NORTHWESTERN ENERGY GREEN POWER STAKEHOLDER ADVISORY GROUP
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Green Tariff Background |1 NorthWestern Energy Green Power Stakeholder Advisory Group Background on Green Tariffs February 2020 Introduction As part of the 2018 NorthWestern Energy Electric Rate Review (Rate Review), NorthWestern Energy (NorthWestern), along with the Montana Department of Environmental Quality (DEQ), the Montana Consumer Counsel (MCC), and Walmart reached an agreement for NorthWestern to initiate a process to review its Efficiency Plus (E+) Green Program and consider options for a new renewable energy product tariff, including but not limited to an option for non-residential customers. The Montana Public Service Commission (Commission) approved this agreement in its Final Order, Order No. 7604u in Docket No. 2018.02.012 (Stipulation and settlement agreement and excerpt of Order No. 7604u is attached). As part of the agreement and Final Order, NorthWestern is required to report progress to the Commission by March 19, 2020, and also required to file changes to the E+ Green Power Program, propose a new renewable energy product, or explain why no changes are needed by June 17, 2020. NorthWestern’s E+ Green Program NorthWestern Energy has offered Montana electric retail customers* the E+ Green Program, since 2003. This program allows customers to support renewable energy generation and offset carbon emissions through a premium on their electric bill -- $2 purchases a 100 kWh block of renewable energy benefits from renewable generation in the Northwest and Wyoming. NorthWestern’s E+ Green Program is offered through a tariff approved by the Commission. E+ Green has been offered since 2003 with only slight modification and it meets requirements of Montana statute requiring the utility to offer a green product option to customers. Through the current E+ Green Program, a customer may choose how many 100 kWh blocks to purchase. Residential and non- residential customers may participate. The E+ Green premium is added as a line item on the customer’s monthly billing statement. NorthWestern buys Renewable Energy Certificates (RECs)* to cover the customer participation in the E+ Green Program through a contract with the Bonneville Environmental Foundation (BEF). BEF is a non- profit organization which sells Green-e* certified RECs from renewable generation resources, mostly from the WA, OR, ID, WY, and UT. Currently, none of the RECs supporting E+ Green are from Montana. The RECs are Green-e certified but NorthWestern’s program is not. NorthWestern makes no profit on this offering. The proceeds of the E+ Green Program cover NorthWestern’s purchase of the RECs through a green power product provider and promotional costs, with remaining funds being directed into funding incentives for small scale renewable generation on NorthWestern’s system through the E+ Renewable Energy Program which is part of Universal System Benefits (USB)* programs administered by NorthWestern Energy. More information on NorthWestern’s E+ Green Program is available at www.NorthWesternEnergy.com/greenpower and the Electric Green Power Service Tariff is available at http://www.northwesternenergy.com/docs/default-source/documents/MT_Rates/Electric/egps-1. *A Glossary of terms related to Green Tariffs and NorthWestern’s Montana Service Area follows the Examples of Green Tariffs.
Green Tariff Background |2 Other Green Product Offerings The model of a utility offering customers environmental benefits via Green Product programs, such as E+ Green, is common around the country. Green Product programs can make it easy for residential and non-residential customers to choose to green up their electric usage without investing in renewable energy systems on their homes or businesses. Offered as an optional program, it has no impact on non-participating customers’ bills. The remainder of this document does not detail other utilities’ Green Product programs, rather it focuses on providing information related to Green Tariffs. Green Tariffs Another approach that has been utilized around the country is a “Green Tariff” program. Green tariff programs are offered by utilities and approved by state PUC or PSC which allow customers, usually larger non-residential customers, an option to buy bundled renewable electricity from a specific project, or projects through a special utility tariff rate. Generally, green tariffs provide customers an option to meet their sustainability and renewable energy goals, reduce long-term energy risks, and demonstrate commitment to the development of new renewable energy projects while working within a framework the individual utility can support. Because the tariff is tied to a specific resource(s), participation may be limited to a number of customers. Terms and conditions apply. Utility Examples of Green Tariffs To provide more background, information about Green Tariffs has been compiled from a handful of utility websites (northwest states, UT, CO and MN). Program descriptions as well as links to the tariffs are provided below. The Green Tariffs identified are among those listed in the Renewable Energy Buyers Alliance (REBA) Green Tariffs Brief Update, by the World Resources Institute (WRI) from November 2019. For those wanting to dig deeper, the full report REBA report is available at https://www.wri.org/publication/emerging-green-tariffs-us-regulated-electricity-markets.
