The Minnesota Public Utilities Commission (PUC) has notified the public that the comment period regarding Xcel Energy’s NGIA plan ends at 4:30 pm on Wednesday, October 21, 2026. NGIA is short for the Natural Gas Innovation Act.
The formal title for this is: In the Matter of A Petition of Northern States Power Company for Approval of Its First Plan Under the Natural Gas Innovation Act. The PUC Docket Number is G002/M-23-518. The relevant PUC web pages are:
The PUC has asked for written comments on the following seven questions:
- What, if any, action should the Commission take regarding Northern States Power Company d/b/a Xcel Energy’s (Xcel’s) Natural Gas Innovation Act plan in response to its 2026 Natural Gas Innovation Plan Annual Report?
- Should the Commission approve the continuation of Xcel’s plan, approve the continuation of Xcel’s plan with modifications, or disapprove the continuation of Xcel’s plan?
- Should the Commission modify any pilots or R&D projects?
- Should the Commission disapprove the continuation of any pilot or R&D project, including but not limited to the Pipeline Blending CRADA R&D project proposed by the Company?
- Has Xcel adequately assessed impacts from federal and state law and/or tax policy that might affect the feasibility of approved projects?
- Should the Commission approve the Company’s proposed NGIA Rider rate of $0.018269 per therm for Residential Customers; $0.009594 per therm for Commercial Firm customers; $0.006063 per therm for Commercial Demand Billed customers; and $0.015966 per therm for Interruptible customers, and the associated customer bill message?
- Are there other issues or concerns related to this matter?
My public comments further below, on behalf of the Center of the American Experiment (CAE), focus on the final question, and are based on highlights from the following dozen articles, that I have so far written in relation to the NGIA.
Heat pumps: less heat, more pump
Source: https://www.americanexperiment.org/heat-pumps-less-heat-more-pump/
Two posts from a couple years back in Powerline sounded the alarm on the push to replace gas heating in Minnesota with heat pumps. The author was no less than John Hinderaker, the President of Center of the American Experiment.
The initial post on March 19, 2024 of “Next Up, Heat Pumps” first alerted:
If you’ve wondered how liberals expect you to heat your house after they have outlawed fossil fuels, the short answer is heat pumps.
The subsequent post on September 19, 2024 of “Here Come the Heat Pumps?” then warned:
Liberals have every intention of depriving you of the option of heating your home (or cooking your food) with fossil fuels.
Xcel Energy are currently spending significant sums of money on research and development (R&D), under the auspices of the “Natural Gas Innovation Act” (NGIA). NGIA was signed into law by Governor Tim Walz on June 26, 2021. The relevant Minnesota Statute is 216B.2427 entitled “Natural Gas Utility Innovation Plans.”
Xcel filed their first NGIA report with the PUC on June 15, 2026, based on Xcel’s original NGIA plan filed with the PUC on December 15, 2023, and subsequently approved by the PUC on May 16, 2025. All of these documents, and more, can be found under PUC eDocket 23-518.
One key highlight from the 2026 Xcel report to the PUC is that:
The Company is transitioning the name of this pilot from ‘Community Ground Source Heat Pump’ to ‘Utility Thermal Energy Network’ (UTEN) to match the industry trend[.] … At a high level, the Company hopes to learn more about whether this technology can be used to decarbonize our gas utility system, cost effectively, at scale.
Another key highlight from that report is:
Locating an [Industrial Heat Pump (IHP) Field Trial] customer has been challenging for several reasons. First, because, even if an IHP is a good technical solution that supports decarbonization, in many instances the payback period and/or increased electric charges are not financially beneficial to the customer.
Regarding geothermal heat pumps, in particular, the Energy Information Administration (EIA) explains that:
Geothermal heat pumps are generally more expensive ($2,000-$5,000) to install than outside air heat pumps.
The economics, from the vantage point of one company in the heat pumps business, Abe Heating & Cooling, is:
A geothermal system is much more expensive to install than a gas furnace.
Another company, but in the broader heating business, Bryant Heating & Cooling Systems, has a similar take of:
The average installation cost for a geothermal heat pump system typically ranges from $15,000 to $30,000.
A ‘liberal’ position is provided by the Center for Energy and Environment (CEE) in their January 9, 2024 post calling for “The need for natural gas decarbonization in Minnesota.” In this, CEE, however, acknowledge:
Despite advances in technology, electric heating alternatives like cold-climate heat pumps still lose efficiency and the ability to produce the same quantity of heat at very low temperatures, meaning most households in Minnesota will need a secondary heating system.
A ‘conservative’ position is provided by the Competitive Enterprise Institute (CEI) in their March 18, 2025 post celebrating that “Trump cancels Biden’s heat pump crisis.” As CEI note:
While a heat pump’s cooling capacity is comparable to that of a stand-alone air conditioner, its heating capacity is definitely not on par with a gas furnace. Thus, many heat pump owners would still need to rely heavily on a backup source of heat…to get through the winter, especially in northern states. Keep in mind, natural gas is [seven] times cheaper than electricity on a per unit energy basis[.] High upfront costs are also an issue.
