In keeping with our commitment to transparency and excellent customer service, we invite our customer-owners in Clark County to participate in the conversation around the Clean Energy Implementation Plan (CEIP). This webpage will host public comments submitted, along with responses from staff as applicable and appropriate. Please note that comment submissions may contain links to external sites reflective of the commenter’s views. Links in submitted comments will take you away from our website and may expire in the future.
Utility policy and direction is determined by the elected board of commissioners and implemented by staff. Many variables impact power planning so please note both comment and response dates and source when reviewing entries on this page, as responses or positions may shift.
Submitted 10/7/2021
Comment:
I have a short comment — about a REQUEST, an OPPORTUNITY, and a WIN-WIN PARTNERSHIP.
My REQUEST is one I’ve made before: I urge Clark PUD to sponsor another Community Solar project. A Community Solar project is very timely, and (based on past experience), it would likely be in high demand– especially among apartment residents, like myself.
The OPPORTUNITY is available roof space for a Community Solar project. I understand that the Port of Camas/Washougal has offered its roof space to Clark PUD for a Community Solar project.
The WIN-WIN PARTNERSHIP is, I hope, obvious. Clark PUD has an opportunity to utilize the Port’s roof space for a Community Solar project. This seems like an obvious partnership that would benefit PUD, the Port, and the County.
Please pursue this opportunity and promote Community Solar for the residents of Clark County.
Submitted on 10/16/2021
Comment:
CPU needs to begin investing in and incorporating renewable energy sources such as wind and solar. Vancouver is working on a Climate Action Plan to reduce local greenhouse gas emissions. One factor is the emissions from the River Road Gas Generating plant, which is one of the top 10 GHG emitters in the state. We want CPU to reduce dependence on fracked gas earlier than required by the state. You also need to plan for increased demand for electricity due to building and transportation electrification. The CEIP should be a roadmap for how to meet projected increased demand with cleaner power.
Submitted 10/16/2021
Comment:
I would like to see you reduce dependency on the River Road Gas generation and accelerate your use of clean energy (solar and wind). As Clark County has more electrical vehicles and electrified buildings, there will be an increased need for electricity. Plan now for this increase. The CEIP should clearly outline a plan for decreasing greenhouse emissions and quickly moving to clean energy sources. Thank you
Submitted 10/16/2021
Comment:
Clark Public Utilities needs to be ready for quickly accelerating clean electricity demand starting now. The methane power plant should be for emergency only until shuttered. People want wind, solar or other safe ( not nuclear) fossil fuel free energy.
To meet Washington State climate goals we need to electrify everything as quickly as possible.
Transportation: Like Vancouver, businesses are pushing to electrify their fleets NOW. Our public transportation is converting to electric. Personal EVs are close to quick adoption now that the fuel and maintenance savings are well documented. One good purchasing incentive program (state, federal or local) will accelerate EV use. Used EVs are now within reach of most people. Norway will not sell petroleum fueled vehicles after 2025. Slovenia, Netherlands, Iceland, Denmark, Ireland, Israel, Sweden plan no new petroleum fueled vehicles by 2030. We should expect similar here soon.
Buildings: Buildings account for about 40% of fossil fuel use. We should expect developers, planning departments and Washington State to push for more LEED buildings, carbon neutral buildings and no new fossil fuel hook-ups.
As the public demands action on climate, we should expect increasing legislation on climate. As we know the basic answer is electrify everything NOW. In 2019, Washington passed the Washington Clean Energy Transformation Act 2019. In 2020, Washington passed the Washington had a Zero Emissions Vehicles Mandate and updated the Greenhouse Gas reduction goals. Carbon neutral buildings and communities. Interim Green Building Plan. On the national level, according to GovTrack, there are 257 bills dealing with climate at the federal level presently.
Clark PUD could help the electrification process by 1) Make sure there are no hook up charges for developers or residents wanting to install adequate electricity for all appliances, EV and solar panels. 2) Continue to oversee and make sure there is adequate EV charging in the service area. 3) Provide accurate information to your service base regarding installation and maintenance cost of electric vs methane fueled heating and cooking. 4) Provide incentives for installation of electric appliances/heating and replacement with electric especially to lower income home owners and landlords housing lower income persons, (Perhaps those in the Section 8 housing program.) 5) Encourage and provide information to your service base regarding solar collectors. Help renters find shared community solar projects.
Submitted 10/16/2021
Comment:
Please develop a plan to rapidly increase our use of renewable electricity and quickly phase out our dependency on natural gas including “renewable” natural gas. I would also like to see more enthusiasm and help for residential solar instillation.
Climate change makes this move imperative. I have removed my gas dryer and replaced it with an electric dryer. I gave my gas SUV away and bought a new electric SUV – it is great, way better than my Honda Pilot. I gave my gas lawn mower away. My new Toro electric is terrific. So quiet my neighbor came over to see what was going on. He thought I was “vacuuming” my lawn. We have new electric heat pump. Our gas water heater is going out the door next. Ford has made a multi billion dollar investment in Kentucky and Tennessee, two multi square mile campuses for electric vehicle manufacture. They have received 160,000 paid reservations for the new Lightening F150. This is what is happening. Help our city/county be ready.
Submitted 10/16/2021
Comment:
Submitted 10/25/2021
Comment:
I think it is important for the PUD to act now in three ways:
1. Protection: Know that forests and streams need to be protected because they are most vulnerable and the best filter for our environment. The air quality affects everyone. Lower emissions.
2. Transition: Get on board with renewable energies because transition to new renewable energy sources is the future.
3. Conservation: Find ways to support those in need of heat and light while penalizing those who use energy flagrantly and irresponsibly. A scaled pricing structure works well, energy is cheap if you don’t use much, but the more you use the more you pay per unit.
Submitted 10/25/2021
Comment:
Our Alliance for Community Engagement submitted it’s letter to Commissioners and staff (on 10/21/2021), with 10 organizations signing on, for the CEIP process.
We have had one additional organization, Friends of Clark County, that has signed on to the letter.
I have attached this final version, with 11 signatories instead of the original 10, and request that you let the Commissioners and staff know of this addition as well as update the CEIP record.
Thank you!
Submitted 11/2/2021
Comment:
Please do not consider purchasing nuclear energy.
While Renewable energy sources are getting more affordable, nuclear energy is becoming more expensive over time.
Nuclear energy is untested technology. Some of the newest are most prone to errors.
Nuclear energy has expensive up front costs and often cost more than projected.
It would take too long to be in service. We need clean energy now and cannot wait 10 years.
But the most important reason that nuclear should never be considered is that there is no way to contain the radioactive waste for hundreds of thousands of years. Hanford continues to leak after decades of clean up. Metal casks off the shore of LA leak. Concrete cracks and erodes. Metals won’t last that long. Mountains move and even solid rock moves over time. Nuclear is by far the dirtiest, extremely dangerous energy and should never be encouraged.
Submitted 11/2/2021
Question:
Am I to understand that part of your plan is to remotely control smart thermostats in residential homes to curtail consumption? If not, can you please tell me what the section regarding smart thermostats means
Response:
Thank you for submitting your question regarding to the Demand Response section of the CEIP and the concept of controlling residential smart thermostats. To specifically answer your question, the narrative provided in the CEIP about smart thermostats is meant to provide an example around the need for Advanced Metering Infrastructure (AMI) deployment in order to offer successful Demand Response programs.
Our Demand Response strategy for the CEIP period that covers 2022 – 2025 is to explore the possibility of introducing these types of programs. As you’ll note in this section of the CEIP, implementation of smart thermostat demand response programs require Advanced Metering Infrastructure (AMI), sometimes referred to as “smart meters.” Clark Public Utilities does not currently have that technology deployed.
The reason for this requirement is AMI allows the utility to gather real-time consumption data and serves as the tool to verify if a customer participated in the demand response event. Without the ability to determine who participated in the event we cannot determine what customers would receive the demand response incentive. Additionally, without real-time data we would have trouble determining the overall success of the program.
Due to this constraint it is unlikely we will be able to run any thermostat based Demand Response programs unless the utility deploys AMI.
Submitted 11/4/2021
Comment:
I am grateful that Clark PUD and the City of Vancouver have Climate Action Plans. Electric vehicles and EV charging stations have been discussed often and would help transition to cleaner energy use.
But where are the charging stations? Out of curiosity, I took an informal survey of available EV charging stations in my Cascade Park neighborhood. The results were disappointing:
- At the popular Cascade Park library and adjacent Firstenburg Community Center, there are no EV charging stations. (Okay, so what about newer construction?)
- At the new Wy-east Middle School (just south of the Library), the parking lot was completely redone. Yet, there are no EV charging stations.
- Just north of the Library are several brand new buildings associated with the Evergreen School District. There are no EV charging stations at Legacy High School, Hollingsworth Academy, the Transition Program building, or the Administrative Service Center. These new buildings are modern and attractive, with pleasant landscaping. But where are the EV charging stations?
I urge CLARK PUD TO WORK WITH THE CITY to require EV charging stations as part of all new development projects.
Submitted 11/5/2021
Comment:
Clean energy still uses coal and natural gas. I would like to see us use nuclear energy. I do not want to be in the same situation as Texas was in.
Stand up for real progress people. I think so much money has been wasted on solar and wind that you feel like you have to keep moving in that direction. Time will tell what mess we are in because people are politically motivated to stay the current course.
Good luck with your choices.
Submitted 11/5/2021
Question:
How is the benefit-cost ratio for Demand Response measures calculated? (Pages 5-6)
It seems like the biggest cost would be adopting AMI but that would be mostly a one time cost with potentially multiple DR benefits? Is AMI fractionally allocated for each DR initiative or is each initiative expected to pay for the entire AMI cost?
Was seasonal or low water pricing looked at? (wouldn’t require AMI)
Voluntary DR has been dismissed by staff but given the very low cost it doesn’t take much benefit to be worthwhile. Please consider voluntary DR initiatives. A suggestion would be to start with solar, EV, and ductless heat pump customers and perhaps customers who have signed up for text alerts (might be a younger demographic more willing to participate)? An example of easy participation that could possibly help: Most current EV owners also own a ICE vehicle. During a polar vortex or heat dome event, those EV owners could be asked to not charge for a couple of days. With current forecasting, we should be able to give enough notice that folks can go fill up their gas powered vehicles ahead of time.
It looks like PGE may be ahead of us in this area? https://portlandgeneral.com/news/2021-10-15-pge-plans-to-nearly-triple-clean-resources-by-2030
Are there other voluntary DR programs possible without AMI? There are lots of other utilities out there. Who is considered ahead of the pack (just as CPU is justifiably recognized for outstanding customer service)? Demand meters for heavy residential users? Rebates to heavy seasonal users who meaningfully cut their use? Individual counseling to very heavy residential users just to let them know they are using much more than average coupled with advice on how to cut seasonal usage?
Response:
In 2021, Clark Public Utilities contracted with Lighthouse Energy Consulting to perform a Conservation Potential Assessment (CPA) and a Demand Response Program Assessment (DRPA). In Lighthouse’s analysis the DR potential calculation process began with the quantification of technical potential, which is the maximum amount of DR possible without regard to cost or market barriers. The assessment then considered market barriers, program participation rates, and other factors to quantify the achievable potential. Finally, the economic or cost-effective potential is quantified by applying an economic screen to the achievable potential.
To perform the screening, Lighthouse estimated the costs of capacity avoided through demand response for Clark Public Utilities. As part of the CPA, Lighthouse identified the following avoided costs related to reductions in peak demand:
- Avoided capital costs related to the deferral or avoidance of capacity expansions on the transmission and distribution systems that deliver power to CPU’s customers
- Avoided generation capacity costs associated with reductions in peak demand
Clark Public Utilities’ avoided generation capacity costs are currently best reflected in the monthly demand charges paid to BPA. Lighthouse used these charges as well as estimates of the months in which each DR product could be used to estimate the avoided generation capacity costs for each DR product. These avoided generation capacity costs were combined with the avoided transmission and distribution system costs and compared with the costs of each product. The lack of AMI in Clark Public Utilities’ service territory is a barrier to the implementation of most of the DR measures included in the DRPA. The cost of adopting AMI is not included in the analysis.
Regarding voluntary DR efforts, Clark Public Utilities is exploring including modules related to DR and time-of-use electricity consumption in the Home Energy Reports that currently go to 40,000 residential households in Clark County. The vendor we partner with on this program, Opower, has successfully run these types of messages with other utility partners and the strategy has proven to be a good way to introduce residential customers to the concept of DR and when electricity is consumed.
A few specific topics we may explore using this platform include setting timers on smart appliances like dishwashers and clothes dryers to run during nighttime hours, encouraging electric vehicle owners to charge overnight, as well as general information explaining when Clark Public Utilities’ peak demands typically occur over a calendar year.
Additionally, we are in the process of launching an online marketplace that will be hosted on our EV level II charger incentive program webpage that will allow customers to instantly receive the program’s $500 rebate. Beyond the customer benefit of realizing the Clark Public Utilities rebate at the point of purchase, we’ll have an opportunity to introduce load management and DR events to the customers who participate in the online marketplace. That effort would be a second phase of the project, and is not yet contracted, but something we’ll be considering next year.
