By Lindsay Beebe, Senior Campaign Representative, Sierra Club Beyond Coal Campaign
One summer morning in 2019, in the shadow of the Gatsby Power Plant smokestacks, a group of thirty people gathered in Salt Lake City outside the headquarters of Rocky Mountain Power, a PacifiCorp company. We stood on the sidewalk in clumps, maskless, exchanging warm greetings and hugs. Some pulled on kelly green t-shirts, emblazoned in white with the broad lettered demand to “Act on Climate.” Others milled restlessly, pondering aloud to no one in particular about what to expect from the day. We had come from across the state, by train and by car and by bike, at 9:00 AM on a Tuesday to attend a little-known meeting of utility and energy executives, state regulators, and advocates, called the Integrated Resource Plan Public Input Process. Each of us came for very personal reasons, some with their motivation [children & grandchildren] in tow, to bear witness to the tediously technical process of long-term resource planning for the largest coal-owning utility in the West.
Once we made our way inside and past the security ID checkpoint, we were escorted in small groups past a series of magnetic card entry doors into a slightly stuffy room with high windows, a large horseshoe-shaped table at its center, and folding chairs lining the walls, presumably for us. People in suits ringed the center table, and there was an expectant air since the presence of so many members of the public at the Public Input Meeting had also drawn the attendance of a news camera and the CEO of Rocky Mountain Power, Mr. Gary Hoogeveen. We were informed of the tight agenda, but that everyone would be allowed to go around the room and introduce themselves quickly. Names and business titles started spewing forth in perfect monotonous brevity. Then a green-shirted girl of about seventeen stood, “My name is Rachel. I’m a resident of Ogden, a daughter, a student, and president of the Davinci High Environmental Club. I’m here today because I’m terrified of the world I will inherit, and I want my utility to plan for my future by transitioning to clean energy as quickly as possible.” Chairs creaked in the silence that followed.
Next to rise was a mustachioed grandfather, his young granddaughter on his hip dwarfed in a green t-shirt down to her ankles. Then a mother of two young children spoke, one of them still in the stroller plopped incongruously amidst office furniture and briefcases. Next, a pediatrician, then a retired high school English teacher, a mother and teenage daughter, and two college students from the University of Utah each rose in turn to share their identity, which communities they came from and loved, and their hopes and fears for the future. Needless to say, introductions took longer than usual that day.
In 2019, PacifiCorp had just released a long fought-for economic analysis of its aging coal fleet. Through various regulatory pressures, the Company had been forced to publicly admit that 60% of the coal fleet was uneconomic, meaning that it would be cheaper to close the plants than to continue to keep them running. We were there to ask the Company, with this new information on the table, what their plan was to transition to a fully decarbonized electricity supply by 2030, as the best science on climate change demands. We were told that day by the senior planner in the room that Pacificorp was not the Company that would make grand climate announcements or even set the most basic emissions reduction goals. Instead, he assured us that we would see PacifiCorp’s commitment to sustainability by their actions. Judge them by their actions, we were asked.
It has been two years, including more than 18 months of an updated planning cycle for the 2021 Integrated Resource Plan (IRP), and the receipts are in. PacifiCorp filed its 2021 IRP on September 1st in each of the six state public utility commissions in which it does business. The Company has kept only part of the promise it made to its customers that day in June, 2019. To date, they are one of the last major utility companies, and the only one in the Western United States ravaged by wildfire and drought, not to commit to an emission reduction goal or climate resilience plan. The “Action Plan” in the 2021 IRP is the first five-year window of the 20-year plan. Little has changed since the 2019 Action Plan, with the only new coal “retirement” in the action window coming from a plan to convert two units at the giant Jim Bridger coal plant in Wyoming to fracked gas. Taking into account commitments made in 2019, that leaves 16 of the company’s 22 coal units burning past 2025, including some of the largest units running well into the 2030’s. Utah’s 1,500 MW Hunter plant is slated to burn coal into 2042, more than a decade past when the best climate science demands we stop burning coal altogether, and despite being the second largest polluting coal plant harming America’s National Parks.