The following quote, from Tim Blair writing in Quadrant on June 26, 2026, not only echoes John Hinderaker’s alert and warning from March and September 2024, but it perfectly sums up the big push for heat pumps, renewable energy and all the rest:
“The green agenda put simply: things will cost more, won’t work as well, and you’ll have no choice but to comply.”
NGIA: ‘No more’ Gas Innovation Act
Source: https://www.americanexperiment.org/ngia-no-more-gas-innovation-act/
The NGIA, is yet another example of Orwellian doublespeak. Rather than being about innovation in natural gas, the NGIA’s provisions are about the replacement of natural gas. And like renewables in electricity, the replacements promise to be unreliable, expensive and mandatory. Let’s look at the ‘devil in the details.’
The following provision states the goal of the NGIA, that being to “reduce the overall amount of natural gas…to customers.” It is on the second last page of Minnesota statute 216B.2427. It should be on the first page, or at least be the provision right after the definitions.
It is the goal of the state of Minnesota that through the Natural Gas Innovation Act and Conservation Improvement Program, utilities reduce the overall amount of natural gas produced from conventional geologic sources delivered to customers.
There are twenty one definitions. The key one is “Innovative resource,” which crucially does not include conventional natural gas (CNG) in any form, low carbs or not. Indications are that the following ‘big three,’ of the eight below, are most likely to replace CNG [i.e. “District energy,” “Renewable natural gas” and “Strategic electrification”].
“Innovative resource” means biogas, renewable natural gas, power-to-hydrogen, power-to-ammonia, carbon capture, strategic electrification, district energy, and energy efficiency.
The overall goal of replacing CNG is reflected in, and funded through, the following definition.
“Total incremental cost” means … cost savings achieved through avoidance of purchases of natural gas produced from conventional geologic sources, including but not limited to avoided commodity purchases and avoided pipeline costs.
Both CenterPoint and Xcel have recently filed plans with the PUC. These plans are mainly about the utilities spending money on how best to get rid of CNG. Money which they will be compensated for, by the PUC, out of the pockets of Minnesotans. Even the possibility of lower emissions CNG is ruled out by design.
Upon approval of a utility’s plan, the commission shall establish cost-effectiveness objectives for the plan based on the cost-benefit test for innovative resources developed under section 216B.2428.
The PUC adopted “the partial cost-benefit-analysis framework [CBAF] jointly recommended by the parties and participants” on June 1, 2022. The PUC should have produced a full CBAF.
The important phrase below, of course, is “natural gas that the innovative resource displaces.”
Without filing an innovation plan, a natural gas utility may propose and the commission may approve cost recovery for: utility expenditures for innovative resources…per unit of natural gas that the innovative resource displaces.
Below appears to be a cross-subsidy from residential and commercial to industrial customers, on top of them having to pay for their own ‘transition’ away from CNG.
The first innovation plan filed under this section by a utility…must include a pilot program to provide thermal energy audits to small- and medium-sized businesses in order to identify opportunities to reduce or avoid greenhouse gas emissions from natural gas use. The pilot program must provide incentives for businesses to implement recommendations made by the audit.
According to the EIA:
Natural gas use for power generation in the state has substantially increased during the past decade, and in 2024 the sector consumed a record amount of natural gas in the state. Minnesota’s electric power sector used almost four times more natural gas than it consumed in 2014. [O]ne-fifth goes to the state’s electric power sector.
CNG removal appears to be aimed at residential households and non-industrial commercials, even as, according to the EIA:
The industrial sector consumes the largest share of natural gas delivered to consumers in Minnesota and accounts for about three-tenths of state consumption. The residential sector, where two out of three Minnesota households heat with natural gas, uses about one-fourth of the natural gas delivered to consumers in the state. The commercial sector accounts for more than one-fifth[.]
Although it is not all that clear from the NGIA legislation, what are the favored replacements for natural gas and by when, it is clear that CNG is intended to be replaced one way or another, ‘come hell or high water.’
Natural gas: the quiet energy affordability crisis
Source: https://www.americanexperiment.org/natural-gas-the-quiet-energy-affordability-crisis/
Energy affordability is a big issue for Minnesotan voters. This is according to the most recent Thinking Minnesota poll. Although the focus of concern is more so on gasoline and electricity, as per Chart 1 below, natural gas is also on the affordability radar. And it should be, given it has significantly, but quietly, been inflating.
Chart 1
Source: Meeting Street Insights
A few things that stand out in Chart 2 below of Minnesota natural gas (NG) prices are:
- Prices for all four major customer classes largely move up and down together over time. This is because NG is part of, not just a state or regional, but a national and international market.
- Prices were relatively flat in the 1980s and 1990s, but then largely took off since then. This is because the 80s and 90s were about economic growth not climate change.
- Residential prices are the highest followed by commercial, industrial and electric power. In 2024 for example, 10.65 residential, 8.46 commercial, and 5.10 industrial. Minnesota electric power prices are only available for 1997-2002 and 2008. The average was 4.32.
Chart 2
Source: Energy Information Administration
Chart 3 below compares NG residential prices (RP) in Minnesota to the Midwest (MW) and the nation (US). MW is comprised of: 1.) IL; 2.) IN; 3.) IA; 4.) MI; 5.) MN; 6.) NE; 7.) ND; 8.) OH; 9.) SD; and 10.) WI. Chart highlights include:
- In 2025, NGRP was lowest in MN at 10.98, compared to 11.06 in the MW and 15.34 in US.