Submitted 11/6/2021
Comment:
I appreciate reading today in Columbian’s Energy Advisor that comments are solicited on the draft CEIP Plan.
CPU’s draft CEIP is a very fine approach to a very difficult assignment. I don’t have the time at present to analyze it in detail, but the methodology appears transparent and sound. I did notice that average water years were used (I believe that is correct) and I continue to worry about dependence upon hydro under the Slice product if the 2021 extreme Western U.S. critical water conditions were to continue. The public believes that hydro supplies are stable and dependable but there are low water years and fish-related mandates must be met. Ideally, scenarios would be run on low water, and I’m sure that has been done.
I also am concerned about the availability of either firm or interruptible energy/capacity in the Western Interconnect generally or the NWPP as every utility has to meet these goals and aspirations.
I encourage CPU to insist on placing priority on providing reliable electricity service to all rate classes. Reliability should be a higher priority than meeting aspirational state mandates laid down by non-experts with insufficient knowledge of the challenges. Businesses (commercial and industrial) deserve consideration along with vulnerable communities. I acknowledge that vulnerable communities deserve the attention they receive in the CEIP but to attract jobs here, CPU must continue its excellent service in a dependable fashion far into the reasonable long-term planning horizon applied by many businesses.
My main concern is the transition cost and its future impact on rates. The high cost of making the transition mandated by the state of Washington is not being made clear to the public. If costs are mentioned, the rate impacts in our communities are not made clear. Our citizens are dealing with high costs for every necessity (gasoline, food, property taxes, etc), and I believe they do not understand the cost risks of the aspirational goals of zero net CO2 by 2050, or the like. Not understanding this may lead to some poor policy decisions that cannot be undone, such as divesting the portfolio of certain fossil fuel resources. Once decommissioned, they cannot easily or at all be restored to the system.
I am pleased to see that cost is addressed in the CEIP modeling. Specifically, I want to compliment CPU on its analysis entitled Functional Replacement of CCCT Renewable Energy + Batteries. I haven’t reviewed it in detail, but a cursory reading shows me that a valuable, sophisticated, and highly challenging analysis has been performed.
Finally, I believe the public and elected officials do not understand that utilities cannot plan based on technology that is not tested and proved safe and reliable. And utilities cannot shut down other resources that are safe and reliable in the hope/ confidence that other new untested resources will be good and affordable replacements. At least that has been my experience with planning for a very large number of utilities (PUDs, municipals, IOUs, and especially cooperatives) over the years. I certainly hope that standard is maintained.
Thank you for the obviously exhaustive effort on this task.
Submitted 11/8/2021
Question:
I wish to comment on the draft Clean Energy Implementation Plan (CEIP), the “roadmap” for meeting CETA’s goals. As stated on page 4, the CEIP demonstrates how “customers are benefitting from the transition to clean energy.”
As I scanned through the report, I did not see any plans for future community solar projects. And yet (if I’m not mistaken), the uncaptioned photo on page 9 shows a large community group celebrating the community solar array in 2015.
With COP26 as a backdrop, and with Climate Action Plans endorsed by the City and the Port, it is surprising that Clark PUD has no plans for a community solar project.
As has been stated at other meetings, the Port of Camas/Washougal is offering roof-top space for solar panels. Please explore this opportunity without delay.
Please include community solar to promote clean energy that also benefits customers.
Response:
Regarding potential for further community solar projects, on page 14 of the report, included in item 7 is this passage:
“Clark Public Utilities is currently exploring additional opportunities that will allow for limited and low-income customers to participate in renewable energy programs and projects. Clark Public Utilities has engaged governmental agencies located in the county in these conversations.”
So while there are no specific community solar plans laid out in the draft report, this passage is meant to speak to additional opportunities for renewable energy such as community solar. Discussions with various stakeholders are ongoing for potential future community solar projects.
Submitted 11/8/2021
Question:
I would like to better understand how CPU makes decisions regarding RRGP operations.
Could you please explain the methodology CPU has used to calculate “economic displacement”? What is the typical time period used (day, month, season?) and what risk factors if any are included? Will this calculation change once RRGP is made more flexible? The presentation on RRGP flexibility only included one month of past analysis. Why not a whole year or years if the calculation is simple? The only available public wholesale price data for the Mid C trading hub is from EIA for day ahead peak. Will CPU use something similar? Can this be shared with rate payers? Thanks
Response:
With respect to economic displacement, in an organized Energy Imbalance Market, such as the Western EIM, natural gas plants bid their marginal costs into the market based on daily economic heat rates which are determined by the relationship between daily gas and daily wholesale power prices. If a seller of hydro, wind, or solar, with zero marginal costs, is willing to sell for less than the marginal cost of a given natural gas plant then the gas plant is not dispatched. The gas plants with the highest heat rates are displaced first in an EIM. RRGP has a very low heat rate of about 7.1 and as such, would be one of the last gas plants economically displaced in an EIM.
RRGP is not in an EIM, but dispatch for daily trading looks much the same. RRGP’s dispatch is evaluated each day based on marginal economics based on day-ahead market gas prices and day-ahead wholesale power prices. The unit currently operates in binary mode, either offline or running at full capacity which varies based on ambient temperatures. And, due to wear and tear on plant equipment, Clark Public Utilities has not historically displaced RRGP for less than a two week period. Since market gas prices are daily, the RRGP economic heat rate varies daily.
RRGP’s economic heat rate is a calculated operational heat rate for RRGP to operate at breakeven costs. Since wholesale power market prices are typically lower during off-peak periods RRGP is sometimes not economic to run in off-peak periods (out of the money) but economic to run in on-peak periods (in the money). RRGP cannot be economically displaced for the 8-hour off-peak period each day. However, with the flexibility product that we are pursuing RRGP could be ramped down to near 90 MW in off-peak hours and other periods in which it is not economic to run.
With respect to the RRGP flexibility analysis, EES Consulting evaluated the potential savings associated with ramping RRGP up and down to follow loads, resources and market-implied heat rates using calendar year 2020 historic hourly wholesale power prices, gas prices, loads and resources. Based on 2020 hourly data the estimated annual savings associated with adding ramping capabilities to RRGP are between $2.5 and $3.2 million.
With respect to Mid-C market prices, our access to market price information is proprietary and confidential and we are limited in how we can share that data, but rest assured we are very much plugged into hourly, daily, monthly, quarterly and annual gas and power market pricing.
Submitted 11/9/2021
Comment:
I am happy to have a public utility that is responsive to customer comment. I appreciate the direction you are taking in turning to clean energy, especially incentivizing electric vehicles. I would encourage you to consider ways to achieve those clean energy goals even faster than your draft plan. The CETA requirement of 80% clean power by 2030 is the minimum. Your target should be more aggressive. The sooner we are generating clean power the better positioned we will be for the building and transportation electrification of the near future. Thank you
Submitted 11/9/2021
Question:
Transportation and building sector electrification is likely to continue increasing, and so will our need for clean energy. Let’s be proactive in procuring more clean energy as quickly as possible. This will, in the worst case scenario, only position us ahead of the curve, and we will end up with surplus clean energy, potentially allowing us to export clean energy to other areas.
Additionally, please consider whether utilizing RRGP, even solely in the event of extreme, emergency events such as heat domes, prolonged exposure to wildfires smoke, droughts, transmission failures, and polar vortexes is a viable option. How much power is typically available and at what cost? Does current hydrology and weather forecasting allow adequate lead time to start RRGP, or would there be significant ramp up duration? What is the financial and operation cost of starting and stopping RRGP several times a year, as may become necessary if extreme weather events increase in severity and frequency as the IPCC predicts? Would utilizing RRGP less extend the duration for which it is a viable source of power? How does purchasing work, and how would this play in?
Response:
The draft 2022 budget includes RRGP annual generation of 1,989,913 MWh or 227 aMW. It assumes the plant generates energy in all months except May when it is scheduled to be off-line for annual maintenance. Total RRGP costs included in the draft 2022 budget are $75.3 million. As such, the draft 2022 budget results in a unit cost of $37.9/MWh from RRGP.
RRGP was designed to run as a baseload resource and currently operates in binary mode, either offline or running at full capacity, which varies based on ambient temperatures. We plan for RRGP to run 11 months each year allowing for a 1-month maintenance outage. As conditions change from planning to actual operations, opportunities arise when wholesale power can be procured from the market at prices less expensive than the cost of power produced at RRGP. When this happens, we take action to capture these savings. This process is referred to as “economic displacement.” If RRGP is economically displaced, current hydrology and weather forecasting information allow adequate lead time to re-start RRGP. RRGP can be re-started from 0 MW to full load in 4 to 5 hours.
Due to wear and tear on plant equipment, RRGP has not historically been displaced for less than a two week period. We do not foresee an operating regime in which RRGP is stopped and started several times a year. However, as noted in the draft CEIP, an option of upgrading RRGP with equipment that will allow plant generation to be ramped down from its base generating level to near 95 MW is being explored. This capability is designed to reduce carbon emissions and local pollutants and would allow RRGP generation to follow loads, resources and markets. Running RRGP less will extend the life of the plant. However, under the Clean Energy Transformation Act, RRGP must be retired by 2045. In order to mitigate market price risk, natural gas to fuel the plant is purchased in relatively small amounts in the months and years leading up to a calendar year so that all required natural gas has been purchased well before an impacted year. The utility will continue to diligently purchase natural gas well in advance of planned generation months.
Submitted 11/9/2021
Question:
What is the deadline for comments on the draft plan to be submitted?
Response:
The public comment period on the draft CEIP is set to close December 3, 2021. Any comments received after that time will be considered for future planning.
Submitted 11/10/2021
Comment:
The yearly consideration of how to spend our PUD surplus means significant resources could be applied to taking on broadband, which would not only improve community access but demonstrate that equity is being addressed. I urge you to take this under serious consideration, given the access issues that have become more obvious as remote meetings and gatherings have become necessary for so many in our community to maintain health and connection with others
Submitted 11/10/2021
Comment:
1. EV charging is still skimpy and sparsely distributed. For EVs to really take hold, work on providing charging at apartment building sites will be important. Requiring one charger at new build commercial seems inadequate- if people do not think they can charge, they are less likely to buy or use EVs.
2. Recommend tiered pricing, with the more energy used, the higher the price.
3. A big waste of electricity occurs in commercial budlings that are cooling servers, dumping that heat to the exterior, then using more energy to heat the building- can you push heat exchange solutions?
4. So encouraging to see you actively working to make aggressive progress on this critically important problem of carbon release and climate change.
Submitted 11/11/2021
Comment:
Please stop this ridiculous idea that we as a state, county, or country can live without fossil fuels for energy!!! What planet do you live on? STOP going down this ridiculous road, don’t you remember what happened to Texas last winter when their windmills FROZE and many people suffered and some died!! That is my opinion of anyone trying to change this country from being energy independent!!
Response:
As a public utility we are always working to maintain the most reliable system possible, at the lowest possible cost, while providing excellent and responsive customer service to a broad customer base. While we are required to take a least-cost approach, we are also mandated to meet clean energy targets outlined in the Clean Energy Transformation Act. As with all laws, we will maintain compliance.
Submitted 11/12/2021
Comment:
Some of the suggestions I will make are so obvious that they are not new or unique.
Continue to support home owners and businesses in changing the way they use energy. Efficient electric heating for old construction. Encourage people to change from oil and gas to electric heat pumps. We have a combination of gas and electric ductless heating. If there was incentive I would switch from gas.
Insulation programs that would make it easy to increase the amount of insulation and to replace windows and doors. The leasing of roofs for installation of solar panels. Incentives to buy electric cars.
I am sure there are more things to do, keep up the good work.
Response:
To address a couple of items you mention and provide a little more information, we’d note that Washington law currently prohibits public utilities from incentivizing “fuel switching” like switching from gas to electric heat. For customers with existing electrically heated homes there are several incentives available through our rebate and low interest loan programs. The programs help customers make energy-efficient home improvements that save energy while offsetting some of the cost. Insulation upgrades and replacing eligible windows and doors with qualified efficient options are included in our program offerings.
More information is available here: https://www.clarkpublicutilities.com/residential-customers/reduce-energy-waste-and-lower-your-bill/all-rebates-incentives-and-low-interest-loans/
Submitted 11/12/2021
Comment:
I designed and built two energy efficient houses that I’ve lived in since 2000 and understand that energy efficient residences are a NET SAVINGS contrary to many who say that they cannot afford energy efficiency features beyond the basic county code requirements. If a county has proper building codes there is much energy to be saved and therefore the energy supply can be reduced on a per capita measure. Not only are these houses more energy efficient they are more comfortable to live in as they also reduce outside noise and reduce hot/cold spots in the house.
Codes could require 1) better air sealing to reduce the ACH 2) wrap-around insulation to reduce thermal conductivity through the building studs 3) higher efficiency electric HVAC with HRV 4) better solar orientation of the major roof components 5) PV solar. Does the PUD work with Clark County Building Code on these issues? Are the financial lending institutions understanding the economics of all this and willing to participate? Are all of the parties willing to think outside of the proverbial box?