Green Tariff Background |3
Colorado – Xcel Energy
Renewable*Connect – Official Green Tariff program listed in the WRI brief
Marketed to Residential Customers (source – NOTE: Select “Colorado” Customer Support in top left
corner of Xcel Energy website)
https://www.xcelenergy.com/programs_and_rebates/residential_programs_and_rebates/renewable_e
nergy_options_residential/renewable_connect_for_residences
“Clean energy is important to all of us. We're proud to offer Renewable*Connect, which delivers
additional clean, solar energy with no equipment necessary and a chance to save money.”
Enrollment period has ended, but still taking applications for waitlist.
Program Benefits
• Flexible - Choose your subscription length: month-to-month, 5-year or 10-year.
• Affordable - Low cost solar with the potential to save money.
• Choice - Choose your amount of renewable energy.
• Green - Wind and solar energy generated from resources in Colorado.
“Solar energy will be sourced from an additional 50 MW resource to be built in Deer Trail, Colorado in
eastern Arapahoe County on a site that's roughly the size of 265 football fields combined. It's estimated
that roughly 133,000 MWh will be produced in the first year which would be enough to power over
17,000 homes.”
Pricing
The cost of Renewable*Connect is in addition to current electric charges. The longer the contract, the
more economical it could be.
Month-to-Month 5-Year 10-Year
2020 Charge (cents per kWh) 4.4 cents 4.1 cents 4.0 cents
2020 Credit (cents per kWh) 3.6 cents 3.6 cents 3.6 cents
2020 Net Price (cents per kWh) 0.8 cents 0.5 cents 0.4 cents
The prices shown in the table above are for 2020 only. The most significant factor that will fluctuate over
time is the credit, which is based on the cost of fuel and is unknown in future years. The net price will
change year to year.
Xcel Colorado has compiled an Additional Information section of the Residential Renewable*Connect
webpage that includes:
Frequently Asked Questions
https://www.xcelenergy.com/programs_and_rebates/residential_programs_and_rebates/renewable_e
nergy_options_residential/renewable_connect_for_residences/renewable_connect_for_residences_faqGreen Tariff Background |4
Sample Month-to-Month Contract
https://www.xcelenergy.com/staticfiles/xe-responsive/Programs%20and%20Rebates/Residential/CO-
Sample-Month-Month-Contract.pdf
Sample 10-Year Contract
https://www.xcelenergy.com/staticfiles/xe-responsive/Programs%20and%20Rebates/Residential/CO-
Sample-10-Year-Contract.pdf
REC Info Sheet
https://www.xcelenergy.com/staticfiles/xe-
responsive/Programs%20and%20Rebates/Residential/Renewable-Energy-Credits-Info-Sheet.pdf
There’s also a specific Renewable*Connect email/phone number to assist residential customers.
Marketed to Business/Commercial Customers (source – NOTE: Select “Colorado” Customer Support in
top left corner of Xcel Energy website)
https://www.xcelenergy.com/programs_and_rebates/business_programs_and_rebates/renewable_ene
rgy_options_business/renewable_connect_for_business
“Power your business with easy, clean solar energy. Businesses and communities are seeking additional,
renewable energy sources to meet their sustainable energy needs and reduce carbon emissions. That's
why we're proud to offer Renewable*Connect®, which delivers clean solar energy with no equipment
necessary and a chance to save money.”
Enrollment period has ended, but still accepting applications for waitlist.
Program Benefits
“Meet Environmental Goals - With Renewable*Connect, the associated Green-e
Energy certified Renewable Energy Credits (RECs) are retired on your behalf, which is an important
distinction from other types of renewable programs. This allows your business to make claims on the
use of renewable energy, use RECs toward LEED® certification, and communicate the positive impact
your business is making on the environment.
Renewable*Connect aligns with the Corporate Renewable Energy Buyers' Principles created by the
World Wildlife Fund and World Resources Institute, and adopted by more than 60 of the nation's leading
brands.”
