Open Letter to Fort Collins PRPA Board Members on All-Dispatchable Resources RFP

Dear Mayor Arndt and Acting Executive Utility Director Marr –

The FCSG was very pleased to learn that the Platte River Power Authority (PRPA) issued an “all-dispatchable resources request for proposals (RFP)” on February 22nd to help firm its increasingly renewable energy portfolio.  We have been advocating for this since September of 2023, after PRPA management initially asked the board to express support for a single technology (aero-derivative combustion turbines designed to burn methane) instead of remaining open to other dispatchable technologies, including batteries and virtual power plants.

There are, however, a few “devils in the details” of the all-dispatchable resources RFP that we urge you to raise at the board meeting scheduled for February 29th and ask the PRPA to address.  Those are:

  1. Short timeline for bidders to respond. Bidders are encouraged to submit a “Notice of Intent to Bid” (NOI) just 12 calendar days after release of the bid documents, and final bids just 60 days after release of the bid documents.  Without submitting an NOI, prospective bidders will not be able to receive answers to questions concerning the RFP from the PRPA.  We note that in 2022, the Public Service Company of Colorado (Xcel Energy) issued an all source solicitation for dispatchable resources, and allowed 75 days for bidders to submit NOIs and 90 days to submit proposals.  We believe that this is a more reasonable timeline.
  2. Lack of inclusion of the social cost of carbon (SCC) in evaluating bids. PRPA states that it will evaluate bids received in terms of cost, location, flexibility, and probability of timely completion.  The RFP states that other criteria may be added, but does not explicitly mention the SCC.  Colorado State law requires that utilities regulated by the Public Utilities Commission (PUC) take the SCC into account when considering the acquisition of new electric generating resources (CRS 40-3.2-106).  Despite the fact that the PRPA is not regulated by the PUC, we believe that consideration of the social cost of carbon would be consistent with the PRPA’s environmental pillar.
  3. Distributed energy resources (DERs) not allowed. The RFP requires that power be delivered at the transmission system level.  This appears to eliminate the possibility of aggregating local resources (e.g. vehicle or building battery systems) into a virtual power plant (VPP) to meet the minimum dispatchable capacity requirement of 40 Megawatts.  Local VPPs could enhance the energy resilience of the owner communities.

Again, we are very encouraged by the PRPA’s release of an all-dispatchable resources RFP.  To demonstrate that the RFP was released in good faith, we ask that you call for the response timeline to be lengthened, that the SCC be added to the list of evaluation criteria, and that DERs delivered at the distribution level via VPPs be included in the list of acceptable resources.

Sincerely,

Kevin Cross, FCSG Convener

 

 

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Author: Kevin Cross

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