Dear Mayor Arndt, Mayor Pro-Tem Francis, Assistant City Manager Marr, and Light and Power Director Walker –
Thank you for meeting with representatives of the Fort Collins Sustainability Group (FCSG) and 350 Northern Colorado recently to discuss our findings that building a new gas-fired power plant is superfluous. We urge you to take follow-up action commensurate with those findings as Fort Collins City Council members and as Platte River Power Authority (PRPA) board members as soon as possible.
As we stated during our meetings with you, the values that the PRPA placed on its renewable resources (wind, solar, and storage) in its recent Integrated Resource Plan (IRP) are far lower than those it placed on its renewable resources during a presentation made to the PRPA board on October 31st of this year. Those values are also known as “effective load carrying capacities,” or ELCCs. The ELCCs used by PRPA in its IRP are also far lower than the ELCCs used by the Southwest Power Pool Regional Transmission Organization (SPP RTO), which is the “balancing authority” (BA) that the PRPA plans to join in 2026.
ELCCs are used to calculate a utility’s “planning reserve margin,” which is the amount of reliable generating capacity the utility has in excess of its peak annual or seasonal electric loads. In its recent IRP, the PRPA stated that it needs to have a planning reserve margin of 19.9%, i.e. reliable generating capacity 19.9% over and above its annual peak. The PRPA’s new ELCCs show that it would have a planning reserve margin of 39.8% in 2030 WITHOUT building a new gas-fired power plant. That is twice the planning reserve margin that it says it needs!
The SPP RTO currently uses ELCCs that are a little different from those recently presented by the PRPA, it has different planning reserve margin requirements for the winter and for the summer, and those planning reserve margin requirements differ from those specified by the PRPA. The conclusion using the SPP RTO’s numbers is similar, however: both the summer and winter planning reserve margins for the PRPA’s summer and winter peaks will be significantly greater than those required by the SPP RTO for entry, without building a new gas-fired power plant. We have attached our full planning reserve margin analysis here, together with our sources, so that you can confirm the validity of our analysis yourselves.
What do these findings mean? They suggest very strongly that building a new 200 Megawatt gas-fired power plant is NOT necessary. Appropriate responses would be a) to ask the SPP RTO to evaluate this analysis and provide their opinion on whether a new gas plant is necessary in order to join them in 2026, and/or b) request a review of the PRPA’s IRP by the National Renewables Laboratory (NREL) to determine whether and how it can be approved on. As you know, the FCSG, 350 Northern Colorado, other community organizations, and the Fort Collins Energy Board have been requesting a review by NREL since late summer of this year.
These third-party review(s) should be completed BEFORE the PRPA board commits $350 Million to purchasing a new gas-fired power plant. Such an investment is almost certainly unnecessary, and will result in significant increases in the cost of electricity paid by residents, businesses, and institutions in the four municipalities that own the PRPA. A new gas-fired power plant would also result in ongoing damage to front range air quality and long-term damage to the climate. Please do your duty as public servants and require that at least one third-party review be conducted before considering funding any new gas-fired power plant for the PRPA.
Sincerely,
Kevin Cross
Convener
Fort Collins Sustainability Group
SPP and PRPA PRMs based on respective ELCCs 110624
SPP and PRPA PRMs based on respective ELCCs Sources Page 110624
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Response from Travis Walker, Fort Collins Power and Light Director, dated December 4th, 2024
Good afternoon everyone,
Kevin, thank you for meeting with us a few weeks ago. As I mentioned, I have followed your work for a long time, and I believe that you and the various groups that you interact with have had a positive impact on Fort Collins’ sustainability and non-carbon energy efforts.
I know that you had an updated version of the spreadsheet that you provided- much of the information I can relay was based on the original, but I think the general information remains the same.
Just to be transparent, I want to start this conversation with the recognition that we are dealing with a complex issue with many variables. We could go back and forth with numbers and percentages all day- and some of them may still change.
Background/review for Council members added: Platte River Power Authority will decommission Rawhide Unit 1 on December 31, 2029, effectively retiring coal generation and moving PRPA to an anticipated 85-88% non-carbon energy mix, and resulting in a ten-fold decrease in CO2 emissions. This will be accomplished by integrating solar, wind, and battery storage resources, as well as participating in an RTO (regional transmission organization), the SPP (Southwest Power Pool), which will provide additional resources when needed, as well as providing a “buyer” for excess renewables when Platte has excess at any given time. The SPP has resource requirements for participants, to make sure that they can cover “their share” plus some margins. These margins are known as PRM’s (planning reserve margins) and they are determined in part by ELCC’s (effective load carrying capacities) of the mix of resources. As an example, coal or natural gas resources have ELCC’s of 90-100%- so if you have a 100 MW generator, you will get 90 to 100 MW of output over time. Renewables have different ELCC’s based on time of day, time of year, etc. For example, a 100 MW wind farm may have an ELCC of 5-25%, so an output of 5-25 MW when looked at over time- some days may be more, some less. Solar looks to be anywhere from 5-60% depending on the season.
Right now, the SPP has only published PRM’s and ELCC’s for its eastern footprint, and only for 2025. This includes some areas further towards the Midwest. Platte believes that the ELCC’s will be lower for our footprint (RTO West) due to different mixes of resources, different concentrations of resources, topography, and load dynamics. Platte is also using 2030 projected numbers, not 2025- so between now and 2030 (and beyond), as more renewables come on-line, ELCC’s will go down, and PRM’s will need to increase.