And let’s not forget that this all works for commercial buildings also. The federal labs have modeled all of this and have the data so the research has already been done and nothing needs to be invented to put this into play today. The PUD engineering knows all of this but how can this be better leveraged into the community?
Energy savings for the environment, net savings for all of the occupants/users of buildings, higher comfort level, easier road to compliance with new State 2045 directive – what is not to like about that?
Response:
Regarding your comments around building and energy codes, thank you for the thoughtful suggestions. While we do not work directly with Clark County on building codes we do encourage the most efficient building practices through our portfolio of energy efficiency and conservation programs. We also certainly agree there are several innovative manners in which builders can make homes and buildings more energy efficient and we offer new construction programs that provide rebates to builders who exceed state energy codes by ten percent or more. We also offer a loan program to our residential customers for the installation of energy efficiency upgrades at their homes, as well as solar PV installations.
Notably, Washington State has some of the most stringent and aggressive energy codes in the nation and we’re fortunate to have a local community, and local builders that support exceeding the already high standard set by our state policy makers.
Submitted 11/13/2021
Comment:
Greetings,
I’m a registered nurse and member of Washington Physicians for Social Responsibility. It’s important for Clark Public Utilities to emphasize that we need an even cleaner, even faster transition to 100% clean, renewable and affordable energy as soon as possible. The trends of transportation and building electrification will require more clean energy, and Clark Public Utilities has an opportunity to be a leader in the region to provide this energy. The worst case scenario of being a leader in the clean energy transition would be surplus clean energy, which is better than the worst case scenario of not acting and increasing climate chaos. During this transition, it is also important that the utility focuses on cost-burdened payers, who may have difficulties affording clean energy but still support the idea. Let’s shoot for clean energy abundance and make sure everyone who wants has a chance to participate in programs like community solar or early EV adoption!
Submitted 11/15/2021
Comment:
There is no more urgent need to help lessen our disastrous impact on the climate than to stop our use/production of methane immediately or yesterday. This should be the top priority for CPUD — do anything it takes to increase renewable energy production and shut down the River Road plant. There is no such thing as sustainably producing methane — even from cattle. Raising of cows for food production is also damaging to the atmosphere (most of the methane they produce is belched out during digestion so you can’t capture that anyway), so this can’t be a viable alternative to renewable and sustainable energy sources.
Submitted 11/15/2021
Comment:
I applaud your current efforts to make the switch to renewable energy for the health and safety of all. I attempt to avoid fossil fuel usage through my choices of housing and transportation. I live in a small condominium and walk, ride a bike or drive a pre-owned Bolt EV. However, my housing situation prevents me from being able to add solar panels or a Level 2 charger and am told it would be prohibitively expensive to switch to a solar water heater and all-electric heat pump, as mine is “duel-fuel”. I am one of many who would welcome the availability of community solar and nearby affordable charging stations and all incentives that encourage others to reject gas heating, cooking, lawn mowers and leaf blowers, and especially automobiles.
Submitted 11/15/2021
Comment:
Thank you for being a public utility that offers reliability and high customer satisfaction, and for seeking to be fiscally and environmentally responsible.
I urge you to take significant actions to phase out greenhouse gas emissions even sooner than required by CETA, including phase-out of the natural gas fired RRGP, and accelerate the conversion to clean energy.
I urge you to develop additional Community Solar projects. Everyone should have a chance to participate. I own shares in the first Community Solar project and I would invest in additional projects if I had the opportunity. I have too many trees around my house to make roof-top solar feasible, so Community Solar offers an alternative to distributed generation at my residence.
I urge you to plan for increased electrification of vehicles and buildings. Most automotive manufacturers are moving towards all-EV fleets within the next 10 years, so you need to plan for distributed charging stations at places where people work, shop and recreate. All new construction should include being ready for EV-charging, particularly public facilities such as schools, libraries and recreation centers, new commercial construction, and multi-family residential construction. The elementary school in my neighborhood was just replaced with a new building but I have not seen any EV charging stations in the newly constructed faculty parking lot.
There should not be any more natural gas hook ups in new buildings and all new buildings should be solar-ready. The plan should incentivize electrification.
There should be incentives for customers to convert from natural gas to electric residential and commercial heating, cooling, water-heating and cooking, with a priority on electric heat pumps for heating and cooling in existing buildings. I have taken advantage of your past incentives to install an electric heat pump for home heating and cooling and a hybrid electric heat-pump water heater. I have purchased a battery-powered lawn mower and string trimmer. I participate in Lights Out by installing motion-detector outdoor lighting instead of leaving exterior lights on all night.
There should be a continued focus on conservation, including coordinating with city and county building codes to seek energy efficiency in commercial applications.
Community broadband should be added to the conservation mix. The COVID-19 pandemic has showed us that many people can work from home and many organizations are functioning well with online meetings, reducing the need for travel. Community broadband also is an equity issue, providing equal access to all customers.
The plan should not include nuclear. There is no proven and established way to deal with radioactive waste so don’t pursue that alternative. Nuclear is not clean energy.
The plan should address the use of batteries for energy storage to meet peak demand loads.
Submitted 11/15/2021
Comment:
I think it is great that the CEIP process is encouraging CPU to focus more on helping energy burdened customers (page 10). Too often a simplistic use of the concept of affordability means we don’t really help those customers who are energy burdened and instead provide perverse incentives to heavy energy users to not conserve or be as efficient as they can afford to be.
Do we have any basic demographic data on energy burdened customers? How many are renters vs homeowners? These two groups would seem to warrant very different programs. Do we have any insight into what types of housing house the most energy burdened customers? Are particular types of apartments (age, style?) or types of single family residences (mobile homes, older homes?) problematic?
Has the utility considered placing absolute or relative income levels on which energy burdened customers are to be helped? In other words, if a household income is over $100,000 but energy costs are very high could this be more a case of residential bitcoin mining or a home based business or simply energy waste and what assistance should be offered in these cases? Alternatively, a high income and high energy costs could be the result of a large family or multigenerational living. Is household size flagged in the demographic data?
Has the utility looked into supporting a residential energy score or similar type program? One of the biggest hurdles for renters or new homebuyers is understanding what their operating costs are likely to be. There is a horrible information asymmetry between buyer and seller. And sometimes landlords don’t even know the energy profile of their units unless their tenants are willing to share that information. It seems like CPU is in a unique position as the holder of actual usage data. Past usage data (which would not impact privacy in anyway) coupled with basic building information that is publicly available from county tax roles would help renters or buyers understand if they were looking at above average operating costs. This could be significant for lower income households.
Response:
The CETA statute defines energy burdened customers as households who spend six percent or more of their household income on energy bills. Over the last year Clark Public Utilities has contracted with Empower Dataworks to assist in identifying Clark County households who meet the CETA definition of energy burdened. That work has resulted in identifying just over 18,000 customers who fit that definition of energy burdened.
Additionally, the customer demographic dashboard developed by the vendor includes other attributes such as homeowners versus renters, the primary language spoken in the household, employment status, household size, senior citizens and more. This will be a valuable tool in developing specific programs that can benefit different subsets of energy burdened customers.
The utility intends on developing a mix of targeted energy conservation and bill assistance programs next year and rolling them out in 2023, upon the Board’s approval. While we do not have plans to create absolute or relative income thresholds, we do offer free home energy reviews that are completed by our Energy Services field staff and those efforts provide a great opportunity to identify the drivers of high consumption.
We are hopeful the Covid-19 situation improves and we can begin meeting with customers in their homes again. Related to your energy score question, we currently partner with Opower to provide home energy reports to 40,000 residential customers. Those reports have a “similar home comparison module” built into them that rates each participating household against 100 similar homes. We’ve found this program to be a cost effective way to achieve energy conservation and also assists customers in better understanding their electricity consumption. We agree having well informed consumers of electricity is an important goal and we’ll continue to focus on this effort.
Additionally, we do offer customer brochures that help our customer better understand their consumption, on that topic please see here.
Submitted 11/15/2021
Comment:
Some thoughts on affordability
Residential retail rates in 2001 .0698/kWh, in 2019 dollars (adjusted for inflation) .1008/kWh.
2000 median Clark County household income $48,376 (census data), in 2019 dollars $71,821.
2019 retail rates .0816/kWh. 2019 median household income $80,555.
So real median household income has gone up by about 12% and real residential rates have dropped by 19%. If rates were affordable in 2001 then they are much more affordable to many more people today! (These numbers would probably be more dramatic if extended through 2021.)
Clark County has become a much richer place in the last 20 years but median or average numbers mask a probable increase in inequality and unaffordability for many residents. Residents on fixed incomes or with lower wage levels have also faced dramatically increasing housing costs. It would be nice to know how the percentage of energy-burdened residents has changed over time. The above data highlight that for most Clark County residents, energy costs have become much more affordable over time and we should be trying to help those ratepayers who actually need help.
When adjusted for inflation, CPU has been lowering real electric rates every year since 2011. There is no reason to lower rates even more with another surplus rebate. Assistance to energy burdened customers should be much more highly targeted. Continuous rate reductions and windfall surpluses may be encouraging less desirable behavior among heavy energy users (bitcoin mining, beer fridges) and encouraging customers to underinvest in energy efficiency and conservation.
What to do with a surplus? That begs the question of why do we have a surplus? Is budgeting too conservative or is the budgeting process being sandbagged? Unlikely. Staff seems very cautious and extremely competent. It doesn’t seem like they are incented to sandbag.
Is it luck? North American gas prices have stayed low and demand for power from CA has stayed high but how long will this go on? What do we have control over? Have we been over reliant on shrewd trading and an aging gas plant? Have we been lucky with no really low water years in the past decade? It’s unclear how much the surplus reflects staff skill vs overall luck. I think the prudent course of action would be to invest the surplus especially if we are currently underinvesting in long term reliability and rate stability.
Please invest any 2021 surplus. Please look at either debt reduction or increased investment in areas like tree trimming, moving distribution underground, distributed energy resources (DERs), or other measures which increase future reliability, stability, and ultimately affordability. Public power represents a tremendous bargain for ratepayers. The value received is likely much greater than our costs. Almost all wealthier states have much higher average electric rates than WA and we’re not seeing an exodus to WA based on power cost differentials. CPU is delivering a great deal already!
Also, please consider reordering the following factors: reliability, stability, and affordability. CPU may be sacrificing long run reliability and stability for short run perceived affordability. But as already mentioned, gross affordability is a poor mechanism to help those that actually need help and may be encouraging rate payers to underinvest in profitable energy efficiency because of a complacent perception of never changing rates.
Reliability — Probably the most important factor
Stability — Rates don’t change rapidly year to year, customers have time to adapt and make investments or changes if needed.
Affordability — Our power keeps getting cheaper every year but most ratepayers don’t understand that or appreciate it. At some point, ultra low rates encourage inefficiency and waste.
Walmart and Dick Hannah don’t need rebates! (Sorry to pick on Dick Hannah but County records show he owns a 15,000sf house.) And very little of last year’s rebate was actually donated to Operation Warm Heart (less than 1%?). Please be more targeted and take a longer term view if we really want to help rate-payers with affordability. Thanks!
Submitted 11/15/2021
Comment:
Thank you for taking the time to read the public’s comments and questions. And thank you for making it easy for the public to submit comments and questions!
When was the last time the utility thoroughly reviewed its rate structure and overall rate levels?
How does CPU rates compare to the Portland utilities and other west side WA utilities?
Has CPU ever looked at moving to a block style rate structure? This was mentioned by a previous commenter and seems like a good idea. It might be a way to help energy burdened customers as well as encourage heavy residential users or those with larger than average homes to invest more in energy efficiency and conservation. My understanding is that rates could be lowered on the first block or two but raised on subsequent blocks in a manner that is revenue neutral.
Response:
Ultimately retail rate structures (and levels) are a board decision. Inclining block energy rates would result in lower monthly bills for customers that consume less than the average customer. However, the benefits of such a rate structure may not disproportionately lie with energy burdened customers as suggested. Customers that rely on natural gas for heating and water heating benefit the most from inclining block energy rates because they have the lowest energy consumption.
Energy burdened customers that rely on electric heating would likely see an increase in their monthly bills because they likely use more energy than the average customer. In addition, it is not generally true that low income customers use less energy than the average customer. Low income customers have often invested less in energy efficiency or live in rented homes or apartments in which they cannot invest in energy efficiency. As a result low income customers often live in poorly insulated residences and have higher energy consumption than the average customer. Inclining block energy rates would increase the monthly bills of such customers. There is also a lot of conversation in the industry about transitioning from natural gas to electric heat in order to reduce overall carbon emissions. The transition will result in an increase in energy consumption for the average utility customer. This transition will take many, many years, however, most utilities will likely balk at the idea of implementing inclining block energy rates until the transition is complete. At that time all customers will be on a level playing field and the price signal included in inclining block energy rates will properly incentivize all customers to reduce energy consumption.
