kosa or other solar
1:50:03developers or interests or experiences
1:50:06be happy to um get to you each now and
1:50:09again I apologize that I don't think my
1:50:11internet is still quite good enough to
1:50:13have my my video on but I'm hearing you
1:50:17loud and clear uh listening and
1:50:21so um uh up I have
1:50:32Miss thank you commissioner Gilman uh uh
1:50:36appreciate it and just want to make sure
1:50:38that um everyone can hear me
1:50:42okay yes you're good okay great thank
1:50:45you um so good afternoon commissioner
1:50:47Gilman advisers fellow participants my
1:50:50my name is Ellen Howard CER uh e- l l n
1:50:53h o w a r d kuu t z r I'm General
1:50:58Council for the Colorado solar and
1:51:00storage Association or kosa um so as you
1:51:03know kosa is a trade organization that
1:51:05represents the businesses that work to
1:51:07deploy um distributed energy resources
1:51:10or deers to the grid this includes the
1:51:13companies that build residential and
1:51:15Commercial onsite solar and storage and
1:51:18the companies that develop community
1:51:20solar Gardens um many of which are now
1:51:22providing income qualified customers
1:51:25with significant Bill savings so many of
1:51:28the other commenters that you've already
1:51:29heard from um are have covered some of
1:51:31the same points that I plan to so I'll
1:51:33try to be succinct um we appreciate uh
1:51:36the commission's investigation into the
1:51:38barriers for uh both beneficial
1:51:40electrification and deers in uh Colorado
1:51:44um I want to stress that we're observing
1:51:46that um you know the utilities react Ive
1:51:50approach to distribution system capacity
1:51:52planning is appearing to be a very huge
1:51:55problem both for de deployment um as
1:51:58well as other development and I observe
1:52:01that this is an ongoing barrier
1:52:05um you know distribution system capacity
1:52:08contraints are are the significant
1:52:10barrier to De deployment as well when
1:52:13the system lacks sufficient capacity a
1:52:15customer cannot interconnect a Dr
1:52:17without paying up to upgrade the system
1:52:21um and increase that capacity um our
1:52:23understanding is that customer
1:52:25responsibility for system upgrade costs
1:52:27are captured in internal policies that
1:52:30right now have little or no pu oversight
1:52:34um and as utilities have applied the
1:52:36traditional cost causation principles
1:52:38including the bond bright cost causer
1:52:41pays principle the customer who triggers
1:52:44a system upgrade related to a de is
1:52:47responsible to pay the full cost of it
1:52:50um as applied as you're hearing today
1:52:52it's just the few unlucky customers who
1:52:54are triggering these system upgrades who
1:52:56are paying the bulk of the costs for
1:52:59these um these system improvements so um
1:53:02just as an example a customer who wants
1:53:04to adopt residential onsite solar might
1:53:07be hit with a $77,000 Transformer
1:53:09upgrade charge if there's no more
1:53:12capacity in their neighborhood for new
1:53:13solar um most of these customers will
1:53:16end up deciding to cancel their plans to
1:53:18put on solar storage if an upgrade is
1:53:21required but for example if the customer
1:53:23does agree to pay the system upgrade
1:53:25costs their investment opens the door
1:53:28for others to adopt soul in the future
1:53:31without any promise of recouping the
1:53:33costs of their investment in the system
1:53:35in other words the neighbor who pays for
1:53:37the Transformer upgrade opens the door
1:53:39for the Neighbors um down the line to
1:53:42get solar with zero system upgrade costs
1:53:44of their own um this is creating an
1:53:46inequitable situation where some
1:53:48customers in a small area foot the bill
1:53:51for other customers not all customers uh
1:53:55or cost causers are paying equally so
1:53:58application of these principles gets
1:54:01even more complicated when a customer is
1:54:03looking to adopt both de and
1:54:06electrification measures Kos is hearing
1:54:08stories of inconsistent
1:54:10determinations determinations of
1:54:13customer cost responsibility for system
1:54:16upgrades um when you're looking at De
1:54:19compared to the electrification measures
1:54:21and presumably this is because um the
1:54:24measures that sell are more electricity
1:54:26like electric vehicle adoption um are
1:54:29not looked at equally to um deers which
1:54:33decrease electricity sales so as an
