Every few years Montana’s largest for-profit utility, NorthWestern Energy, is required to produce a Resource Procurement Plan — a blueprint for how to meet expected energy demand over the next 20 years. The plan is supposed to inform decisions by the utility, its regulators, and stakeholders regarding how the utility will meet long-term energy needs in a “least-cost” manner.

Importantly, this includes decisions about what kind of power plants to build and when.

NorthWestern Energy is required to accept public comments on the Draft 2019 Resource Procurement Plan until May 5, 2019.

NorthWestern’s draft plan (found here – PDF) contains significant shortcomings that undermine its status as a least-cost plan. For example, it doesn’t account for Colstrip’s clean up costs or evaluate it for cost effectiveness compared to other energy options.

What You Can Do

Please use the form linked below to submit comments – tell the company what kind of energy future you would like to see.

Feel free to use the suggested comments below when drafting and submitting your own.

Suggested Comments

1) To protect ratepayers from future risks, the final plan should model a scenario where the Colstrip power plant retires in 2025.

  • The draft plan assumes Colstrip will operate at least through the plan’s 20-year time horizon of 2039. This places ratepayers at extreme risk by ignoring the countless warning signs that the facility will all but certainly close much earlier, including no-coal legal requirements for utilities in Oregon and Washington by 2030 and 2025, respectively. Pretending Colstrip will never close undermines the least-cost credibility of the plan, exposes ratepayers to poor decision-making by the utility, and ultimately exposes ratepayers to the risk of paying too much for energy.

2) The final plan should clearly model the costs of running existing power plants in the portfolio compared to other options so ratepayers know they’re getting least-cost energy.

  • The draft plan does not explain what costs were assigned to existing power plants or whether existing facilities were evaluated for cost-effectiveness against other options. How can ratepayers know they’re getting least-cost energy if existing power plants are never evaluated for cost-effectiveness?

3) The final plan should detail expected clean-up costs for the company’s existing share of Colstrip and how much more ratepayers will have to pay if the facility runs until 2039 (or later) compared to 2025.

  • The draft plan does not indicate it incorporates clean-up costs into the cost of operating Colstrip. These are costs that must be paid by someone at some point. Clean up cost estimates can be quantified and are clearly not zero. To ignore these costs is to hide the true cost of coal energy and again calls into question the least-cost status of the plan.

4) The final plan should make a reasonable estimation of new power plants coming onto the grid, not just power plants going offline.

  • The draft plan places extra emphasis on potential power plants going offline in the region when estimating how much market energy will be available while giving little consideration to new power plants coming onto the grid, which would add to regional energy supply.

How to Submit Comments

Comments must be submitted via this form on the company’s website by May 5, 2019:

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