- Thus, MW was only 0.7% higher than MN, but the US was a whopping 39.7% more.
- However, between 2002 and 2025, MN’s NGRP inflated by 66.1%, which was somewhat greater than the MW’s of 64.3%, yet thankfully far less than the nation’s 94.4%.
Chart 3
Source: Energy Information Administration
Affordability is as much about the quantity or use of energy as it is the price. Both are determined by market demand and supply, subject to government interventions. Regarding the latter, NG and electricity markets are intertwined and have both been increasingly impacted by renewable mandates and subsidies. As per Chart 4 below:
- Whilst residential and commercial NG use data for MN goes back to 1967, industrial and electric power (EP) data only starts in 1997.
- From 1997 to 2025, EP use skyrocketed by 1,507%, compared to 25.9% industrial, 18.8% commercial and 9% residential.
- NG use ratios (of 100%) went from 1.8% EP, 32.1% commercial, 27.6% commercial and 38.5% residential in 1997, to 20.3%, 28.0%, 22.7% and 29.1% respectively by 2025.
Chart 4
Source: Energy Information Administration
Chart 5 below shows EP use for MN, MW and US as an index, with 2002 as the base year set to 100. Indexes make readily apparent any change over time. Especially when there are large differences in scale, as is the case for NG use in a state compared to that in a region or nation. As per below, NGEP use for 1997 to 2025 grew:
- relatively modestly in the US nation, from 71.7 index points to 230.2, or by 221%;
- very robustly in the MW region, from 68.3 index points to 567.4, or by 731%;
- like gangbusters in the state of MN, from 46.4 index points to 745.8, or by 1,507%.
Chart 5
Source: Energy Information Administration
CleanTechnica recently wrote: “Low cost natural gas began pushing coal out of the power generation business in the early 2000’s.” As is typical with environmentalist narratives, this is a half-truth. The full truth is: A.) activist governments were behind “pushing coal out;” and B.) “low cost natural gas” was “low cost” relative to wind and solar, rather than to base-load coal.
Natural gas prices have been inflating in the 21st century because it has had to increasingly carry the load (base and peak) for reliable electricity generation, whilst coal was being pushed out and off the grid, at the same time renewables were being pushed in and on.
Natural gas affordability: CPI inflation and volatility
Source: https://www.americanexperiment.org/natural-gas-affordability-cpi-inflation-and-volatility/
I wrote about natural gas affordability with the aid of official data on prices and quantities from the EIA. Now let’s examine this using the official data on Consumer Price Index (CPI) from the Bureau of Labor Statistics (BLS).
Although CPI literally has the term “price index” in the full name, there is an element of quantity index as well. Quantity of goods and services that is. BLS has decades of CPI data for electricity and natural gas specifically and respectively. Unfortunately, these are no longer compiled since 2025 for metropolitan areas, like Minneapolis-St. Paul (MSP), nor for regions, such as the Midwest (MW).
Chart 6 below of CPI, for the Twin Cities or MSP alone, contrasts natural gas CPI with all items CPI. Key trends include:
- natural gas CPI was relatively flat between 1986 and 1999, increasing only 4.2% from 83 index points to 87;
- natural gas CPI exploded by 65% from 112 in 2000 to 186 in 2008, then dropped and was 41% lower by 2020 at 110, but shot up again by 88% to 206 in 2022;
- overall from 2000 until 2024, although natural gas CPI had inflated 43% compared to all items CPI inflation of 76%, the former has high volatility at 28 standard deviation points compared to the medium volatility of the latter of 20 points.
Chart 6
Natural gas CPI has largely been contiguous in its trend as well as ups-and-downs from 1978 to 2024, when comparing MSP to both MW and US. Chart 7 below of natural gas CPI has five stand-out trend periods. Highlights from these, for MSP only, include:
- 1978 to 1984: inflation of 127%; and standard deviation or volatility of 22;
- 1985 to 1999: deflation of -6%; and volatility of 8;
- 2000 to 2008: inflation of 65%; and volatility of 31;
- 2009 to 2019: deflation of -8%; and volatility of 9;
- 2020 to 2024: inflation of 46%; and volatility of 34.
Chart 7
CPI measures changes in price and quantity, but not quality as such. Volatility, however, can also be gleaned from it. A few important things to know about volatility are as follows.
“Volatility is the most fundamental risk measure in [statistics]. Standard deviation (σ) measures the dispersion of [data] around their average (mean). A higher standard deviation means more volatility — wider swings in both directions.” – Ryan O’Connell
“If we lose 50% of our money, we cannot simply average our results across the multiverse of alternative selves who may not have lost theirs. The best we can do is try to average our results over time on our one, singular path. When you average over time, choices compound. And when choices compound, so does risk. The impact of compounding means that volatility matters.” – Return Stacked Portfolio Solutions
” The prices of electricity and natural gas are subject to continuous fluctuations, a phenomenon known as energy pricing volatility. Beyond direct costs, volatility undermines financial planning for both households and businesses, creating budgetary uncertainty that can lead to stress for families and hinder long-term investment or growth—especially in energy-intensive sectors. Because energy is a fundamental input across various industries, including manufacturing, agriculture and retail, rising costs often ripple through the economy.” – Energy Business Review
Energy affordability has three major dimensions of price inflation, quantity or quality curtailment or deprivation, as well as volatility of these. In electricity, deprivation can take the form of blackouts. Electricity CPI in MN has been more about inflation than volatility, whereas natural gas CPI in MSP has been more volatile but with an inflationary trend upwards. Either way, both electricity and natural gas are significantly less affordable in the 21st century.