Clark Public Utilities 2020 bond issuance documents included a comparison of monthly electric rates and noted that Clark Public Utilities enjoys a competitive rate advantage when measured against utilities in the Portland metro area. Below is the rate comparison which reflects utility rates as of July 2020. Some of the utilities shown below may have implemented rate increases since July 2020 while Clark Public Utilities has not.
| Residential (1,200 kWh) |
Commercial (30 kW, 9,000 kWh) |
Large Commercial (400 kW, 150,000 kWh) |
|
| Clark County PUD No. 1 | $109 | $718 | $10,131 (w) |
| $9,336 (s) | |||
| Selected Public Utilities: | |||
| Benton County PUD No. 1 | 108 | 622 | 9,979 |
| Cowlitz PUD No. 1 | 106 | 813 | 11,394 |
| Franklin County PUD No. 1 | 115 | 709 | 7,738 (w) |
| 6,388 (s) | |||
| Grays Harbor PUD No. 1 | 144 | 907 | 13,343 |
| Mason County PUD No. 3 | 124 | 765 | 10,242 |
| Pacific County PUD No. 2 | 97 | 664 | 10,909 |
| Peninsula Light Company | 120 | 740 | 10,982 |
| Snohomish County PUD No. 1 | 125 | 851 | 12,635 |
| Selected Municipalities: | |||
| Eugene Water & Electric Board | 130 | 870 | 12,365 |
| City of Ellensburg | 116 | 776 | 10,495 |
| City of Richland | 110 | 636 | 8,713 |
| City of Seattle | 149 (w) | 948 | 13,757 |
| 155 (s) | |||
| City of Tacoma | 113 | 739 | 10,548 |
| Investor Owned Utilities: | |||
| Avista – WA | 109 | 1,017 | 14,738 |
| Pacific Power & Light – WA | 112 | 797 | 10,824 |
| Pacific Power & Light – OR | 124 | 872 | 9,493 |
| Portland General Electric | 147 | 843 | 12,423 |
| Puget Sound Energy | 125 | 797 (w) | 14,272 (w) |
| 968 (s) | 12,684 (s) | ||
| Average (excluding the Clark) | $121 | $803 | $11,137 |
Submitted 11/16/2021
Comment:
Thank you for requesting public comment on the CEIP. I think the plan is very good. People want the cleanest energy as quickly as possible. I have 3 requests.
1) Please remove nuclear energy from consideration because nuclear waste cannot be contained for tens of thousands of years. Even solid rock in mountains cracks and moves in that amount of time. The Yucca Mountain depository has not been permitted; the US Geological Survey reports even fissures and possible earthquakes in the most secure solid rock site identified. Nuclear has proven more expensive and costs increase over time. The technology is experimental, not available for years.
2) Aggressively seek out and promote new clean energy sources. As new wind, solar, geothermal, and tidal energy sources become available, please be ready. Geothermal is long used technology providing Iceland with abundant energy for decades; Calpine’s The Geysers has been running for decades and supplies 725 megawatts of reliable power to 6 utility companies; Washington has similar potential. Please support and be ready to take advantage of clean energy. Batteries are improving. Soon we will have batteries, geothermal and tidal energy generation to ensure reliability.
3) Plan to discontinue use of River Road in the next 5-8 years. Methane should be expected to become much more expensive. At COP26 100 countries led by the US have pledged to decrease methane emissions. Expensive equipment will soon be required at well heads and pump stations to capture methane. The demand for methane will decrease as buildings convert to heat pumps. There is an acceleration of pension/endowments pulling investments from oil fields and midstream companies in addition there is a growing movement to stop government subsidies and tax advantages all of which makes fossil fuel more expensive.
Submitted 11/16/2021
Comment:
The Draft CEIP states that “In 2021 Clark Public Utilities signed a non-binding letter of intent with a Small Modular Reactor (SMR) developer and has been exploring the potential to add generation from SMRs to its resource portfolio beginning in 2030.” The developer is not named in the draft, but when it comes to nuclear power, the devil may be in the details.
The “developer” is NuScale and the nuclear plant, not yet built, is the UAMPS/NuScale plant near Idaho Falls, an untested nuclear reactor, with significant risk that it will follow the usual history of nuclear project cost overruns, delays and failures. The private financial sector has not stepped forward to pay for it, and neither have large investor-owned utilities, leaving backers looking to put the financial risk on smaller utilities and towns, first in Utah, and now in surrounding states, including Washington. One by one in 2020 Utah municipalities that had previously signed up to purchase power from the proposed Idaho SMNR began to reconsider and a number of them ultimately withdrew. Energy Northwest recently withdrew as proposed plant operator.
The nuclear industry pitches “advanced nuclear” in the form of “small modular nuclear reactors” as cheaper and faster. The truth is, small modular NUCLEAR reactors (SMNR’s) are not a reality anywhere in the United States, and in spite of significant taxpayer subsidies, the costs of generating electricity by SMNR’s can be summed up in one word: uncertainty. Early estimates by UAMPS for its project with NuScale in Idaho Falls promised $55/MWh, but have risen to $58/Mwh. NuScale itself had a different estimate for the project: $65/MWh. And cost estimates calculated by major utilities like PacifiCorp and Idaho Power came in higher still: $95/MWh and $121/MWh respectively. By comparison, the levelized cost of energy from wind is presently in the $26-$54/MWh range, and utility-scale solar in the $29-$42/MWh range, according to Lazard.
An in-depth report on the UAMPS/NuScale proposed SMNR project for Idaho Falls, by University of British Columbia’s Dr. M.V. Ramana, found that increasing project and electricity costs, lengthy schedule delays, and nuclear waste disposal issues could be a significant albatross for participating municipalities. This project, under consideration in the long-term plan being proposed for our PUD, is following the same trajectory of rising costs that has plagued most nuclear projects across America. Total project estimates started at 3.1 billion in 2015, rose to 4.2 billion in 2017, and then to 6.1 billion in 2020 – all before construction has even begun.
Consider this from a former chairman of the Nuclear Regulatory Commission: “Small modular designs are only promising to be cheaper than traditional reactors. Current estimates show they are more expensive than renewables, like wind and solar, even with storage and without subsidies. Small reactors have a long way to go to be competitive. Dramatic cost decreases for high-volume energy storage, which address the intermittency of some renewables, make the competitive case for any form of nuclear even tougher.”
It clearly does not seem prudent or wise for our PUD, considering financial risks, escalating costs and ongoing uncertainty, to look 9-10 years down the road and magically believe that by the time we need to use it, this SMNR project will be there and be cost-effective for our clean energy needs. We can do better looking elsewhere.
Submitted 11/17/2021
Comment:
A great opportunity for solar power generation is the new Interstate Bridge Replacement project. Clark Public Utilities could be instrumental in coordinating and helping with design of a massive array above the bridge decks. The timing and funding of this scale of project couldn’t be better.
Submitted 11/17/2021
Comment:
Teachers annually receive important medical alerts about our students. When I began teaching, the list was short and was dominated by allergies, typically related to bee stings. By the time I retired, the list had tripled and was dominated by asthma and similar conditions. Deteriorating air quality is to blame. CPU should do all in your power to end the pollution of carbon-based energy production, such as as River Road. Kids’ lives matter. Thank you.
Submitted 11/18/2021
Comment:
Thank you for asking for customer input. Clark PUD should transition to 100% renewable energy as soon as possible. The River Road Generating Plant needs to be phased out, not upgraded. The $10 million dollars spent on RRGP’s “flexible” upgrade would be far better spent on sourcing actual renewable energy, as others have said. Upgrading RRGP may amount to putting lipstick on a pig. I would like to see to see that plant phased out even earlier than CETA requires. Then Vancouver can start to reduce the ghg emissions that are affecting all of us, some of us disproportionately.
I live next to 205 and 14 and I always wonder about the quality of air here. Please continue to incentivize electric vehicles however you can. Please use more local renewable energy sources, and increase conservation and energy efficiency. Please reduce peak demand by using demand response measures. Avoid using Renewable Energy Credits to meet CETA mandates, unless there really is no better option. RECs are not as good as actual renewable energy. RECs are lazy.
I have a couple comments about the actual CEIP draft document. I think the term “Small Modular Reactors” is deceptive. You are talking about nuclear technology. Nuclear does not belong here in the Cascadia Subduction Zone. We are overdue for a massive earthquake. While small modular reactors may be “non-emitting,” they are also risky and expensive. Please use the more accurate term: “Small Modular Nuclear Reactors.” I also suggest a few changes to the Highly Impacted Communities section. I think everyone is more familiar with zip codes than census tract numbers. You should change that if you can, so we can understand what we’re looking at. On your Highly Impacted Communities Map, please overlay some streets so customers can see where they live. I can’t tell where I am on that map.
Thank you for letting us participate in this process.
Submitted 11/22/2021
Comment:
I’m quoting my friend Don here as his note to you says everything I’d like to say. Thank you for the opportunity to share my opinion on my children’s future:
“I’ve been very impressed by staff over the years, particularly in their recent workshops. However, I’m concerned about your flex plans at your River Road Fossil Fuel Plant. We should shut the thing down ASAP, unless you plan to capture the CO2 you produce. We shouldn’t ask our children to do that later. They will have enough burdens dealing with heat-domes, drought, wildfires and washed out roads and bridges caused by climate change which is exacerbated by our gas plant.
I suggest that we not get rushed into building a flex plant. We need the whole truth about it. We need a full EIS first. That may take two years and involve public hearings. The State Environmental Policy Act has established protocols for that.
Instead of investing $10 million in a flex system, invest $10 million in solar. The fuel is free. The Northwest Power and Conservation Council recommends for the region that we acquire 3.5 gigawatts of renewable energy within 5 years. The population of Clark County represents 3% of that region. 3% of 3.5 gigawatts is about 105 Megawatts. Our community solar farm is rated at 1/3rd of one Megawatt.
That means we need to build 315 projects equal to our Community Solar farm to do our proportional share. I hope you are planning on that. Renewables may not get us to zero emissions, but they will get us closer.
At your budget workshop, if I remember correctly, staff reported that a truck fleet operator wanted to operate in your service territory using electric trucks and you told them they would be limited to 4 megawatts of charging capacity.
If you were to accommodate all their needs, it would be a financial benefit to all of us. But it would be even more beneficial to the ratepayers in a reduction of health harming pollution as well as helping Vancouver reach its goal of reducing greenhouse gas emissions.
Regarding Renewable Energy Certificates. It became apparent eight years ago that unbundled RECs were not accomplishing anything. Walmart and others recognized this and decided instead to sign purchase power agreements, which means they buy both the REC and the energy.
You plan to retire a huge number of RECs in 2030 and 2031. How have you accrued them, and how are you planning to accrue them between now and 2030?
Unbundled RECs seem to be like pixie dust. Purchase Power agreements seem real. PPA give developers more confidence and has already prompted a surge of clean energy projects. In 2020 alone, Corporate and Industrial buyers in the US procured 10.6 gigawatts of renewable energy. Voluntary procurement by the C&I sector has become a major driver of the energy transition.
I applaud your plans to launch a heat pump water heater program for new residential and new multi-family construction I’m pleased to see you are anticipating that $1 million will be spent pursuant to the early adopter part of HB1257, the Clean Buildings Act. I hope Peter Van Norwick has notified the eligible property owners. I’m also pleased to see a continuation of your Transportation Electrification plan. If you to create post about those programs on your FB page, I’d amplify the message. Thanks for the opportunity to speak.
Response:
Thank you very much for submitting comments related to the Clark Public Utilities’ CEIP. Below you will find responses to the specific aspects of the plan you commented on, please let us know if you have any additional questions or thoughts.
Flex Technology at RRGP
CETA’s mandate of 80/20 net-carbon-free electricity starting in 2030, and 100% carbon-free in 2045, were based on the most recent science at the time and drove both the goals and the narrative around how fast Clark Public Utilities needs to reduce the amount of generation at the River Road Generating Plant. Our goal in this CEIP is to build the foundation that will allow us to exceed the first timeline mandate for 80/20 net-carbon-free electricity as required under CETA. These specific mandates, passed by the Washington Legislature in 2019, include the following language which links the 2030 and 2045 goals to specific timeframe requirements – CETA targets are indeed ‘swift reductions in greenhouse gas emissions.’
“The transition to one hundred percent clean energy is underway, but must happen faster than our current policies can deliver. Absent significant and swift reductions in greenhouse gas emissions, climate change poses immediate significant threats to our economy, health, safety, and national security. The prices of clean energy technologies continue to fall, and are, in many cases, competitive or even cheaper than conventional energy sources.”
Further, the CETA law identifies the ways utilities like Clark Public Utilities can achieve their important role in this transformation:
“The legislature declares that utilities in the state have an important role to play in this transition, and must be fully empowered, through regulatory tools and incentives, to achieve the goals of this policy. In combination with new technology and emerging opportunities for customers, this policy will spur transformational change in the utility industry.”
The turn-down flexible technology available for installation at our River Road Generating Plant is a new technology opportunity that aligns with the goals of CETA – to reduce greenhouse gas emissions faster, and, we can do so while maintaining critical capacity at the plant to cover peak loads during extreme events. With this new technology opportunity, we will not only exceed the 2030 target but do so without triggering the cost cap within CETA.
