Background: NorthWestern Energy makes blanket statements about the unreliability and intermittency of renewable energy, but the company’s analysis is shallow. Other states are embracing wind and solar energy and have integrated it into their electricity portfolios. Could it be NorthWestern Energy wants to shortcut this analysis so it can build expensive fossil fuel infrastructure that will reward its stockholders? This attitude puts its ratepayers at risk. Why should we pay more than the going rate because of a monopoly utility’s aversion to Montana’s vast resources of wind and solar?


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.

NorthWestern Energy’s procurement plan states that renewable energy is unreliable, intermittent, and can’t meet capacity at times of peak loads. But the plan should go into more depth to prove this argument. The argument seems designed to lead to a foregone conclusion, not one to truly examines the integration of renewables backed by storage technologies such as lithium ion batteries and the FERC-certified pump storage facility at Gordon Butte.

Certainly an exploration of how other states and nationalities have solved this problem would be helpful.

Those who have followed this issue have seen the same NorthWestern Energy graphs for three years now. It seems that NorthWestern Energy uses them as a pummel. Let’s just say that the company has lacked initiative – or knowledge – to model other possibilities.

Other companies, meanwhile, have graphs that show peak demand as something other than one-dimensional. Peak demand can be graphed to show to lead-up, many dimensions of the peak itself, and then the decline in electricity demand. One study found that 10 percent of the U.S. electrical system is built to address the demand of 1 percent of the year’s hours.

Reducing those demand peaks – which NorthWestern Energy meets with the costliest, most climate-polluting electricity generation – can have a significant impact on consumers’ bottom lines. One analyst suggested that every dollar spent on reducing peak demand will save consumers $2 to $3.

Certainly the Northwest Planning and Conservation Council has noticed the details of demand response, suggesting that utilities like NorthWestern Energy can meet all power needs in the northwest with conservation and demand response.

Energy technology is rapidly changing. It’s an era of the “smart grid,” where variable platforms carrying energy from different – sometimes distant – places must be intergrated. Companies that master this integration of wind generators, fossil fuel generators, hydroelectric dams, and distributed energy such as solar panels will succeed. NorthWestern Energy seems to be a company wanting to rely on engineers who just want to be able to turn knobs will fail.

In Montana, an extensive 2016 Montana Conservation Voter poll revealed that over 90 percent of Montana voters favored increasing wind energy, more than 85 percent favored increasing solar energy, and two-thirds supported renewable energy and carbon reductions to meet the targets of the federal Clean Power Plan.

Why has NorthWestern Energy avoided discussions of actions other utilities have taken to increase reliability for renewable energy power? Why hasn’t NorthWestern Energy included in depth analysis of microgrids and solar and wind projects coupled with battery storage?

Why hasn’t NorthWestern Energy discussed in its procurement plan other ideas out there for increasing the reliability of renewable energy:

  • Investing in local distributed generation?
  • Investing in energy efficiency?
  • Investing in other technologies of energy storage like the Gordon Butte hydro storage project?

The company should go back to the drawing board with an open mind, with creative engineers who want to explore these questions and get rid of the old graphics.