Energy affordability misery: electricity and natural gas, inflation and volatility
I have been analysing Minnesota’s energy affordability, but separately as either electricity or natural gas. Let’s now look at these side-by-side, using CPI as published by the BLS. Spoiler alert: Energy affordability is looking miserable for Minnesota; electricity, more so than natural gas, so far.
Chart 8 below presents three types of CPI: all items; electricity; and natural gas. The base of 1982-84 was set to 100 by BLS. Note that 2002 is the key year, as both electricity and natural gas consistently inflate from then. This is no surprise given that wind and solar promotion policies in Minnesota, and the Twin Cities, get going from 2001 onwards. Highlights from this chart, for 2002 to 2024, include:
- all items CPI inflation of 67%, from 180 to 300 index points, and volatility of 34;
- electricity CPI inflation of 131%, from 139 to 321 index points, and volatility of 53;
- natural gas CPI inflation of 60%, from 113 to 181 index points, and volatility of 32.
Chart 8
Chart 9 below compares electricity CPI for MSP to the MW region and the US as a whole. Highlights from this chart, for 2002 to 2024, include:
- MSP electricity CPI inflation of 131%, from 139 to 321 index points, and volatility of 53;
- MW electricity CPI inflation of 92%, from 126 to 241 index points, and volatility of 34;
- US electricity CPI inflation of 105%, from 136 to 279 index points, and volatility of 37.
Chart 9
Chart 10 below compares natural gas CPI for MSP to the MW and the US. Highlights from this chart, for 2002 to 2024, include:
- MSP natural gas CPI inflation of 60%, from 113 to 181 index points, and volatility of 32;
- MW natural gas CPI inflation of 50%, from 127 to 190 index points, and volatility of 33;
- US natural gas CPI inflation of 70%, from 135 to 230 index points, and volatility of 30.
Chart 10
To summarise the energy inflation highlights from the charts above, for 2002 to 2024:
- MSP electricity inflation = 131%, natural gas inflation = 60%, energy inflation = 191%;
- MW electricity inflation = 92%, natural gas inflation = 50%, energy inflation = 142%;
- US electricity inflation = 105%, natural gas inflation = 70%, energy inflation = 175%.
To summarise the energy volatility highlights from those same charts, for 2002 to 2024:
- MSP electricity volatility = 53, natural gas volatility = 32, energy volatility = 85;
- MW electricity inflation = 34, natural gas volatility = 33, energy volatility = 67;
- US electricity volatility = 37, natural gas volatility = 30, energy volatility = 67.
A revealing way to summarise and compare the highlights from the charts above is to take a Misery Index (MI) approach. The original MI is easily calculated as the inflation rate (usually CPI) plus the unemployment rate, but expressed as a percentage change not as an index number. Given that inflation and unemployment are each bad in themselves, a large and increasing MI is even worse. Zero, or negative due to deflation, would be the ideal.
Given that inflation and volatility are each bad in themselves, a large and increasing energy misery index (EMI) is really bad. Zero, or negative, would be the ideal. The following EMI data for energy inflation plus volatility is expressed as an index number, not a percentage change:
- MSP EMI = 335, given electricity = 235 and natural gas = 100;
- MW EMI = 246, given electricity = 150 and natural gas = 96;
- US EMI = 305, given electricity = 180 and natural gas = 125.
Minnesota energy affordability, as represented by the Twin Cities, has been miserable from 2002 to 2024. More miserable than the country by a factor of 110%, and far more than the region by 136%. And, electricity inflation and volatility have been the senior partners, to those of natural gas, in driving 21st century energy affordability misery in the North Star State.
Hands off my gas! The plan to ban natural gas
Source: https://www.americanexperiment.org/hands-off-my-gas-the-plan-to-ban-natural-gas/
Minnesota is now into the fifth year of a long-term plan to effectively ban the use of natural gas for most homes and businesses. This plan is called the “Natural Gas Innovation Act” or NGIA, which was signed into law by Governor Walz in June 2021.
The NGIA process is governed by the PUC, which stated in November 2021:
The NGIA establishes a framework to allow natural gas utilities to meet Minnesota’s greenhouse gas reduction and renewable energy goals through innovative resources. … needed to decarbonize natural gas service[.]
The PUC has a web page devoted to the NGIA, including the following on “Why it matters:”
The NGIA and its innovation plans enable gas utilities to begin testing methods to reduce their emissions, and in some cases, transfer their business away from natural gas entirely. The results of approved pilots will lay the groundwork for future decarbonization efforts in the state and help gas utilities achieve the state’s goal of economy-wide carbon neutrality by 2050.
