Dear Board Chair Troxell, Vice Chair Hornbacher and Directors Bagley, Bergsten, Bernosky, Cunniff, Koenig and Marsh:
Northern Colorado Partners for Clean Energy (NCP4CE) listened closely to the Board’s discussion of the draft Integrated Resource Plan (IRP) Report during your meeting on August 27th. We were pleased to hear Chair Troxell and Director Marsh express opposition to the inclusion of a new natural gas plant in the IRP.
We wholeheartedly agree that it does not make any sense to build a new fossil fuel-fired plant in the same year that PRPA has pledged to achieve a 100% non-carbon resource mix, subject to the qualifications included in the Resource Diversification Policy approved on 12/6/18. Planning – even provisionally – to build a new natural gas plant in 2030 is tantamount to giving up on the 100% non-carbon goal ten years early. PRPA can and must do better than this.
We call on PRPA to go back to the drawing board and either revise Portfolio 3 or develop a new portfolio that would achieve the 100% non-carbon goal at lower cost and with better reliability than the current version of Portfolio 3. There are serious deficiencies with the draft IRP Report, and it is not necessary to submit that report to the Western Area Power Administration until July 2021. Time remains to do a better job.
We have already explained why we think PRPA’s costs for Portfolio 3 are too high and why we think it is important to include the Social Cost of Carbon (SCC) in the analysis for all portfolios (see our White Paper dated 6/9/20, available at https://colivableclimate.org/ncp4ce-white-paper-on-prpa-integrated-resou… and our letter to the Board dated 7/17/20). We are concerned that the slide on page 69 of the August 27th board presentation appears to have been prepared to argue against acknowledging the SCC. We are not asking PRPA to charge people more because of the SCC. We are simply asking PRPA to acknowledge the true documented external costs resulting from burning fossil fuels and to take those costs into account in the planning process.
We believe that if more attention were given to distributed energy resources (DERs), better reliability could be achieved than suggested for Portfolio 3. The Draft IRP Report mentions only distributed solar, electric vehicles, and energy efficiency. To these should be added active demand side management for commercial, governmental and residential customers. Additionally, the IRP should address – at least on a conceptual basis – the possibility of using hydrogen produced with renewables and biogas produced by municipal wastewater treatment plans to generate electricity when needed.
The public comment session at the August 27th board meeting showed that there is significant support for PRPA’s 100% non-carbon goal, and significant opposition to a new natural gas plant. We look forward to an improved public comment process at the September board meeting that will allow all those who wish to provide input to do so. We also look forward to a decision by the PRPA Board to direct staff to take the time to develop an IRP Report that will align better with the 2018 Resource Diversification Policy.
NORTHERN COLORADO PARTNERS FOR CLEAN ENERGY
Jane Clevenger, Renewables Now Loveland
Kevin Cross, Fort Collin Sustainability Group
Abby Driscoll, Sustainable Resilient Longmont
Nick Francis, Fort Collins Partners in Climate Action
Tom Street, Estes Valley Clean Energy Coalition