2024 Integrated Resource Plan Comments

A public comment period is included as part of every Integrated Resource Plan development. This happens for both full Integrated Resource Plans as well as plan updates. Customers can submit comments during the open public comment period from July 17th, 2024 until 5pm on August 16th, 2024, by filling out the comment form on the main IRP page or sending an email to [email protected]. All comments are reviewed by staff and Clark Public Utilities’ Board of Commissioners.

Please note that public 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 on 8/16/2024

Clark PUD Commissioners:

I strongly support renewable energy sources.

One not emphasized is geothermal. The State of Washington is drilling near Mt Baker and Mt St Helens. Our area here has geothermal sources nearby. For instance, Carson, WA, has hot springs.

A heat exchange system would enable the use of geothermal resources without deep drilling. Washington State University has a report: https://www.energy.wsu.edu/documents/geothermal.pdf, which states in part:

Much of the state of Washington east of the Cascade Range has good low-temperature (less than 100°C, or 212°F) geothermal resources. This is especially true in the southern portion of the state throughout the Columbia River basin, where there are more than 900 thermal wells.

This available resource, completely renewable, with no waste, is an excellent option!

Submitted on 8/16/2024

I wholeheartedly support all of your Community Solar Projects and I very much want to encourage you to do more of them. Using rooftops around Clark County like the ones at the Port of Camas/Washougal is a great idea. Clark County has lots of rooftops on warehouses, schools, libraries, apartment buildings, and so on. You could offer to rent them or give the occupants a break on their energy costs – I don’t think any school district in the world would turn you down.

Both of your Community Solar Projects sold out in a very short time. People want that option – not everyone lives in a situation where they can have their own panels, but we all want to have the feeling that we are helping with the climate problems instead of contributing to them.

I would like to see enough Community Solar come on line to be able to reduce our dependence on the River Road Generating Facility. In addition to solar, we might be able to develop other renewable resources such as more wind, wave and tidal energy, geothermal, etc., and possibly make a real dent in our dependence on fossil fuels. Every little bit helps and we need myriads of local and public supported projects to carry out our fight against our changing climate. We cannot wait for solutions to come from techno-wizardry or believe there are easy answers – we must act now and you have made an excellent start with your Community Solar Projects.

Submitted on 8/16/2024

Clark County PUD Commissioners:
I enthusiastically support renewable energy projects as have been so well endorsed in other comments:

However, I do NOT support Small Nuclear Reactors (SMRs) for many reasons. One is that SMRs are NOT carbon-free.Fossil fuels are required to get the uranium out of the ground, transport it to a processing and enrichment facility, and to the SMR.

https://trac.pnnl.gov/ is a very good website to see what and where nuclear waste is stored at and how much all across the United States. For instance, a lot of uranium waste is stored near Moab, Utah, where some uranium mines are located.

Nuclear waste and the chemicals used to process the fuel do not have a permanent repository now and will probably not for a long time. NIMBY (Not in My Backyard) is the feeling of many.

Please take SMRs off your list of renewables because they are not and will lead to even greater problems in the future.

Submitted on 8/16/2024

I cannot agree with the PUD’s policy of continuing to look at SMRs for our future power needs. I think that increasing nuclear power production when we don’t have a way to dispose of the wastes safely is short-sighted at best. This technology should be put on hold until the waste problem has been solved.

Energy Northwest, the company the PUD is planning to work with, does not have a plan to dispose of waste safely. Currently their radioactive waste is stored in huge canisters on site until a national depository can be developed. Unfortunately, none is on the horizon so this dangerous waste will remain in an earthquake zone close to the very important Columbia River indefinitely. There are hundreds of these canisters scattered around the country at various energy plants and each plant has dozens of these canisters. There is no easy solution to this problem we have created for ourselves, but not adding to it is a step in the right direction.

We have other options to supply the energy needs of the future. Storage batteries are being developed, solar and wind farms are expanding, tidal and wave energy production is being ramped up, and so on. SMRs are not ready now and, despite the hype, their by-products are no less deadly or shorter-lived than their larger cousins.

In addition, they are not as carbon free as advocates say. The uranium and other ingredients must be mined and transported. The mine tailings have environmental problems of their own. Also, the amount of water necessary for energy production is huge. Even the Columbia has bad years where snowmelt is way down and the water could be better used for irrigation and fish health.

Please look beyond this way of providing for our energy future. The PUD does so many great things – I’m sure you can come up with something else.

Submitted on 8/16/2024

Thank you Clark Public Utilities for providing reliable power to our county. It would be great to see you accelerate your transition away from the gas-powered River Road Generating Plant. I would support more of your incredibly popular community solar projects. I don’t know why there is so much waiting between these projects. I do not support nuclear power as an option for us since we are in the Cascadia Subduction zone and we have a huge mess at Hanford that still needs cleaning up. Thank you for soliciting public comment.

Submitted on 8/16/2024

https://urldefense.com/v3/__https://scitechdaily.com/cheaper-faster-cleaner-scientists-have-developed-the-worlds-first-anode-free-sodium-battery/__;!!Cgow9cUcYahK!75Pv8WkyFBU4BQ4RFTn5VDJ_5T_us0Z-x6phm1DAAdTZFIXRhwhWcueyvWT9uIsxF7Dl-nR-5JDl2gIlspOS1IEO$

Submitted on 8/16/2024

Dear PUD,

I was very excited to purchase 5000 watts of Community Solar this past year.  I would have liked to purchase more.  I’m worried about climate change and would like to do my part.  I have 5 grandkids that live in the area and I want them to have a good future.  Please build more community solar or other solar projects.  I’d be happy to participate again and it would be wonderful if I wouldn’t have to worry about another electric bill ever again.  Thank you very much.

Submitted on 8/16/2024

I appreciate Clark Public Utilities’ reliability and reasonable rates.  Thank you for the community solar project recently undertaken at the Port of Camas-Washougal.  I would love to see more community solar in other parts of the county, such as at the Port of Vancouver.  We need more projects of this type to handle increased demand that will come with population growth and widespread adoption of EVs.  I would also like to speed up the phaseout of the River Road Generating Plant.

Submitted on 8/16/2024

It is getting hotter and hotter. There is less and less rain. Please concern yourselves with the climate crisis. Please subsidize more green energy. Solar wind etc. are cheaper now,and better for our world. Do not go for nuclear power which creates a nightmare for future storage. Thank You

Submitted on 8/16/2024

Re: Section 1.5 Least Cost Action Plan Summary: “CPU will meet the growing needs of its customers through a combination of strategies.”

This section starts with “CPU will optimize River Road Generating Plant generation using the flexibility product installed in May 2024.” It then goes on with: “CPU will also acquire all cost-effective conservation measures and monitor opportunities for demand response and distributed generation investments. CPU will continue to explore opportunities for adding both utility-scale renewable and behind-the-meter renewable resources, such as community solar projects, to its resource portfolio.” The conclusion says: “Additional utility-scale renewables will only be added to the resource portfolio when the load/resource balance shows that new resources are needed from an energy perspective.”

It seems clear that with load growth being predicted, there is a need to lower emissions with new carbon free resources as soon as possible, not wait.

Later in the document there is an acknowledgement that reducing River Road plant generation lowers carbon emissions, and this plant generation reduction can be done with sufficient carbon-free resources. It makes sense that “optimizing River road” should be the last and least used measure from this list, and eventually RRGP could be retained to be used solely as a back up for extreme weather events that might make its use necessary only briefly, once Clark has focused primarily on acquiring and implementing those conservation measures, made demand response and distributed energy investments and acquired sufficient carbon-free resources by adding more utility-scale renewables and behind-the-meter renewable resources to its portfolio.

Submitted on 8/16/2024

Hi, I would like to offer a few thoughts for the next 20 years. 1. As a property owner in Washington, I would like to see more opportunities and lower costs for residents to install solar or wind on private property. We would love to install solar but it is just too costly. 2. I am very much against any increase in nuclear energy until the issue of radioactive waste can be resolved. What is the point in protecting the climate if we leave the planet radioactive? 3. I also feel that PUD is doing good work in the areas of conservation and that those efforts should be continued and increased. Public education on ways to reduce use waste should be a top priority. 4. I really enjoyed the pollinator festival you hosted. It had an incredible turn out and people still talk about it. Thanks for taking comments.

Submitted on 8/16/2024

I am concerned with this in section 12:
If load growth materializes, look for and acquire RECs to meet the EIA requirements, subject to EIA cost cap limits
As CPU prepares to comply with the renewable energy requirements included in the EIA and the carbon-free energy requirements included in CETA, it will continue to explore opportunities to purchase RECs. There will be years in which CPU is long energy but short on renewable and/or carbon-free energy. Rather than increase the amount of surplus energy in its portfolio and re-sell more energy into the wholesale market, potentially at a loss, in order to reduce its risk and costs, which are passed on to its customers through retail rates, CPU will explore options for purchasing RECs and/or offsets when available. There has been greater scrutiny in recent years about the use of RECS to achieve GHG emissions reductions which may delay and undercut real-world emissions reductions.

Consider this: https://icleiusa.org/wp-content/uploads/2024/06/Public-REC-Guidance-FINAL-May-2024.pdf

The ICLEI USA Renewable Energy Credit Guidance for U.S. Local Governments ( published in May of 2024) says that: Local Governments for Sustainability USA (ICLEI USA) generally does not recommend that local governments purchase Renewable Energy Credits (RECs) as a greenhouse gas (GHG) emissions-reduction strategy. The purchase of unbundled RECs in particular is not recommended, as these RECs are not effective at reducing electricity-generation emissions and per the U.S. Community Protocol,cannot be included in an emissions inventory.