The PUC approved the initial plans for CenterPoint in October 2024 and Xcel in May 2025. The process for each of these began in June and December 2023 respectively. CenterPoint interestingly noted on page 3 of their plan that:
Decarbonizing the natural gas sector requires a different approach than decarbonizing the electricity sector, and CenterPoint has crafted a plan that uses innovative resources to reduce GHG emissions and natural gas throughput.
The next stage of the process are the annual reports to the PUC by both CenterPoint and Xcel on their NGIA progress so far. Their 2025 ones were submitted in 2026, on June 1 and June 15 respectively. A key highlight from the Xcel annual report is regarding geothermal heat pumps:
At a high level, the Company hopes to learn more about whether this technology [of Community Ground Source Heat Pump or Utility Thermal Energy Network (UTEN)] can be used to decarbonize our gas utility system, cost effectively, at scale. The more specific learning objectives for this pilot are…understanding the challenges and solutions for securing customer participation for this technology, including costs[.]
The NGIA is not about “Natural Gas Innovation,” but instead “Innovation” away from “Natural Gas” towards expensive electricity. And electricity became costly for the same reason and in the same way. That reason is the unscientific fear of catastrophic climate change. That way is forcing affordable and reliable energy off the grid for unaffordable and unreliable energy.
Hands off my gas! Xcel is spending your money to ban natural gas
Source: https://www.americanexperiment.org/hands-off-my-gas-xcel-is-spending-your-money-to-ban-natural-gas/
CenterPoint Energy and Xcel Energy both filed NGIA annual reports with the PUC, on June 1st and 15th respectively. I focus here on Xcel’s NGIA report for 2025, with a view to subsequently and separately examining CenterPoint’s NGIA report.
Xcel’s annual NGIA report is for the period of May 16 to December 31 of 2025. The former date is when the PUC issued the NGIA Plan Order. Xcel points out on page 1 that: “Most of the Company’s efforts during this time focused on planning, project design, and contract negotiations for the projects.” The report is 113 pages in length.
On pages 2-3, Xcel summarises early progress on: Renewable Natural Gas [RNG]; Urban Tree Planting; Strategic Electrification; Thermal Energy Network; and Hydrogen Blending CRADA R&D Project. The CRADA project “will not be proceeding [as] there have been changes in the industry including economic feasibility concerns…and challenges to scalability.”
Xcel reports on 13 pilots and 6 research and development (R&D) projects. Lowlights from Xcel’s NGIA pilots and R&D projects include:
- Re Industrial Heat Pump (IHP) Field Trial: “Locating an IHP customer has been challenging…because, even if an IHP is a good technical solution that supports decarbonization, in many instances the payback period and/or increased electric charges are not financially beneficial to the customer.”
- Re Sherco 5MW Hydrogen: “the hydrogen equipment supplier space has narrowed as a result of declining general market enthusiasm for green hydrogen systems.”
- Re Custom Projects for Large Customers: “the Company did not have any large customer electrification projects that failed the ECO [Energy Conservation and Optimization] screening criteria, so did not implement any projects in this Pilot.”
- Re Prairie Island Indian Community (PIIC): “There are limited equipment options with both furnaces and heat pumps that physically fit in the unique spaces of manufactured homes [and we have] yet to find a heat pump water heater that can be installed, primarily due to space constraints.”
- Re Utility Thermal Energy Network (UTEN): “At a high level, the Company hopes to learn more about whether this technology can be used to decarbonize our gas utility system, cost effectively, at scale.”
As per page 60, Xcel is looking to recover the following level of NGIA costs from rate payers:
- $54,334,960 spend between 2025 and 2029, with 94% pilots, 5% R&D and 1% admin;
- $981,881 has been spent in 2025, with 91% pilots, 3% R&D and 6% admin;
- 2027 has the largest anticipated spend of $18,363,124, with 91% pilots and 9% R&D.
Xcel is seeking to monetize their NGIA spending, through rate increases in natural gas tariffs for most customer classes, to take effect from January 1, 2027. These are found on page 83 as follows:
- Residential: 6% increase from $0.017214 to $0.018269 per therm;
- Commercial Firm: 9% decrease from $0.010520 to $0.009594 per therm;
- Commercial Demand Billed: 408% increase from $0.001194 to $0.006063 per therm;
- Interruptible: 142% increase from $0.006601 to $0.015966 per therm.
There is also a natural gas rate case before the PUC, with a final decision expected by November 30, 2026. Xcel’s current rates for 2026 reflect a PUC interim decision, that allows for an annual 6.8% increase of $51.47 million. But Xcel is seeking a 8.2% increase of $63.40 million.
Hands off my gas! CenterPoint says ‘me too’ on natural gas ban spending
CenterPoint Energy (CPE) and Xcel Energy both filed NGIA annual reports with the PUC, on June 1st and 15th respectively. I focus here on CPE’s NGIA report for 2025, given I recently and separately examined Xcel’s NGIA report.
CPE’s annual NGIA report is for the entire calendar year. CPE points out in the cover letter that: “Through this second annual report, [CPE] reports back on activities from 2025, which included both internal and external developments as several pilots and projects get underway.” The report is 355 pages in length.
On pages 4-5, CPE summarises accomplishments including: “[The Company] is proud to report the first savings in energy consumption and GHG [greenhouse gas] reductions [and] is excited to provide an update on networked geothermal feasibility within its service area.”
