Wind Power and Clean Energy Policy Perspectives Benton PUD
Rick Dunn, General Manager
Commissioners:
Barry Bush, Jeff Hall, Lori Sanders
July 14, 2020
Executive Summary
Clean energy technology and public-policy development continue to be in the news and at the forefront of much political debate and discussion. While wind power has emerged as a popular choice for helping meet greenhouse gas emission reduction goals, reasonable questions continue to be raised regarding its ability to cost-effectively contribute to the powering of modern civilization and how the lifecycle environmental and ecological impacts compare to other types of technologies. With Washington State’s passage of the Clean Energy Transformation Act (CETA) in 2019 and the current schedule for expiration of renewable energy federal tax credits, there is a resurgence in proposed wind power development activity in the Pacific Northwest (PNW), including projects proposed for eastern Washington and Benton County specifically. As developers and many elected officials tout the economic and environmental benefits of wind farms, Benton PUD believes it is important for our customers and the general public to hear utility perspectives. Unlike the narrower focus of some wind power interests, utilities must balance environmental benefits and concerns with costs and power grid reliability; and we will be held accountable if we fail on any of these dimensions. While Benton PUD acknowledges wind power development in the PNW will likely continue as Washington State utilities respond to the 2025 CETA deadline for eliminating coal-fired energy and in response to nearby state and corporate clean energy mandates and goals, we do not support further development of wind power in the PNW for the following primary reasons:
1) Benton PUD’s current power supply is hydro and nuclear based and is over 93% “nonemitting” by Washington State standards. While we are ahead of the clean energy curve, we do experience supply deficits during hot summer months and deeply cold winter periods. To cover these deficits, we make power market purchases from generation resources that can be counted on to run on the days and hours needed (dispatchable). Since wind power relies on natural weather conditions decoupled from electricity demand, it is not dispatchable generation and therefore will not help us resolve our seasonal energy deficit problems.
2) The PNW’s hydroelectric generation resources are the foundation of a reliable and clean energy supply that has historically resulted in Washington State contributing no more than 0.5% to the nation’s annual total greenhouse gas (GHG) emissions from electricity production; even with soon to be retired coal-fired power plants in the mix. Further development of wind power in the PNW will not result in consequential reductions in national or global GHG emissions attributable to Washington State utilities and will do very little to mitigate the increasing risk of northwest power grid blackouts; which could grow to a 26% probability by 2026 if utilities are unable to replace the reliable generating capacity of shuttered coal plants.
3) The low availability of wind power requires utilities to continue paying for dispatchable generation capacity that may run infrequently but is still sized to meet most of the peak energy demand on the grid. This “double paying” is why electricity rates in countries and states with high wind penetrations are rising despite the declining costs of this popular renewable energy source. Benton PUD believes further wind power development will unnecessarily contribute to increases in northwest utility retail electricity rates which could erode the economic development advantage low rates has given our region for many years.
4) Energy production from wind farms in the PNW is often high during periods of maximum hydro generation contributing to energy gluts that can drive short-term market prices to zero or even to negative values due to federal tax credits received by wind power. To minimize the net cost of hydro generation the region needs for year-round flexible and reliable electricity, the value of surplus hydro energy sales needs to be maximized. Building more wind farms in the PNW will contribute to untimely energy supply gluts and low shortterm market prices which reduces surplus hydro energy sales revenues, increases net hydro power costs and puts upward pressure on retail rates Benton PUD and other utilities charge our customers.
5) Benton PUD believes the best long-term, sustainable and environmentally responsible strategy toward meeting the CETA goal of 100% clean electricity in Washington State by 2045 could be to transition coal power to natural gas and then natural gas to nuclear. It is estimated wind power requires 30 to 45 times as much land and about 10 times as much concrete and steel to produce the equivalent power of nuclear. In addition, a recent study estimates that assuming hydro and nuclear power in the PNW stay in place, meeting a theoretical 100% clean electricity goal in our region using wind (and solar) power would require a land area 20 to 100 times the area of Seattle and Portland combined.