1:54:36example a customer installing on-site
1:54:38solar is typically responsible for 100%
1:54:40of a system upgrade costs but a customer
1:54:43installing a level two charging system
1:54:45pays 0% of a system upgrade costs when
1:54:48de are paid paed with electric vehicle
1:54:50charging the customer cost
1:54:52responsibility is
1:54:53inconsistent sometimes these customers
1:54:55pay nothing sometimes they're asked to
1:54:57pay 50% and sometimes they're asked to
1:55:00pay 100% of the system upgrade costs
1:55:03again this inconsistency shows that not
1:55:05all cost causers are paying equally
1:55:08under the current
1:55:09system um this problem isn't limited to
1:55:12on-site solar Community solar Gardens
1:55:14are also facing significant
1:55:16interconnection challenges as you heard
1:55:17from the representative from pivot
1:55:19energy
1:55:20um this is starting to cause many
1:55:22projects that have been successful in
1:55:24obtaining an offsite agree offtake
1:55:26agreement excuse me um in the renewable
1:55:29energy Standard Process um to cancel
1:55:32those projects for csgs that may be
1:55:34serving low-income customers we're
1:55:36hearing stories of planned
1:55:38interconnection costs now exceeding $2
1:55:41million or more um sometimes these
1:55:44estimates um are not coming in
1:55:46consistently I think pivot touched on
1:55:48this but um um they may get an initial
1:55:51estimate and a feasibility study of
1:55:53little or no interconnection upgrade
1:55:55costs and then later down the road those
1:55:58costs end up being very
1:56:00significant um recently in a third
1:56:02quarter report um Excel Energy uh read
1:56:05out to renewable energy standard
1:56:07participants that we are seeing 135
1:56:11megawatts of a pool of 46 megawatts of
1:56:15approved csgs actually coming online
1:56:18we're expecting to only see an
1:56:19additional 16 to 18 megawatts that will
1:56:23be added this year or 10% of the awarded
1:56:27capacity um you know we're really
1:56:29concerned about this because as we're
1:56:31seeing Community solar Gardens now
1:56:33serving more and more income qualified
1:56:35customers you know having um just over a
1:56:39quarter of the allotted capacity coming
1:56:41onto the system means like we're not
1:56:42getting the bill credit savings that
1:56:44we're expecting that's frustrating the
1:56:46goals that the commission has um and
1:56:48really the purpose of of the res plan as
1:56:50a whole so um I think I'll defer to miss
1:56:54wizowski to talk about some of the
1:56:56problems that um members are
1:56:57encountering with the construction of
1:56:59new with the construction of new homes
1:57:01that have on-site solar but I just note
1:57:03that this is also a significant issue um
1:57:06and one where we're not seeing
1:57:08sufficient capacity reserved for new
1:57:10home development new neighborhood
1:57:12development with on-site solar so just
1:57:14to conclude the lack of transparent
1:57:16policy and inconsistency raises
1:57:18significant Equity concerns as
1:57:21increasing levels of De and beneficial
1:57:23electrification are deployed random
1:57:26system upgrade costs are becoming a
1:57:28significant barrier to Colorado's
1:57:30ability to meet our um electrification
1:57:32and decarbonization goals we observe
1:57:35that a larger question exists should the
1:57:38traditional cost causation principles
1:57:40continue to apply when we have state
1:57:43level policy goals that require the
1:57:45deployment of um Technologies such as de
1:57:49and beneficial electrification customer
1:57:52uh kosa believes that customer
1:57:54responsibility for these costs should be
1:57:56viewed within the context of our larger
1:57:58decarbonization goals and socializing a
1:58:01majority of all or at least some of
1:58:03these costs among rate payers as a whole
1:58:06would allow customers to um continue to
1:58:09deploy the Technologies we need to meet
1:58:11our decarbonization goals um kosa hopes
1:58:14the commission will consider this as
1:58:16they investigate a pathway forward thank
1:58:18you very much for your time and
1:58:20consideration of our
1:58:23comments thank you I really appreciate
1:58:26your comments uh next we'll go to
1:58:28Katherine wowski just a reminder if any
1:58:31else is on representing any uh solar
1:58:34interests companies free to your hand
1:58:36and we'll get you after Miss
1:58:40wowski uh thank you so much commissioner
1:58:42Gilman um I'm Katherine wiskowski uh
