Climate Change

Friends of Two Rivers - Bonner, Milltown, Montana

The Dave Gates Generating Station. Photo courtesy NorthWestern Energy. As published in The Montana Standard.Despite regulatory and legal challenges NorthWestern’s construction of the methane-fueled generation plant near Laurel, Montana is moving forward. Now called the Yellowstone County Generation Station, when completed it will emit 300,000 – 600,000 tons of CO2 annually, depending upon whether it is generating half the time or more than half the time. NorthWestern has proposed to make a one-time purchase of a carbon offset to mitigate the CO2 emissions of the Laurel plant. The Proposed purchase amount would be $327,000. The amount of CO2 that would be offset is 21,800 tons. This one-time purchase would offset only a tiny fraction of the CO2 production of the Laurel plant over its lifetime. Fully offsetting CO2 production of the plant would require an annual purchase of roughly $5 million in carbon offsets. Carbon offsets of any amount are widely regarded to be ineffectual in reducing CO2 emissions.

NorthWestern has no goal for carbon reduction in its generation resource portfolio. The utility must set goals that match those of the Paris Climate Agreement, adopted in 2015: Cut greenhouse gas emissions by at least 50% below 2005 levels by 2030.

Public comment of Gary Matson, MPSC listening session, October 20, 2020

NorthWestern externalizes the cost of climate change. It is a tragedy of our time that the science has been politicized and is ignored or even denied by many in responsible business and government positions. There has never been simpler science: The behavior of greenhouse gasses is a fixed constant, just as is the law of gravity. As these gasses increase in our atmosphere we create a climate change cost that is staggering. Though the cost is large it is so widely distributed among so many emission sources that the cost to any single source cannot be quantified. The only acceptable cost avoidance is to eliminate greenhouse gasses from every source where it’s feasible .

I agree with the findings in testimony by intervenors Montana Environmental Information Center (MEIC) and Montana Consumer Council (MCC) that NorthWestern’s acquisition of an additional share of Colstrip 4 would bring unacceptable cost increases for NorthWestern consumers. MEIC’s and MCC’s evidence is strong and compelling. Add to this evidence the increasing cost of climate change and the Colstrip 4 acquisition can be defined as just plain wrong.

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NorthWestern now owns 30% of Colstrip Unit 4. It proposes to buy 25% more from Puget Sound Energy for $1.00 and operate the plant until the year 2042. Not only would this coal-fired generation add very large amounts of CO2 emissions at a time when they must be decreasing, it would also add high costs for ratepayers. The utility claims to “….reduce the carbon intensity of our energy generation in Montana by 90% by 2045.” This claim utilizes bogus math, ignoring the millions of tons of CO2 that would be emitted should it construct its proposed 800 MW of natural gas generation and increase its coal-fired generation to 220 MW.

The only acceptable course for NorthWestern is to set a goal to “…deliver net zero carbon emissions by 2050.” Goals to drastically lower CO2 emissions are being set more and more throughout the U.S. As reported by the Environmental Defense Fund (Annual Report 2019) three major utilities have set the zero carbon emissions by 2050 goal, providing “…a yearly carbon benefit equivalent to closing 45 coal-fired plants.

Public comments regarding NorthWestern’s proposal to buy more of Colstrip Unit 4 are now being accepted by the PSC. For more talking points, go to the Montana Environmental Information Center (MEIC) website https://meic.org/2019/11/submit-public-comment-on-the-northwestern-energy-resource-plan/

An end to the public comment period will be set after NorthWestern officially files its proposal, which is expected to occur by the end of January 2020. You can submit comments now through the PSC website https://svc.mt.gov/psc/web/PublicComment, by email to This email address is being protected from spambots. You need JavaScript enabled to view it. (there is an underscore between psc and utility), or by postal mail to: Public Service Commission, PO Box 202601, Helena MT 59620-2601.

Sample letter to PSC on Colstrip Unit #4

Source: Earth System Research Laboratory, Global Monitoring Division, National Oceanic and Atmospheric Administration, United States Department of Commerce. 3/29/19 Where are we going? Atmospheric CO2 measured at Muana Loa Observatory, Hawaii, is not only increasing but doing so at a faster rate.
March, 1958 – 315.7ppm
December, 1975 – 330.8
December, 1995 – 360.7 (29.9ppm increase in 20 yr)
December, 2015 – 401.9 (41.2ppm increase in 20 yr)
February, 2019 – 411.75 (if rate of increase continues, would be 49.3 increase in 20 yr)

Tell NorthWestern Energy to set a CO2 reduction goal
The investor-owned utility’s latest electric supply plan was released on March 5, 2019 and is open for public comment until May 5, 2019. After the end of the public comment period the plan will be finalized and submitted to the Montana Public Service Commission. Commenters should additionally send your comment to the Montana Consumer Council: email to Suzanne Snow This email address is being protected from spambots. You need JavaScript enabled to view it. or postal mail to Montana Consumer Counsel, PO Box 201703, Helena, Montana 59620-1703, referrencing PSC Docket No. N2018.11.78

Talking Points