The report goes on to say about Renewable Energy Strategies: Before pursuing REC purchases, local governments should consider other strategies to build
and advocate for renewable development in their community and region. In addition to providing greater certainty than most REC purchases for reducing emissions, these strategies may provide additional co-benefits, such as a higher return on investment, improvements to local air quality, resilience through on-site renewable energy, and support for local businesses

I would like to advocate for more renewable development in our community and point to CPU’s successful community solar projects (Orchards and the latest Community Solar East Project) – although both were well supported within the built in limits that capped amounts available within each sector, it is my understanding that although the residential customer section sold out, there could have been more municipal investment that the program itself did not allow, and our city staff remain open to supporting additional community solar projects, along with those residential applicants who were not able to purchase when the allotted program sold out.

Submitted on 8/16/2024

In Section 1.6, Clean Energy Action Plan, the concluding statement is: Finally, CPU will continue to monitor and engage with opportunities for new low and zero carbon capacity resource technologies including geothermal and small modular nuclear reactors. Clark’s IRP draft cites “Least Cost” multiple times throughout the document. Least Cost remains a core foundation of the Clean Energy Transformation Act and the WA State Energy Strategy, which continues to assess Small modular reactors as NOT cost effective. In 2023 Clark PUD contributed $200,000 to Energy Northwest for a proposed SMR proposal to be located at Hanford, in spite of ratepayers raising concerns and objections. What has been pitched as a “feasibility” study for the proposed project has actually progressed to a development agreement with X-Energy for 12 Xe-100 SMR units, not yet NRC approved or licensed or proven to operate safely and affordably. This proposed project now appears to be moving forward without any clear benefit to Clark PUD ratepayers. Energy Northwest is instead now relying on an unidentified “large load industrial customer” to pursue funding the project and procuring the energy output if/when it gets built and operates, with public utilities NOT being able to afford to participate in the cost prohibitive first installment of the project that has an unknown timeline years away, due to high costs and risks that, based on the trend in the industry, will not come down anytime soon. I would like to see staff and Commissioners doing actual due diligence on cost, risk and the uncertain timeline of SMR’s instead of shortchanging ratepayers by continuing unrealistically to engage in what appears to be at best a speculative and unaffordable, out of range resource possibility that predicts no clear benefit to ratepayers for their energy needs. Section 13.9 concludes that SMR’s “are carbon free resources that could help CPU meet future CETA requirements. Saying SMR’s are “carbon free” ignores the carbon intensity of the entire nuclear fuel cycle, which inflicts significant harms throughout the cycle and conflicts with the the equity provisions in CETA. Pursuing SMR’s also ignores CETA’s “Least Cost” imperative and makes no sense when all evidence points to focusing instead on cost effective alternatives that can be deployed with more timely, affordable and equitable outcomes for our public utility ratepayers. https://www.utilitydive.com/news/nuscale-uamps-project-small-modular-reactor-ramanasmr-/705717/

Submitted on 8/15/2024

Thank you for implementing the highly successful Community Solar East project. It sold out so quickly! Please continue to be more aggressive with pursuing community solar projects, there’s huge demand!

Submitted on 8/15/2024

Appreciate your excellent costumer service and willingness to engage with the community. I’d love to see more urgency placed on conservation and renewable energy (like less than 20 years) even if that means increased utility costs.

I wonder if there are initiatives in place to educate the general public around the IRP and how it impacts everyone? Also, how can we get more folks engaged? I see there are only around 27 comments

Submitted on 8/15/2024

I am concerned that in spite of how important your IRP Public Comment Period is in soliciting comments from ratepayers, the Clark PUD website has the whole undertaking buried, not readily visible (e.g. especially no notice or Alert on the home landing page, which is where anyone going to the web site would see this if prominently placed) which means that it is difficult for ratepayers to even know that this process is happening, that their comments and feedback is being invited and is important and relevant to staff and Commissioners. I would encourage a transparent and open, welcoming and visibly displayed invitation on the home page that would genuinely alert ratepayers along with strategically placed and timed reminders so that the reason and willingness to obtain feedback is prominently conveyed to all ratepayers. I remember being told in an earlier comment period that website metrics (the number of comments and commenters versus the number of visitors to the website (for any/all reasons) rendered the amount and meaning of public comments received to be relatively small, which had the effect of diminishing the relevance and credibility of the comments received. Increasing the percentage of Ratepayers who do know about the process (with more active and visible ways to alert ratepayers of the IRP itself and Public Comment Period) would likely result in an increase in those ratepayers who take the time and make the effort to provide input, with the result of better informing policy decisions.

Submitted on 8/15/2024

I support the PUD in making a rapid transition to a 100% renewable energy grid. To that end, please continue to roll out new community solar projects and get solar panels installed on the new school buildings that are designed to be solar ready. School buildings with solar panels paired with electric school buses should be designated as, and equipped to be used as, community emergency centers in a joint effort with CRESA. Hot summers and long periods of drought are causing conifers to be dangerously dry and deciduous trees to be dropping leaves out of season. PUD needs to be making maximum effort to decarbonize our power sources. It should also take a leadership role in building partnerships with schools and CRESA to have schools be safe places in case of disaster with on-site renewable and/or stored power. Clark County, including cities like Vancouver, is no more fireproof than Santa Rosa, California. We, as a publicly-owned utility district, need to fully committed to taking steps towards solving the climate crisis while also becoming much more resilient.

Submitted on 8/15/2024

Please consider using some of the Transportation Electrification money to provide vouchers for Ebikes!

Submitted on 8/15/2024

I’m really concerned about localized air pollution and especially PM2.5. Please move to 100% clean energy as soon as possible!

Submitted on 8/15/2024

I’m very concerned about Climate Change, please move faster to 100% clean energy!

Submitted on 8/15/2024

2024 IRP comments

The 2024 IRP fails to acknowledge the elephant in the room: Climate Change/Global Warming. Global warming is an existential crisis which demands we all, including CPU, do what we can to reduce emissions and improve our ability to withstand increased heat, drought and poor air quality. While you mention a number of Washington State laws that have been passed to reduce GHG emissions in order to alleviate climate change, the lack of addressing it in the IRP demonstrates a lack of commitment on the part of CPU to meet the expectations of its customers and the rest of the state.
In the Executive Summary, you state that the goal of the IRP is to forecast demand and identify the “optimal mix of resources that is affordable and reliable while meeting regulatory requirements and social expectations of our community.” However, the IRP does not meet the community’s expectations.
The City of Vancouver has adopted an aggressive Climate Action Framework which aims for the city to become carbon neutral by 2040. You do not mention that.
Similarly, the Port of Vancouver has adopted aggressive GHG reduction goals in its climate action plan, but you do not address that. While Clark County has not yet adopted a specific climate action goal, it is currently developing a new Growth Management Plan which must, by state law, take the climate into consideration. There is no indication in the IRP that you are working or plan to work with, any of the local jurisdictions to help them meet their emission reduction goals.
The bottom line is that your community expects you to aggressively reduce emissions in your portfolio to the maximum extent and as quickly as possible. The IRP does not show that commitment.
As noted in the draft IRP, historically approximately 29% of CPU power has been from the River Road (methane gas) Generating Plant. If I read the IRP correctly, you are expecting to reduce that to approximately 20% over the timeline addressed. That is not adequate. Local jurisdictions cannot meet their emission reduction goals when between 20 and 29% of their electricity is produced using methane gas. CPU invested a significant amount of money into making RRGP flexible. You should take urgent steps to reduce gas power generation as quickly and as often as possible by actively seeking to replace RRGP power with as much renewable power as possible.
I applaud CPU’s steps to acquire the output of Box Canyon and Combine Hills and plans to acquire more wind power when the Combine Hills contract expires. I also appreciate the Community Power projects. What I am asking is that you do more of these types of things. More PPAs will help you to meet the expected significant deficits with clean power. Solar and wind power and energy conservation are the fastest and most affordable ways to meet expected energy demand without adding to emissions. Also note that while purchasing RECs, especially bundled RECs, is allowed as a way to meet state requirements, they generally do nothing to reduce emissions.
Although you identify AMI as a way to help reduce consumption, you admittedly have only begun to roll it out. You need to vigorously pursue advance metering until it reaches your entire customer base.
Rather than passively waiting for the community to ask you to accept new community solar projects, you should be actively working with the public, cities, ports, school districts, and private developers to encourage creation of large numbers of community solar and distributed generation projects.
Please revise your plan to be consistent with your community’s expectations by recognizing the urgency of replacing methane generated power and meeting expected power deficits with as much clean power as possible,.

Submitted on 8/13/2024

The IRP mentions the possible future purchase of power produced by SMRs. As the IRP recognizes, SMR power is expensive. Although the IRP states some SMR power might be available as early as 2030, that is far from a certainty. Although proponents state SMR nuclear power is safe, at best, SMR nuclear power, while arguably safer than power from a Trojan type reactor, is not totally safe. We live in a state with massive quantities of nuclear waste, waste that hasn’t been safely handled and that threatens the Columbia River. There’s no reason to resort to nuclear power when our power needs can be met by renewable power, even if CPU doesn’t plan to invest in building SMRs. The purchase of nuclear power from SMRs should not be a part of CPU’s future power acquisition plans.