If this sounds like dismal climate news and an abdication of a public utility’s moral responsibility to serve it’s communities, that’s because it is. But even putting aside the impending climate catastrophe, the plan is a fantasy. The 2021 IRP falls short simply by failing to accurately account for the resource and regulatory realities in which PacifiCorp must do business. With a six-state service territory, there’s no denying that comprehensive utility planning is complex. But, that doesn’t give the utility license to ignore federal and state laws in the process.
Oregon, Washington, and California all have state laws on the books that disallow coal in utility rates by 2025 or 2030. Together, those states represent a third of PacifiCorp’s customer base. Yet, the Company plans to maintain more than 4,200 MW of coal capacity past 2030. The Company has also yet to produce an approved Clean Energy Transition Act plan that satisfies Washington law, despite repeated delays and overdue deadlines, or account for a new Oregon law that demands carbon free electricity by 2030. Presumably, the Company is gambling that its eastern states will accept a transfer of liability for all coal assets, which means that Utah, Wyoming, and Idaho customers will be on the hook for an increasing share of expensive, increasingly unreliable power, when cleaner and cheaper options are readily available.
To add insult to injury, PacifiCorp has spent years and millions of dollars fighting clean air protections on their coal plants in Utah and Wyoming. Since 2013, four of PacifiCorp’s dirtiest coal plants have been tied up in one lawsuit after another as they fight the installation of common-sense pollution controls that have been installed at over 200 plants across the county. For close to a decade those plants have been allowed to spew thousands of tons of nitrogen oxide pollution into National Park airsheds in violation of the Clean Air Act, recently aided and abetted by a Trump Administration ravaging the watchdog agencies meant to protect our health. Now, with a renewed Biden-backed EPA, the loopholes to avoid compliance are closing. And still, in the 2021 IRP, PacifiCorp has refused to model the economic impact of their coal plants, should pollution controls be required, despite the fact that one unit has an EPA mandate to install what’s known as Selective Catalytic Reduction (SCR) technology by the end of this year or close. In other words, the utility has refused to produce even a single planning scenario that complies with federal law.
At this point you may be wondering how we got here. Is it malfeasance or incompetence? Whether either or both, the path to the 2021 IRP has been paved with secrecy, confidentiality, and a lack of accountability. These tools for hoarding power have allowed the monopoly utility corporation, one of the largest in the country, to avoid scrutiny and produce a 20-year plan that is neither lawful nor moral. Public stakeholders were not allowed access to even the most initial modeling results until the last two months of an 18-month planning period. Repeated requests for vital model assumptions were met with the response to “see workpapers after the filing,” and after any influential input into the modeling process could be made. New resources, like the wildly unrealistic advanced nuclear plant slated to be operational in just seven years, were “locked-in” to the model without notice or stakeholder discussion. For all these reasons, and more, the state utility regulators in PacifiCorp’s six states have an obligation to disacknowledge the results of this 2021 Integrated Planning, and to send PacifiCorp back to the drawing board.
The bottom line is that this utility refuses to take climate change seriously, despite the irrefutable evidence that increased drought and wildfires are already severely impacting the health and well-being of their customers and the security of the regional power grid. PacifiCorp is one of the country's largest greenhouse gas polluters, which means their responsibility to act is greater than almost any other single entity in the West. New, modest gains in near-term clean energy commitments, while maintaining a massive coal burning capacity into 2040 and beyond doesn't cut it. As a monopoly corporation that has been using millions of publicly furnished dollars to fight pollution controls on their coal plants, ignore climate science, and waste years of precious time with inaction, PacifiCorp owes us more. They owe Rachel, the student leader from Ogden, more. They owe each one of us a long-term utility plan that meets the demands of a changing climate, implemented at a scale and pace determined by the realities of existing state and federal law and the best climate science.
We each have the opportunity to ensure that our Public Service Commissioners represent our best interest. Deliberation on the 2021 Integrated resource plan will take place over the next five months. You can submit your comment, urging the commission to not acknowledge this IRP, to PSC@utah.gov with the Subject: “Public Comment on Docket No: 21-035-09.”