RRGP Flex vs Solar
With the RRGP Flex Technology implemented, along with the additional hydro resource we have included in our CEIP, we will meet the first CETA clean electricity target before 2030. Once those goals are met we must balance system reliability and cost to our customers, as well as meeting any Resource Adequacy goals that might be required by the Western Resource Adequacy Plan. Required capacity will be purchased on a least-cost basis to balance the requirements in CETA. Capacity factors for hydro, wind, solar, non-emitting will be used in the analysis. Our 2022 Integrated Resource Plan update will include updated capacity factor and costs for all available capacity technologies including battery technologies. As you can see, there are many factors to consider when planning for future resources but we are confident solar will play a role in meeting our future CETA mandates beyond the 2030 target.
Renewable Energy Certificates
Renewable Energy Certificates (RECs) allow organizations to reduce the environmental impact of their Scope 2 emissions in North America by matching their electricity use with RECs. By investing in RECs, organizations can help increase demand for renewable energy — encouraging the development of new renewable energy projects and providing project owners with additional revenue that goes beyond selling the project’s electricity. The CETA statute only allows the use of RECs for “alternative compliance” and that allowance is designed to clean up any electricity generation that was derived from an emitting resource (the 20% bucket of the 80/20 net-carbon-free 2030 mandate).
The specific strategy related to Clark Public Utilities procurement plans for the RECs needed to meet the alternative compliance mandates within CETA has yet to be developed. Staff will include details on this effort in future CEIP’s that will also include a public process.
Thank you for taking the time to provide your comments.
Submitted 11/29/2021
Comment:
I appreciate the PUD’s CEIP planning efforts to reduce GHG emissions. But the scientific consensus is that our past inaction has made the climate situation dire. The dire situation requires very aggressive actions to reduce emissions. I don’t think the CEIP is aggressive enough.
My specific concern relates to the RRGP. To effectively and substantially reduce GHG emissions, the PUD has to plan to replace the RRGP production as soon as possible.
The CEIP doesn’t clearly include a plan to totally shut down the RRGP. I understand that can’t happen immediately. I also understand the PUD plans to purchase equipment that will allow flexible use of the plant and installation of that equipment will result in a reduction of the plant’s GHG emissions. But even that equipment won’t reduce the RRGP GHG emissions immediately given the time frame for purchase and installation. And purchase of that equipment tells me the PUD plans to operate the RRGP for years to come.
As long as the PUD continues to rely on the RRGP production, the PUD will be forced to look elsewhere to meet the 2030 reduction standards. I understand the Pend Oreille purchase is a possibility. But it’s not clear to what extent that purchase will offset or reduce RRGP production.
The PUD can purchase Renewable Energy Certificates, but those certificates are a trade. While they are available, the PUD should be looking to actually reduce its GHG emissions, not buy someone else’s reductions.
Because the situation is dire, the PUD should set higher goals. One of those goals should be to shut down the RRGP as soon as possible. The CEIP should reflect that goal and specify exactly how and when the PUD plans to accomplish it.
Thank you for allowing me to comment.
Response:
Thank you for submitting your comments on the Clark Public Utilities CEIP. The Clean Energy Transformation Act (CETA) is one of the most aggressive clean energy standards in the country and was drafted based on the scientific consensus that the need to decarbonize electricity generation is indeed urgent. The Clark Public Utilities CEIP lays out a strategy that will achieve the 2030 carbon-neutral mandate ahead of schedule. We agree that it is important to reduce as much emissions as quickly as possible but we also recognize this must be done while ensuring safe, reliable and affordable electricity.
The resource plan within the CEIP calls for ramping down the RRGP production through the installation of the flexibility equipment you referenced. Doing so will allow the utility to materially reduce emissions ahead of the law’s 2030 mandate and also ensures we will not trigger the cost cap or put substantial upward pressure on retail rates. The plan does call for the continued use of the RRGP, but at much lower volumes than historical operations. Historically, the RRGP has served ~35% of Clark Public Utilities customer demand and the CEIP shows the RRGP output will be as low as ~12% of total utility demand by 2029 (see figure 6 in the CEIP). That effort will be countered with new, carbon-free resource procurement, and will result in a much cleaner resource portfolio. Ultimately, by 2045 we will need to completely shut down the RRGP in order to comply with the law.
Thank you again for taking the time to submit your comments, they have been noted and shared with staff.
Submitted 11/29/2021
Comment:
I support the phase out of the RRGP, expanded electrical vehicle programs, more renewable distributed generation such as rooftop solar, expanded community solar such as the one on Padden Parkway, and continued work towards residential and commercial energy efficiency.
Submitted 11/29/2021
Question:
Thanks for all the great work you doing to create a more sustainable energy future for all of us. I have just a few questions/comments in regards to how I as a customer end-user can have a more active role in our clean sustainable energy future.
How can this program support additional customer programs to promote renewable distributed energy resources (particularly rooftop solar and customer/community energy storage), demand response, and load shifting as part the plan. Will the plan also support FERC Order 2222? If not, why not?
As a more customer focused sustainable energy plan, why not include more end-use customer programs that includes rooftop solar and energy storage, EV smart charging at the customer and community level including community microgrids that not only will support supply side goals but also to improve end-use customer service reliability and resiliency? These can be structured to be net neutral or beneficial to both participants and non-participants in terms of costs and benefits.
Thanks for your excellent service.
Response:
Thank you for contacting Clark Public Utilities regarding our draft Clean Energy Implementation Plan (CEIP), we very much appreciate the feedback and questions. And thank you for your patience over the holiday weekend. The CEIP is mandated under the Clean Energy Transformation Act (CETA) law and acts as a four-year plan to guide the utility in meeting the clean energy and equitable transition requirements that exist in CETA. Within the CEIP we identify a variety of different programs that will assist in meeting those CETA mandates, many of which you identified in your comments. There will be a particular focus on continuing our past success with energy conservation and renewable energy programs in this first iteration of the plan. We plan on using the next four years to develop different load management and demand response efforts. FERC order 2222 allows distributed energy aggregators to participate in organized wholesale energy markets; Clark Public Utilities does not operate in an organized wholesale market although efforts are currently under way to develop one in the Pacific NW and the Energy Imbalance Market (EIM) has grown in participation. While our CEIP does not directly reference this FERC order we do work with customers who wish to interconnect large renewable systems and have an avoided cost rate in place to compensate those customers.
As the utility works to phase out carbon emitting generation from our portfolio there will definitely be a need to introduce more end-use programs as you suggest. The Demand Response section of the CEIP references some of those future efforts, like residential thermostat load shifting programs, and we will also consider smart charging programs for our EV owner customers. We look forward to working with our customers in meeting these important goals.
Thanks again for the thoughtful comments and questions. Please feel free to submit additional thoughts and questions if they arise.
Submitted 11/30/2021
Question:
I’ve read the CEIP and have some questions. It’s my understanding I can ask those questions as part of the CEIP comment process.
Is there any way to identify how much of the negative environmental impact to the “highly impacted communities” identified by census tract information is from the RRGP? Or is the impact likely mainly from transportation sources? Has the PUD made any attempt to identify the RRPG environmental health impact to any community?
The CEIP includes a section discussing the PUD contract with the BPA. The CEIP says the current BPA contract expires in 2028. Are any of the PUD’s described actions related to the existing contract? That is, is the PUD trying to renegotiate the existing contract to accomplish the described actions before the existing contract expires in 2028? Or, do the described actions only relate to what the 2028 contract would provide? I can’t tell from the CEIP what BPA contract result is possible in the years 2021-2024 (or pre-2028) and what is only aspirational for future years under the 2028 contract. Because this is included in the long-term plan section, it looks like no change is possible until 2028. Is that correct?
The CEIP statement that Modular Reactors will allow PUD to “displace the RRGP plant more often” seems to indicate the PUD plans to operate the RRGP well past 2030 because the reactors wouldn’t even be operational until 2030 at the earliest. Is that correct?
Thanks for your responses.
Response:
You are certainly welcome to ask any questions you may have, that is indeed part of the public process and we appreciate your thoughtful questions. We have addressed your specific questions below, please let us know if additional clarity is needed.
The “Highly Impacted Community” designation comes from the WA Department of Health (DOH) environmental and health disparity mapping tool and the CETA statute mandates that utilities use the tool when developing targeted programs that aim to reduce the number census tracks that meet the Highly Impacted label. The WA DOH staff developed that tool and took into consideration all the different forms of air pollution in our community. The Department of Ecology has additional information on this topic you may find helpful. It is our understanding that the largest drivers of the Highly Impacted rankings on the DOH map are due to criteria pollutants that mainly derive from the transportation sector. The RRGP does certainly emit some criteria pollutants but the bulk of the emission are carbon based that have less impact on health considerations (versus atmospheric impacts). Clark Public Utilities has gone through environmental impact studies related to the RRGP but did not perform a specific analysis or study to measure the direct impacts on the Highly Impacted Communities in Clark County.
Clark Public Utilities current 20-year Power Sales Contract with BPA does end on 9.30.2028, and you are correct that there is no ability to change the constructs of the existing contract prior to that time. We are, however, currently working with BPA to partially “un- declare” that portion of the RRGP energy declared to serve our firm load that can’t serve load based on the 2030 carbon-neutral standard within CETA. BPA held a public comment period pertaining to our request on 11.30.21, and we anticipate a decision by the BPA Administrator by early Q1 next year. To learn more about this public comment period and to provide comments to BPA please see this web site https://www.bpa.gov/PublicInvolvement/Cal/Pages/IndividualEvent.aspx?item=1386
You are correct that the current resource plan calls for the continued operation of RRGP after 2030, albeit at much lower average 4-year compliance period generation levels. Ultimately, by 2045, RRGP will either have been retired due to the end of its useful life, or it will be running on clean gas or hydrogen.
Submitted 12/2/2021
Question:
Thank you for the development of this report, especially the data-driven aspects of the Clark County Public Utility District’s Clean Energy Implementation Plan. The CEIP plays a critical role in reducing greenhouse gas emissions in Washington and helping the state meet its climate objectives and goals.
The CEIP’s objectives to seek additional clean energy resources through the 2028 BPA contract renegotiation and seek 100 percent electricity delivery from BPA, as well as establishing a PPA with Pend Oreille Public Utility District for the entire output of the Box Canyon Hydroelectric Project are cost-effective and low-risk electricity resouce contracts that make significant gains toward meeting Washington’s Clean Electricity Standard. Further, continued focus on conservation and energy efficiency programs help reduce overall energy consumption, potentially reduce RRGP generation needs, and also have the added benefit of playing a role in reducing electricity energy burden in low-income households. I highly support the CEIP plan in this area.
I am concerned about the lack of utility investment in AMI, which is precursor to so many of the Demand Reponse programs available. As the report states, I would also encourage CCPUD to “evaluate this product further to refine the regional assumptions for program participation, cost, and impacts to see if a DR program using this technology across both seasons could be a cost-effective capacity resource.” AMI is a critical prerequisite for the use of DERs as a generation asset for utilities, so it is essential that CCPUD identify funding for the procurement and deployment of this technology. AMI is a well understood technology that is deployed in about half of U.S. residences, and with housing growth escalating in CCPUD’s service territory, there is an opportunity to get AMI installations in place today, at a lower overall cost to the utility. Further delay in AMI infrastructure investments will hamstring CCPUD’s opportunities to use new technology to achieve clean electricity targets, improve resource adequacy, and take full advantage of a wide distribution of Distributed Energy Resources that customers will be putting in their homes.
The report does not provide sufficient data to indicate investments in the RRGP are the most cost effective and prudent investment for CCPUD ratepayers. The numbers provided seem to support the upgrade in reducing use of the plant when the resources is not cost effective to operate, and it is further notable that the report indicates that in times where additional generation is available the cost to provide the electricity is rarely low enough to be cost competitive, and yet the report flags that the RA needs of the future may make the RRGP’s energy more valuable. It does not, however, flag that any future carbon pricing actions may in the best case scenario force CCPUD’s RRGP to contend with clean power preferences in energy markets lowering the demand for natural gas-produced electricity or in the worst case scenario leading to a stranded utility asset. It is notable, however, that there are some studies indicating the use of natural gas plants will be necessary to maintain RA in the region, but even then it is likely the higher efficiency newer gas plants will not only offer cheaper electricity costs but also less emissions, meaning RRGP may struggle to compete in this market as well.
There is no comparison of the costs to upgrade the RRGP with other options, nor is the overall costs associated with this investment listed or any discussion on debt and debt repayment timelines. Meanwhile, the availability of low-cost renewables continues to grow and battery storage costs are dropping as well. The use of DERs as described above may also provide sufficient resources to offset use of the RRGP. In addition, no discussion is presented on participation in other energy markets such as the California Independent System Operator’s Energy Imbalance Market or discussions that are occurring among western states to establish a day-ahead market. Participation in such markets may provide the necessary resources to reduce the need to operate the RRGP during more times of the year. The appearance of the options listed here indicate a preference toward cementing the use of the RRGP for the next 25 years, rather than providing a good faith cost effectiveness discussion of all potential options. I am not advocating for the unilateral shuttering of the plant, but rather a more robust assessment of all potential scenarios to better understand all the options available when considering the use of ratepayer funds. There is insufficient information to make this call based on the information provided in this report.