CPE provides updates on 17 NGIA pilots, and also makes the 1 proposal and 3 requests. Lowlights include:
- Re Pilot I (New Networked Geothermal System): “… additional empirical data has been collected from multiple utility-owned geothermal projects across the United States showing that, for the majority of these projects, the actual costs associated with the construction of a networked geothermal pilot have been significantly higher than anticipated.”
- Re Pilot J (Decarbonizing Existing District Energy Systems): “… will help existing district energy systems that currently use geologic gas identify opportunities to reduce the lifecycle GHG impact of their systems … In 2025, no customers selected to study a full decarbonization/electrification scenario.”
- Re Pilot K (New District Energy System): “… will help current natural gas customers considering developing district energy systems … In 2025, 0 customers completed a New District Energy System (Pilot K) study and the Company paid rebates to 0 customers through Pilot K.”
- Re Pilot O (Small/Medium Business GHG Audit): “… the largest energy savings recommendation in many audits is to replace the customer’s boiler with a condensing unit. This measure is often prohibitively expensive and complex. Because most customers are not opting for this high cost and high savings measure[.]”
- Re Pilot P (Residential Gas Heat Pumps): “… the planned supplier of combination (“combi”) space and water heating gas heat pumps had suspended all business operations…which impacted the technology’s availability during the current five-year NGIA Plan period.”
As per page 10, CPE is looking to recover the following level of NGIA costs from rate payers:
- $2,427,787 spent in 2025, with 93% for pilots and 7% research and development (R&D);
- $5,114,820 spent so far under NGIA, which is 5% of the approved 5-year spend of $105,701,516, with the latter having 90% earmarked for pilots and 10% for R&D.
CPE is seeking to monetize their NGIA spending, through rate increases in natural gas tariffs for both customer classes, to take effect from January 1, 2027. These are found on page 246 as follows:
- Residential: 48% increase from $0.00360 to $0.00533 per therm;
- Commercial: 30% increase from $0.00618 to $0.00804 per therm.
Hands off my gas! Have your say by October 14-21
Source: https://www.americanexperiment.org/hands-off-my-gas-have-your-say-by-october-14-21/
This article serves as an important reminder to Minnesotans of all political stripes (who prefer to keep their places warm, showers hot, clothes dry and food cooked) to take a public stand and say, “Hands off my gas!” The best way to do that, besides casting a vote on November 3 for those willing to repeal the NGIA, is to submit comments to the PUC by October 14-21. Anyone from the public can and should comment. Not just on the details of the two annual reports, but also on the ends, means and costs of the NGIA.
Yet another Minnesota fraud? Natural Gas Innovation Act
Source: https://www.americanexperiment.org/yet-another-minnesota-fraud-natural-gas-innovation-act/
On the evening of August 26, the Center of the American Experiment (CAE) won a hard-earned and well-deserved award from the State Policy Network (SPN) for bringing to national attention Minnesota’s fraud scandal of “Feeding Our Future.” In his acceptance speech, CAE President John Hinderaker pointed out that:
It can be tough being a policy organization in a blue state because it isn’t easy to get good policy implemented. On the other hand, bad policy and incompetent government create a lot of opportunities for important public campaigns.
One such “bad policy,” from an “incompetent government” in this “blue state” of Minnesota, has “created” yet another “opportunity for an important public campaign” on fraud. That being the Natural Gas Innovation Act or NGIA, which is not about “natural gas innovation,” but about natural gas elimination from residential homes and commercial businesses.
Although probably not actionable in a court of law, this fraudulently titled statute is actionable in the court of public opinion. And, the NGIA may not be within the letter, but is certainly within the spirit, of the legal definition of fraud:
For a statement to be an intentional misrepresentation, the person who made it must either have known the statement was false or been reckless as to its truth.
The NGIA has an opaque end game: “It is the goal of the state of Minnesota that through the Natural Gas Innovation Act, utilities reduce the overall amount of natural gas produced from conventional geologic sources delivered to customers.”
The NGIA has speculative means to that end: “Innovative resource means biogas, renewable natural gas, power-to-hydrogen, power-to-ammonia, carbon capture, strategic electrification, district energy, and energy efficiency.”
The PUC is far clearer about NGIA than the statute:
The NGIA and its innovation plans enable gas utilities to begin testing methods to reduce their emissions, and in some cases, transfer their business away from natural gas entirely.
Six of the eight “innovative resources” use a lot of electricity. That six includes the most favored one of strategic electrification, which in turn includes geothermal heat pumps, which can result in four times the usage of electricity in winter.
And electricity in Minnesota is no longer cheap, since the era of renewables. From 2002 to 2025, electricity prices increased 118%, whilst natural gas decreased by 9%. Thus, electricity went from 319% more expensive than natural gas in 2002, to 763% by 2025. Renewable electricity caused this. The No-more Natural Gas Act will make this far worse.
The first complication is that the NGIA is one of the purportedly more than 40 state climate laws and programs in the Climate Action Framework (CAF), which aim to:
- reduce GHG emissions by 50% by 2030;
- 100% carbon-free electricity by 2040;
- achieve net-zero emissions by 2050.