1:58:45here representing Sova energy uh Sova
1:58:48energy International is a leading
1:58:51residential solar and energy storage
1:58:52service provider with over 300,000
1:58:56customers across the US and its
1:58:57territories including Colorado uh Sova
1:59:00works with Community developers that
1:59:02build new construction projects with
1:59:04solar ready homes uh beneficial
1:59:08electrification has uh been hindered by
1:59:11overloaded circuits and how they're
1:59:13communicated new development studies and
1:59:16uh timeline durations for
1:59:18interconnection
1:59:19so in in Public Service Company of
1:59:22Colorado territory the distribution
1:59:24system was not planned to include solar
1:59:27and storage and the increase in load has
1:59:30caused delays for new developments uh
1:59:33overloaded circuits have been the main
1:59:35issue for new Compu communities seeking
1:59:38interconnection uh psco has been able to
1:59:41solve this um by moving loads from one
1:59:44circuit to another sometimes but um this
1:59:47solution still creates delay in projects
1:59:51um psco currently studies each home
1:59:55individually um and it doesn't plan for
1:59:57the impact the entire Community could
2:00:00have on a circuit to avoid this barrier
2:00:03we suggest utilities study entire new
2:00:06communities so they can plan for solar
2:00:08and storage on the front end of new home
2:00:10development uh Fort Collins utility
2:00:13already has a process to review
2:00:15neighborhood developments in their
2:00:16entirety to understand the change in
2:00:19load and how to make it more
2:00:21balanced uh this practice also allows
2:00:24developers to know what the cost of
2:00:26upgrades for Transformers and Ducks will
2:00:29be upfront uh it also allows individual
2:00:32homes to skip the the study process so
2:00:36the developer can receive a quicker
2:00:39analysis um another barrier to
2:00:42beneficial electrification is
2:00:44communication of circuit locations um
2:00:47psco will inform the developer that a
2:00:50circuit is overloaded and provide them
2:00:52the circuit name but the name doesn't
2:00:55identify where the circuit is located
2:00:58and the current hosting capacity Maps
2:01:01don't allow searches by Circuit names
2:01:04this is an issue that can easily be
2:01:06solved and will save a lot of time for
2:01:09developers California utilities like
2:01:11Southern California Edison have a map
2:01:13that allow users to easily find circuit
2:01:16location and it would be very beneficial
2:01:19for uh the psco hosting capacity maps to
2:01:22include a similar feature um developers
2:01:25obviously prefer to build solar ready
2:01:27communities in areas that are not
2:01:29overloaded um but it's difficult to find
2:01:32those areas right now with the current
2:01:34hosting capacity map um the last issue
2:01:37is more of a procedural issue between
2:01:40the utility and permitting offices there
2:01:43have been times um that interconnection
2:01:46takes so long to complete that that a
2:01:49Project's permit becomes pass due
2:01:52permitting departments are asking
2:01:54developers to resubmit permit
2:01:56applications and redo inspections for
2:01:59homes that have already received permits
2:02:02um this again is an issue that can be
2:02:05solved um by studying new developments
2:02:08in their entirety in the early stages of
2:02:11development um they'll just allow the
2:02:14interconnection timelines for individual
2:02:16homes to be reduced and avoid needing a
2:02:18new permit um Sova really appreciates
2:02:22commissioner Gilman's time and this
2:02:24opportunity to address barriers to
2:02:29electrification thank you Miss
2:02:31appreciate it um and representing solar
2:02:35interest I'll also open it up to any
2:02:38other
2:02:39de um vendors or uh contractors we can
2:02:44understand the experiences particular to
2:02:46that area if any folks are on right
2:02:53now okay not seeing anyone uh I see Mr
2:02:58Hy I know you weren't available before M
2:03:01did you want to offer a comment now or
2:03:04uh maybe you're not quite available good
2:03:08afternoon commissioner Gilman H this is
2:03:10Keith hay I'm the senior director of
2:03:11policy at the energy office uh I
2:03:14apologize uh for not being able to join
2:03:16you at the start of uh today meeting um
2:03:20but appreciate uh the opportunity uh to
2:03:23speak now I am going to have to leave uh
2:03:26my camera off I am at a conference and