6) Benton PUD supports Energy Northwest (EN) in their efforts to develop small modular reactor (SMR) technology. However, we are concerned continued large-scale investments in PNW wind power projects will contribute to increases in the normally surplus annual energy supplies in the region thereby eroding the hourly energy supply opportunities needed by SMRs to achieve economic feasibility. Maintaining the existing Columbia Generating Station operations while expanding SMR technology development and possible manufacturing in the Tri-Cities represent opportunities for economic stability and growth in an area with a long history of grid-scale energy production and world class scientific research capabilities. As some legislators and certain advocacy groups continue to call for more wind power while simultaneously calling for removal of hydro-electric dams, Benton PUD believes it is important for our customers and citizens of Washington State to hear the utility side of the energy story. To this end, we are committed to facilitating education and outreach efforts based on the premise that all energy choices represent economic and environmental tradeoffs and that consideration of utility business models and the physics of the power grid matter when taking a position to promote one form of power generation technology over another. Existing wind farm development in Washington State and along the northern Oregon border has already resulted in the industrialization of previously scenic hillsides, canyons and desert vistas in the region in and around Benton County. Before Benton PUD customers and citizens throughout our region accept further sacrifice of the natural beauty and open spaces that are part of our way of life, we want them to know there are other options we should be asking our legislators and utility industry leaders to urgently and seriously consider. This is the reason for this report and for our formal declaration that Benton PUD does not support further development of wind power in the PNW.
The full report can be found at:
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Washington Department of Commerce: 2021 Energy Strategy: Transitioning to an Equitable Clean Energy Future
This is the draft of latest state energy plan with over 100+ pages. It can be found at:
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The following draft report is the response of the Benton County PUD to the 2021 State Energy Strategy report:
Below is the report without graphs and some additional documentation:
December 11, 2020
Ms. Kate Kelly Senior Energy Policy Specialist Energy Division energystrategy@commerce.wa.gov
RE: Comments by Benton PUD on the First Draft of the 2021 Washington State Energy Strategy
Ms. Kelly: Thank you for the opportunity to provide comments on the draft 2021 Washington State Energy Strategy (SES). Benton PUD (BPUD) is an electric distribution utility located in Kennewick with over 55,000 metered accounts and is a preference customer of the Bonneville Power Administration (BPA). Over the years BPUD has been actively engaged in trying to help shape clean energy policies in Washington State. We have invested significant time and money to help the state legislature and the governor’s office to better understand electric utility perspectives when it comes to balancing environmental benefits and concerns associated with particular types of generating technologies with financial costs and power grid reliability. Most recently, BPUD through our membership in the Public Generating Pool (PGP) helped fund and produce a study released in 2019 by E3 (Energy+Environmental Economics) titled “2019 Resource Adequacy in the Pacific Northwest”. This study was also funded by investor owned utility partners Avista Corp., Puget Sound Energy and NorthWestern Energy. Prior to the Resource Adequacy study, BPUD helped fund a PGP study released in 2018 titled “2017-2018 Pacific Northwest Low Carbon Scenarios”. Both E3 studies were based on complex and rigorous analytical methods and processes with the goal of providing a scientifically informed foundation for constructive discussions with Washington State legislators, the governor’s office and the public on the least-cost approach to carbon reduction in the electricity sector while still “keeping the lights on”. BPUD recommends all participants helping develop the SES take the time to review both E3 studies (https://www.publicgeneratingpool.com/studies-reports) with particular attention to conclusions from the Resource Adequacy study related to the (1) role of natural gas-fired
generation in the near term versus long term and (2) the land-use impacts associated with aggressive and widespread build-outs of wind and solar power; see attached one-page summary and frequently asked questions document which is also available at the link previously provided. At a high level, results of the Low Carbon Scenarios study warned against (3) using renewable portfolio standards as a means of carbon reduction in the electricity sector as it would cost twice as much and be half as effective. So we hope it can be appreciated why a utility in our position might look back on the PGP study efforts and be frustrated and concerned with the draft SES which has as its foundation the Clean Energy Transformation Act (CETA); legislation which BPUD asserts has ignored many of the key conclusions of the PGP studies by: (1) creating planning constraints (social cost of carbon) and future financial