I am concerned about CCPUD’s non-binding intent to develop SMR resources by 2030. While I am intrigued by the technology and believe their may be a place for such resources in a clean electricity resource mix, the information so far leaves much uncertainty. Most notably, a year ago 8 of 36 utilities backed out of an agreement to procure SMRs through the Utah Associated Municipal Power Systems’ SMR development in Idaho. Further, the project, while still proceeding, is behind schedule and over budget. More testing, information, and data is required before CCPUD should enter into any formalized agreement on an SMR generation asset. And although nuclear fuel use and recycling is much more efficient than previous nuclear generation facilities, it must still be disposed of eventually, and there is currently no official federally mandated fuel disposal sight in the U.S., nor is one expected anytime in the near future. I highly recommend CCPUD have a contingency plan for additional zero-emitting resources in the event that SMRs do not prove cost effective, safe, or practical.
I very much appreciate CCPUDs reference to resource adequacy and the vital role a utility plays in ensuring generation resource assets are adequately planned for and available when we need them. I do not, however, see an assessment of the impacts of climate change-induced extreme weather events on load forecasts or changes to the availability of water in the hydropower system, and the effects this might have on the CEIP plan. These changes have strong implications for how often the RRGP may need to be operated or whether the additional Box Canyon hydro procurements will be as robust as this plan forecasts. The need to operate the RRGP more often could mean the difference between meeting the 80% target or not in 2030. I encourage additional analysis of forecasted climate impacts through work from the Northwest Power Council and others to ensure CCPUD is assessing RA appropriately for a rapidly changing system and environment.
I commend CCPUD for its outreach and efforts to get input from low-income communities and representatives to inform this report. It is essential that these voices are supported by providing opportunities to be heard as well as providing resources to help individuals better understand the trade-offs in the energy choices made by the CCPUD and its board. I would point out that this CEIP was not easily found, nor prominently displayed on the web-site. I found it particularly cumbersome when I landed on a CCPUD webpage (from a CCPUD newsletter no less) that instructed me to “type Clean Electricity Transition Plan” into the search bar on the CCPID webpage rather than provide a simple hyperlink in the spot where the CEIP was first mentioned. Further, there were no links or resources provided in the report to help interested parties find information that would help them better understand how different pieces of the plan will help CCPUD meet its goals while maintaining reliable and affordable power. For example, the RRGP upgrade will enable the plant to operate at a baseload of 95 MW, which is less than current baseload – but how much is current baseload? I went searching for that answer, but didn’t readily find it, although I suspect it is located somewhere in your latest IRP. Nevertheless, I still do not know how much of a reductiont that is off of currentl baseload power, so I have no frame of reference to really understand the energy savings. I am certain the CCPUD wants to enable all their customers to have a robust understanding of the challenges the utility faces and the options it has to face those challenges, and I encourage CCPUD to add more transparency to their work and provide foundational resources that are easy to locate for customers who want to know more.
One final thought – while this was not specifically addressed in the report – transportation energy burden. While not traditionally an electric utility concern, the rapid uptake of EVs is transforming all electric utilities into transportation fuel providers. Many Washingtonians suffer from different types of energy burden, including transportation energy burden. Where EV owners are able to charge at home using the relatively stable, low cost electricity provided by CCPUD, transportation fuel costs are as little as a fourth that of gasoline. Significantly lower maintenance costs also make EVs much less costly to drive, not to mention direct improvements in local air quality. I highly support the EV programs CCPUD has already established, but encourage more, especially in the case of supporting workplace charging and medium- and heavy-duty charging infrastructure needs.
Thank you for the opportunity to provide comment. Congratulations on achieving this milestone.
Response:
Thank you very much for submitting your detailed comments, suggestions and questions. We very much value our customer’s inputs and appreciate you taking the time to develop a thorough comment letter. Below you will find additional information and answers to your questions; we’ve drafted this response in sections that tie to your comments. Please feel free to respond if additional clarity is required.
AMI Deployment and Demand Response:
We agree that AMI deployment is required to realize the full opportunity of DERs in our service territory and certainly opens the door to broad DR program development. At our next public Board of Commissioners meeting, next Tuesday at 9:00am, our team will be presenting the final versions of our Conservation Potential Assessment (CPA) and Demand Response Potential Assessment (DRPA) for Board approval. During that presentation we will have a chance to review the cost effective DR opportunities as identified in the DRPA and staff will note that AMI deployment is required to implement residential sector DR programs. Ultimately, the decision to invest in AMI will be up to our Board of Commissioners and staff will ensure they understand the many benefits that come with implementing AMI. Additionally, the utility intends to further explore DR program opportunities that may exist without AMI deployment; one strategy we’ve been considering is using our Home Energy Report program that involves 40,000 residential households as a platform to introduce time-of-use load management programs along with the existing energy conservation tips and strategies.
RRGP Investments, Resource Adequacy and Resource Comparisons:
The CEIP does not include the detailed analysis that staff performed before recommending the RRGP flexibility upgrades, primarily because the CEIP is to act as a four-year roadmap that the utility will use to meet its CETA mandates. That said, staff did consider a variety of resource options, analyzing each resource’s key attributes including capacity, capacity factor, costs, and return-on-investment (ROI), prior to recommending the RRGP upgrades. Our research found that the RRGP upgrades were clearly the most cost effective path to reduce GHG emissions and meet the CETA mandates. The flexibility upgrades have a simple ROI of 3.5 years and the upgrades can be completed in a relatively short timeframe, approximately 18 months. An attribute-for-attribute analysis found that no other options could meet all the attributes provided by the RRGP upgrade. A carbon-free capacity analysis considered hydro, stand-alone batteries, stand-alone solar and solar plus batteries and found none of those carbon-free options could provide the capacity value that the RRGP upgrades will provide. Solar plus batteries came close to the RRGP upgrade from a carbon-free capacity perspective but the costs were, by comparison, extremely high and the ROI was beyond the asset lifespan. Lastly, staff looked for other options that would result in lowering GHG emissions in an amount equal to the RRGP upgrade and found the other options were not feasible or cost-effective.
Resource adequacy standards are still under development in the region through the Western Resource Adequacy Program. Clark PUD will be participating in the first, non-binding phase of the program beginning in 2022. Over the next year, Clark PUD will evaluate whether or not it will participate in the next phase of the WRAP. As a west-side resource RRGP will continue to provide valuable capacity in the region while reducing transmission congestion. With a heat rate less than 7,000 Btu/kWh when operating at maximum capacity, it is anticipated that RRGP will be a competitive resource in the near future. This CEIP covers the four-year period 2022 through 2025. Much more will be known about the WRAP and Clark PUD and RRGP’s roles therein when the 2nd CEIP, which will cover the four-year period 2026-29, is developed.
Small Modular Reactors:
Your concerns are appreciated and noted. Nuclear is included in CETA as a “non-emitting” resource. Under CETA, non-emitting and renewable resources, such as wind and solar, are the two options available to get to 100 percent clean energy. Our IRP and CEIP must look at all available technologies. We intentionally included “non-binding” in this section of the CEIP because our Board of Commissioners have not yet made a final decision on participation and staff realizes there is much due diligence left to complete. Our team is aware of the challenges the technology has faced in the past and we’ll continue to closely monitor the technology as it further develops. We appreciate your recommendation for a contingency plan and will consider adding one to the CEIP.
Community Outreach and Accessibility:
Thank you for highlighting some of the website navigation challenges you experienced. We appreciate the feedback on access to planning materials on the website and are continuing to work on making the user experience better, navigation to these resources easier and additional resources readily available online. You can expect ongoing improvement in this area and your comments help us as we determine those priorities. Our team is working hard to ensure the transition to the clean energy economy is equitable and all customers have an opportunity to participate in our programs. Next year our Energy Services team will be working on designing targeted energy conservation programs that aim to reduce the number of energy burdened customers in Clark County; we’re eager to start this important and impactful work. In your comments you asked what our existing baseload is; our average load is slightly above 500 MW, depending on the year, and our one-in-ten winter peak demand exceeds 1,100 MW. A few months ago during the “heat dome” we experienced an all-time high summer peak of over 1,000 MW; additional detail can be found in the most recent IRP that is hosted on our public website.
Transportation Sector:
Thank for the thoughtful comments related to transportation electrification and transportation energy burden. While these topics are not specifically addressed in the CEIP they are topics important to Clark Public Utilities. In March of this year our Board of Commissioners adopted our first Transportation Electrification Plan (TE Plan) and that formal step allowed the utility to develop and begin offering electric vehicle (EV) related incentives. Our team was proud to introduce a variety of programs in April and we’ve realized much success since that launch. We introduced a “Used EV Rebate” of either $2,000 or $1,000 for income qualified customers and also introduced an EV grant program for local government agencies that aims to increase the amount of publically available EV chargers in Clark County. We look forward to building on these efforts in the future.
In closing, we’d again like to thank you for the very thoughtful comment letter and your congratulations on achieving this milestone. We look forward to collaborating with our customers in the future as we work to meet the CETA mandates.
Submitted 12/2/2021
Comment:
Thank you Clark PUD for putting this front and center and encouraging comments. We live in a global community, we’re affected by acid rain, pollution from China, and fires burning 1000 miles away. But we can still impact the Pacific Northwest by actions we take now. We can’t throw up our hands and say it’s out of our hands, we have an obligation to generations to come to be responsible stewards of this Earth. This obligation includes all the living things and beings on this planet and morally, ethically and economically transcends any jobs vs. environment issues.
And we must do this as soon as practicable. As soon as possible sounds better but let’s be practical about this. Do we want to spend the enormous budget busting costs of implementing nuclear power plants. Ostensibly this form of energy seems “clean” but at its root it rivals and exceeds coal in the degradation of resources, the carbon emissions in mining, transporting and construction, and it is not by any stretch a quick enough available energy source. Build outs take a decade or longer! That much is documented worldwide.
And dollars spent chasing that “carbon free” energy source are diverted from existing technologies that utilize renewable sources.
There’s no penny wise pound foolish label for nuclear energy, it’s pound foolish and an health affront to all who pay the price for their proximity.
Years from now you will be asked, by your children or grandchildren, to answer this one question when you tell them you had it in your power to make policy. “Mom, what did you do when you knew?”
Submitted 12/2/2021
Comment:
I am writing regarding the draft Clean Energy Transformation Act (CETA). I am in support of a transition to 100% clean energy and support the phasing out the River Road gas plant (RRGP). By conserving energy beyond what the PUD is currently proposing, committing to local renewable energy sources, and exploring all possible cost effective alternatives to RRGP, we can and must achieve 100% clean energy. This accomplishment can be done by further reducing the peak demand with measures to offset this demand. I realize this comes at a price but the long term impact to our health and environment is of greater significance than the benefit of the continued operation of the RRGP. The RRGP is located near communities of color, thus exacerbating health disparities such as asthma. As a long term sufferer of asthma, I can testify regarding the chronic problems air quality has had on my own health. I do recall having spend an entire night coughing and wheezing until finally I was able to seek medical care.
Among my other concerns is the PUD’s long term consideration of using nuclear power in the form of Small Modular Nuclear Reactors (SMNR’s). I consider this risky technology as having tremendous economic and social difficulties and not meeting our immediate clean energy needs.
I am ever grateful for the diligent work of the PUD and of the willingness to listen to members of the public on this important issue. In finding solutions, I urge you to consider the health and environmental aspects of this decision rather than just the economic value.
Response:
Thank you very much for your comments and suggestions related the to the CEIP. We agree there are a variety of programs and strategies that will assist in meeting CETA mandates. Clark Public Utilities has a long and successful history of exceeding our energy conservation goals and we look forward to continuing that trend into the future. We also agree a focus on peak demand reduction will be crucial in meeting our goals. Regarding the health issues you identified, our CEIP calls for broad use of the WA Department of Health environmental disparity mapping tool to ensure we are identifying the highly impacted communities and designing targeted programs that can provide the most benefit to those customers in the most need. Additionally, we have contracted a vendor who developed a customer demographic dashboard that will allow staff to further segment customers on a variety of characteristics.
Regarding small modular reactors and nuclear resources, your concerns are noted. Nuclear is included in CETA as a “non-emitting” resource. Under CETA, non-emitting and renewable resources, such as wind, solar and hydro, are the two options available to get to 100 percent clean energy. Our IRP and CEIP must look at all available technologies. We intentionally included “non-binding” in this section of the CEIP because our Board of Commissioners have not yet made a final decision on participation and staff realizes there is much due diligence left to complete. Our team is aware of the challenges the technology has faced in the past and we’ll continue to closely monitor the technology as it further develops.
Submitted 12/2/2021
Comment:
Dear Commissioners:
We support the general goals of the CEIP.