Pricing (2019, not 2020)
Month-to-Month 5-Year 10-Year
2019 Charge (cents per kWh) 4.4 cents 4.2 cents 4.1 cents
2019 Credit (cents per kWh) 3.7 cents 3.7 cents 3.7 cents
2019 Net Price (cents per kWh) 0.7 cents 0.5 cents 0.4 cents
Same disclaimers as residential pricing.Green Tariff Background |5
Xcel Colorado has compiled an Additional Information section of the Business Renewable*Connect
webpage that includes:
Frequently Asked Questions
https://www.xcelenergy.com/programs_and_rebates/business_programs_and_rebates/renewable_ene
rgy_options_business/renewable_connect_for_business/renewable_connect_for_business_frequently_
asked_questions
Sample Month-to-Month Contract
https://www.xcelenergy.com/staticfiles/xe-responsive/Programs%20and%20Rebates/Residential/CO-
Sample-Month-Month-Contract.pdf
There’s also a specific Renewable*Connect email/phone number to assist business customers.
Filings with Colorado Public Utilities Commission (PUC) (source – NOTE: Select “Colorado” Customer
Support in top left corner of Xcel Energy website)
https://www.xcelenergy.com/company/rates_and_regulations/filings/renewable_connect_filing_in_col
orado
• Full Length: Xcel Energy Colorado PUC Green Tariff
https://www.xcelenergy.com/staticfiles/xe-
responsive/Company/Rates%20&%20Regulations/Regulatory%20Filings/CO-RC-Tariff.pdf
• Final Pricing: Xcel Energy Colorado PUC Schedule RC Tariff
https://www.xcelenergy.com/staticfiles/xe/PDF/18AL-0808E_AL%201781-
E_Renewable%20Connect_TARIFF_FINAL.pdfGreen Tariff Background |6
Minnesota – Xcel Energy
Renewable*Connect – Official Green Tariff program listed in the WRI brief
Marketed to Residential Customers (source – NOTE: Select “Minnesota” Customer Support in top left
corner of Xcel Energy website)
https://www.xcelenergy.com/programs_and_rebates/residential_programs_and_rebates/renewable_e
nergy_options_residential/renewable_connect_for_residences
“With no equipment necessary and access to a blend of wind and solar, Renewable*Connect is an
affordable way to benefit from renewable energy.”
Fully subscribed, but still accepting applications for waitlist. Proposed new phase of Renewable*Connect
to the Minnesota PUC – approved 8/2019.
https://www.xcelenergy.com/company/rates_and_regulations/filings/renewable_connect_minnesota_
phase_ii
Program Benefits
• Flexible — Choose subscription term: month-to-month, five-year, or 10-year.
• Affordable — Low cost renewable energy with more price certainty.
• Choice — Select the amount of renewable energy to subscribe to.
• Local — Wind and solar energy are generated locally from the North Star Solar project in
Chisago County and the Odell Wind Farm in southern Minnesota.
Pricing
Month-to-Month 5-Year 10-Year
2020 Price per block $3.62 $3.33 $3.28
Average Fuel Cost Credit* $2.52 $2.52 $2.52
Net Price per Block $1.10 $0.81 $0.76
*Based on the 2019 average Fuel Cost Credit for Minnesota residential electric customers.
Xcel Minnesota has compiled an Additional Information section of the Residential Renewable*Connect
webpage that includes:
Frequently Asked Questions
https://www.xcelenergy.com/programs_and_rebates/residential_programs_and_rebates/renewable_e
nergy_options_residential/renewable_connect_for_residences/renewable_connect_for_residences_faq
Product Content Label
https://www.xcelenergy.com/programs_and_rebates/residential_programs_and_rebates/renewable_e
nergy_options_residential/renewable_connect_for_residences/renewable_connect_product_content_l
abelGreen Tariff Background |7
Price, Terms & Conditions
https://www.xcelenergy.com/programs_and_rebates/residential_programs_and_rebates/renewable_e
nergy_options_residential/renewable_connect_for_residences/renewable_connect_price_terms_and_c
onditions
Sample Renewable Connect Contract (PDF)
https://www.xcelenergy.com/staticfiles/xe-responsive/Programs%20and%20Rebates/Residential/MN-
Renewable-Connect-%20Contract.pdf
Renewable Energy Claims
https://www.xcelenergy.com/energy_portfolio/renewable_energy/renewable_energy_claims
There’s also a specific Renewable*Connect email/phone number to assist residential customers.