penalties which chill investments in natural-gas-fired generation as a replacement for retiring coal power (in spite of ongoing reliability studies which show an unacceptably high risk of blackouts in the northwest over the next five years); (2) essentially ignoring land-use impact concerns through the promotion of aggressive build outs of more wind and solar farms which will come with the need for extensive new transmission lines; and (3) indirectly creating a renewable portfolio standard through strong wind and solar preferences which can be demonstrated by study and experience in other states and countries may not be the least-cost approach to effective carbon reduction in the electricity sector. BPUD continues to work hard to inform our own views and to help educate others regarding the complexities and considerations related to clean energy policies and believe we are well positioned to provide substantive comments on the assumptions and conclusions related to electric utilities made in the SES. BPUD is somewhat encouraged by a recurring theme in the SES regarding the need for maximum outreach and engagement with communities and families in “all parts of the state” and the need to “identify and amend laws and rules, remove barriers and change systems that prevent equitable and just participation in our policy choices and the costs and benefits of implementing them”. While we agree with the overall sentiment of this goal, we are skeptical of its sincerity given past practices and the continued insistence that the primary means for generating clean electricity must be to build expansive wind and solar farms in rural areas of Washington and adjacent states while never mentioning the most efficient and potentially least environmentally impacting solution in the long term could be to build power generating stations closer to population centers. To continue to promote the idea that we can advance civilization globally by deepening our dependence on the vagaries of nature and discouraging (or at the least showing little enthusiasm for) the use of energy-dense fuels like cleaner burning natural gas and emissions free nuclear power seems more like rigid ideology than inclusiveness and “global leadership”. While the SES continues to promote rapid wind and solar power development as an absolutely necessary and inevitable part of Washington State’s clean energy future, BPUD questions whether this would be the case if the sprawling wind and solar farms were being built in the back yards of
the majority of those who are most influential in the development of state policies and now the SES. For BPUD’s customers and the nearly 300,000 citizens of the Tri-Cities area in Benton and Franklin counties, our back yard includes the iconic Horse Heaven Hills which is where a developer is proposing to build what would be the largest wind farm constructed in Washington. If development proceeds according to ultimate plans, a forest of more than 200 industrial wind turbines reaching heights of 500 feet and stretching for more than 25 miles across the horizon would transform the stark beauty of the treeless hills, defacing the landscape for decades to come. And all within view of the eighth largest population center in the Pacific Northwest. While BPUD hopes the voices of Tri-Cities residents served by utilities with clean hydro, nuclear and existing wind power will be heard, there is not much evidence based on past practices that local opposition would matter (https://nawindpower.com/state-supreme-court-upholds-permit-for-washington-wind-project). It is not lost on BPUD that the cover sheet of the SES seems to be suggesting wind turbines will be seen by most as a complimentary and even a beautiful addition to the natural landscape. But we want Washington State clean energy policy makers and those developing the SES to please consider that wind turbines are not a novelty and that they may not be a celebrated symbol of environmental virtue to many of us in eastern Washington who have to live with them as an intruding presence along every path we travel in and out of our community and as a back drop to our favorite fishing, hunting, hiking and site-seeing destinations. While we are not suggesting we speak for everyone in the communities we serve, our experience over the years and the feedback we have received recently regarding the proposed Horse Heaven Hills wind farm indicates many people outside the political power centers believe we have sacrificed enough of our scenic hillsides, canyons and desert vistas and we have sincere questions as to whether further sacrifice is necessary or even environmentally responsible over the long term.
Additionally, it is very concerning to BPUD that the SES (consistent with existing Washington State policies as it may be), asserts an urgent need for aggressive and rapid decarbonization to “avoid the worst impacts of climate change” without providing a point of reference for where we stand relative to other states in the U.S. or to the energy consumption trends and needs of advanced economies and developing countries in other parts of the world. If you are going to ask citizens to rethink “virtually every aspect of energy use in Washington”, it seems reasonable to make some attempt to provide evidence, or at least a logical argument, as to why the state believes our actions and the sacrifices that will come with them should be expected to make a measurable difference nationally and globally.