In particular, we support wind, tide and solar energy projects. We already have solar panels in the PUD solar program and would purchase more if available.
However, we do not support Small Modular Reactors for nuclear energy. The use of fossil fuels to mine and transport the fissionable nuclear fuel is a bad idea and makes the process expensive. The storage of spent fuel, which will last for thousands of years to even reach the half life level, will burden future generations, who will not forgive us.
Thank You.
Submitted 12/2/2021
Comment:
DEAR SIR December 2 2021
I saw in your bill flier about “The clean energy implementation plan” and I have some questions.
Seeing as how the whole US power grid has only about two percent wind and solar energy as of this writing, if the state is unable to meet its goal will customers see brown outs or black outs and or higher energy bills to compensate for the lack of clean energy? Like in California?
Perhaps you were not, but I was around for Washington state corrupt criminal boondoggle of WPPSS (WHOOPS) that cost us rate payers billions because of Washington states criminal incompetence.
What safe guards are there in this bill that will protect us rate payers against criminal politicians and judicial corruption?
Response:
Thank you for taking the time to submit your comment around the draft Clean Energy Implementation Plan. It’s been received and shared with staff.
The Clean Energy Transformation Act (CETA) lays out multiple mandates that Washington utilities, including Clark Public Utilities, must meet. As with all applicable laws, we will comply. As a public utility, we have a core focus of providing reliable, at-cost power to our customers while providing excellent customer service. While complying with legislative mandates this will still remain at our core.
You can find further information about the details, safeguards, equitable distribution of clean energy benefits, etc. of CETA, on the Department of Commerce’s website here: https://www.commerce.wa.gov/growing-the-economy/energy/ceta/.
Submitted 12/3/2021
Comment:
Please, bring citizens the cleanest energy possible as quickly as possible.
I have always appreciated Clark Public Utilities and expect the best service for them, from caring about people who have trouble paying bills to picking up old refrigerators when we buy a new one.
We need the cleanest plan available in line with your caring service.
Submitted 12/3/2021
Comment:
I very strongly support the CEIP. It’s critical that this be implemented as soon as possible. Greenhouse gas emissions are killing our planet, and there is no planet B.
Submitted 12/3/2021
Comment:
On page 6 of the draft CEIP it states: “Most of the DR measures included in the DRPA typically require Advanced Metering Infrastructure (AMI) which Clark Public Utilities has yet to deploy.” Page 7 notes: “Because the cost-effective DR programs require AMI and Clark Public Utilities does not have AMI, total demand response over the four-year period 2022-25 is projected to be 0 MW . I am concerned that Clark PUD is not recognizing the potential that AMI and DR have in the pursuit of both clean energy compliance efforts, but also staying even, if not ahead of what customers are looking for in smart and forward-thinking service that will lead to even greater customer satisfaction ratings. It is clear to me, and should be to staff and Commissioners, that AMI and DR measures will be essential to Clark PUD’s viability in delivering up-to-date service going forward, and any delay in deployment is “penny wise and pound foolish” from the perspective of those of us who support our PUD to be decisive on our behalf when it comes to deploying smart grid technology . My understanding is that AMI provides more information to allow we, the customers, to manage consumption, cost, and other decisions about service and usage. It provides higher reliability, more accurate billing, and better quality of water delivery, while keeping utility costs (water and electricity) at reasonable levels. I would like to see the CEIP include deploying both AMI and DR measures ASAP, as part of Clark PUD’s emphasis on exemplary customer service. It is a waste of time and resources to consider half measures, as suggested in the draft: “one strategy we’ve been considering is using our Home Energy Report program that involves 40,000 residential households as a platform to introduce time-of-use load management programs along with the existing energy conservation tips and strategies.” The half measures are certainly important, but why settle for half a loaf when a full loaf will get is to what customers are clearly asking of our PUD: “Get us cleaner, faster.”
Response:
Thank you very much for your comments and suggestions related the to the CEIP.
We agree that AMI will be an important tool to meet future CETA mandates and will bring a variety of benefits to both the utility and our customers. Staff will continue analyzing the costs and benefits of AMI deployment; ultimately the decision will be made by the Board of Commissioners.
We are hopeful that voluntary, or informal, Demand Response programs that can be deployed without AMI will present an opportunity to introduce the concept of load shifting to a broad group of our customers. Doing so will also provide valuable learning experiences for our team at the utility. Your comments have been noted and shared with the team, thanks again for taking the time to submit them.
Submitted 12/3/2021
Comment:
On page 6 of the draft CEIP it states: “Most of the DR measures included in the DRPA typically require Advanced Metering Infrastructure (AMI) which Clark Public Utilities has yet to deploy.” Page 7 notes: “Because the cost-effective DR programs require AMI and Clark Public Utilities does not have AMI, total demand response over the four-year period 2022-25 is projected to be 0 MW . I am concerned that Clark PUD is not recognizing the potential that AMI and DR have in the pursuit of both clean energy compliance efforts, but also staying even, if not ahead of what customers are looking for in smart and forward-thinking service that will lead to even greater customer satisfaction ratings. It is clear to me, and should be to staff and Commissioners, that AMI and DR measures will be essential to Clark PUD’s viability in delivering up-to-date service going forward, and any delay in deployment is “penny wise and pound foolish” from the perspective of those of us who support our PUD to be decisive on our behalf when it comes to deploying smart grid technology . My understanding is that AMI provides more information to allow we, the customers, to manage consumption, cost, and other decisions about service and usage. It provides higher reliability, more accurate billing, and better quality of water delivery, while keeping utility costs (water and electricity) at reasonable levels. I would like to see the CEIP include deploying both AMI and DR measures ASAP, as part of Clark PUD’s emphasis on exemplary customer service. It is a waste of time and resources to consider half measures, as suggested in the draft: “one strategy we’ve been considering is using our Home Energy Report program that involves 40,000 residential households as a platform to introduce time-of-use load management programs along with the existing energy conservation tips and strategies.” The half measures are certainly important, but why settle for half a loaf when a full loaf will get is to what customers are clearly asking of our PUD: “Get us cleaner, faster.”
Response:
We agree that AMI will be an important tool to meet future CETA mandates and will bring a variety of benefits to both the utility and our customers. Staff will continue analyzing the costs and benefits of AMI deployment; ultimately the decision will be made by the Board of Commissioners.
We are hopeful that voluntary, or informal, Demand Response programs that can be deployed without AMI will present an opportunity to introduce the concept of load shifting to a broad group of our customers. Doing so will also provide valuable learning experiences for our team at the utility. Your comments have been noted and shared with the team, thanks again for taking the time to submit them.
Submitted 12/3/2021
Comment:
To PUD staff:
My husband and I want to support the transition to 100% clean energy by urging our PUD to:
1. Increase conservation and energy efficiency
2. Commit to phasing out the use of gas quickly
3. We do not support renewable energy credits. They are a shell game that does not actually do anything to solve this enormous problem.
4. We are deeply disturbed by the news that PUD is considering the use of nuclear power. Please remove this from the portfolio entirely until such time that more data and research is available on this technology. This is not something we want to be an early adopter for.
5. We would like to see more incentives that allow Clark County residents to lease land for solar and wind projects. I know there are many facets of this that we do not understand, but it seems to me there are likely many residents who would welcome the opportunity to be part of the solution if given the chance.
Thank you for taking the time to read and consider my comments. Have a happy holiday season.
Submitted 12/3/2021
Comment:
Thank you for encouraging customer input on a very important issue and for the thoughtful outline of the CEIP. In regards to the use of the RRGP I would encourage Clark Public Utilities to follow the science and to keep in the forefront of the decision making process that every minute carbon emissions are being released into the atmosphere, we are getting closer to the point at which global warming will have irreversible effects on our planet and all species residing on it. The consequences of ignoring the science were predicted decades ago and through lobbying efforts by the oil and gas industry, the science has largely been ignored by those decision makers that were able to do something about it. By most scientific estimates we need to make drastic cuts in our emissions by 2030 in order to avoid the most dire consequences of global warming. With this in mind, please do all that is possible to take the RRGP off-line as soon as possible. Thank you.
Submitted 12/3/2021
Comment:
Please close your River Rd plant ASAP. I believe that this plant is in use primarily in the dry months, when the Columbia River doesn’t have enough flow to supply our electricity. These dry, summer months have the most potential to generate solar power. Think of the heat dome of this past summer. Wouldn’t it be great to cover many of our dark surfaces with solar panels to reduce heat islands AND generate electricity? We could have rows of solar-covered parking at schools, malls, and schools. The buildings in these same areas could be covered in solar panels. I really see this as solving two problems at once. Many people seek the shade of a meager, lonely tree in a parking lot. We can create multitudes of covered parking spaces while generating electricity.
Reducing fossil fuels, especially methane, is the only way to quickly bring our greenhouse gas emissions under control. You need to do this more rapidly than you can even fathom. If we don’t get on this ASAP, it will lead to more and costlier problems down the road.
Submitted 12/3/2021
Comment:
I want to support the transition to 100% clean energy by urging our PUD to:
*Increase conservation and energy efficiency measures beyond what the PUD is currently doing
*Reduce peak demand with demand response measures
*Focus primarily on the transition to new renewable energy sources in a timely way, with a greater commitment to using local renewable energy sources, conservation and energy efficiency to make our system more reliable and resilient.
*Commit to ending our reliance on gas by phasing out the River Road gas plant (RRGP) even earlier than CETA requires (to reduce local pollution in areas most affected, and help Vancouver meet it’s GHG emission reduction goals.)
*Explore and thoroughly analyze all possible cost effective alternatives to continuing to operate RRGP, in order to get us to 100% clean energy without reliance on REC (Renewable Energy Credits) offsets, faster.
*Consider the adverse public health and environmental impacts that disproportionately burden community members in affected locations by continuing to operate the RRGP indefinitely.
In addition, it is a concern that our PUD is considering (in it’s longer range planning) nuclear power in the form of Small Modular Nuclear Reactors (SMNR’s), an emerging risky technology that has significant economic hurdles and delays that do not make it a viable option this decade. This is a distraction for staff who who can better serve planning for customer needs by focusing on more readily deployable and cost effective alternatives this decade.
I know our PUD values customer service and we can thank them for what they are already doing while urging them to do more in the spirit of being a public utility that listens to it’s customers and wants us to have not just affordable and reliable but also healthier and environmentally responsible energy going into the future.
Submitted 12/3/2021
Comment:
To be blunt our children and grandchildren are going to deal with some major impacts of climate change if we do not act fast like this was a crisis, is a crisis. Yes there’s a small number of people that are speaking up about how fast we need to act but it’s because we’ve done the research. Learning anything is hard, learning that the human race can no longer be is hard but I don’t know how else to say it respectfully and kindly and urgently that I need to save my son’s future and you all hold the key, please take this crisis seriously and act. I know my fellow activist friends are so intelligent and they have spoken of great ideas how we can reach our goals. Please think of the planet first. Please think of the planet first.
Submitted 12/3/2021
Comment:
It’s important to move towards the use of 100% clean energy as fast as possible, even exceeding the Clean Energy Transformation Act requirements. It’s beneficial to all of us that the River Road gas plant closes asap, for you to work towards being able to generate more solar energy in the summer months (which is probably when that plant is most used), and to add more power generation from wind.
Submitted 12/3/2021
Comment:
I am a member of a “highly impacted community” with more than 6% of my household income going to energy costs. I live in a neighborhood with air pollution from two highways and both airports. I support prioritizing energy conservation as the lowest hanging fruit. For many of your customers, myself included, getting help weatherizing my rented house has been very difficult even though the property owner is supportive. My experience so far was to be directed to lists of resources and service providers that are out-of-date and inaccurate. Programs like LIHEAP need to be scaled up to serve more people, more effectively. The income requirements should be adjusted so people who aren’t destitute, but still cannot afford the cost of weatherizing a house, are served. The PUD should take the lead in coordinating energy assessments and getting energy conservation projects completed by well-vetted service providers and contractors.
Also, many new buildings in Vancouver and Clark County including the new Vancouver School District buildings were designed to be “solar ready.” Installing solar on those buildings should be another one of the PUDs priorities. Having on-site solar power and batterie storage distributed through neighborhoods is a matter of public safety in case of disaster.
Regarding the use of nuclear power; until Hanford and all other leaking nuclear waste storage locations are solved, I urge that no new nuclear facilities of any kind be built.
Thank you for the amazing job you do providing reliable power. I rely on the Clark PUD to move as rapidly as possible to 100% clean renewable energy. I will continue working to reduce my personal and household overall energy use by 50% this decade and to eliminate my use of fossil fuels completely by 2025. I hope Clark PUD will help me in this effort.
Submitted 12/3/2021
Comment:
In a response to a customer’s question/feedback, staff wrote:
“The RRGP does certainly emit some criteria pollutants but the bulk of the emission are carbon based that have less impact on health considerations (versus atmospheric impacts). Clark Public Utilities has gone through environmental impact studies related to the RRGP but did not perform a specific analysis or study to measure the direct impacts on the Highly Impacted Communities in Clark County.”
