NorthWestern Energy’s 2019 draft Montana Electricity Supply Resource Procurement Plan is available for public comment until May 5, 2019

Your comment will make a difference! Send it to: http://www3.northwesternenergy.com/environment/energy-supply This site provides links to the plan’s Executive Summary, the full draft plan, frequently asked questions, and the Stakeholder Comment Form.
Some good things about the plan

• A mix of generation sources are considered, including natural gas powered generators, solar and wind generation, and electricity storage.
• The utility’s “action plan” envisions a staged process, adding approximately 200 megawatts of capacity per year beginning in 2022. As stated in the report, “The staged approach allows for incremental steps through time with opportunities for different resource types and new technologies…” (Page 11-2). This added capacity is expected to be “flexible,” meaning generation that can be called upon at any time to ramp up or shut down.

Some not so good things about the plan

• NorthWestern will utilize a Request for Proposal (RFP) process inviting proposals for electricity generation from qualified sources. The utility will “…focus on the most reliable, lowest long-term cost bids…” (Page 11-3) Your comment should note that NorthWestern must first make a commitment to reducing its carbon footprint. For example, a 50% reduction in CO2 emissions by the year 2030 and a 100% reduction by 2045. RFP’s should be solicited and evaluated using three criteria, in order of priority: 1) CO2 reduction to meet the utility’s defined goals, 2) Reliability, 3) Cost.
• NorthWestern states in the plan that “Meeting our customers’ future needs by adding carbon free resources is projected to cost $523,000,000 more than meeting their needs with natural gas fired resources. Moving to a 100% carbon free portfolio was not modelled…”(Page 1-13) “Portfolio” as used here and throughout the plan refers to the mix of all generation sources available to the utility. Your specific comment should note that the procurement plan ignores entirely the costs of climate change caused by increasing CO2. NorthWestern’s final report to the PSC should include a realistic estimate of these climate change costs as well as a commitment to consider them in its evaluation of RFP’s for electricity generation proposals.
• Geothermal electricity generation utilizes underground steam to power generators. https://www.renewableenergyworld.com/geothermal-energy/tech/geoelectricity.html NorthWestern’s procurement plan completely ignores this resource which, presumably, is abundant at many places in Montana. Your specific comment should note that the utility must include in its plan an evaluation of this potentially very large, carbon-free electricity generation source.

A submitted comment letter:

NorthWestern Energy
11 E. Park St.
Butte, MT 59701-1711

Comment: NorthWestern Energy Draft 2019 Montana Electricity Supply Resource Procurement Plan
Summary
The plan is well described and thorough but is based on an incomplete set of assumptions. The goal of meeting electricity demand with facilities of highest reliability and lowest cost leaves out the goal of reducing CO2 emissions. This should come first, before reliability and cost. The costs to Montanans of the increasing impacts of climate change are externalized and not considered. These costs are likely to exceed those of reducing CO2 emissions.
Comment
I offer these comments as a 52-year customer of Montana Power and Northwestern Energy (NWE), a retired wildlife laboratory scientist and business owner, and a grandfather. I have high praise for the reliability and customer service I’ve received from these utilities and am grateful for the continued service dependability. Further, I appreciate the thoroughness with which NWE has researched and prepared its draft electricity resource procurement plan. The written plan is well-organized, readable and, for the most part comprehensive.
The staged approach described in NorthWestern’s draft plan is excellent. Quoting from the plan, this approach “…allows for incremental steps through time with opportunities for different resource types and new technologies…” Also an appreciate recognition is “…it is more likely resources that were not identified or modeled, or could not be identified during the planning process, will be acquired.”
In contrast to my appreciation for the fine service I’ve received from NorthWestern and for its thorough work in preparing the procurement plan, I am a strong critic of the plan for fundamental reasons:

• There is no mention of NWE recognition of the critical role it could play in countering the increasingly damaging effects climate change is having on Montana. There is an overwhelming and growing worldwide scientific consensus that the increasing release of greenhouse gasses by human activity is causing climate change with increasing catastrophic consequences. In spite of that consensus, and in contrast with the recognition by a great majority of the world’s governments that there is an urgent need for action, strong political influences in our country are  blocking appropriate measures to limit greenhouse gas emissions and stem the growing climate consequences. It is not only appropriate but essential that America’s businesses join its governments in reducing greenhouse gas emissions. Our utilities are a primary source of excessive CO2 and play a key role in reducing emissions. NorthWestern’s final procurement plan must include a recognition of the utility’s responsibility in reducing greenhouse gas emissions.
• NorthWestern’s draft procurement plan does an excellent job of matching energy production portfolios to two essential consumer needs: 1) Reliability; 2) Cost. There was a time in our history when these two criteria were sufficient. At this time of human-caused change that is lowering the expected quality of life for future human societies, these criteria are severely insufficient. NorthWestern’s final procurement plan must include the correct ordering of criteria for procuring additional electrical generation: 1) CO2 emission reduction, 2) reliability, 3) cost.
NorthWestern’s final procurement plan must include electric generation portfolio design that begins with a specific goal of CO2 emission reduction. For example, “Reduce NWE CO2 emissions by 50% by the year 2030; 100% by the year 2045.” Although the recognition of this goal is essential, there is at least some likelihood of difficulty in consumer acceptance because of the possibility of higher electric generation cost. I recognize that a large number of Montanans, possibly a majority, are completely unfamiliar with climate science and would prefer not to add even $20 to their monthly utility bill let alone any greater amount. It is in this area of consumer acceptance that leadership from our government, the Montana Public Service Commission, and NorthWestern energy is critical if we are to enjoy the hope of a future with high quality of human life.
• Consider a hypothetical generation portfolio: In recognition of the need for NWE to establish a peaking generation capacity that is adequate for the coldest months, it should be possible to add traditional thermal generation that would operate only during peak load times. Renewables with storage could be added that would be sufficient in themselves to supply energy needs during the seasons of lessened load. These combined measures could potentially allow NWE to meet a goal of, for example, 50% reduction in CO2 perhaps with only a modest increase in generation cost. NorthWestern’s final procurement plan must include a generation portfolio that is consistent with the recognition of the importance of limiting CO2 emissions to enable future quality of human life even though the mix of appropriate generation facilities may be more expensive than one that does not reduce CO2.
• Externalized costs are completely omitted from the draft energy procurement plan. These costs, though very difficult to quantify, are increasingly recognized by our courts. A federal judge has blocked drilling on roughly 300,000 acres of public land in Wyoming because the Department of Interior failed to take climate change into account when auctioning off the land for oil and gas leasing. The financial consequences of increasing CO2 emissions simply cannot be ignored in planning that involves these emissions. Montana agriculture, recreation, and tourism are “big business” and stand to suffer increasing financial consequences with increasing climate change. NorthWestern’s final procurement plan must include a valid, science-based estimate of climate change costs to Montanans and must consider this cost in evaluating/comparing costs of adding generation from all available sources.

I would like to call attention to some specific insufficiencies in the planning document.

o A consideration of geothermal generation is entirely omitted. This technology offers an inexhaustible generation resource free of CO2 emissions. NorthWestern’s final procurement plan must include a consideration of geothermal electricity generation as a viable option for electricity generation.  Carbon-free geothermal generation adds no climate change cost to the generation portfolio.
o In the Solar PV portfolio (Pages 10-16, 10-17) it is incorrect that solar PV “...does not contribute to the capacity required during NorthWestern’s peak load hours…” This inaccuracy leads one to question the validity of PowerSimm/ ARS for modeling. Solar will contribute more during longer hours of daylight but will also contribute even during winter cloudy days and certainly during winter sunny days. Of course, the cloudy winter day contribution will be much less and will require supplement by other generation. Northwestern’s final procurement plan must include a correction of the misconception that solar arrays do not contribute to generation during peak load hours. In some circumstances, the contribution can be substantial.
I applaud NEW’s partnering with Montana educators in developing pilot solar projects. One variable that will be important in Montana’s winter season will be the orientation of panels. I note that some of the pilot projects have vertical panels, with the orientation offering snow shedding.
o Considering non-quantified costs (Page 10-20), the siting requirement of 1.5 acres each for 20 Li-ion batteries is presented as a problem. In Montana, this amount of land use is trivial. NorthWestern’s final procurement plan must recognize that this amount of land for this use does not detract from the value of electricity storage.

I appreciate the opportunity to comment on the NWE electricity supply resource procurement plan.

Sincerely,
Gary Matson