The second complication is that the PUC is pursuing reduced natural gas use through other means. This includes the Energy Conservation and Optimization (ECO) program, which encourages heat pumps over central air conditioners for some new homes. This also includes the Gas Integrated Resource Plan (IRP), which will evaluate specific dual-fuel heating models that use electricity for most heating and switch to natural gas only during the coldest hours.
The third complication is that natural gas has increasingly been used for electricity generation in the 21st century, as renewables generation was massively increased, coal generation was retired, and no new nuclear generation has been allowed. The latter is more than likely to change in 2027 or 2028, but it might take until 2035 for new nuclear generation capacity to come into operation.
These complications make repealing the NGIA somewhat harder and possibly mooted. This is because these will still put pressure on residential and commercial users to reduce and replace natural gas use in favor of industrial, very large (e.g. data centers) and electricity generation users. The latter two will reinforce and accelerate that, given the long lead times for building new nuclear electricity generation.
These complications can be overcome. Firstly, affordability is the top voter issue in this state, and energy is one of the key reasons for that. Repealing the NGIA is an easy first step for the new governor and legislature to take in 2027. This is made easier given that Democrats across the nation are backing away from climate change as an election issue in 2026.
Secondly, NGIA’s repeal is also made more likely by the current Minnesota government study to possibly end the moratorium on new nuclear power in the state. This study has strong bipartisan support and is due by the end of January 2027. Expectations are that the study will recommend ending the moratorium. And new nuclear could come online by 2030, rather than 2035, given the recent advances in technology, along with federal government support and data center uptake.
Repealing the moratorium and NGIA together could possibly form part of a legislative package on energy affordability. This would not only immediately defund NGIA related programs to curtail and replace natural gas, and related rate increases, it would send a strong signal to the PUC to back off and get real on ECO and IRP.
This might also sow the seeds for the PUC, CenterPoint and Xcel to heed the winds of change in the air on climate change. Big Tech have been a big part of that change, as they increasingly look to build [not wind and solar renewables but instead] nuclear and natural gas to power data centers, and to do so in ways that don’t hurt ratepayers (e.g. bring their own power off-grid) or even help (e.g. build excess capacity on-grid).
Nukes and natural gas: End two bans, for the price of one
Source: https://www.americanexperiment.org/nukes-and-natural-gas-end-two-bans-for-the-price-of-one/
Electricity prices started to become more and more unaffordable in Minnesota from 2002 onwards. This was driven by the state’s: 2001 Renewable Energy Objective (REO); 2007 Renewable Energy Standard (RES); 2022 Climate Action Framework (CAF); and 2023 Clean Electricity Standard (CES).
Electricity unaffordability is made far worse by two bans. One is the current ban on any new nuclear electricity generation since 1994. The other is the planned ban, under the 2021 NGIA, on natural gas use in most homes and workplaces, by 2050, perhaps 2040 or even 2030.
The lack of additional nuclear generation has already contributed to electricity inflation since 2002. This has been mitigated by the addition of natural gas generation. However, the latter is 3 times more expensive than the former, and is usually better suited to peak-load than base-load. Although, wind and solar are 8x and 13x more expensive respectively than nuclear.
Electricity prices have been inflating in a sustainable way since 2002, as renewables increased, coal decreased and nuclear stayed [largely] the same, through to 2025. Natural gas prices, on the other hand, have slightly deflated over this same period of time.
- Chart 11 below shows that electricity prices, in dollars per one million British thermal units ($/MMBtu), rose by +118% from $16.99 in 2002 to $37.12 in 2025.
- Chart 11 also shows that natural gas prices ($/MMBtu) fell by -9% from $5.33 in 2002 to $4.86 in 2025.
- Chart 12 below plots the ratio (%) of electricity to natural gas prices, demonstrating that it skyrocketed by 3.5x from 216% in 2005 to 763% in 2025.
Chart 11
Chart 12
Electricity usage grew from 1978 to 2008, then has declined since, until 2025. Natural gas usage grew from 1978 to 1996, then took off in 1997 and 1998, as it started being used for electricity generation, in addition to residential, commercial and industrial uses.
- Chart 13 below shows electricity use (MMBtu) growing by +120% from 107 Million in 1978 to 235 Million in 2008 but then shrinking by -5% to 224 Million in 2025.
- Chart 13 also shows natural gas use (MMBtu) nicely grew by 28% from 195 Million in 1978 to 250 Million in 1996 but then took off by 100% to 501 Million in 2025.
- Chart 14 demonstrates below that the ratio of electricity to natural gas uses halved from a high of 88% in 1987 to a low of 43% in 2019 then flattened out since.
Chart 13
Chart 14
Revenues, which are prices times uses, started to noticeably pile up for electricity public utilities in the renewables era, from 2002 onwards, and for natural gas companies in the electricity generation era, from 1997 onwards. The former has since reinforced the latter.
- Chart 15 below shows that electricity revenues increased by 131% from $3.6 Billion in 2002 to 8.3 Billion in 2025.
- Chart 15 also shows that natural gas revenues grew by 145% from $979 Million in 1995 to 2.4 Billion in 2025.
- Chart 16 demonstrates below that the ratio of electricity to natural gas revenues plummeted from 334% in 1987 to 129% in 2008 then exploded up to 341% by 2025.
Chart 15
Chart 16
Total electricity customers include residential, commercial, industrial and electricity generation. Total natural gas customers include the first three classes, but not the fourth.