Submitted on 8/13/2024

The IRP indicates CPU intends to rely on RECs to meet its state emission reduction goals. To the extent that means purchasing unbundled RECs, purchasing the RECs allows CPU to comply with state GHG reduction requirements without having to actually reduce its own GHG emissions. In buying unbundled RECs, CPU would be paying for someone else to do the work of acquiring and developing renewable energy. Without knowing what unbundled RECs CPU might buy, it’s possible the RECs will represent the power output of facilities already built. In that case, the RECs don’t actually result in any GHG emission reduction anywhere. Relying on unbundled RECs allows CPU to pretend to reduce GHG emissions while not actually reducing those emissions. Although the law allows CPU to do that, CPU can do better and should be working to reduce its own emissions. CPU should not use unbundled RECs as a way to avoid actively reducing its own GHG emissions.

Submitted on 8/13/2024

I appreciate the IRP goal of implementing a “least cost” plan. CPU has been very successful in keeping our rates down. But cost is not only a financial cost. Cost to customers includes the environmental impact of CPU’s services. If air is unhealthy, customers suffer. As climate impacts become more severe, customers suffer. If transitioning to more renewable sources of energy increases the cost of CPU power, CPU can simultaneously implement rate policies that offset the impact of any increases on low-income customers.

In considering the cost of future power, CPU should consider climate impact on customers. Considering that cost, CPU should work to transition sooner to providing power entirely from renewables.

Submitted on 8/13/2024

Thank you for the opportunity to comment on the draft IRP.

I appreciate CPU’s emphasis on conservation and the past successes in that area. I encourage you to continue your emphasis on conservation to achieve the goal of continuing to meet aggressive conversation targets. I also appreciate CPU’s recent purchase of power from the Box Canyon Hydroelectric Project, recent development of the Community Solar East Project, and CPU’s negotiations with a renewable energy developer to purchase the entire output of two solar projects for 20-year contract terms.

But I’m concerned about CPU’s continued reliance on the River Road Gas Plant. The IRP repeatedly states CPU intends to continue to rely on the RRGP output at the current level until at least 2036. Every graph the IRP includes shows the RRGP output constant. Even though less of the RRGP load is dedicated for purposes of CPU’s contract with the BPA, the IRP projection is for no change in the plant’s output.

The IRP rationalization is that the RRGP output is necessary to provide CPU the flexibility to transition to renewable and solar. Yet the IRP states the lead time to implement solar and wind power is three years. 2036 is twelve years from now. The IRP doesn’t explain why solar and wind implementation can’t begin well before 2036. Although the IRP states CPU will continue to support any additional community solar opportunities that may arise, that is too passive an approach. CPU should be actively seeking solar and wind resources as well as planning to develop those resources beginning now.

Decreasing reliance on RRGP matters. Natural gas is almost entirely methane, a potent and planet-warming greenhouse gas that is responsible each year for an estimated 40% of greenhouse gas emissions and an estimated one-third of global climate change. The more solar and wind power we have now, the less need we have for the gas plant.

CPU’s success with the Community Solar East Project indicates it’s possible to develop community solar projects that have an impact. The popularity of the project is further support for immediately planning to develop more community solar. CPU customers want more solar. The IRP should include the goal of developing more community solar beginning now, not 12 years from now. The IRP should set forth a specific time frame for implementing that goal.

Submitted on 8/6/2024

The proposed Clark PUD (CPUD) Integrated Resource Plan (IRP) is a conservative approach to meet the stated goals for providing reliable electricity supply for the coming twenty (20) years.  I applaud the pivot to abandon the prior ill-fated strategy to rely on the Market to meet our energy needs by abandoning the Slice product.  That approach resulted in almost $50M in annual losses over the past three years. ($11M FY2022, $17M FY2023, over $20M so far in FY2024).

The current strategy is conservatively incremental: buying into commercial wind and solar developments and returning to what was previously termed ‘full-requirements’ status with BPA.  It, however, lacks any innovative approach to meeting our future energy needs as we strive to ‘electrify everything’.  As our prior investment in the River Road Generating plant showed, the only truly reliable generation is that controlled by the PUD.  CPUD has failed to adopt recommendations for greatly accelerating initiatives such as continuous Community Solar.  It also lacks any thinking to innovatively engage with the substantial Public Power presence in Washington State.

Community Solar affords us an opportunity to greatly accelerate Solar adoption – with no direct rate impacts, as the investment costs are borne by ‘subscribers’: the CPUD membership/customers.  Deploying a Community Solar Project every five (5) years is not going to help us reach our goals.  As the second largest Public Power provider in Washington State, CPUD has failed to rally Public Power and provide the leadership to develop a large-scale comprehensive Community Solar strategy.  For example, working through the Washington PUD Association (WAPUDA), CPUD could lead in the acquisition of a large tract of property on the east-side of the Cascades.  This could host separate ‘racks’ for member Public Power utilities, but dramatically reduce costs by sharing a common transmission interface and large-scale energy storage.  We are engaged in replacing large-scale conventional generation (carbon) resources that were financed and shared by multiple Utilities.  This approach effectively minimized costs and serve as a blueprint for how we can pivot now.  The large tract of property could be provided at no cost from the Bureau of Land Management (BLM), as directed by the Biden Administration, but today no evidence exists of CPUD pursuing this option.

By procuring a large tract, CPUD could offer innovative programs such as allowing members/customers to buy solar monthly by allowing subscribers to buy, say, $10 worth of solar per month as a billing item.  That would allow CPUD to continuously increase Solar.  Alternatively, the costs of commercial solar and wind development typically costs at least 30% more due to the costs of financing and bonding, let alone the required profit required for a commercial entity.  Community Solar provides more power, more cost effectively and more quickly.

CPUD is a large Public Power entity and should be approaching the radical changes we need to make with innovation and intensity.  It is not demonstrating the leadership its size and stature allow.  Incremental approaches will not accomplish our stated goals in the timeline we must.

Submitted on 8/5/2024

Hi Clark PUD,

I live on the other side of the county so I am less concerned about the emissions from your plant effecting the air I breathe.
But as a resident of the hills of Washougal I do fear that fire may soon come our way and threaten my husband’s breathing, even my home.

In our neighborhood you have always been quick to get the power back on line when high winds and storms take them down but we must work as fast as we can to stop burning fossil fuels like from your plant. It seems you are leaps ahead of other utility districts with Bonneville as a source of so much power. But replace that gas power plant with renewables and I will do my part and get solar on the roof and hopefully someday in a future summer I might make enough power to send a little back to you.

Please keep working hard to save us from destructive weather. (I lost 12 trees in the last storm. Neighbors lost two, three, four times this) I know if we don’t work fast dangers will only increase exponentially.

Submitted on 8/5/2024

Dear PUD, first of all I would like to say that I am very happy to be part of a public utilities system. Furthermore I am also very pleased with PUD’s pioneering on the community solar projects in Orchards and Washougal. Having said that, I feel that there is much higher urgency than any of our local government (and yours, too) are showing! Global climate collapse is here, right in pur face. Natural gas should not even be on the table anymore. I urge you to exponentially ramp up community solar projects, as well as small scale residential solar, which could be owned/subsidized by you (compare to Germany’s balcony solar strategy). Another idea could be PUD maintaining larger residential solar placements with good exposure, with the home owner getting a reduced rate for the energy produced in exchange for letting PUD use their roof. Our urban infrastructure has so much unused space that could be utilized for solar and or wind- let’s not waste it, and act now, so that our children will have a livable future (and the cats of all us childless cat ladies too)

Submitted on 8/5/2024

RE: comment on Integrated Resource Plan
As a community member, I am hoping you will use money currently spent on purchasing renewable energy certificates for developing warehouse solar capability instead. Flying over western France a few months ago, I was struck by the number of solar panels on top of warehouse roofs. Couldn’t we do the same? Flying into Portland reveals the amount of acreage devoted to flat warehouse roofs, such perfect solar panel territory.
We have solar panels on our roof. They generate energy all year long, even when the weather is grey and rainy. There are only a few months that we have to pay any utility bills at all. Most of all, our little house is not generating pollution or greenhouse gases. Think of all the pollution a warehouse roof would eliminate, particularly if it could replace some of the energy provided by the natural gas plant.
Thanks for giving community members the opportunity to comment on the IRP.

Submitted on 8/5/2024

I am appreciating that “least-cost” power is the theme of responsible resource planning, especially at this time when rates have gone up and so many in our community are struggling to make ends meet. If I am understanding correctly, energy efficiency lowers energy costs, which is why I am in support of having a more efficient (as well as healthy) way of heating my home. I am hoping that Clark PUD will continue to advocate for statewide legislation that allows incentives to be possible for ratepayers who are interested in “fuel switching” , since I have a gas furnace that is aging out and am currently not eligible for incentives through Clark to help me replace my system with a heat pump. With the hotter summers I have had to invest in an air conditioning unit to cool my upstairs bedroom, which adds to the energy cost burden for my home. I urge Clark to amplify it’s track record of exceeding energy conservation goals by stretching even further with progressively more emphasis on pursuing even more ambitious energy conservation goals in the years ahead. Thank you for prioritizing this for your ratepayers.

Submitted on 8/5/2024

We need to continue phasing out dirty energy and bringing in more clean energy. It would be fantastic if we could exceed the state goals by 10 years. Please keep moving Vancouver in this direction. Thank you.

Submitted on 8/4/2024

Residential shares in Community Solar East sold out within a few hours, showing high public demand for participation in renewable energy. Such projects draw on the technical expertise of Clark PUD, leverage the economy of scale, and make solar energy participation possible for many whose homes are not good candidates for solar. Please include more of these projects in the IRP.