Marketed to Business/Commercial Customers (source – NOTE: Select “Minnesota” Customer Support in
top left corner of Xcel Energy website)
https://www.xcelenergy.com/programs_and_rebates/business_programs_and_rebates/renewable_ene
rgy_options_business/renewable_connect_for_business
“More businesses and communities are seeking additional clean, renewable energy sources to meet
their sustainable energy needs and reduce carbon emissions. That's why we're proud to offer
Renewable*Connect®. It provides an easy, affordable path to renewable power. We're enabling your
business to utilize a blend of locally sourced wind and solar energy without the need to invest in
equipment.”
Fully subscribed, but still accepting applications for waitlist.
Program Benefits
“Meet Environmental Goals - With Renewable*Connect, the associated Renewable Energy Credits (RECs)
are retired on your behalf, which is an important distinction from other types of renewable programs.
This allows your business to make claims on the use of renewable energy, achieve LEED® certification,
and communicate the positive impact your business is making on the environment.”
Pricing
Month-to-Month 5-Year 10-Year
2020 Price per Block $3.62 $3.33 $3.28
Average Fuel Cost Credit* $2.47 $2.47 $2.47
Net Price per Block $1.15 $0.86 $0.81
*Based on the 2019 average Fuel Cost Credit for Minnesota commercial and industrial demand
customers.
Xcel Minnesota has compiled an Additional Information section of the Residential Renewable*Connect
webpage that includes:Green Tariff Background |8
Frequently Asked Questions
https://www.xcelenergy.com/programs_and_rebates/business_programs_and_rebates/renewable_ene
rgy_options_business/renewable_connect_for_business/renewable_connect_for_business_frequently_
asked_questions
Product Content Label
https://www.xcelenergy.com/programs_and_rebates/residential_programs_and_rebates/renewable_e
nergy_options_residential/renewable_connect_for_residences/renewable_connect_product_content_l
abel
Price, Terms & Conditions
https://www.xcelenergy.com/programs_and_rebates/residential_programs_and_rebates/renewable_e
nergy_options_residential/renewable_connect_for_residences/renewable_connect_price_terms_and_c
onditions
Renewable Connect Information Sheet (PDF)
https://www.xcelenergy.com/staticfiles/xe-
responsive/Programs%20and%20Rebates/Business/Renewable_Connect_Information_Sheet.pdf
Sample Renewable Connect Contract (PDF)
https://www.xcelenergy.com/staticfiles/xe-responsive/Programs%20and%20Rebates/Residential/MN-
Renewable-Connect-%20Contract.pdf
There’s also a specific Renewable*Connect email to assist business customers.
Filings with the Minnesota PUC (source– NOTE: Select “Minnesota” Customer Support in top left corner
of Xcel Energy website)
https://www.xcelenergy.com/company/rates_and_regulations/rates/rate_books
Electric Rate Book Section 5 – Rate Schedules
• Voluntary Renewable*Connect Pilot Program Rider – (NOTE: Select “Minnesota” Customer
Support in top left corner of Xcel Energy website)
https://www.xcelenergy.com/company/rates_and_regulations/rates/rate_books
o PDF Page 187 of 196 of Electric Rate Book Section 5
• Voluntary Renewable*Connect Government Rider – (NOTE: Select “Minnesota” Customer
Support in top left corner of Xcel Energy website)
https://www.xcelenergy.com/company/rates_and_regulations/rates/rate_books
o PDF Page 192 of 196 of Electric Rate Book Section 5Green Tariff Background |9
Oregon – Portland General Electric
Green Future Impact – Official Green Tariff program listed in the WRI brief
Marketed to Business Customers (source & source)
https://www.portlandgeneral.com/business/power-choices-pricing/renewable-power/green-future-
impact
https://www.portlandgeneral.com/business/power-choices-pricing/renewable-power/choose-
renewable
“We’re proud to introduce Green Future Impact, our newest local renewable product available to large-
scale businesses and municipalities.
