Saturday, April 30, 2011

IRP as AG with the ACC (aka: alphabet soup- yum!)

The Arizona Corporation Commission (ACC) requires all of its regulated utilities to perform an Integrated Resource Plan (IRP) every two years. This requirement could be considered a form of Anticipatory Governance (AG) not only in the form of the IRP as a tool, but also as a process. Take APS, for instance. Their last IRP report was published in January of 2009 and their next one is due by July 1st of 2011. The regulatory landscape has changed since then, in addition to reality changing, so it should be interesting to compare their visions of the future and how that vision has changed in two years.
The ACC’s docketed opinion and order:
“The purpose of IRP is to minimize the total societal cost of meeting the demand for electric energy services giving due consideration to ratepayer impacts, utility financial health and economic growth within a utility’s service area. The goal of resource planning can be achieved by finding the mix of supply and demand side resources that minimize society’s costs.”
As for Anticipatory Governance, the IRP process correlates fairly well. The Corporation’s own description of the raison d’etre has social considerations and social science built into it. The fact that the Utility is probably only complying with the process because it is required to does not negate the benefits of the process. This is a form of forecasting, or foresight. It is actually something that energy companies have been doing for decades already (Shell) because it allows them to see what kinds of challenges they will have moving forward. Many energy companies are fairly conservative and look to long term stability for a return on their investments, so the IRP process is not an unfamiliar a task.
APS uses long-term forecasting based on the economy, growth trends, and customer usage to start. Risk analysis and judgement, along with the inevitability of change also affect their decision about planning for future energy needs. They use Stakeholder input, ACC guidance, and Regulatory Requirements to guide their “vision for Arizona”. So now, from the utility’s point of view, we have more correlation between AG concepts and real applications.
While I’m focusing on Foresight, there are other elements of AG to be considered: Engagement and Integration are two. With engagement, we get the potential for co-production and more reflexivity. Integration is a topic more suited for upstream engagement, so we’ll focus on Engagement. This is the place where the air becomes as unclear as a cool, still winter morning in the Valley of the Sun when the mountains are not visible, due to the brown cloud of pollution. What counts as good public engagement? Public polls? Letters to the utility, or the ACC which regulates them? Or perhaps open meetings or town hall meetings? Even this latter option might be skewed if supporters or others are bused in by the hundreds. But at least they’re trying. The open meetings of the ACC last for two full days and part of that time is for public comment. The process allows for live comment by anyone who signs up to be on the roster.
Back to Foresight. The IRPs are used to make decisions by many stakeholders. This is done not just by looking at the numbers, but also by deciding how much they do or do not trust a certain institution. The very presence of the IRPs is relevant to the discourse. It says to the public that the ACC is interested enough in protecting their constituents, that the IRPs are required. That says a lot.

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