Submitted on 8/4/2024

PUD should develop more community solar projects in Clark County. The current ones sold out quickly with very little publicity (I bought some). I know of no market research to determine how much could be developed if there were appropriate sites and active marketing.

Submitted on 8/4/2024

Thanks for exceeding your conservation goals. Instead of purchasing renewable energy certificates (recs), please use that money to develop PV projects in Clark County. There are plenty of sites on buildings and open field for large scale PV projects.

Submitted on 8/4/2024

Dear Clark PUD Commissioners,

Thoughts re: the IRP:

Good work with conservation – let’s see even more of that

Please do not use REC purchases to meet renewable energy goals. Use the money to invest in actual renewable energy sources such as

1. a) community solar projects
2. b) mid-size commercial solar projects
3. c) solar on the tops of warehouses, schools and other large area roofs

Submitted on 8/4/2024

Sent from my iPhone…..  Please  consider more community solar….. it sold out so fast because it’s what people want ….. lots of new warehouses and big apartment buildings going in …. Rooftops save land …..

Submitted on 8/4/2024

Thank you for your work on the IRP. Please prioritize contracting with wind and solar to quickly transition to 100% clean electricity as soon as possible.

Submitted on 8/4/2024

1. I am writing this testimony to express my concerns regarding the operating strategy of our local Clark Public Utilities power plant, specifically the River Road facility. It is my belief that the PUD is not considering all the costs involved in their operations, which may lead to inefficient and potentially harmful outcomes. By neglecting these costs, the true expense of power generation from River Road is not accurately reflected, and it is possible that there are more cost-effective and environmentally friendly alternatives available.

There are four main areas of cost that the PUD is currently ignoring in their operating strategy. First, the issue of carbon pollution needs to be addressed. Although the Climate Commitment Act carbon allowance auctions provide a tangible price per ton, it is crucial to acknowledge that this price may be lower than the actual social cost of carbon. The PUD receives free allowances, and they have the option to either run River Road and forfeit the allowance or purchase clean power and sell the allowance at a future auction. Including the cost of carbon pollution is essential in making informed decisions.

Secondly, the localized pollution caused by the power plant, particularly in terms of NOx and PM 2.5 emissions, cannot be disregarded. While other sources such as cars, trains, and buildings may contribute to overall pollution levels, it does not justify ignoring the potential costs associated with River Road’s pollution. Various estimates exist on the health impacts and economic costs of such pollution, and the community should be made aware of the trade-offs being made. It is crucial to explicitly consider these costs and prioritize the well-being of our community.

Moreover, the PUD should take a longer-term perspective when making operating decisions, as they are not a for-profit company but a public agency. Ignoring the wear and tear on the power plant, or the depreciation, would be contrary to typical business school decision science. If River Road is meant to serve as a valuable resource, whether as a backup or in support of new renewables, it is important to avoid wasting its limited lifespan on low-value production when there are potentially better alternatives available. Including wear and tear as a cost is vital for making informed decisions.

Finally, thermal power plants inherently pose risks and may not always function when needed. River Road has experienced several unplanned outages in the past five years, and other regions have faced difficulties with their coal, gas, and nuclear plants. The Columbia Generating Station also encountered issues during startup. Given the high temperatures and numerous moving parts involved, problems are inevitable. Thermal plants require backup resources or significant redundancy to minimize disruptions. While the Northwest has been fortunate to have ample hydro backup from the region and Canada, it is important to recognize that this backup has associated costs.

Currently, the PUD appears to be solely considering the cost of fossil gas when determining how to utilize River Road. In my opinion, this approach does not effectively utilize ratepayer funds and overlooks or downplays the costs outlined above. While some pollution may be unavoidable, it should only occur for exceptionally compelling reasons.

I acknowledge that there may be gaps in this testimony or areas where the logic could be further strengthened. However, I believe it is crucial to combine concerns over both types of pollution with rigorous accounting principles. Accountants are skilled at quantifying and evaluating various factors, making it difficult to dispute their findings. It is my hope that by addressing these issues, we can encourage the PUD to make more informed decisions that prioritize the well-being of our community and utilize our resources more wisely.

Thank you for your attention to this matter.

2. The Solutions that can be Named are not the Solutions | Frankly 67 23 minutes 25 seconds https://youtu.be/1ea4hmI2xmk?si=gHCx6eCPn-OMfrzf

The speaker outlines the “human predicament” we face – our unsustainable global energy use, ecological overshoot, and the complex challenges of climate change, biodiversity loss, and more. However, the speaker is hesitant to propose specific “solutions,” arguing that this is more of a “predicament” than a problem with clear fixes.

The speaker explains that responses to this predicament need to consider multiple dimensions – the superstructure of ideas/values, the social/economic structures, and the physical infrastructure. Solutions must also account for different scales (individual, local, global) and timelines (pre-crisis, crisis response, long-term).

The speaker argues that publicly presenting “solutions” can be counterproductive, as human systems quickly adapt and respond to new information. The most effective responses may need to remain unseen or unpopular. The speaker also acknowledges the difficulty in knowing the right path forward with certainty.

Instead, the speaker emphasizes the importance of first helping people understand the fundamental dynamics at play – the interconnections between energy, money, technology, and environmental impacts. From this foundation, individuals can then determine their own values and strategies for navigating the challenges ahead.

3. Overshoot and Its 7 Fundamental Drivers | Frankly 68 16 minutes 47 seconds https://youtu.be/ZDN8ABCIDyg?si=sZL_DtBjL0Tt_CLS

Here is a concise summary of the key points from the video: The video discusses the concept of “overshoot” – when a species grows beyond the carrying capacity of its environment. The speaker argues that humanity is currently in a state of overshoot, driven by 7 fundamental factors:

1. The “carbon pulse” – the sudden influx of ancient, stored energy (fossil fuels) that has enabled human population and consumption to explode.
2. Financial systems that discount the environmental costs of growth and resource extraction.
3. Governance and decision-making being outsourced to financial markets focused on short-term growth.
4. A widespread lack of ecological literacy and understanding of environmental limits.
5. Cultural emphasis on status, consumption, and “dopamine-driven feedback loops” that promote unsustainable choices.
6. Cognitive dissonance that prevents people from fully grappling with the implications of overshoot. The speaker suggests some potential “antidotes” to overshoot, including reducing energy surplus, the planet imposing its own limits, a cultural shift towards an “earth-centered” worldview, and developing more sustainable, synergistic technologies. Ultimately, the video calls for greater individual and societal recognition of humanity’s overshoot of ecological boundaries.

Submitted on 8/3/2024

Hello Clark PUD,

First, thanks for providing my home with reliable power for the 6 years I’ve lived in Vancouver.

I’m very concerned about climate change, and it’s impacts on our area. In addition to the highly visible fires, heat waves, and declining salmon runs, there are hundreds of other impacts.  Note that climate change will reduce late summer snow melt, impacting the amount of hydropower available in hot summers for AC loads, even as those loads increase.

We all must do our part to decarbonize as quickly as possible. This is why my home is solar powered, and why we replaced our gas furnace with a heat pump.

In reviewing the new Integrated Resource Plan, I see aspirations to support decarbonization, but not a sense of urgency.  I’d prefer to see a plan to reduce operating hours of the gas plant to zero over the next decade through:

• Coordinated development of renewable assets and battery storage (BESS) in Clark County
• Incentivizing rooftop solar, BESS, heat pumps and other solutions to eliminate burning gas
• More Public charging infrastructure and EV incentives, Vehicle to Home (V2H) support
• Implementation of demand response systems, this starts with smart time of use pricing to reduce demand at times when the gas plant would otherwise be required.
• Pursuing building codes that ensure energy efficiency and electrification

Keep up the good work, but let’s move faster and with purpose to make Clark County part of the solution to climate change, not part of the problem.

Submitted on 8/3/2024

I have asthma and it is definitely exacerbated by air pollution.  I am concerned about air pollution by the River Road Gas Plant.  Please consider replacing that source of energy with renewables.  Also please consider incorporating more community solar.  There seems to be a demand considering how many people have participated in local existing projects and that there are people who want to participate but there is no more space.  Thank you for all of your conservation efforts.  I am concerned for myself and my family.

Submitted on 8/2/2024

Please transition to fully renewable energy sources, especially wind and solar, ASAP.  The children need your leadership.  Community solar is very popular.  How about starting 3 more projects like the one in Camas-Washougal.

Submitted on 8/2/2024

To whom it may concern,

In regards to the current IRP you are considering, I would like to submit some comments.

1. Instead of purchasing renewable energy certificates, why not use that money to develop renewable energy projects in Clark County, for example on top of warehouses, parking lots, grocery stores, etc. And,

2. Be more aggressive with community solar. Where and when is the next project? The last project sold out quickly. Have we satisfied individual, business, or municipal demand for more community solar?

Submitted on 8/2/2024

Our gas plant was constructed  to be flexible in order to integrate intermittent energy resources.  Please take advantage of that flexibility by acquiring more renewables! Instead of purchasing renewable energy certificates,  for instance, why not use that money to develop renewable energy projects in Clark County like  solar energy on top of warehouses.   Combating climate change is important to me. The natural gas power plant puts carbon in the air.  I want my Public Utility Company to use more renewable energy like wind and solar.

Submitted on 8/2/2024

Dear Madams and Sirs:

It’s great that you exceeded our conservation goals.  More must be done.  Nuclear is one way of bridging the energy needs.  It has almost no air pollution.  We all hate air pollution.