Green Future Impact will offer large customers the opportunity to source up to 100% of their electricity
from a new wind or solar facility in Oregon, adding up to 300 MW of clean energy to PGE’s system…
When we opened Green Future Impact for enrollment, customers committed to purchase the
equivalent output of a 160 megawatt renewable energy facility in just over three minutes.
Overall, the project supports the local and regional green economy by bringing a new renewable facility
online in Oregon and contributing to green energy jobs.”
Program Benefits
• Additional options for sourcing up to 100% renewable energy.
• The ability to purchase full output of a facility or just a share of it.
• The knowledge that you’re helping to bring a new, local renewable resource online.
• A more tangible connection with your renewable power resource.
• Predictable, energy prices through a long-term contract.
Current Enrollment
• Adobe • The City of Hillsboro
• Comcast • The City of Lake Oswego
• Daimler Trucks North America • The City of Milwaukie
• Digital Realty • The City of Portland
• Multnomah County • The City of Salem
• Oregon Health & Science University • The City of West Linn
• Portland State University • The City of Wilsonville
• Portland Community College • Washington County
• The City of Beaverton
Pricing
Pricing options not laid out on PGE’s site. Only resource is the Minimum Power Purchase Agreement
(PDF opens in Adobe Reader link midway down page of
https://www.portlandgeneral.com/business/power-choices-pricing/renewable-power/green-future-
impact). Pricing changes for different term lengths – 10, 12, 15 and/or 20 years.
Filings with the Oregon PUC (source) https://www.portlandgeneral.com/our-company/regulatory-
documents/tariff
Schedule 55 is found in the list at the link above – Large Nonresidential Green Energy Affinity Rider
(GEAR)
• Branded as “Green Future Impact”
• Opens as PDF in Adobe ReaderG r e e n T a r i f f B a c k g r o u n d | 10
Utah – Rocky Mountain Power
Two Green Tariff Schedules outlined in WRI brief
Electric Service Schedule 32 – Service from Renewable Energy Facilities
Branded as Utah Subscriber Solar Program or Blue Sky
Marketed to Residential Customers
Utah Subscriber Solar
https://www.rockymountainpower.net/savings-energy-choices/blue-sky-renewable-energy/subscriber-
solar.html: “This program gives you the ability to use solar power even if you cannot afford or do not
want solar panels on your home.
• Get your power from a 20-megawatt solar plant in Millard County, Utah,
• Subscribe in blocks of 200-kilowatt-hours (kwh) to offset your usage on your bill.
• Keep your subscription for up to 20 years. If you move to another site in Utah served by Rocky
Mountain Power, your solar blocks go with you.”
(https://www.rockymountainpower.net/content/dam/pcorp/charts/en/rockymountainpower/ut-
subscriber-solar-residential.jpg)
Blue Sky https://www.rockymountainpower.net/savings-energy-choices/blue-sky-renewable-
energy.html
“Support renewable energy in fixed price, 200 kilowatt-hour “blocks” of 100% western region wind
(50%) and solar (50%) energy and help fund new, community-based renewable energy projects in your
state. The cost is $1.95 per 200 kWh block per month.”
Marketed to Business Customers
Blue Sky Block
https://www.rockymountainpower.net/savings-energy-choices/blue-sky-renewable-energy.html :
“Support renewable energy in fixed price, 200 kilowatt-hour “blocks” of 100% western region wind
(50%) and solar (50%) energy and help fund new, community-based renewable energy projects in your
state. The cost is $1.95 per 200 kWh block per month.”
Blue Sky QS: “Renewable sources are the same as Blue Sky Block, but you get a discount when you
purchase more than 101 blocks per month for 12 months (1,212 blocks minimum purchase). The cost
ranges from $1.94 to $0.70 per block (calculated on a sliding scale by volume).”
Filing with Utah PSC
Utah Rates and Tariffs https://www.rockymountainpower.net/about/rates-regulation/utah-rates-
tariffs.html
Full Text: Electric Service Schedule 32 (Select from list on link above)
Electric Service Schedule 34 – Renewable Energy Purchases for Qualified Customers
Aimed at customers 5,000 kW and over. Program not marketed on RMP site. “This Schedule governs
contract guidelines for the Company to acquire renewable energy on behalf of qualified Customers.”