2:03:29and the conference Wi-Fi is not
2:03:30particularly good so uh my hope is that
2:03:34with the camera off you all can can hear
2:03:36me okay uh is this coming through you're
2:03:38coming through great great um and
2:03:42commissioner Gilman again appreciate the
2:03:45the work that you were doing and and the
2:03:47work of the commission
2:03:49uh to look at the impacts and the
2:03:52implications of the distribution system
2:03:54and distribution system
2:03:56planning for beneficial electrification
2:03:59and I understand from talking to my
2:04:01Council that there is a lot of ground
2:04:03that has been trod so I think what I'd
2:04:05like to do is perhaps keep my remarks
2:04:07brief and and make some
2:04:09observations uh about what I've heard in
2:04:12in the last sort of 45 minutes uh or an
2:04:15hour that that I've been on you know I
2:04:18think
2:04:19starting at a particularly high level I
2:04:22think part of the the issue here is one
2:04:25that the energy office raised going back
2:04:28to uh the commission's rulemaking on
2:04:31distribution system planning uh and that
2:04:34is that historically the utilities have
2:04:36planned their Distribution Systems uh in
2:04:40a particular way and that is to ensure
2:04:42you know reliable electrical service
2:04:44safe electrical service um but not
2:04:48necessarily
2:04:49in a way that would take account of what
2:04:52I would suggest is is a very different
2:04:54environment today and that is that uh
2:04:56customers are changing the way they are
2:04:59acting and
2:05:00interacting uh with the distribution
2:05:02grid uh and that the utilities are being
2:05:05pushed uh to really have to plan the
2:05:08distribution grid uh to help achieve a
2:05:13range of policy goals I I think that
2:05:15kosa did an excellent job summarizing a
2:05:18lot of those and that because we are now
2:05:21asking the utilities to to serve their
2:05:24customers in a different way and to
2:05:26achieve uh these policy outcomes uh we
2:05:30really need to plan in a very different
2:05:31way uh than we have in the past and and
2:05:34I think that a big part of that from
2:05:37listening to the developers today is to
2:05:39make sure that uh a range of distributed
2:05:42energy resource developers have access
2:05:45to information that can help them uh
2:05:49understand where it may be beneficial
2:05:51early on to plan and where their
2:05:54investments in whether it's Home
2:05:57Building or if it is you know low-income
2:06:00multif family units or it is fleets
2:06:03electrifying in the transportation
2:06:05sector where there'll be more
2:06:07significant grid upgrades that would be
2:06:09required um but without having access to
2:06:12that information and having access to
2:06:14that information early in their
2:06:16development
2:06:17processes really does two things as
2:06:20you've heard from the developers today
2:06:22it it frustrates their work and and adds
2:06:25costs uh and I think that Ellen was
2:06:28right when she said you know it also
2:06:30frustrates the the state achieving its
2:06:31policy goals and so I think what you
2:06:34know from the energy office perspective
2:06:37we would encourage the the commission to
2:06:39look at what it can do to help ensure
2:06:43that developers have access to the
2:06:46information that they need and I think
2:06:49we have pushed hard in many instances
2:06:51for uh mapping and and in particular
2:06:54interactive mapping that would allow uh
2:06:57folks to understand that and I don't
2:07:00think this is unrelated to the issue of
2:07:03cost of service regulation and tariff
2:07:06design um that is that you know we again
2:07:09are are in a place where we are doing
2:07:11things in a way that has worked
2:07:13historically uh but we are also you know
2:07:16bridging into a future where things are
2:07:19going to to have to be done a little bit
2:07:21differently in order to achieve uh these
2:07:24policy goals that that the state has um
2:07:27and so you know when we think about
2:07:29doing traditional cost causation where
2:07:32you know the last customer in is the
2:07:33customer bearing the brunt of that cost
2:07:36it really is creating barriers to levels
2:07:39of investment in electrification both in
2:07:41the building space and in the
2:07:43transportation space uh that that we
2:07:45need to I think take a step back and
2:07:48look at you know I know the energy
2:07:50office and and this may commissioner