My adult son has asthma and air pollution worsens it. We need more solar projects.  We need to reduce tree destruction.

Thank you for reading my comments.

Submitted on 8/2/2024

1. Thank you, Clark Public Utilities, for utilizing more “clean” energy in the future. (Ex: Figure 27 shows an increased percentage of energy from solar and a decrease from  natural gas.) Is that enough — and soon enough — to address climate goals?
2. To offset the recent rate increase to customers, could Clark PUD offer tiered pricing? (Ex: My friend in Germany runs her dishwasher after 9 p.m. because electricity is cheaper then.)
3. The July 30 (?) issue of the New York Times had an article about small, affordable, plug-in solar panels available in Germany to residential customers. The price was under $300.
4. Please continue to offer community solar projects, and allow greater participation.

Submitted on 7/27/2024

Do the NPVRR calcs for WRAP vs no WRAP (page 65) include any estimation of the costs of a major outage or shortage (multiplied by probability of the event with WRAP vs no WRAP)?  The whole point of a RA initiative is to prevent a major supply problem so there has to be some benefit to that insurance or why bother with RA?  Even though the likelihood of an extreme event is small, the costs are large and this past winter should be a reminder of the potential costs.  We’re never going to estimate the probabilities and total costs precisely but some amount of avoided cost or insurance benefit to being resource adequate ought to be included in any NPVRR.  Otherwise, NPVRR calcs would seem to lead us to delay RA indefinitely.  Thanks!

Submitted on 7/23/2024

How has the cost of power from BPA compared to RRGP output over the last decade on a yearly average basis? The monthly numbers in most monthly financial reports typically show BPA power running somewhat cheaper than RRGP. Thanks!

Submitted on 7/21/2024

Do you have any info on how our local rates compare to other nearby utilities and across the nation? I find that a lot of ratepayers, especially those that have lived in Clark County for some time, aren’t aware of just how low our rates are and what a tremendous value we are getting from our public utility.

On a similar note, a lot of ratepayers aren’t aware of just how reliable our local distribution system is compared to other utilities. Do you have any quick reliability data that you could share? The utility has done a great job of proactive tree trimming and undergrounding distribution where possible. I’d recommend continuing to emphasize those areas and really look to underground as much as possible.

Also, there seems to be wide confusion as to whether outages are caused by distribution problems or supply problems. Have we ever had an outage caused by lack of supply?

Thanks!

Submitted on 7/21/2024

Thanks as always for the opportunity to provide public comment. Could staff please explain the last sentence on page 7, paragraph 1 “Additional utility-scale renewables will only be added to the resource portfolio when the load/resource balance shows that new resources are needed from an energy perspective.” Given the significant investment in making River Road more flexible, I’d assume the utility would be open to procuring more utility-scale renewables if they are cost effective and can be easily integrated into our resource mix? A flexible River Road could balance (or integrate) a whole lot of new renewables and I’d hate for us to be passing up opportunities to reduce pollution and save rate payers money. Thanks!

Submitted on 7/20/2024

To Clark Public Utilities regarding your 2024 IRP. The quotes are from your IRP.
1. Quote: from section 1.7. “CPU has a considerable deficit in capacity to meet (peak) capacity demand and, without the implementation of a comprehensive and well-planned strategy, would likely see that deficit increase to as much as 750 MW by 2044. CPU will leverage all the tools available to meet this need reliably, affordably, and sustainably. These tools include optimization of BPA Tier 1 power, CPU’s RRGP, renewables, [add conservation] and battery storage options.”
2. Quote: “CETA requires that all utilities in Washington must supply carbon neutral electricity by 2030. Although CPU retains the flexibility to include carbon-emitting resources in its portfolio equal to up to 20 percent of its retail load until 2045, any carbon emissions generated from these resources must be offset by the procurement of renewable energy credits or the investment in renewable energy projects. In addition, when contemplating such resources, the societal cost of carbon must be included in the evaluation.”
Question 1a: Elsewhere the draft IRP says you have already purchased RECs to comply with the EIA. Please elaborate. Why purchase RECs instead of developing local solar projects here?
Question 1b: Please discuss in detail the types of renewable energy credits (recs), and investments in renewable energy projects (I-REP) you might pursue to offset emissions of your gas plant after 2030.
Question 1 c: What do you think of developing your own RECs by developing local solar projects such as on warehouses?
Question 1d: If BPA accepts you as a load following customer, will you be able to retire your gas plant before 2035?
Question 1e: Do you know where BPA will get the resources to provide for our load growth?
3. Quote “Based on market data, the cost of battery storage, fixed for a 15-year term, is assumed to be $144/kW-yr in 2027.”
Question 2a: Could you define “kilowatt-year? Google wasn’t much help.
4. From the last page of the IRP. “CPU will continue to support any additional community solar opportunities that may arise. “
Question 3a: Instead of waiting for a project to arise, why not make opportunities arise?
5. Quote: “The goal of this 2024 IRP is to forecast the future electric demand of our customers and to identify the optimal mix of resources that is affordable and reliable while meeting regulatory requirements and social expectations of our community. “
Question 4a: I’m glad you want to meet the social expectations of the community. Many people would like you to reduce emissions as fast as possible. Do you want to look for ways to shut down the gas plant for longer periods of time?
6. Quote: CPU is currently a purchaser of RECs from Idaho PURPA solar generation facilities which contribute to satisfying CPU’s EIA renewable requirements.”
Question 5a: How much are we spending on this?
Question 5b: How do we benefit from these RECs?
7. Quote: “The Inflation Reduction Act impacts numerous sectors including energy, manufacturing, environmental, transportation, agriculture, and water, with a primary focus on the electric industry.”
Question 6a: How will the Inflation Reduction Act benefit Clark Public Utilities?
Question 6b: Washington State has received about $160 million from the Federal Solar for All Program. Is Clark Public Utilities working on an application for some of those funds?
8. Quote: In Section 1.7 you say “CPU will leverage all the tools available to meet this need reliably, affordably, and sustainably.”
Question 7a: Does the Climate Commitment Act help you meet those goals?
Question 7b.: Have you received any funds from the Clean Fuels Program?
9. Question 8a: In July of 2024, Bloomberg reported that the price of large batteries in China have fallen 51% this year $53 per kwh. Is that reflected in the graph of expected battery prices?
10. Question 9a: What does ICE mean in this sentence: “For carbon pricing the IRP uses recent auction settlements and bilateral Washinton Carbon Allowance (WCA) and California Carbon Allowance (CCA) trades on ICE” ??
11. Question 10 a: In section, under least cost option it says : Reducing plant generation will also result in reduced carbon emissions as CPU will be looking for opportunities to displace RRGP generation with surplus carbon-free resources. Consider replacing the expression “surplus carbon free resources” with “surplus carbon free resources plus new local carbon free resources developed by Clark PUD”.

Submitted on 7/18/2024

Thank you for making it easy for the public to comment on this IRP! As always, CPU should be commended for their focus on reliability and affordability. Public power in Clark County provides tremendous value to our community and we are lucky to be served by a world class local utility.

In a first reading of this IRP, it appears that CPU is using State mandates (the law) as a goal for reducing GHG (green house gas) emissions and other criteria pollutants. Compliance with the law does not seem to be an overly ambitious goal considering that the majority of rate payers (in addition to world class reliability and lowest in the nation power costs) would also like to see as rapid as possible pollution reduction. Compliance is not really a strategy but a simple expectation. Has CPU considered more aggressive pollution reduction goals and is there any analysis showing the impact of different reduction paths on rates and reliability? Thanks!

Submitted on 8/15/2024

I’m very concerned about Climate Change, please move faster to 100% clean energy!

Submitted on 8/15/2024

2024 IRP comments

The 2024 IRP fails to acknowledge the elephant in the room: Climate Change/Global Warming. Global warming is an existential crisis which demands we all, including CPU, do what we can to reduce emissions and improve our ability to withstand increased heat, drought and poor air quality. While you mention a number of Washington State laws that have been passed to reduce GHG emissions in order to alleviate climate change, the lack of addressing it in the IRP demonstrates a lack of commitment on the part of CPU to meet the expectations of its customers and the rest of the state.
In the Executive Summary, you state that the goal of the IRP is to forecast demand and identify the “optimal mix of resources that is affordable and reliable while meeting regulatory requirements and social expectations of our community.” However, the IRP does not meet the community’s expectations.
The City of Vancouver has adopted an aggressive Climate Action Framework which aims for the city to become carbon neutral by 2040. You do not mention that.
Similarly, the Port of Vancouver has adopted aggressive GHG reduction goals in its climate action plan, but you do not address that. While Clark County has not yet adopted a specific climate action goal, it is currently developing a new Growth Management Plan which must, by state law, take the climate into consideration. There is no indication in the IRP that you are working or plan to work with, any of the local jurisdictions to help them meet their emission reduction goals.
The bottom line is that your community expects you to aggressively reduce emissions in your portfolio to the maximum extent and as quickly as possible. The IRP does not show that commitment.
As noted in the draft IRP, historically approximately 29% of CPU power has been from the River Road (methane gas) Generating Plant. If I read the IRP correctly, you are expecting to reduce that to approximately 20% over the timeline addressed. That is not adequate. Local jurisdictions cannot meet their emission reduction goals when between 20 and 29% of their electricity is produced using methane gas. CPU invested a significant amount of money into making RRGP flexible. You should take urgent steps to reduce gas power generation as quickly and as often as possible by actively seeking to replace RRGP power with as much renewable power as possible.
I applaud CPU’s steps to acquire the output of Box Canyon and Combine Hills and plans to acquire more wind power when the Combine Hills contract expires. I also appreciate the Community Power projects. What I am asking is that you do more of these types of things. More PPAs will help you to meet the expected significant deficits with clean power. Solar and wind power and energy conservation are the fastest and most affordable ways to meet expected energy demand without adding to emissions. Also note that while purchasing RECs, especially bundled RECs, is allowed as a way to meet state requirements, they generally do nothing to reduce emissions.
Although you identify AMI as a way to help reduce consumption, you admittedly have only begun to roll it out. You need to vigorously pursue advance metering until it reaches your entire customer base.
Rather than passively waiting for the community to ask you to accept new community solar projects, you should be actively working with the public, cities, ports, school districts, and private developers to encourage creation of large numbers of community solar and distributed generation projects.
Please revise your plan to be consistent with your community’s expectations by recognizing the urgency of replacing methane generated power and meeting expected power deficits with as much clean power as possible,.

