Background: After utilities in the Northwest lost billions of dollars planning nuclear generators that were never built in the 1980s, the federal government established the Northwest Power and Conservation Council to make sure Oregon, Washington, Idaho, and Montana never again cost ratepayers money for private utilities’ planning efforts gone bad. The Council provides objective planning information for utilities in the Northwest. For some reason, NorthWestern Energy ignores the Council’s work.


NorthWestern Energy
11 East Park Street
Butte, MT 59701

The Montana Public Service Commission
1701 Prospect Street
Helena, MT59701

The Montana Consumer Counsel
P.O. Box 201703
Helena, MT 59620-1703

Dear Montana Energy Officials,

Please accept my comment on NorthWestern Energy’s procurement plan.

My question, why is this plan so out of sync with the regional planning council?

The authority on utilities and power supplies since the early 1980s, the Northwest Power and Conservation Council, makes the case in its latest study that “energy efficiency and demand response can meet nearly all growth in energy and capacity needs through 2035.”

NorthWestern Energy’s 2019 procurement plan says the company needs to build new generators to provide electricity to meet peak loads. The plan doesn’t mention saving energy through conservation and energy efficiency.

As the regional authority suggests, energy conservation is more than giving out light bulbs. The NorthWestern Energy procurement plan should address conservation as a way of meeting the peak load gap. What are the returns on investment in energy conservation? If the company invests in a good faith effort to help Montanans insulate and modernize homes and businesses, how much energy can meet the gap?

Power plants are the single largest source of the greenhouse gases that are causing climate change. Energy conservation should work hand-in-hand with the need for action on climate change. Building more fossil fuel plants or purchasing a larger share of the Colstrip coal plant doesn’t measure up to the effectiveness of conservation.

The reason the Northwest Power and Conservation Council believes energy efficiency is the solution is because, according to its figures, it costs less:

Why didn’t NorthWestern Energy use the council’s figures for its procurement plan? Did the company even consider the council’s recommendations? Why not?

The Council also makes a key finding that “No immediate need to acquire or build new natural gas-fired generating recourses” if conservation and demand response goals are met.

What are NorthWestern Energy’s conservation and demand response goals and how do they compare to the regional power council’s? What level of energy efficiency and demand response would meet the company’s needs?