2:07:52Gilman not be the appropriate moment but
2:07:54the energy office more than once has
2:07:57observed that that it may be worth
2:07:58revisiting this question of uh
2:08:01Performance
2:08:03Based uh
2:08:04regulation um and how to couple that
2:08:07with the traditional principles of cost
2:08:09of service regulation that ensure the
2:08:12kinds of of Consumer Protections and
2:08:14rate guard rails uh that many of us who
2:08:16have done this for a long time
2:08:18understand and and appreciate but
2:08:21knowing that you know we are also again
2:08:23in this policy-driven environment where
2:08:26we need to be helping Focus the
2:08:28utilities on the outcomes that we would
2:08:30like them to achieve you know and
2:08:33thinking about how to
2:08:35structure both the cost causation and
2:08:38the rate design as well as the recovery
2:08:41um that gets the utilities moving in the
2:08:43direction of working with customers and
2:08:47partnering with developers to begin to
2:08:50meet these policy goals I think really
2:08:52speaks to the the need to take that
2:08:54higher level look and to focus first on
2:08:57what those outcomes
2:08:58are um so with respect then just for a
2:09:03moment to the the uh question of of
2:09:06tariffs you know the energy office has
2:09:09observed in a number of proceedings that
2:09:12um tariff design really can be key to
2:09:16meeting uh the state's energy goals or
2:09:19the the state's climate goals or or to
2:09:22not making as much progress uh towards
2:09:25these goals I mean at the end of the day
2:09:27the Tariff design really does impact
2:09:30that policy and so things like
2:09:32residential time of use EV time of use
2:09:35at the secondary voltage level um you
2:09:39know potentially net metering and and
2:09:41for the utilities all are things that
2:09:44that will help customers make the kinds
2:09:47of Investments that's State policy is
2:09:49suggesting we want them to make uh or
2:09:51can impede that level of investment and
2:09:53so it's it's good to couple this
2:09:55conversation of planning with recovery
2:09:59with the way that customers are
2:10:01compensated for what they provide to the
2:10:03grid and to make sure that the utilities
2:10:06uh are also earning what they need to
2:10:09cover the costs of building out a grid
2:10:11that provides that safe and reliable
2:10:13service while allowing customers uh to
2:10:16change the way that they are interacting
2:10:18and and providing things onto that grid
2:10:21so I really appreciate the opportunity
2:10:23uh to offer a few thoughts and
2:10:25observations uh at a much higher level
2:10:28and I'm happy to answer questions if you
2:10:30have any thank you commissioner
2:10:33Gilman thank you Mr hey appreciate it
2:10:36very much um questions just at the
2:10:39moment for me uh especially I want to
2:10:42make sure that we have time for everyone
2:10:44to participate here it's been a very
2:10:45hearty discussion um and and and want to
2:10:48get to to the rest of our participants
2:10:50but thank you so much for taking the
2:10:52time to uh participate with us and offer
2:10:55your um your insights um so not seeing
2:10:59anyone else right now I'm going to turn
2:11:00to um category of utilities I think we
2:11:03do have several utility Representatives
2:11:05not sure if you all um do intend to
2:11:08offer any comments here um but certainly
2:11:11invite those if you would so please
2:11:14ahead and Signal um bying your viral
2:11:17hand and I can get to you in the order
2:11:20that you show up um if you wish to offer
2:11:25live comments
2:11:29today um while I'm waiting to see if I
2:11:32have any hands there um I I do okay so
2:11:37we'll go to public Serv um otherwise any
2:11:41other utilities please go ahead and
2:11:42raise your hands and we'll make sure we
2:11:44get to you after public company Colorado
2:11:47and then i' all Al offer also if we have
2:11:50any other uh participants on who have
2:11:53not had a chance to offer maybe you
2:11:55didn't see where you fit in my broad
2:11:57categories something like that um go
2:11:59ahead and raise your hands anyone
2:12:01remaining who wishes to comment and we
2:12:03will get you in the order I see your
2:12:05hands um uh yet in this session so um Mr
2:12:09Burman from Public Service Company
2:12:11Colorado go ahead good afternoon can you
2:12:15hear me commissioner Gilman just want to
2:12:16make sure the technolog is working
2:12:19I can and again apologies about my video