Submitted on 8/13/2024

The IRP mentions the possible future purchase of power produced by SMRs. As the IRP recognizes, SMR power is expensive. Although the IRP states some SMR power might be available as early as 2030, that is far from a certainty. Although proponents state SMR nuclear power is safe, at best, SMR nuclear power, while arguably safer than power from a Trojan type reactor, is not totally safe. We live in a state with massive quantities of nuclear waste, waste that hasn’t been safely handled and that threatens the Columbia River. There’s no reason to resort to nuclear power when our power needs can be met by renewable power, even if CPU doesn’t plan to invest in building SMRs. The purchase of nuclear power from SMRs should not be a part of CPU’s future power acquisition plans.

Submitted on 8/13/2024

The IRP indicates CPU intends to rely on RECs to meet its state emission reduction goals. To the extent that means purchasing unbundled RECs, purchasing the RECs allows CPU to comply with state GHG reduction requirements without having to actually reduce its own GHG emissions. In buying unbundled RECs, CPU would be paying for someone else to do the work of acquiring and developing renewable energy. Without knowing what unbundled RECs CPU might buy, it’s possible the RECs will represent the power output of facilities already built. In that case, the RECs don’t actually result in any GHG emission reduction anywhere. Relying on unbundled RECs allows CPU to pretend to reduce GHG emissions while not actually reducing those emissions. Although the law allows CPU to do that, CPU can do better and should be working to reduce its own emissions. CPU should not use unbundled RECs as a way to avoid actively reducing its own GHG emissions.

Submitted on 8/13/2024

I appreciate the IRP goal of implementing a “least cost” plan. CPU has been very successful in keeping our rates down. But cost is not only a financial cost. Cost to customers includes the environmental impact of CPU’s services. If air is unhealthy, customers suffer. As climate impacts become more severe, customers suffer. If transitioning to more renewable sources of energy increases the cost of CPU power, CPU can simultaneously implement rate policies that offset the impact of any increases on low-income customers.

In considering the cost of future power, CPU should consider climate impact on customers. Considering that cost, CPU should work to transition sooner to providing power entirely from renewables.

Submitted on 8/13/2024

Thank you for the opportunity to comment on the draft IRP.

I appreciate CPU’s emphasis on conservation and the past successes in that area. I encourage you to continue your emphasis on conservation to achieve the goal of continuing to meet aggressive conversation targets. I also appreciate CPU’s recent purchase of power from the Box Canyon Hydroelectric Project, recent development of the Community Solar East Project, and CPU’s negotiations with a renewable energy developer to purchase the entire output of two solar projects for 20-year contract terms.

But I’m concerned about CPU’s continued reliance on the River Road Gas Plant. The IRP repeatedly states CPU intends to continue to rely on the RRGP output at the current level until at least 2036. Every graph the IRP includes shows the RRGP output constant. Even though less of the RRGP load is dedicated for purposes of CPU’s contract with the BPA, the IRP projection is for no change in the plant’s output.

The IRP rationalization is that the RRGP output is necessary to provide CPU the flexibility to transition to renewable and solar. Yet the IRP states the lead time to implement solar and wind power is three years. 2036 is twelve years from now. The IRP doesn’t explain why solar and wind implementation can’t begin well before 2036. Although the IRP states CPU will continue to support any additional community solar opportunities that may arise, that is too passive an approach. CPU should be actively seeking solar and wind resources as well as planning to develop those resources beginning now.

Decreasing reliance on RRGP matters. Natural gas is almost entirely methane, a potent and planet-warming greenhouse gas that is responsible each year for an estimated 40% of greenhouse gas emissions and an estimated one-third of global climate change. The more solar and wind power we have now, the less need we have for the gas plant.

CPU’s success with the Community Solar East Project indicates it’s possible to develop community solar projects that have an impact. The popularity of the project is further support for immediately planning to develop more community solar. CPU customers want more solar. The IRP should include the goal of developing more community solar beginning now, not 12 years from now. The IRP should set forth a specific time frame for implementing that goal.

Submitted on 8/6/2024

The proposed Clark PUD (CPUD) Integrated Resource Plan (IRP) is a conservative approach to meet the stated goals for providing reliable electricity supply for the coming twenty (20) years.  I applaud the pivot to abandon the prior ill-fated strategy to rely on the Market to meet our energy needs by abandoning the Slice product.  That approach resulted in almost $50M in annual losses over the past three years. ($11M FY2022, $17M FY2023, over $20M so far in FY2024).

The current strategy is conservatively incremental: buying into commercial wind and solar developments and returning to what was previously termed ‘full-requirements’ status with BPA.  It, however, lacks any innovative approach to meeting our future energy needs as we strive to ‘electrify everything’.  As our prior investment in the River Road Generating plant showed, the only truly reliable generation is that controlled by the PUD.  CPUD has failed to adopt recommendations for greatly accelerating initiatives such as continuous Community Solar.  It also lacks any thinking to innovatively engage with the substantial Public Power presence in Washington State.

Community Solar affords us an opportunity to greatly accelerate Solar adoption – with no direct rate impacts, as the investment costs are borne by ‘subscribers’: the CPUD membership/customers.  Deploying a Community Solar Project every five (5) years is not going to help us reach our goals.  As the second largest Public Power provider in Washington State, CPUD has failed to rally Public Power and provide the leadership to develop a large-scale comprehensive Community Solar strategy.  For example, working through the Washington PUD Association (WAPUDA), CPUD could lead in the acquisition of a large tract of property on the east-side of the Cascades.  This could host separate ‘racks’ for member Public Power utilities, but dramatically reduce costs by sharing a common transmission interface and large-scale energy storage.  We are engaged in replacing large-scale conventional generation (carbon) resources that were financed and shared by multiple Utilities.  This approach effectively minimized costs and serve as a blueprint for how we can pivot now.  The large tract of property could be provided at no cost from the Bureau of Land Management (BLM), as directed by the Biden Administration, but today no evidence exists of CPUD pursuing this option.

By procuring a large tract, CPUD could offer innovative programs such as allowing members/customers to buy solar monthly by allowing subscribers to buy, say, $10 worth of solar per month as a billing item.  That would allow CPUD to continuously increase Solar.  Alternatively, the costs of commercial solar and wind development typically costs at least 30% more due to the costs of financing and bonding, let alone the required profit required for a commercial entity.  Community Solar provides more power, more cost effectively and more quickly.

CPUD is a large Public Power entity and should be approaching the radical changes we need to make with innovation and intensity.  It is not demonstrating the leadership its size and stature allow.  Incremental approaches will not accomplish our stated goals in the timeline we must.

Submitted on 8/5/2024

Hi Clark PUD,

I live on the other side of the county so I am less concerned about the emissions from your plant effecting the air I breathe.
But as a resident of the hills of Washougal I do fear that fire may soon come our way and threaten my husband’s breathing, even my home.

In our neighborhood you have always been quick to get the power back on line when high winds and storms take them down but we must work as fast as we can to stop burning fossil fuels like from your plant. It seems you are leaps ahead of other utility districts with Bonneville as a source of so much power. But replace that gas power plant with renewables and I will do my part and get solar on the roof and hopefully someday in a future summer I might make enough power to send a little back to you.

Please keep working hard to save us from destructive weather. (I lost 12 trees in the last storm. Neighbors lost two, three, four times this) I know if we don’t work fast dangers will only increase exponentially.

Submitted on 8/5/2024

Dear PUD, first of all I would like to say that I am very happy to be part of a public utilities system. Furthermore I am also very pleased with PUD’s pioneering on the community solar projects in Orchards and Washougal. Having said that, I feel that there is much higher urgency than any of our local government (and yours, too) are showing! Global climate collapse is here, right in pur face. Natural gas should not even be on the table anymore. I urge you to exponentially ramp up community solar projects, as well as small scale residential solar, which could be owned/subsidized by you (compare to Germany’s balcony solar strategy). Another idea could be PUD maintaining larger residential solar placements with good exposure, with the home owner getting a reduced rate for the energy produced in exchange for letting PUD use their roof. Our urban infrastructure has so much unused space that could be utilized for solar and or wind- let’s not waste it, and act now, so that our children will have a livable future (and the cats of all us childless cat ladies too)

Submitted on 8/5/2024

RE: comment on Integrated Resource Plan
As a community member, I am hoping you will use money currently spent on purchasing renewable energy certificates for developing warehouse solar capability instead. Flying over western France a few months ago, I was struck by the number of solar panels on top of warehouse roofs. Couldn’t we do the same? Flying into Portland reveals the amount of acreage devoted to flat warehouse roofs, such perfect solar panel territory.
We have solar panels on our roof. They generate energy all year long, even when the weather is grey and rainy. There are only a few months that we have to pay any utility bills at all. Most of all, our little house is not generating pollution or greenhouse gases. Think of all the pollution a warehouse roof would eliminate, particularly if it could replace some of the energy provided by the natural gas plant.
Thanks for giving community members the opportunity to comment on the IRP.