- Chart 17 below shows that electricity customers went from 1.9 Million in 1987 to 2.6 Million in 2008, an increase of 37%, and grew a slower 12% to 2.9 Million by 2025.
- Chart 17 also shows that natural gas customers went from 936 Thousand in 1987 to 1.5 Million in 2006, an increase of 56%, and grew a further 20% to 1.8 Million by 2024.
- Chart 18 demonstrates below that the ratio of electricity to natural gas customers dropped from 197% in 1987 to 164% in 2006, then continued on to 160% by 2024.
Chart 17
Chart 18
Bills, which are revenues divided by customers, have been on a serious and sustained rise for electricity customers since 2004, overtaking natural gas bills from 2009 onwards. The latter, however, did spike up close to the former in both 2014 and 2002.
- Chart 19 below shows that electricity bills rose by 36% from $1,175 in 1987 to $1,601 in 2004 and then ramped up another 77% to $2,834 by 2025.
- Chart 19 also shows that natural gas bills went up by +19% from $694 in 1987 to $825 in 1995 before skyrocketing by +226% to $2,688 in 2008, and then has been up-and-down since, although has sunk to -41% lower at $1,574 in 2024.
- Chart 20 demonstrates below that the ratio of electricity to natural gas bills fell from 169%in 1987 to 78% in 2008, then reversed course up to 175% in 2012, and roller coastered along to be at 175% again in 2024.
Chart 19
Chart 20
Natural gas use for electricity generation took off from 1997 onwards. Also from 1997, industrial customers use began to be tracked, along side residential and commercial.
- Charts 21 and 22 below show natural gas use for electricity generation expanding exponentially from 1997 to 2025 by 1,507%, with overall use ratio rising from 2% to 20%.
- Charts 21 and 22 also show, for 1997 to 2025, residential growth of 9%, with overall use ratio falling from 38% to 29%;
- Charts 21 and 22 in addition show, for 1997 to 2025, commercial growth of 19%, with overall use ratio falling from 28% to 23%.
- Charts 21 and 22 show as well, for 1997 to 2025, industrial growth of 26%, with overall use ratio rising from 32% to 28%.
Chart 21
Chart 22
Dear fellow Minnesotans, rise up and have your say on nuclear power by September 14, as well as on natural gas by October 14 and October 21. There is a rare opportunity to both: lift the current ban on new nuclear generation; and stop the planned ban on natural gas use. Also contact your state level DFL and GOP officials and candidates, before and after Tuesday November 3.
In Chart 23 below, MN’s electricity generation mix of both renewables and natural gas grew from 3% each in 2004 to 31% and 27% respectively by 2024, whilst coal and nuclear both shrunk from 65% and 25% respectively in 2004 to 20% each by 2024. Renewables include hydro, solar and wind.
Chart 23
In Chart 24 below, MN’s renewables generation mix of wind grew from 2% in 2004 to 25% by 2024 and solar grew from 1% in 2017 to 4% by 2024, whilst both hydro and biomass stayed relatively flat from 2004 to 2024 at less than 2% and 1% respectively.
Chart 24
Chart 25 below shows renewables generation ratio for MN increased from 3% to 31%, for MW from 2% to 21%, and US from 7% to 21%.
Chart 25
Chart 26 below shows a comprehensive Levelized Cost of Energy (LCOE), where nuclear at $37.18 per MWh is:
- 1.3x less expensive than combined cycle at $50.03;
- 2.4x less expensive than coal at $89.79;
- 3.1x less expensive than natural gas at $115.83;
- 7.9x less expensive than wind at $296.97; and
- 13.3x less expensive than solar at $496.16.
Chart 26
In summary, Minnesota’s electricity affordability has worsened due to the meteoric rise in renewables generation, especially that of wind, and to a much lesser degree solar. However, this has been mitigated, to some extent, by the almost parallel rise in natural gas generation. But natural gas is far better suited to peak-load generation, whereas wind and solar are suited to supplemental generation. Coal and nuclear are best suited for base-load.
Conclusion
Are there other issues or concerns related to this matter?
In conclusion, the NGIA is a very bad idea. It is all about moving towards effectively banning natural gas use for residential and commercial customers, but not industrials and generators, and in an opaque manner and unspecified timeframe. Natural gas in this state is vastly cheaper than electricity. NGIA will massively cost a majority of Minnesota households and businesses, to the benefit of a minority of climate “Baptists” and renewable “Bootleggers.”
What, if any, action should the Commission take regarding Northern States Power Company d/b/a Xcel Energy’s (Xcel’s) Natural Gas Innovation Act plan in response to its 2026 Natural Gas Innovation Plan Annual Report?
The NGIA is a MN law, but one with no deadlines for either achieving the “Throughput goal,” nor for when the PUC needs to “evaluat[e] a utility’s annual report” by and decide to “approve,” “require” or “disapprove” utility pilot programs or plans. Prudence would strongly suggest that the PUC puts the NGIA process on hold until early 2027, given that is when:
- there will be a new governor and legislature, that may keep or repeal the NGIA;
- there will be a new nuclear power report, that may keep or repeal the moratorium;
- the PUC’s current electricity and natural gas affordability investigation concludes.