Filing with Utah PSC
Full Text: Electric Service Schedule 34 (Select from list on link above)G r e e n T a r i f f B a c k g r o u n d | 11
Washington – Puget Sound Energy
Green Direct – Official Green Tariff program listed in the WRI brief
Marketed to Business Customers (source)
https://www.pse.com/green-options/Renewable-Energy-Programs/green-direct
“This [Green Direct] initiative is an effort to provide a dual solution for PSE’s corporate and municipal
customers. One that meets both carbon reduction goals, providing them with the ability
to purchase 100 percent of their energy from a dedicated, local, renewable energy resource, while
providing them with a stable, cost efficient solution.”
Power from Skookumchuck Wind Energy Project in SW Washington. 135MW capacity constructed in
2019.
PSE has 19 businesses and municipalities partnering on this program.
Pricing information and other program benefits are not outlined on the site.
Filings with Washington UTC (source)
https://www.pse.com/pages/rates/electric-tariffs-and-
rules#first=30&sort=%40fdocumentdate43883%20descending and then search for “Electric Schedule
139”
Full Text: Electric Schedule 139 – Voluntary Long Term Renewable Energy Purchase Rider
• Branded as “Green Direct”
• PDF opens in Adobe Reader
Customers must enroll in this program during a designated “Open Season” timeframe and/or through a
multi-year contract. Upon acceptance, customers may also request additional resources to be
built/purchased at a future date which will meet “the guidelines” (tariff language).
Pricing
a. Energy Charge Credit: ($0.047125) per kWh
b. Resource Option Energy Charge: Listed in Section 9 of Electric Schedule 139. There are six options for
resource fuel mix at different price points (see pages 7-9 of Electric Schedule 139).
Charges under this Schedule will be in addition to all the other charges under the Customer’s existing
Electric Service schedule.G r e e n T a r i f f B a c k g r o u n d | 12
Useful Terms for the NorthWestern Energy Green Power Stakeholder
Advisory Group
C&I Commercial and industrial customers.
Choice In Montana, this refers to customers who are buying electricity supply
from a competitive supplier but are still NorthWestern’s delivery
customer.
Demand Charge Daily or monthly charges paid by large electricity customers for their
peak demand in kilowatts from the grid. This is a measure of the
capacity they require from the grid in a time period.
Green-e Green-e is an independent consumer protection program providing
certification and verification for renewable electricity and renewable
energy certificates (RECs) sold to households and organizations.
GS General service.
IOU Investor-owned utility.
IPP Independent power producer, a company that generates and sells
power.
KW Kilowatt.
kWh Kilowatt-hour.
MW Megawatt.
MWh Megawatt-hour.
Net Metering A billing mechanism that credits customers supplying surplus solar or
other renewable energy power to the public grid.
PPA Power purchase agreement.
PUC (or PSC) State Public Utility Commission (or Public Service Commission) which
regulates the electric utilities in a given state also known as utility
regulator.G r e e n T a r i f f B a c k g r o u n d | 13
RE Renewable energy.
REC A renewable energy certificate is a tradable, legal mechanism that
represents the environmental benefits associated with one Megawatt-
hour (MWh) of electricity generated from a renewable energy resource.
It may be bundled with electricity generated or unbundled in which case,
the REC is the environmental benefits and can be transferred.
RPS Renewable Portfolio Standard, for example, state-law requirements
as to the proportion of energy sold by a regulated utility that must
come from specified types of RE generation.
Tariff Electricity pricing, and price structure, charged to customers as
approved by the PUC or PSC.SETTLEMENT AGREEMENT ON E+ GREEN TARIFF
DEPARTMENT OF PUBLIC SERVICE REGULATION
BEFORE THE PUBLIC SERVICE COMMISSION
OF THE STATE OF MONTANA
IN THE MATTER OF NorthWestern Energy’s ) REGULATORY DIVISION
Application for Authority to Increase its Retail )
Electric Utility Service Rates and For Approval ) DOCKET NO. D2018.2.12
Of its Electric Service Schedules and Rules. )
STIPULATION AND SETTLEMENT AGREEMENT OF
NORTHWESTERN ENERGY, THE MONTANA DEPARTMENT OF
ENVIRONMENTAL QUALITY, THE MONTANA CONSUMER COUNSEL,
AND WALMART
NorthWestern Corporation d/b/a NorthWestern Energy (“NorthWestern”), the Montana
Department of Environmental Quality (“DEQ”), the Montana Consumer Counsel (“MCC”), and
Walmart (collectively “Stipulating Parties”), by and through their undersigned representatives,
hereby submit to the Montana Public Service Commission (“Commission”) this Stipulation and
Settlement Agreement (“Agreement”).
