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To:  Montana Public Service Commission
Re: Docket 2019.12.101 –NWE proposes to acquire Puget Sound Energy’s 25% ownership interest in Colstrip 4 for $1.00
This proposal is dead wrong for these reasons:

1.    It is critical that utilities phase out fossil fuel electricity generation, not add more. Each day we refuse to act on lowering CO2 emissions is another nail in the coffin of a dying quality of life for our planet’s future residents. Public demand to reduce CO2 emissions is rapidly growing as is scientific evidence that the consequences of continued fossil fuel emissions will be increasingly catastrophic. Responsible utilities are responding to the climate crisis. As reported by the Environmental Defense Fund (Annual Report 2019) three major utilities have set a goal of zero carbon emissions by 2050, providing “…a yearly carbon benefit equivalent to closing 45 coal-fired plants.”

2.    NorthWestern’s claim to “….reduce the carbon intensity of our energy generation in Montana by 90% by 2045” is deceptive to the point of being entirely “bogus.” The measure that must be taken is to reduce CO2 emissions. NorthWestern would add 800 MW of fossil fuel generation from proposed new natural gas-fired generation as well as 185 MW from its increased share of Colstrip 4. Both additions result in major increases in CO2 emissions and this is the only relevant consideration, not “carbon intensity.”

3.    If NorthWestern was to acquire an increase share of Colstrip 4, Montana ratepayers would suffer:
•    Millions of dollars in repairs would be needed to enable the aged generation equipment to continue operating.
•    Even with repairs, breakdowns similar to those that have occurred in the past could be expected requiring unacceptable electricity market exposure and potential accompanying increased cost to ratepayers.
•    Current clean-up costs at Colstrip are in the hundreds of millions. Increasing NorthWestern’s share represents an additional saddling of ratepayers with unacceptable cost.
•    Continued generation at Colstrip would add even more to clean-up costs. If effective upgrades of waste disposal equipment and procedures were found, they would add further to the current environmental remediation costs that are now so expensive. History tells us that pollution control protocols are almost never as successful as touted at the beginning of a project.

Commissioners, please deny NorthWestern’s proposal to purchase more of Colstrip 4. Instead, the utility must set a goal of zero carbon emissions by a target date in the near future and commit all of its efforts to planning a generation portfolio consistent with reaching that goal. Colstrip 4 could be “mothballed” until solid, dependable technologies are developed for removing CO2 from emissions, creating new value for Montana coal.
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