TALKING POINTS
• The consensus among the world’s climate scientists is solid: The leading cause of the climate change we are now experiencing is increasing CO2 emissions caused by the burning of fossil fuels. According to the UN Environment Programme (UNEP) annual emissions gap report, global CO2 emissions must fall by 7.6% every year from now until 2030 to stay within the 1.5C ceiling on temperature rises that scientists say is necessary to avoid disastrous consequences.
• NorthWestern Energy has eliminated renewable energy (called in the Plan as the “No Carbon Option”) as the primary source of procuring future electricity generation because it would cost $523 million more than the fossil fuel option. This cost entirely ignores the cost of the worsening impacts of climate change, which would be far greater than the cost of moving towards sole reliance upon carbon-free electricity generation.
• NorthWestern has the human resources and technical tools to fully incorporate renewable energy into its electricity generation portfolio. The higher financial cost of full incorporation of carbon-free electricity generation in NorthWestern’s system must be paid by the utility’s owners and its ratepayers. Otherwise, future generations will inherit from us living conditions that are degraded and increasingly life-threatening.
• NorthWestern dismisses geothermal generation as “too expensive.” Montana has substantial geothermal resources that should receive NorthWestern’s full evaluation.
• The potential of carbon-free nuclear energy (Small Modular Nuclear Reactors) is mentioned in NorthWestern’s plan but not considered as a source of generation. Citizens are understandably reluctant to embrace nuclear energy because of the accident history and risks of storing nuclear waste. However, there are currently fifty eight operating nuclear power plants in the United States and two new ones under construction. The risks of nuclear power generation pale in comparison to the certainty of a degraded global environment caused by fossil fuel generation and its increasing CO2 emissions. NorthWestern should fully evaluate the potential of this source of electricity generation.
• Cryptocurrency operations in Montana are extremely large energy consumers. Such operations in Butte will consume more energy than the entire city. They enrich a very few persons while depriving Montanans of extremely valuable energy resources. Four electric utilities in the U.S. have imposed moratoriums or other limits on cryptocurrency mines. NorthWestern should do the same.
• The Montana Public Service Commission must require NorthWestern to establish the goal of lowering its CO2 emissions to 80 percent of the current level by the year 2050. Provide your comment to the PSC. The deadline is January 3, 2020.
• Attend the listening session in Missoula Tuesday, December 17, 4 PM, Missoula Public Library.
• Use the online tool provided by the Montana Environmental Information Center https://meic.org/2019/11/submit-public-comment-on-the-northwestern-energy-resource-plan/
• Mail your comment before December 31st to: Montana Public Service Commission, Northwestern 2019 Electricity Procurement Plan, PO Box 202601, Helena, MT 59620-2601
SAMPLE COMMENT
Gary Matson
(Address)
(Email address)
(Phone number)
December 17, 2019, Comment for MPSC listening session, Missoula
NorthWestern Energy 2019 Electricity Supply Resource Procurement Plan
I speak as a 52-year customer of Montana Power and NorthWestern Energy, as a biological scientist, and as a grandfather with 4 grandchildren ages 12 to 21. I am appreciative of the excellent service I’ve received from MPC and NorthWestern over the many years. I’ve had nothing but good experiences with personnel, and service interruptions are rare. On a winter morning I can enjoy warmth, light, and coffee in the comfort of my home.
I have read all 200 plus pages of NorthWestern’s Plan. I am better aware of the complexities involved with operating a dependable utility. I applaud the Plan’s goal to meet customers’ needs “with reliability at the lowest cost.” The plan appears to do a thorough job of meeting this goal but has a tragic flaw. The flaw is in the consideration of cost. The climate change costs of current and increasing CO2 emissions are entirely ignored. NorthWestern’s plan identifies fossil fuel generation as “lowest cost.” Its true cost is greatly underestimated because it externalizes the costs of climate change caused by increasing CO2 emissions.
The long term objective of the Plan must be re-stated: “To provide a stable, reliable energy portfolio which will by the year 2050 be at least 80% below current levels of CO2 emissions.”1,2 It can be assumed that NorthWestern’s internal costs of reaching this goal will be the lowest possible through use of the RFP process. The externalized costs to all of us, should this goal not be met, are incalculably greater.
We know these things about CO2 emissions and climate change:
- CO2’s warming effect on our atmosphere is a well understood scientific fact
• There has never been greater worldwide scientific agreement that the burning of fossil fuels is the primary cause of increased CO2 and the accompanying climate change
• Atmospheric CO2 concentration has steadily increased from the pre-industrial level of 280 ppm to today’s 400+ ppm. “Today’s rate of increase is more than 100 times faster than the increase that occurred when the last ice age ended.” (NOAA, Earth System Research Laboratory, Global Monitoring Division).
• As reported by the World Meteorlogical Organization, CO2’s effect in the atmosphere lasts for centuries. Even if we added no more CO2 the climate changes we are now experiencing will continue into the future.
• Scientists’ predictions about climate change have been conservative. Severe climate change consequences are occurring sooner than predicted.