Submitted on 8/5/2024

I am appreciating that “least-cost” power is the theme of responsible resource planning, especially at this time when rates have gone up and so many in our community are struggling to make ends meet. If I am understanding correctly, energy efficiency lowers energy costs, which is why I am in support of having a more efficient (as well as healthy) way of heating my home. I am hoping that Clark PUD will continue to advocate for statewide legislation that allows incentives to be possible for ratepayers who are interested in “fuel switching” , since I have a gas furnace that is aging out and am currently not eligible for incentives through Clark to help me replace my system with a heat pump. With the hotter summers I have had to invest in an air conditioning unit to cool my upstairs bedroom, which adds to the energy cost burden for my home. I urge Clark to amplify it’s track record of exceeding energy conservation goals by stretching even further with progressively more emphasis on pursuing even more ambitious energy conservation goals in the years ahead. Thank you for prioritizing this for your ratepayers.

Submitted on 8/5/2024

We need to continue phasing out dirty energy and bringing in more clean energy. It would be fantastic if we could exceed the state goals by 10 years. Please keep moving Vancouver in this direction. Thank you.

Submitted on 8/4/2024

Residential shares in Community Solar East sold out within a few hours, showing high public demand for participation in renewable energy. Such projects draw on the technical expertise of Clark PUD, leverage the economy of scale, and make solar energy participation possible for many whose homes are not good candidates for solar. Please include more of these projects in the IRP.

Submitted on 8/4/2024

PUD should develop more community solar projects in Clark County. The current ones sold out quickly with very little publicity (I bought some). I know of no market research to determine how much could be developed if there were appropriate sites and active marketing.

Submitted on 8/4/2024

Thanks for exceeding your conservation goals. Instead of purchasing renewable energy certificates (recs), please use that money to develop PV projects in Clark County. There are plenty of sites on buildings and open field for large scale PV projects.

Submitted on 8/4/2024

Dear Clark PUD Commissioners,

Thoughts re: the IRP:

Good work with conservation – let’s see even more of that

Please do not use REC purchases to meet renewable energy goals. Use the money to invest in actual renewable energy sources such as

1. a) community solar projects
2. b) mid-size commercial solar projects
3. c) solar on the tops of warehouses, schools and other large area roofs

Submitted on 8/4/2024

Sent from my iPhone…..  Please  consider more community solar….. it sold out so fast because it’s what people want ….. lots of new warehouses and big apartment buildings going in …. Rooftops save land …..

Submitted on 8/4/2024

Thank you for your work on the IRP. Please prioritize contracting with wind and solar to quickly transition to 100% clean electricity as soon as possible.

Submitted on 8/4/2024

1. I am writing this testimony to express my concerns regarding the operating strategy of our local Clark Public Utilities power plant, specifically the River Road facility. It is my belief that the PUD is not considering all the costs involved in their operations, which may lead to inefficient and potentially harmful outcomes. By neglecting these costs, the true expense of power generation from River Road is not accurately reflected, and it is possible that there are more cost-effective and environmentally friendly alternatives available.

There are four main areas of cost that the PUD is currently ignoring in their operating strategy. First, the issue of carbon pollution needs to be addressed. Although the Climate Commitment Act carbon allowance auctions provide a tangible price per ton, it is crucial to acknowledge that this price may be lower than the actual social cost of carbon. The PUD receives free allowances, and they have the option to either run River Road and forfeit the allowance or purchase clean power and sell the allowance at a future auction. Including the cost of carbon pollution is essential in making informed decisions.

Secondly, the localized pollution caused by the power plant, particularly in terms of NOx and PM 2.5 emissions, cannot be disregarded. While other sources such as cars, trains, and buildings may contribute to overall pollution levels, it does not justify ignoring the potential costs associated with River Road’s pollution. Various estimates exist on the health impacts and economic costs of such pollution, and the community should be made aware of the trade-offs being made. It is crucial to explicitly consider these costs and prioritize the well-being of our community.

Moreover, the PUD should take a longer-term perspective when making operating decisions, as they are not a for-profit company but a public agency. Ignoring the wear and tear on the power plant, or the depreciation, would be contrary to typical business school decision science. If River Road is meant to serve as a valuable resource, whether as a backup or in support of new renewables, it is important to avoid wasting its limited lifespan on low-value production when there are potentially better alternatives available. Including wear and tear as a cost is vital for making informed decisions.

Finally, thermal power plants inherently pose risks and may not always function when needed. River Road has experienced several unplanned outages in the past five years, and other regions have faced difficulties with their coal, gas, and nuclear plants. The Columbia Generating Station also encountered issues during startup. Given the high temperatures and numerous moving parts involved, problems are inevitable. Thermal plants require backup resources or significant redundancy to minimize disruptions. While the Northwest has been fortunate to have ample hydro backup from the region and Canada, it is important to recognize that this backup has associated costs.

Currently, the PUD appears to be solely considering the cost of fossil gas when determining how to utilize River Road. In my opinion, this approach does not effectively utilize ratepayer funds and overlooks or downplays the costs outlined above. While some pollution may be unavoidable, it should only occur for exceptionally compelling reasons.

I acknowledge that there may be gaps in this testimony or areas where the logic could be further strengthened. However, I believe it is crucial to combine concerns over both types of pollution with rigorous accounting principles. Accountants are skilled at quantifying and evaluating various factors, making it difficult to dispute their findings. It is my hope that by addressing these issues, we can encourage the PUD to make more informed decisions that prioritize the well-being of our community and utilize our resources more wisely.

Thank you for your attention to this matter.

2. The Solutions that can be Named are not the Solutions | Frankly 67 23 minutes 25 seconds https://youtu.be/1ea4hmI2xmk?si=gHCx6eCPn-OMfrzf

The speaker outlines the “human predicament” we face – our unsustainable global energy use, ecological overshoot, and the complex challenges of climate change, biodiversity loss, and more. However, the speaker is hesitant to propose specific “solutions,” arguing that this is more of a “predicament” than a problem with clear fixes.

The speaker explains that responses to this predicament need to consider multiple dimensions – the superstructure of ideas/values, the social/economic structures, and the physical infrastructure. Solutions must also account for different scales (individual, local, global) and timelines (pre-crisis, crisis response, long-term).

The speaker argues that publicly presenting “solutions” can be counterproductive, as human systems quickly adapt and respond to new information. The most effective responses may need to remain unseen or unpopular. The speaker also acknowledges the difficulty in knowing the right path forward with certainty.

Instead, the speaker emphasizes the importance of first helping people understand the fundamental dynamics at play – the interconnections between energy, money, technology, and environmental impacts. From this foundation, individuals can then determine their own values and strategies for navigating the challenges ahead.

3. Overshoot and Its 7 Fundamental Drivers | Frankly 68 16 minutes 47 seconds https://youtu.be/ZDN8ABCIDyg?si=sZL_DtBjL0Tt_CLS

Here is a concise summary of the key points from the video: The video discusses the concept of “overshoot” – when a species grows beyond the carrying capacity of its environment. The speaker argues that humanity is currently in a state of overshoot, driven by 7 fundamental factors:

1. The “carbon pulse” – the sudden influx of ancient, stored energy (fossil fuels) that has enabled human population and consumption to explode.
2. Financial systems that discount the environmental costs of growth and resource extraction.
3. Governance and decision-making being outsourced to financial markets focused on short-term growth.
4. A widespread lack of ecological literacy and understanding of environmental limits.
5. Cultural emphasis on status, consumption, and “dopamine-driven feedback loops” that promote unsustainable choices.
6. Cognitive dissonance that prevents people from fully grappling with the implications of overshoot. The speaker suggests some potential “antidotes” to overshoot, including reducing energy surplus, the planet imposing its own limits, a cultural shift towards an “earth-centered” worldview, and developing more sustainable, synergistic technologies. Ultimately, the video calls for greater individual and societal recognition of humanity’s overshoot of ecological boundaries.

Submitted on 8/3/2024

Hello Clark PUD,

First, thanks for providing my home with reliable power for the 6 years I’ve lived in Vancouver.

I’m very concerned about climate change, and it’s impacts on our area. In addition to the highly visible fires, heat waves, and declining salmon runs, there are hundreds of other impacts.  Note that climate change will reduce late summer snow melt, impacting the amount of hydropower available in hot summers for AC loads, even as those loads increase.

We all must do our part to decarbonize as quickly as possible. This is why my home is solar powered, and why we replaced our gas furnace with a heat pump.

In reviewing the new Integrated Resource Plan, I see aspirations to support decarbonization, but not a sense of urgency.  I’d prefer to see a plan to reduce operating hours of the gas plant to zero over the next decade through:

• Coordinated development of renewable assets and battery storage (BESS) in Clark County
• Incentivizing rooftop solar, BESS, heat pumps and other solutions to eliminate burning gas
• More Public charging infrastructure and EV incentives, Vehicle to Home (V2H) support
• Implementation of demand response systems, this starts with smart time of use pricing to reduce demand at times when the gas plant would otherwise be required.
• Pursuing building codes that ensure energy efficiency and electrification

Keep up the good work, but let’s move faster and with purpose to make Clark County part of the solution to climate change, not part of the problem.