2:12:22but once a month your your internet's
2:12:24always got to test you and today is the
2:12:26day so I'm limping along with on the
2:12:28audio no problem at all um Steve Burman
2:12:33St b r Manan uh regional vice president
2:12:37of regulatory for public service just
2:12:40wanted to make some brief comments here
2:12:43um nothing real specific but wanted to
2:12:46acknowledge that we appreciate all the
2:12:47com comments today and we have been
2:12:50listening carefully uh with several of
2:12:53our subject matter experts in the room
2:12:54today to to hear this dialogue um we
2:12:58also look forward to written comments
2:12:59that we can digest more and understand
2:13:02that a number of the commenters today uh
2:13:05suggested they'd be providing those we
2:13:07as you would expect are providing our
2:13:10responses um diligently working on those
2:13:13to the questions that were asked in the
2:13:15original decision and we'll also respond
2:13:18to any written comments that come into
2:13:19the record um just wanted to also say
2:13:23that you know we we do really value our
2:13:25relationship with our customers and I
2:13:27was happy to hear today uh a number of
2:13:30people give some compliments to the team
2:13:33that works directly with them and and
2:13:35the people here we recognize there's
2:13:37challenges with specific projects we
2:13:40recognize that every project is
2:13:42different and we will continue to work
2:13:44with those customers on those projects
2:13:46for looking for Solutions
2:13:49um at a high level I think I would would
2:13:53say I also appreciated Mr Hay's comments
2:13:55and that there's a lot to unpack there
2:13:57and that we again want to be actively
2:14:00participating in these proceedings to to
2:14:03look forward to how we navigate the
2:14:06future um but we are in a clean energy
2:14:10transition and we have seen that drive
2:14:14that and an urgent housing crisis that
2:14:16was discussed today as well in the state
2:14:18of Colorado and in the city of Denver um
2:14:21that's created an environment where
2:14:23we're seeing you know a significant
2:14:25uptick in those interconnection requests
2:14:27and local grid constraints that we
2:14:29haven't seen in the past so we recognize
2:14:31that and that there are challenges to
2:14:33come with that um we look forward to
2:14:36continuing to have that dialogue in this
2:14:38proceeding and in any other proceedings
2:14:40that are tangential to that um like the
2:14:42distribution system planning process
2:14:44that will be undergoing um next year on
2:14:47the second go around there um we want to
2:14:50continue to to think forward and adapt
2:14:52our processes as needed to provide
2:14:56service as best we can however we do
2:14:58recognize that there is an unprecedented
2:15:01need for distribution investment and you
2:15:04know we look forward to discussing
2:15:06policies that encourage and ensure that
2:15:09that investment's made I think Mr Hay's
2:15:11comments were very helpful there about
2:15:13how we can think about that and and look
2:15:15to that in future proceedings um and
2:15:19also recognize that our current policies
2:15:21and tariffs seek to balance both
2:15:23individual customer costs and against
2:15:26the framework of what should the broader
2:15:28system uh cover for cost and we'll need
2:15:31to continue to consider those items in
2:15:33future proceedings as well so I think
2:15:35that's that's kind of all I wanted to
2:15:37say at a high level today and again
2:15:39thank you and thank all the commenters
2:15:42um and just recognize for everyone on
2:15:45the call that we are listening and we
2:15:46look forward to providing responsive
2:15:52comments thanks Mr appreciate that um so
2:15:57now I'm open any other utility
2:15:59Representatives on the line who wish to
2:16:02offer a comment uh go ahead and raise
2:16:05your hand while I'm waiting for that
2:16:07I'll also offer uh Anya Els uh on the uh
2:16:11on the zoom who wishes to off any
2:16:13comments or experience um insights
2:16:17please feel free free to tick on your
2:16:19camera raise your virtual hand and I
2:16:22will get to you we we are winding up
2:16:25time here so if you're waiting uh don't
2:16:29wait any longer go ahead and raise your
2:16:30hand and uh and offer us your comments
2:16:33at this
2:16:42time I don't see anyone coming on so um
2:16:46let me I was going to turn on my camera
2:16:49but I don't want to risk it so I'll just