For example, as part of our research on clean energy Benton PUD identified the annual average level of carbon dioxide (CO2) emissions attributable to Washington State electric utilities by the U.S. Energy Information Administration (EIA) between 2007 and 2017 was 11 million metric tons (MMT) and that the average annual electricity sector emissions during this period for all 50 states was 41 MMT. It is also instructive to know that Texas emitted an average of 223 MMT per year
followed by the next ten highest emitting states who averaged 88 MMT. As acknowledged in the SES, thanks to non-emitting hydro and nuclear power, Washington State is starting from a point of very clean electricity. Which begs the question, what are the reasons other states have such high electricity sector emissions levels and will 100% clean electricity in our state really change the trajectory of other state’s emission levels? Particularly in regions with an existing deep dependence on fossil-fuels and very little land available for productive wind and solar power development.
Additionally, according to EIA data, national electricity sector CO2 emissions peaked at 2,414 MMT in 2007 and have declined since then to a level of 1,619 MMT in 2019. During this period of declining CO2 emissions, electricity produced by natural gas power plants which emits CO2 at a rate of 37% of some coal plants, replaced coal as the largest source of electrical energy in the United States. So as shown in the figure below, natural gas has emerged as a primary contributor to electricity sector emission reductions in the United States and the likelihood utilities in other states will rapidly abandon their investments in this technology under the influence of aggressive actions and 100% clean electricity goals set by states like Washington just doesn’t seem credible.
BPUD believes it is also important for the SES to acknowledge the developing world is accessing low-cost fossil fuels to bring people out of poverty like advanced economies have already done and that United States clean energy policies should not be developed in a vacuum. If we are going to ask our citizens to radically change their energy sources and consumption patterns, we must also consider the scale of electricity generation needed to continue to advance civilization and to reduce the poverty and suffering around the world that comes from energy depravation. Put another way, if you are going to make the claim that Washington State is “a
global leader in the clean energy transition”, then you owe it to citizens to help them understand where we are starting from globally and what near-term or long term global impacts we can conceivably make given the competing and compelling interests of other human beings on the planet. As seen in the following graph, coal and natural gas represent by far the biggest sources of electricity generation in the world today. And while wind and solar are popular in politics and the press as representing the path to a clean energy future, a chart like this really puts global decarbonization of the electricity sector into perspective.
Additionally, the following graph reinforces the decline in electricity emissions in the United States and the rest of the advanced economies in the world contrasted against global electricity emissions which have continued to increase due to developing countries accessing fossil fuels.
Looking at the trajectory and volume of fossil energy use in the world and the continued
construction of coal plants in China and other developing countries, can we honestly say that wind and solar have a chance of making a global difference in the next decade or even the next 30 years? In the September 2020 edition of Modern Power Systems magazine, they wrote: “China, which has half of the world’s operational coal fleet and 48% of planned capacity expansions, continues to dominate the global landscape for coal, accounting for 90% of newly-proposed capacity additions in the first half of 2020, as well as 86% of new construction and 62% of plant openings. During the six-month period under review, 11.4 GW of coal-power capacity was brought online in China, while authorities granted permits for 19.7GW of new coal projects, the highest rate since 2016.”