Submitted on 8/3/2024

I have asthma and it is definitely exacerbated by air pollution.  I am concerned about air pollution by the River Road Gas Plant.  Please consider replacing that source of energy with renewables.  Also please consider incorporating more community solar.  There seems to be a demand considering how many people have participated in local existing projects and that there are people who want to participate but there is no more space.  Thank you for all of your conservation efforts.  I am concerned for myself and my family.

Submitted on 8/2/2024

Please transition to fully renewable energy sources, especially wind and solar, ASAP.  The children need your leadership.  Community solar is very popular.  How about starting 3 more projects like the one in Camas-Washougal.

Submitted on 8/2/2024

To whom it may concern,

In regards to the current IRP you are considering, I would like to submit some comments.

1. Instead of purchasing renewable energy certificates, why not use that money to develop renewable energy projects in Clark County, for example on top of warehouses, parking lots, grocery stores, etc. And,

2. Be more aggressive with community solar. Where and when is the next project? The last project sold out quickly. Have we satisfied individual, business, or municipal demand for more community solar?

Submitted on 8/2/2024

Our gas plant was constructed  to be flexible in order to integrate intermittent energy resources.  Please take advantage of that flexibility by acquiring more renewables! Instead of purchasing renewable energy certificates,  for instance, why not use that money to develop renewable energy projects in Clark County like  solar energy on top of warehouses.   Combating climate change is important to me. The natural gas power plant puts carbon in the air.  I want my Public Utility Company to use more renewable energy like wind and solar.

Submitted on 8/2/2024

Dear Madams and Sirs:

It’s great that you exceeded our conservation goals.  More must be done.  Nuclear is one way of bridging the energy needs.  It has almost no air pollution.  We all hate air pollution.

My adult son has asthma and air pollution worsens it. We need more solar projects.  We need to reduce tree destruction.

Thank you for reading my comments.

Submitted on 8/2/2024

1. Thank you, Clark Public Utilities, for utilizing more “clean” energy in the future. (Ex: Figure 27 shows an increased percentage of energy from solar and a decrease from  natural gas.) Is that enough — and soon enough — to address climate goals?
2. To offset the recent rate increase to customers, could Clark PUD offer tiered pricing? (Ex: My friend in Germany runs her dishwasher after 9 p.m. because electricity is cheaper then.)
3. The July 30 (?) issue of the New York Times had an article about small, affordable, plug-in solar panels available in Germany to residential customers. The price was under $300.
4. Please continue to offer community solar projects, and allow greater participation.

Submitted on 7/27/2024

Do the NPVRR calcs for WRAP vs no WRAP (page 65) include any estimation of the costs of a major outage or shortage (multiplied by probability of the event with WRAP vs no WRAP)?  The whole point of a RA initiative is to prevent a major supply problem so there has to be some benefit to that insurance or why bother with RA?  Even though the likelihood of an extreme event is small, the costs are large and this past winter should be a reminder of the potential costs.  We’re never going to estimate the probabilities and total costs precisely but some amount of avoided cost or insurance benefit to being resource adequate ought to be included in any NPVRR.  Otherwise, NPVRR calcs would seem to lead us to delay RA indefinitely.  Thanks!

Submitted on 7/23/2024

How has the cost of power from BPA compared to RRGP output over the last decade on a yearly average basis? The monthly numbers in most monthly financial reports typically show BPA power running somewhat cheaper than RRGP. Thanks!

Submitted on 7/21/2024

Do you have any info on how our local rates compare to other nearby utilities and across the nation? I find that a lot of ratepayers, especially those that have lived in Clark County for some time, aren’t aware of just how low our rates are and what a tremendous value we are getting from our public utility.

On a similar note, a lot of ratepayers aren’t aware of just how reliable our local distribution system is compared to other utilities. Do you have any quick reliability data that you could share? The utility has done a great job of proactive tree trimming and undergrounding distribution where possible. I’d recommend continuing to emphasize those areas and really look to underground as much as possible.

Also, there seems to be wide confusion as to whether outages are caused by distribution problems or supply problems. Have we ever had an outage caused by lack of supply?

Thanks!

Submitted on 7/21/2024

Thanks as always for the opportunity to provide public comment. Could staff please explain the last sentence on page 7, paragraph 1 “Additional utility-scale renewables will only be added to the resource portfolio when the load/resource balance shows that new resources are needed from an energy perspective.” Given the significant investment in making River Road more flexible, I’d assume the utility would be open to procuring more utility-scale renewables if they are cost effective and can be easily integrated into our resource mix? A flexible River Road could balance (or integrate) a whole lot of new renewables and I’d hate for us to be passing up opportunities to reduce pollution and save rate payers money. Thanks!

Submitted on 7/20/2024

To Clark Public Utilities regarding your 2024 IRP. The quotes are from your IRP.
1. Quote: from section 1.7. “CPU has a considerable deficit in capacity to meet (peak) capacity demand and, without the implementation of a comprehensive and well-planned strategy, would likely see that deficit increase to as much as 750 MW by 2044. CPU will leverage all the tools available to meet this need reliably, affordably, and sustainably. These tools include optimization of BPA Tier 1 power, CPU’s RRGP, renewables, [add conservation] and battery storage options.”
2. Quote: “CETA requires that all utilities in Washington must supply carbon neutral electricity by 2030. Although CPU retains the flexibility to include carbon-emitting resources in its portfolio equal to up to 20 percent of its retail load until 2045, any carbon emissions generated from these resources must be offset by the procurement of renewable energy credits or the investment in renewable energy projects. In addition, when contemplating such resources, the societal cost of carbon must be included in the evaluation.”
Question 1a: Elsewhere the draft IRP says you have already purchased RECs to comply with the EIA. Please elaborate. Why purchase RECs instead of developing local solar projects here?
Question 1b: Please discuss in detail the types of renewable energy credits (recs), and investments in renewable energy projects (I-REP) you might pursue to offset emissions of your gas plant after 2030.
Question 1 c: What do you think of developing your own RECs by developing local solar projects such as on warehouses?
Question 1d: If BPA accepts you as a load following customer, will you be able to retire your gas plant before 2035?
Question 1e: Do you know where BPA will get the resources to provide for our load growth?
3. Quote “Based on market data, the cost of battery storage, fixed for a 15-year term, is assumed to be $144/kW-yr in 2027.”
Question 2a: Could you define “kilowatt-year? Google wasn’t much help.
4. From the last page of the IRP. “CPU will continue to support any additional community solar opportunities that may arise. “
Question 3a: Instead of waiting for a project to arise, why not make opportunities arise?
5. Quote: “The goal of this 2024 IRP is to forecast the future electric demand of our customers and to identify the optimal mix of resources that is affordable and reliable while meeting regulatory requirements and social expectations of our community. “
Question 4a: I’m glad you want to meet the social expectations of the community. Many people would like you to reduce emissions as fast as possible. Do you want to look for ways to shut down the gas plant for longer periods of time?
6. Quote: CPU is currently a purchaser of RECs from Idaho PURPA solar generation facilities which contribute to satisfying CPU’s EIA renewable requirements.”
Question 5a: How much are we spending on this?
Question 5b: How do we benefit from these RECs?
7. Quote: “The Inflation Reduction Act impacts numerous sectors including energy, manufacturing, environmental, transportation, agriculture, and water, with a primary focus on the electric industry.”
Question 6a: How will the Inflation Reduction Act benefit Clark Public Utilities?
Question 6b: Washington State has received about $160 million from the Federal Solar for All Program. Is Clark Public Utilities working on an application for some of those funds?
8. Quote: In Section 1.7 you say “CPU will leverage all the tools available to meet this need reliably, affordably, and sustainably.”
Question 7a: Does the Climate Commitment Act help you meet those goals?
Question 7b.: Have you received any funds from the Clean Fuels Program?
9. Question 8a: In July of 2024, Bloomberg reported that the price of large batteries in China have fallen 51% this year $53 per kwh. Is that reflected in the graph of expected battery prices?
10. Question 9a: What does ICE mean in this sentence: “For carbon pricing the IRP uses recent auction settlements and bilateral Washinton Carbon Allowance (WCA) and California Carbon Allowance (CCA) trades on ICE” ??
11. Question 10 a: In section, under least cost option it says : Reducing plant generation will also result in reduced carbon emissions as CPU will be looking for opportunities to displace RRGP generation with surplus carbon-free resources. Consider replacing the expression “surplus carbon free resources” with “surplus carbon free resources plus new local carbon free resources developed by Clark PUD”.

Submitted on 7/18/2024

Thank you for making it easy for the public to comment on this IRP! As always, CPU should be commended for their focus on reliability and affordability. Public power in Clark County provides tremendous value to our community and we are lucky to be served by a world class local utility.

In a first reading of this IRP, it appears that CPU is using State mandates (the law) as a goal for reducing GHG (green house gas) emissions and other criteria pollutants. Compliance with the law does not seem to be an overly ambitious goal considering that the majority of rate payers (in addition to world class reliability and lowest in the nation power costs) would also like to see as rapid as possible pollution reduction. Compliance is not really a strategy but a simple expectation. Has CPU considered more aggressive pollution reduction goals and is there any analysis showing the impact of different reduction paths on rates and reliability? Thanks!