2:16:52keep myself uh the the box so um I
2:16:57really wanted to thank you all for your
2:16:59comments today um as many of you pointed
2:17:01out there are many really important
2:17:03policy objectives that play including
2:17:05greenhouse gas reductions beneficial
2:17:08electrification deployment more EVS
2:17:11distributed energy resource investments
2:17:13in the grid and really wanted to uh
2:17:16applaud you all for the roles you're
2:17:18playing in that as well as the important
2:17:19roles many of you are playing in housing
2:17:22and particularly housing within the
2:17:24state and your dedication to um to your
2:17:28jobs and your missions and really
2:17:29appreciate you all uh joining us today
2:17:32to share how this piece impacts you um
2:17:36this has been incredibly uh helpful
2:17:38insights uh to me uh as well as many of
2:17:42our advisers and attorneys I'm sure as
2:17:44to how that's going on the ground what
2:17:46that looks like what that feels like
2:17:47like um where things might be going well
2:17:50and where the pain points are um and
2:17:52certainly you know it's my goal to to do
2:17:55what we can address those to ensure that
2:17:58we're as successful as possible and
2:17:59achieving all the policy goals we have
2:18:02set out and of course making things just
2:18:04better and easier across the board in
2:18:06any way we can um so your
2:18:10experiences are incredibly helpful us
2:18:13and I want to point out um at least to
2:18:15me during my time on the commission have
2:18:17um a lot of voices represented here
2:18:19today um really expert insightful voices
2:18:24helping us to understand how things are
2:18:26going how maybe they could be better um
2:18:29so perhaps some of you are not as
2:18:32familiar with our eiling system as
2:18:34others so I just wanted to offer we do
2:18:37have each of your emails from the
2:18:39signups um so I I look forward to and
2:18:43intend to um utilize that as as a
2:18:46service list of sorts to help provide
2:18:48you all any updates within this
2:18:50proceeding on major kind of comments or
2:18:53questions or other goings on here since
2:18:56you all have really uh helpful insight
2:19:00um as we really get our arms around not
2:19:02just issues but what are the proper ways
2:19:05to address um of these as we move
2:19:08forward so um hopefully you know I'm
2:19:11sure there's a way you kned out if we're
2:19:14pestering you um my priority is really
2:19:16to ensure that you all can stay informed
2:19:19on this issue that I can tell you're
2:19:20very knowledgeable and passionate about
2:19:22um so um just one more chance raise your
2:19:27hand take on your camera anything if
2:19:30anyone is still out there who wishes to
2:19:33comment um before I close this
2:19:39out Mr B go
2:19:46right
2:19:49Mr Burke do you want to offer a comment
2:19:51I saw your video on for just a
2:20:01minute no I'm good thank
2:20:03you okay no worries just want to make
2:20:07sure I didn't steal your opportunity
2:20:09from you okay well with that I don't see
2:20:12anyone else here once again please feel
2:20:15free to file any written comments if you
2:20:18have more examples concrete information
2:20:21um facts you'd like to share with us
2:20:23please do file that you can uh do it
2:20:25eiling if you're familiar if you're not
2:20:27familiar you can go to the pu's website
2:20:30which is PU um.
2:20:33colorado.gov got it written here
2:20:35somewhere um you can uh file a a comment
2:20:40there uh there's a large kind of button
2:20:42on the main page there to f a comment uh
2:20:45if you are able you could ref
2:20:47proceeding number 23
2:20:49m-04 64 EG so we can properly get that
2:20:53routed uh to make sure that I see it
2:20:56sooner than later um and like I said
2:20:59very early on in this process so I
2:21:01anticipate there will be more goings on
2:21:04more opportunities for comment and
2:21:06things like that so we have your emails
2:21:08uh and we hope to keep you all informed
2:21:11and please you feel free to reach out
2:21:13any comments or concerns uh to us to add
2:21:16new mentions so with that um I will
2:21:20close out this public comment hearing
2:21:22today thank you all again so much for
2:21:24joining us um thank you Harriet for
2:21:27transcribing for us and uh for the
2:21:29support from our advisers and legal
2:21:31councel um thank you so much everyone
2:21:34enjoy your
2:21:46day

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