For settlement purposes, a fair and equitable resolution has been reached on the issues raised in
this Docket concerning NorthWestern’s E+ green tariff and other potential renewable energy
products (“Settled Issues”). To reach a fair and equitable resolution of the issues that were raised
or could have been raised by the Stipulating Parties regarding the Settled Issues, the Stipulating
Parties stipulate and agree as follows:
1. Within thirty (30) calendar days from issuance of a Final Order from the Commission
approving this Agreement, NorthWestern agrees to initiate a process to review its E+
green program and consider options for a new renewable energy product tariff, including
but not limited to an option for non-residential customers. Such process shall include
customer research and engagement with relevant and appropriate stakeholders, including
DEQ, MCC, and Walmart, in transparent manner.
2. Within ninety (90) calendar days from issuance of a Final Order from the Commission
approving this Agreement, NorthWestern agrees to make a progress report on the status
of the initiated process with the Commission in a docket separate and apart from
NorthWestern’s Electric Rate Review Docket, Docket No. D2018.2.18. NorthWestern
shall copy counsel for DEQ, MCC, and Walmart on the filing of the progress report.
3. No later than one hundred eighty (180) calendar days from issuance of a Final Order
from the Commission approving this Agreement, NorthWestern agrees to make a filing to
either modify its existing E+ green tariff, propose a new renewable energy product tariff,
Page 1 of 3or explain to the Commission why NorthWestern believes no change is necessary to
existing tariffs.
4. This Agreement shall not constrain the rights of DEQ, MCC, or Walmart to file an
alternative proposal to modify NorthWestern’s existing E+ green tariff, to propose a new
renewable energy product tariff, or to contest the filing described in paragraph 3 above.
The Agreement resolves all issues raised by the Stipulating Parties regarding the Settled Issues.
Except as specifically noted below, no individual Stipulating Party’s position in this docket is
accepted by any other Stipulating Party by virtue of its entry into this Agreement, nor does it
indicate any Stipulating Party’s acceptance, agreement, or concession to any rate making
principle or legal principle embodied or arguably embodied in this Agreement.
The Stipulating Parties stipulate to the admission into the evidentiary record of all pre-filed
testimony and exhibits of the witnesses for the Stipulating Parties to support the reasonableness
of the Agreement and shall refrain from cross-examining the witnesses of the Stipulating Parties
regarding the Settled Issues. The Stipulating Parties shall each call one witness at hearing to
support this Agreement.
The various provisions of this Agreement are inseparable from the whole of the agreement
between the Stipulating Parties. The reasonableness of the proposed settlement set forth in this
Agreement is dependent upon its adoption, in its entirety, by the Commission. If the Commission
declines to approve this Agreement as agreed to herein by the parties, or if the Commission adds
or removes any terms or conditions not agreeable to the parties, either party shall, at its sole
option, have the right to withdraw from this Agreement with all of its rights reserved. The
Agreement and all its parts shall then be null and void, and the parties shall not be bound by any
provision of it, and it shall have no force or effect whatsoever. In such event, the existence or
terms of this Agreement shall not be admissible in any proceeding before the Commission or any
court for any purpose.
The Stipulating Parties acknowledge that this Agreement is the result of a voluntary, negotiated
settlement between them pursuant to ARM 38.2.3001, and agree that this Agreement, inclusive
of the compromises and settlements contained herein, is in the public interest.
This Agreement may be executed in one or more counterparts and each counterpart shall have
the same force and effect as an original document, fully executed by the Stipulating Parties. Any
signature page of this Agreement may be detached from any counterpart of this Agreement
without impairing the legal effect of any signatures thereon, and may be attached to another
counterpart of this Agreement identical in form hereto but having attached to it one or more
signatures page(s).