I won’t go into the specific numbers or percentages, but some of the 2030 summer scenarios show PRM’s below 20%. So, you can see that the numbers you have and the numbers that Platte are using are different. That’s where I’m saying we could argue about the numbers all day long, and that’s why I’m trying to keep this general.
Why not just buy/build more renewable energy now? I think it is a balance. If we try to make up the difference, what we could end up with is way too many renewables when it is sunny and the wind is blowing, and still not enough at other points. Then, we’d be forced to sell the renewables at a very low cost or possibly even a negative, meanwhile having spent a lot of money on the wind/solar infrastructure or purchase power agreements. Battery technology is still maturing, and that will help in the near future, but to do large-scale battery installations is still a ways down the road. We are exploring it at utility scale, though, with Platte River.
Here is another reason the new turbines are important to us-
- The Southwest Power Pool (SPP) resource adequacy requirements for regional transmission organization (RTO) market participants are not the sole measure of whether Platte River’s resources can serve owner communities’ loads through all seasons and system conditions 24/7 365.
- Platte must also evaluate whether their resources can serve all owner community load through extended dark-calms (periods where neither wind nor solar resources produce energy). Think of multiple consecutive very calm, overcast days in winter. The data I’ve seen shows that in a dark calm event, Platte’s existing peaking units plus the new gas turbines would cover the 2030 peak demand forecast with a margin of +1%- not a large margin, but keeps the lights on and the heat going in one of those events.
This is core to us- we can’t let our customers be without heat and power in an extended event like we saw in Texas a few years ago. People died, and businesses were damaged. To me, the turbines are an insurance policy for those events. We just don’t have the battery technology, or enough of them in place, to store enough power for these events.
For these reasons, I support Platte River’s IRP, and would not recommend a third party review. I trust our employees, Platte River’s employees, and Platte’s diligence in their work leading up to the IRP. I also trust the Mayor and Deputy City Manager as our representatives on PRPA’s board to help frame these decisions.
What I can promise you is that Energy Services/Light & Power will continue to lead in the effort to make a difference at the local level. We have many employees engaged with PRPA and within the City to work on Electric Vehicle implementations, Utility-scale batteries, building performance, residential and commercial solar, distributed energy resources, and more- and soon as part of the Virtual Power Plant that can help minimize the use of carbon based resources. We are excited for this shift in how we think about power delivery going from one directional to bi-directional, and how we make it work with the distribution system. We’ll do what we can to meet the goals of the VPP and hopefully go above and beyond our share if it makes sense.
I appreciate your insight, and hope to continue productive conversations with you moving forward.
Travis
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TRAVIS WALKER
Light & Power Director
City of Fort Collins
970-222-8579 primary mobile
970-682-9818 emergencies mobile
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Response from FCSG dated December 9th, 2024
Good morning Travis, all –
Thank you for your response to our letter dated November 14th of this year. As briefly as possible:
- The Platte River Power Authority (PRPA) has provided two sets of “Effective Load Carrying Capacities” (ELCCs) over the past several months: one in the 2024 Integrated Resource Plan (IRP) and one in its presentation to the Board on October 31st. Neither of these two sets of numbers match those provided by the Southwest Power Pool (SPP) referenced in the analysis we provided to you or by Xcel Energy in its 2021 ERP CEP Phase II Updated Modeling Inputs and Assumptions report.
- Our goal is not to go “back and forth with numbers and percentages” with you at this point. Instead, we’re interested in having a recognized authority like the National Renewable Energy Laboratory (NREL) evaluate the analysis that led the PRPA to conclude that it needs to build a new gas-fired generating plant. The variation between the ELCCs that the PRPA has used at different times and those provided by the SPP and Xcel suggest to us that the PRPA may have adjusted the numbers it used in its IRP to back into its conclusion concerning the need for additional fossil-fuel generating capacity.
- Given that the PRPA will be joining the SPP Regional Transmission Organization (RTO) in 2026, and given the SPP’s plan to expand and upgrade the region’s transmission capacity, we do not believe it is justifiable for the PRPA to build out enough generating capacity to weather an extended winter “dark calm” period in Northern Colorado. One of the benefits of joining the RTO is that it frees us from relying on local weather conditions. Again, NREL could provide expert insight into this issue.
- Blaming the failure of renewable generation for what happened during Winter Storm Uri in Texas in 2021 is not justified by the facts. The failure of gas plants during that storm was the primary reason for the loss of power, as documented in this article by the Union of Concerned Scientists. Building more gas generating capacity will not provide the PRPA with an insurance policy against powerful winter storms. NREL could provide additional insights into this issue as well.
We are gravely concerned that the PRPA appears hell-bent on spending a vast sum of money – upward of $350 Million – on a project that has not received a legitimate third-party review. This expenditure will burden the ratepayers in the four cities served by the PRPA for years into the future and will contribute to poor air quality on the front range and climate damage. We believe that this entire process makes clear that additional regulation of the PRPA by the State of Colorado is essential to protect the financial interests and physical well-being of everyone in the PRPA’s service territory.
Sincerely,
Kevin Cross
Convener
Fort Collins Sustainability Group
P.O. Box 672
Fort Collins, CO 80522
Ph. 970-484-3141 https://focosustainability.org
