Below are several ideas on comments you could send

In response to the statements in the plan that accept the idea that renewable energy is cost prohibitive and so is not even considered: The question should be: Is the type of energy generated in the public interest, that is – Is it the most cost-effective approach and does it fit with the goals to reduce greenhouse gas emissions over time? When analyzed by some of the utility’s themselves in different states, coal plants built in the 1980’s were found to be more expensive and have an inability to compete with the price of renewable energy. In many states the utility companies have concluded that adding renewables was cheaper than building natural gas plants or converting coal facilities to gas. Also, building new renewable energy is more cost-effective than maintaining old coal plants. Utilities that are not positioned to capture value from the shift to renewables distributed energy resources risk losing revenue.

In response to NWE stating that Natural Gas is the preferred option for new energy projects in the future. The ratepayers will bear the risk that fuel cost estimates are unrealistically low against a history of gas price volatility. In some states, the shareholders are required to risk-share with customers. Will NWE’s shareholders be required to share this risk? Also, there is no responsibility taken by NWE for the methane emissions that natural gas is known to produce. Also, the current natural gas boom depends on fracking that uses toxic chemicals that pollute air and water, threatening the nearby communities.

NWE has a lack of the mention of the amount of greenhouse gas emissions in their energy portfolio plans. When calculating the “cleanness” of natural gas use, are the emissions that natural gas spews into the air while being taken out of the ground, specifically the methane emissions, being considered? Methane is 80% more potent greenhouse gas than carbon. Another point is that considering greenhouse emissions for new energy projects may become a federal requirement in the near future.

In response to NWE’s procurement plan’s statements that renewable energy is unreliable and does not meet capacity at times of peak loads: Many actions have been proven to work to increase reliability for renewable energy power that NWE’s plan did not even consider. Because they do not even consider these actions, they have completely discounted renewable energy to meet the energy demands of the ratepayer. Some of the actions available to deal with the fact that the wind does not always blow and the sun does not always shine locally are:

  • Drawing electricity from a broad geographic area helps ensure a steady supply of wind power.
  • Advanced microgrids and software programs are already being used successfully.
  • Solar and wind energy projects coupled with battery storage are already being implemented and will only improve in the near future.

Other ideas out there for increasing the reliability of renewable energy:

  • Investing in local distributed generation.
  • Investing in energy efficiency
  • Encouraging participation in demand response and demand side management
  • Investing in new, fast-ramp gas turbines as a future resource.
  • Investing in better, variety of energy storage (Hydro storage projects like the Gordon Butte Project in MT)

Other comments about dealing with reliability in renewable energy: Grid operators already deal with large fluctuations in electricity supply and demand. In fact, the gradual and predictable changes in wind power are much easier for grid operators to address than the large-scale outages that can occur at conventional power plants. The gradual changes in wind output are relatively easy for grid operators to accommodate.

In response to NWE’s procurement plan’s statements that renewable energy is cost prohibitive to build: The average wind turbine installment project costs have fallen significantly as the low wind turbine pricing continues to get cheaper. Overall, the average installed cost of wind projects have fallen from their highs in 2008. After topping out at 7cents/kWh in 2009 to a 2017 national average price of 2 cents/kWh. These prices compare favorably to the projected future fuel costs of gas-fired generation. Also, there is no mention in NWE’s plan of the very likely possibility of a future carbon tax or possibility of natural gas prices to spike.