SIGNATURE PAGES DELETED FROM THIS COPY.
Page 2 of 3DOCKET NO. 2018.02.012, ORDER 7604u 78
LANGUAGE FROM COMMISSION FINAL ORDER IN
DOCKET NO. 2018.02.012, ORDER 7604u
RELATED TO E+ GREEN TARIFF
E. E+ Green Tariff Settlement
258. The E + Green tariff is an optional tariff required by Montana statute. Mont. Code
Ann.§ 69-8-210 (2). NorthWestern's initial Green Power Product Offering Program Rate
Schedule was approved by the Commission on October 8, 2002. Dkt. D2002.7.81, Interim Order
No. 6448. The current E+ Green tariffs were re-approved in Docket No. D2009.9.129 in Order
No. 7046h with minimal changes to the original tariffs.
259. DEQ suggests that a replacement or supplementation ofNorthWestern's E+
Green tariff should be developed in consultation with NorthWestern and other stakeholders, and
NorthWestern should file a proposal to replace or supplement the current E+ Green tariff within
120 days ofthe conclusion ofthe final order in this docket. Test. Daniel Lloyd at 13 (Feb. 12,
2019). The tariff allows retail customers to purchase 100-kWh blocks of"green tags" at a rate of
$0.02/kWh (or $20/MWh) per month. The green tags consist ofRenewable Energy Credits
("RECs") purchased by NorthWestern from the Bonneville Environmental Foundation on behalf
ofthe E+ Green customers. Enrollment between 2013 and 2017 averaged 289 residential
customers and 16 commercial customers. The price ofRECs has declined over the period ofthe
program, to $8/MWh as ofJanuary 30, 2019. Id. at 7. The over-collected revenues from the
program are transferred to NorthWestern's Universal System Benefits Renewable Resources
Program.
260. Walmart is involved in contracting for off-site and on-site renewable resources in
other states, and engages in utility partnerships to develop commercial and industrial programs
that have minimal impact on non-participating customers. Test. Chriss at 19-20. Walmart
suggests that the Co1mnission should require NorthWestern and interested parties to develop and
submit a filing for a new renewable product offered to commercial and industrial customers
within 120 days ofa final order in this case. Id. at 22.
261. The MCC recommends that NorthWestern be directed to address concerns
regarding the pricing ofRECs in the E+ Green program, and suggests that a stakeholder group
might be a worthwhile endeavor ifit proceeds from a clean slate, without any pre-conceived
direction to incorporate specific principles. Cross-Intervenor Test. Dismukes at 88. MCC notes
that it is unlikely a workshop process would be completed in 120 days. Id.DOCKET NO. 2018.02.012, ORDER 7604u 79
262. NorthWestern states that a 120-day timeline to review the E+ Green program and
study new renewable programs is too restrictive. Reb. Test. Schroeppel at 4. NorthWestern states
that it is willing to review the programs, and would be willing to report back to the Commission
with a reco1mnended process and suggested deliverables, including a time-line that would be
more appropriate than 120 days. Id. at 6-8.
263. On May 13, 2019, a Stipulation and Settlement Agreement between
NorthWestern, DEQ, MCC, and Walmart was filed with the Commission related to
NmihWestern's E+ Green tariff and other potential renewable energy products. The Stipulation
requires NorthWestern to initiate a process to review its E+ Green program, which includes
customer research and engagement with relevant stakeholders. The Stipulation also requires
NorthWestern to make a filing to modify the existing E+ Green tariff, propose a new renewable
energy product tariff, or justify maintaining the existing tariff without changes.
264. The Commission finds that the E+ Green Stipulation has no impact on current
rates. The low customer subscribership illustrates that the tariffs, which have been in place for 17
years with minimal modifications, are not currently successful in attracting a customer response.
Additionally, the price of RECs has declined over the period of the program, indicating the
current E+ green rate could possibly be reduced. There is no opposition from the other
intervenors in this docket to the Stipulation.
LANGUAGE FROM COMMISSION FINAL ORDER IN
DOCKET NO. 2018.02.012, ORDER 7604u
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