Contributors to developing the SES need to seriously consider by what means will Washington or any other state or country stop China or other developing nations from using low cost fossil fuels to dig themselves out of crushing poverty and associated human suffering? And despite the hopes of many, we must consider the evidence at hand and come to terms with the fact that it is unlikely developing countries will “leapfrog” the fossil-fuel technologies that advanced economies have used to prosper and flourish for decades. BPUD is not suggesting that knowing where Washington State stands nationally and globally with respect to electricity sector CO2 emissions means we should do nothing, we are just suggesting that knowing this information would be helpful when considering the rate at which certain actions should be pursued and perhaps where the state might focus our strategic efforts related to investments in generation technologies that could be exported to other parts of the United States or to other countries in the world. And if there is evidence to support the claims of the SES that Washington State’s aggressive pursuit of more wind and solar power will “avoid the worst impacts of climate change” you owe it to our citizens to produce it. Furthermore, BPUD believe the SES needs to acknowledge that all energy solutions involve environmental tradeoffs and that wind, solar and battery power are not environmentally benign propositions. Particularly if you are promoting them as a regional and global solution and are willing to be totally honest and transparent about the lifecycle environmental impacts; i.e. rare-earth elements mining, industrial manufacturing requirements, concrete and steel use, ecological disruption, and future volumetric and toxic waste recycling and disposal. BPUD is not just saying no to wind and solar power. We believe common ground can be found in emissions reductions by replacing coal with cleaner burning natural gas in the near term and ultimately transitioning more of the country and the world to nuclear power over the longer term. BPUD believes if the Washington State is serious about making a difference in global emissions, we cannot be afraid to discuss nuclear power and that we should be enthusiastically supporting Energy Northwest, X-energy and TerraPower who recently received initial funding from the U.S.
Department of Energy through their Advanced Reactor Demonstration Program. In the words of Energy Northwest (EN):
“The selection of these advanced reactor designs is a promising step forward and underscores the federal government’s commitment to developing advanced nuclear technology in the U.S. Through a 50-50 cost shared partnership with industry, ARDP will accelerate the demonstration of advanced reactors and expand access to clean energy.
As efforts continue to address our climate challenges and reduce carbon emissions, we believe nuclear energy has a key role to play now and well into the future. Department of Energy’s commitment to developing advanced nuclear energy systems – and choice of X-energy and TerraPower-GE Hitachi designs – brings the region one step closer to a carbon-free electric grid.”
To be frank, BPUD believes the draft SES gives lip service to nuclear power when based on the data and information from a national and global perspective, should be recognizing the significant and unique potential for national and global emissions reductions through its use. And how nuclear power seems to be the only large-scale generating technology that could conceivably make a difference in the economy wide electrification strategy so prominent in the draft SES. Additionally, BPUD challenges the idea that Washington State’s preferred strategy of deepening electricity sector dependence on wind and solar power represents “global leadership” particularly when you consider this strategy has been underway in Europe for nearly 20 years with questionable results and during a period in which global electricity emissions continued to increase due to developing nations increased fossil-fuel use. At a minimum, an honest evaluation of a proposed clean energy strategy should include learning from the experience of others. Take Germany’s Energiewende (or energy transition) for example which has resulted in only slight decreases in overall economy wide emissions while electricity rates have increased by 50% since 2007. As for the idea presented in the SES that a total of 11 gigawatts of new transmission lines into Montana and Idaho is essential for capturing the diversity of wind and solar resources in other states, it should be somewhat sobering to know that in Germany only 8 percent (950 miles) of the 4,800 miles of transmission lines planned to bring wind and solar power to population centers have been constructed due to local opposition to construction of towers and lines.
An even more compelling and relevant reality check has been the planning, permitting and right-of-way selection process for the 300-mile Boardman-to-Hemingway 500-kV transmission line which began in 2007 and is still not completed. With a currently expected in service date of 2026, the total project development cycle would be over 19-years for 1 gigawatt (GW) of capacity.
Furthermore, BPUD believes the writers of the SES must also acknowledge that rural and disadvantaged communities (who are likely to be disproportionately impacted by the construction of thousands of miles of new transmission lines and thousands of acres of wind and solar farms)
may see more than a bit of hypocrisy in the fact the SES does not seriously contemplate whether power generating stations built closer to population centers (on vastly smaller footprints) may be the best option when considering realistically achievable and meaningful carbon reductions. And when honestly considering ecological and environmental tradeoffs of all potential technology solutions.
Finally, BPUD would like to acknowledge our support for the comments on the draft SES submitted by the Washington Public Utility Districts Association in their November 23rd letter and would like to extend our appreciation for the hard work of the Energy Strategy Committee in putting together this extensive draft report. Clean energy policies are unbelievably complex and clearly represent politically and even personally polarizing issues.
BPUD appreciates the opportunity to comment on the draft SES and looks forward to continuing to engage in this critically important work.
Sincerely, Rick Dunn, General Manager
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