By Nick Fitzmaurice
Last fall, nearly 500 people showed up at the Montana Public Service Commission (PSC) to tell the elected Commissioners that NorthWestern Energy’s 2023 Integrated Resource Plan (IRP) missed the mark by a long shot. This document is intended to outline a utility’s plans to meet customers’ energy needs over the upcoming 20 years, ensuring that utilities are prepared to provide reliable, affordable power that’s in the public’s best interest.
It is the PSC’s statutory responsibility to protect consumers by identifying deficiencies in these plans so utilities such as NorthWestern can correct their errors in future planning cycles and comply with their ongoing obligation to provide affordable, reliable power. However, since none of the Commissioners have energy backgrounds, they rely heavily on their expert staff to review and recommend action in technical analyses such as IRP reviews. It is standard practice for the PSC to make minor amendments to staff’s recommendations before approving them as the final Commission orders.
Upon completing a thorough review and analysis of NorthWestern’s 2023 IRP, the PSC staff denounced it as unsatisfactory, pointing out that “while the 2023 Plan claims to provide greater detail regarding modeling assumptions compared to the 2019 Plan, the Commission finds the 2023 Plan less transparent, accessible, and analytically rigorous than Montana’s planning statutes and the Commission’s 2023 planning rules require.” The staff detailed numerous serious “deficiencies” in the plan, often referring directly to the public testimony that first identified these deficiencies.
Rather than approving these recommendations, the PSC acted uncharacteristically and withdrew the item from their weekly agenda, requesting more time to review and alter the staff’s recommendations.
A month later, the Commission approved a heavily revised version of the staff’s recommendation produced by Commissioner Jennifer Fielder that omitted every reference to identified “deficiencies” in the plan. While Commissioner Fielder claimed that this revised review “maintain[ed] the critical analysis provided by [staff] while incorporating 5 new statements,” large portions of the original recommendations had been deleted or altered. Commissioner Fielder tried to obscure her heavy edits by highlighting added paragraphs but not marking other revisions and deletions. These would have been easily missed without side-by-side scrutiny with the original staff recommendations, but MEIC discovered this deception through such an analysis. The substantial changes served to water down the staff’s detailed analysis and critique, devaluing the importance of stakeholder engagement and the need for better transparency throughout the IRP development process. The revisions also introduced vagaries that conveyed a murky message to NorthWestern Energy on the elements of the plan that must be improved in future IRP processes. The paragraphs that were added, while including some helpful elements, were thrown into the document haphazardly as a distraction from the pieces that were eliminated.
Opaquely gutting staff recommendations was not only disrespectful to the PSC’s expert staff, but it also hid from the public important elements of the expert critique that were intended to protect ratepayers, instead providing little guidance to ensure NorthWestern Energy plans for affordable and reliable power in future IRP processes. Even NorthWestern has admitted that no one was satisfied with its 2023 IRP, yet the Commissioners were once again inclined to bow down rather than serve as a critical agency overseeing Montana’s largest monopoly utility.
Montana utilities must develop a new IRP every three years, an iterative planning process that picks up as soon as the previous cycle concludes. We can expect NorthWestern to convene its Electricity Technical Advisory Committee (ETAC) any time to begin developing a 2026 plan. MEIC is sure to fight for a seat at the table, advocating for a reliable and affordable clean energy future.
This article was published in the July 2024 issue of Down To Earth.