NorthWestern shares with all of us in a responsibility to lower our carbon impact. The utility now generates 61% of its power from renewable, hydro sources. Even though its rate of CO2 emissions per unit of power generated decreases in the future, it’s proposed selection of natural gas to fuel future electricity generation will drastically increase CO2 emissions. For example, if 200 MW of gas-fired generation is added each year for four years, the resulting increased CO2 emission would be over 1.6 million tons of CO2 added to the atmosphere each year even if the generators operated only 50 percent of the time.3
I appreciate the many factors NorthWestern has considered in its Plan: Providing reliability while incorporating variable, renewable energy sources; upgrading the transmission system; increasing regional cooperation among utilities; minimizing environmental and monetary costs. In spite of obstacles, I believe that NorthWestern can be successful in achieving a re-stated goal to achieve by the year 2050 a CO2 emission level that is at least 80% below the current one.
Four related observations:
1. Cryptocurrency operations in Montana are extremely large energy consumers. Such operations in Butte will consume more energy than the entire city. They enrich a very few persons while depriving Montanans of extremely valuable energy resources. Four electric utilities in the U.S. have imposed moratoriums or other limits on cryptocurrency mines.4 NorthWestern should do the same.
2. Geothermal electricity generation was dismissed from consideration in the Plan, presumably because of its cost. The cost considered is a direct cost, excluding the reduced externalized cost of climate change. Geothermal energy utilization has a carbon cost of near zero, offsetting the initial cost of $1,870/kW and up, depending upon site location.5 According to Montana DEQ, Montana “has the potential to develop significant new sources of geothermal energy.”6
3. Small Modular Nuclear Reactors (SMRs) are mentioned in the Plan but not formally considered. The Utah Associated Municipal Power Systems (UAMPS) formally launched the Carbon Free Power Project (CFPP) in 2015 as part of its long-term strategy to reduce carbon emissions and replace aging coal-fired plants with a non-fossil fuel, and medium-sized, flexible power generating source. The 720 MW project is expected to be operational by 2027.7 In spite of our aversion to nuclear power, because of the concerns arising out of accidents and disposing of waste, there are currently fifty eight operating nuclear power plants in the United States and two new ones under construction. The risks of nuclear power generation pale in comparison to the certainty of a degraded global environment caused by fossil fuel generation and its increasing CO2 emissions.
4. NorthWestern’s full scale adoption of renewable electricity generation will be an essential contribution to lowering our collective carbon footprint in two ways: 1) Removal of CO2 emissions from electricity generated for light and heat; 2) Lowering CO2 emissions in the transportation sector by enabling electric powered vehicles to be recharged with renewable energy.
NorthWestern must fully evaluate these four factors as important considerations in meeting its goal of providing stable, reliable energy to its customers at lowest cost, and at the same time lowering CO2 emissions.
I applaud NorthWestern’s environmental stewardship and its efforts to increase energy efficiency through demand side management. I applaud its community renewable energy pilot projects that are underway. I applaud the “staged approach” directing future electricity procurement. The time for action to reduce our carbon footprint is now. I believe that NorthWestern has the tools to make that happen by revising its Plan to include drastic CO2 emissions reduction in its goal of supplying stable, reliable energy at the lowest possible cost.
Citations
1. Page 9-13 of the Plan. California CO2 reduction target is 80% below 1990 levels by year 2030
2. Utility Drive. https://www.utilitydive.com/news/the-unknown-costs-of-a-100-carbon-free-future/561639/ Six states enacted ambitious laws requiring them to be at or near 100% renewables and zero emissions by mid-century.
3. See Calculations, Page 4
4. Site Selection Magazine. https://siteselection.com/investor-watch/cryptocurrency-miners-reveal-the-site-selection-process-that-led-them-to-montana.cfm Out of concern for the strain on the electric grid, four electric utilities in the U.S. have imposed moratoriums or other limits on cryptocurrency mining, joining five cities in New York and Washington and several cities in Canada.
5. International Renewable Energy Agency. https://www.irena.org/-/media/Files/IRENA/Agency/Publication/2017/Aug/IRENA_Geothermal_Power_2017.pdf
6. Montana DEQ, Geothermal Energy in Montana. http://deq.mt.gov/Energy/renewableenergy/Geothermal
7. Idaho National Laboratory. https://inl.gov/article/frequently-asked-questions/
Calculation of CO2 for 800 MW added natural gas generation
By Gary Matson 12/6/19 (not a mathematical genius but pretty sure calculations are correct)
Sources: U.S. Energy Information Administration; World Resources Institute (2018 CO2 global emissions)
Heat rate of natural gas – 7812 Btu/kWh
CO2 emissions 53.07 Kg/1,000,000 Btu = .00005307 Kg/Btu
For 1 MWh, 7812 Btu/kWh X 1,000 kWh/MWh = 7,812,000 Btu/MWh
For 800 MWh, 7,812,000 Btu/MWh X 800 = 6,249,600,000 Btu/800 MWh
CO2 emissions, 800 MWh, Kg – 6,249,600,000 Btu X .00005307 Kg/Btu = 331,666 Kg CO2
CO2 emissions, 800 MWh, Lb - = 331,666 Kg X 2.2 Lb/Kg = 729,666 Lb CO2/800 MWh
CO2 emissions, 800 MWh, Tons = 729,666 Lb / 2,000 Lb/Ton = 364.83 Tons/800 MWh
CO2 emissions, generating 50% of the time year-round
Generating 24 Hr/day, 183 days/yr = 4,392 Hr
4,392 Hr X 364.83 Tons CO2/800MWh = 1,602,333.36 Tons/Yr CO2 when 800 MW generating 50% of the time