Given that criteria pollutants such as particulate matter (PM2.5) and nitrogen dioxide (NO2) do contribute to the significant health disparities noted in the RRGP’s location and this is an environmental justice issue, I would like to see a specific analysis or study to measure the direct impacts of continuing to operate RRGP even if transitioned to a flex plant, versus other alternatives. In a study of peaker plants it was noted that: Peaker plants disproportionately emit health-damaging air pollutants – mainly ozone forming chemicals like nitrogen oxides (NOx) and harmful particulates – that contribute to poor local air quality and harm public health in these vulnerable frontline communities. It was also noted that: “It has been proven by rapidly advancing market forces, with utilities increasingly choosing to procure peaking capacity from batteries powered by renewable generation over traditional peakers based on both cost and operational ability. Moreover, replacement is not only an economic or emissions reduction opportunity. Retiring or reducing reliance on these plants could be a major win for environmental justice.”
Submitted 12/3/2021
Comment:
Regarding
“Upgrade River Road Generating Project by Investing in Flexibility Product: With the expected buildout of tens of thousands of megawatt-hours of solar and wind projects in the west over the next few years, these intermittent resources will not always match load profiles”
EFSEC has said that the seismic risks at Terminal 5, cannot be mitigated. Will you make a SEPA Determination of Significance and follow up with a thorough EIS?
You should discuss other options in terms of speed of deployment, and cost.
Your flexibility project does not consider other other options such as storage projects and Virtual Power Plants, nor the long-term benefit and viability of other options. Did you give them serious consideration?
The NPCC failed to place a value on reliability in terms of DER, eg after a major seismic event. Did you?
Seismic standards when your RiverRoad Gas Plant was build are no longer considered acceptable in terms of a major subduction zone event. The last one was in the year 1700 and was greater than any seismic event in history in California. Your power plant is in a subduction zone, and in a Tsumani zone, above a possible epicenter along a line from the Tank Farms in Portland to Kalama, according to a Geology Professor Emeritus who spoke at McMenemins in Kalama about 2-3 years.
Please consider other options such as storage and Virtual Power Plants:
Hydrostor plans 4 GWh long-duration storage project in Southern California
Published Dec. 2, 2021
Dive Brief:
- Energy storage developer Hydrostor on Wednesday filed an application with the California Energy Commission through a subsidiary to develop a 500 MW, 4,000 MWh storage facility in Southern California.
- Another project, called the Gem Energy Storage Center, will use compressed air energy storage technology and is expected to have a capital investment of $975 million. The developer expects to bring it online as early as 2026.
- The planned project “is very well suited to service the greater Los Angeles Basin and Southern California in general,” Curt Hildebrand, Hydrostor’s senior vice president of commercial affairs, said. While no announcements about future storage projects are imminent in California, “we do have active development activities underway to assess additional siting opportunities,” he added.
Virtual Power Plants:
Shell has purchased sonnen which creates Virtual Power Plants which are like electronic trading systems arranging the buying and selling of energy from 1000s of rooftop solar and battery systems based on terms established by each owner of solar panels and/or batteries.
In January of this year, Utah utility Rocky Mountain Power launched WattSmart Batteries, a new battery energy storage retrofit program for its 50,000 customers with existing on-site solar arrays. The program– with an eventual goal of aggregating 100 megawatts (MW) of dispatchable energy storage – offers payments to solar customers who add a battery system and allow the utility to control it, per contract terms. Payments include an upfront enrollment incentive of $600 per kilowatt (kW) for a four-year commitment, plus a participation incentive of $15 per kW per year. The customer thus gets a subsidized battery which is designed to provide back-up power in the event of an outage. The utility always leaves some energy in the battery for back-up,
This type of coordinated distributed energy resource (DER) program offers enormous potential to utilities driving towards carbon reduction goals while coping with increasing levels of variable renewable energy resources on their systems. Variants of WattSmart Batteries are likely to be broadly replicated both in the U.S., and globally.
Building on the Soleil Lofts experience: WattSmart Batteries follows on the heels of the successful Soleil Lofts project. This undertaking that was launched just over two years ago was a joint effort between real estate developer The Wasatch Group, energy storage company sonnen (a subsidiary of Shell) and Rocky Mountain Power. The Soleil Lofts apartment complex was furnished with solar arrays and 600 high-end sonnen ecoLinx batteries, resulting in a 5 MW and 12.6 megawatt hour (MWh) virtual power plant controlled by specially designed sonnen software integrated into Rocky Mountain Power’s control room systems. Based on the success of that endeavor, and the optionality created by the existing software and program design, the next logical step was to expand the effort.
Creating the grid of the future takes work and coordination: In an interview, Blake Richetta – Chairman and CEO of sonnen, Inc. commented that this new retrofit program represented the culmination of “years of work and tons of talk.” He expressed a general frustration with the pace of change in other utility service territories, noting “The grid of the future is supposed to be more responsive, and digitalized, but to date it’s been mostly half measures.” Other dispatchable virtual power plants have been announced, he asserted, but none have yet been developed in which the utility is currently controlling the on-site batteries on a daily basis.
And Tesla VPPs
Tesla launched such an initiative in Australia in partnership with the local government in an attempt to reduce electricity rates.
In the US, several companies, like Swell, have used Tesla Powerwall battery packs to build their own virtual power plants and offer grid services to electric utilities.
Now, Tesla is launching its own virtual power plant in California and Texas to help the state’s grid:
Also consider gravity storage projects other than pumped hydro on land considered sacred to the Yakama Nation. For example:
Regarding:
“ CETA requires carbon-free resources be either renewable, such as hydro, solar and wind or non-emitting, such as nuclear. In 2021 Clark Public Utilities signed a non-binding letter of intent with a Small Modular Reactor (SMR) developer and has been exploring the potential to add generation from SMRs to its resource portfolio beginning in 2030.”
Also consider signing letter of intent with a utility scale solar developer, particularly in Clark County. The cost of utility scale solar has fallen 12% in the last year. One good location might be the covered landfill in the middle of the county about 1 mile from your Operations Center.
Regarding
Your Conservation Potential Assessment.
Do you have a program to promote control systems in Commercial Properties particularly for perimeter lights?
Could you accelerate your heatpump water and space heating efforts in the mobile home community.
Could you evaluate the potential of District Energy for ground source heatpumps systems for new and existing commercial developments?
Regarding
Clark Public Utilities’ 2021 CPA shows cost-effective 2-year (2022-23) energy savings of 9.37 aMW, 4-year savings of 17.91 aMW, 10-year savings of 50.07 aMW and 20-year savings of 92.20 aMW. Clark Public Utilities will endeavor to meet or exceed the targets included in the 2021 CPA.
Does cost include the cost of extracting from the air the pollution your power plant generates both onsite, and from the upstream methane leaks from compressor stations, and from the pipeline gathering area, and from the gas wells that will be abandoned?
Regarding
BPA Power: Clark Public Utilities is purchasing all BPA Tier 1 power made available to us under the current BPA power contract that expires September 30, 2028 and is taking steps necessary to purchase all power made available under the next BPA contract that begins October 1, 2028.
The dams are aging and will need repairs. The Yakama nation would like to replace the existing dams on the lower Columbia with other renewables as soon as possible, and the Tribes near the Snake would like the lower SRDs removed immediately.
The repairs will drive up the BPA costs, and prolong their life, instead of restoring salmon resources for the treaty tribes.
I suggest a more aggressive conservation effort and more investments in solar in Clark County instead of relying on the hydro system.
Regarding
River Road Generating Plant Operations: “base load generation”
There are other ways to deal with the issue of baseload, such as
The deep-well geothermal system being piloted in Alberta Canada, by Eaver.
and
- VPP
- Other forms of storage, eg compressed air, and batteries
- And Demand Response
Regarding:
Renewable Distributed Generation: Clark Public Utilities currently operates 319 kW of installed community solar sited within the county.
Consider building the equivalent of 300 similar solar projects within the next five years. The Port of CW is interested, and I believe the POV is also.
According to the NWPCC, we need 3,500 Mw of new renewables regionally in five years. Lets do our part, which would be 300 similarsolar projects based on our population in proportion to the 4 state region.
Regarding
Electric Vehicle Programs:
Consider giving incentives for superusers of fossil fuels, such as contractors that drive a lot and cannot afford an electric truck. The incentive would vary depending on their average consumption over the last few years. https://secure-web.cisco.com/1P551U0veIZHmTiVKLK3J4-HwDZkk_RzBWHTFTeyyUq–71HIIpSKqv0xjs-Y4B4U_772uQMpmkpflrhbj4TnnzvRMfuThggL9g7BXoWoZ_jd_eGbYtq4V5RPmWlk74MkuIXsA1nqAx6z_pb8eVMnQKBTmDakL0NCPIPi3OBcuEBd5hymRMtvvTwoQ6qDwqLSPkYv4IJOZivliYoMCkGA4aXapaDv0KwFt_1F6eUc-GwGIv6gDP5T4kwA1wrnX5qGrLZioIhKqx5pkU–yk7znDaV-BMyc2UfsCdOHY4uV-Gw-sEiHuNKfxcu8ti5JUjicDySzjJe3pDF_jQk2fKhZQMT5CdtpPnWtu29oKiG3FuFRCp-jgBp4Cl4v15jxEyCC4kLrsIqBzjeDC47wup3QiLk-wYKagffbzPM328L1L2X12Px-YBGK2D129FOioM2Ijp1HJaBFXacXc2bT4Zqv0ciyho1lBJTY1eUTPP44HnMSolt1GJn1kzw-ewqwyul/https%3A%2F%2Fwww.coltura.org%2Fgasoline-superusers
Please know that I recognize your industry is the most complicated and that you may be understaffed to comply with all the regulations.
Thanks for all you do.
Response:
To address some of your comments more specifically, here’s some further information from the team. Headers are included to help identify the topic being addressed more easily.
Oil Tank at RRGP Site:
Despite the original intention, the large holding tank at the RRGP site has never actually contained oil. Clark Public Utilities currently uses the tank to store a spare set of air filters for the RRGP. With the recent wild fires, and associated smoke that we have realized locally over the last few years, the utility made a decision to procure and hold onsite a spare set of air filters for the plant turbine. Doing so ensures we can maintain reliability and power supply during the summer heat domes that strongly correlate with poor air quality due to wild fires. This strategy increases local resiliency during the times when power is in the most demand due to air conditioning needs. Additionally, there are no future plans to store any fossil fuels in the storage tank.
Conservation & CPA:
The Clark Public Utilities Commercial Lighting Incentive Program (CLIP) provides incentives for the installation of efficient lighting and control system. This program is long-standing and has a history of robust participation in the commercial sector. The majority of residential conservation programs are available to mobile and manufactured home customers and we have had historical success targeting those customer subgroups for free smart thermostats. Heat pump water heaters (HPWH) are a challenging measure for manufactured homes because the water heaters tend to be located in water heater closets that cannot physically fit a large HPWH.
The CPA does not include any CO2 emission mitigation efforts as your questions describe. The CPA identifies cost-effective energy conservation opportunities for the residential, commercial and industrial sectors. The avoided cost of energy used in the calculation of cost-effective conservation measures includes the social cost of carbon.
Community Solar:
Clark Public Utilities staff is currently analyzing the potential for a future community solar project. Additional community solar may make sense but for any large scale solar deployments, greater than 1 MW, it will be more advantageous to site the potential project in the east side of the state where capacity factors for solar are nearly twice as large as Clark County sited solar systems.
Ground Source Heat Pumps in Commercial Buildings:
Clark Public Utilities would potentially offer incentives for any commercial building employing a ground source heat pump system. There is not currently a prescriptive incentive available, so the project would receive incentives through a custom project program. We would offer incentives for retrofits and new construction projects in the following manner:
New Construction:
Following construction and system commissioning, we would monitor the metered consumption of the building and model it against a building of the same size operating with Washington State Energy Code minimum equipment. Clark Public Utilities would model the weather normalized consumption of the building against the code minimum building and offer incentives at a rate of $0.31 (per the Bonneville Implementation Manual because it is HVAC end use) per kWh that the new building consumes below the consumption of the equivalent code minimum building.
Retrofit:
Following the installation of the ground source heat pump system, we would monitor the metered consumption of the building for 12 months. Once we had 12 months of consumption data we would create a weather normalized energy model comparing the corresponding 12 month period prior to installation of the system with the 12 months of post installation data. Clark Public Utilities offers incentives of $0.23 (per the Bonneville Implementation Manual because it is HVAC end use) per kWh of modelled post construction savings that have not been incentivized through other Clark Energy Efficiency programs.
Over the last several years, our Commercial Program Manager has issued incentives for one ground source heat pump installation. The customer’s primary driver for installing the system was to qualify for a LEED Platinum certification. These systems can be expensive to install (in relation to rooftop packaged or split systems) in conjunction with new construction projects and even more so for retrofit projects.
Long Duration Storage:
The RRGP Flexibility analysis did give serious consideration to other storage projects. This consideration was summarized in a staff report to the Board at the 11/2/2021 Board meeting.