Pacificorp's vision for the next 20 years considers the early closure of several coal-fired power plant units in Wyoming. At the same time, the utility plans to develop significant solar, wind and battery storage resources throughout the region.
Wyoming's commission, though, found several areas of deficiency with Pacificorp's plan. Those led to the commission ordering new directives to be followed in the utility's next IRP in 2021. It also found that the 2019 IRP alone would not be enough to back actions or decisions like the future closure of coal-fired power plant units.
"I recognize the community is serving six states. I don't envy them, however I hope it is clear that Wyoming wants its voice to be heard and the same amount of effort expended by the company to pursue Wyoming directives as to other states," said Commission Chairwoman Kara Fornstrom.
While IRP's are generally accepted by states for filing without further action, Fornstrom said this situation was unique and necessitated further action.
"Given the complete transformation of the company's generation resources proposed in this IRP, I fail to see what other choice the commission had but to open an investigation and take a closer look," she said. "The generation transformation that [Pacificorp's] Mr. Link testified to during the hearing is not gradual in nature and came with absolutely no warning."
Fornstorm raised several issues around the resource plan, citing testimony from July, including lack of a reference case, lack of analysis on potential weather-related outages on intermittent, or heavily renewable, generation, and full consideration of liability of nuclear and natural gas.
Fornstrom said the lack of consideration of carbon capture utilization and sequestration (CCUS) was enough to warrant the commission not to accept the IRP for filing. She also took issue with using a hypothetical carbon tax as a variable in its predicted savings.
Commission Deputy Chair Mary Throne raised that point as well, along with a controversial study of its coal fleet, saying it seemed like Pacificorp was funneling its range of portfolio options too narrowly.
"It kind of seemed like a little results-oriented modeling instead of the modeling driving the conclusion. The preordained conclusion, somewhat drove the modeling," she said.
Fornstrom and Throne signed off on 11 new directives that Pacificorp will be required to follow in its next IRP. It addresses each of the issues that the commission found in the 2019 IRP. A written order detailing the directives has yet to be released.
Due to these areas of deficiency, the PSC found the 2019 IRP alone would not be sufficient to support the approval of any specific project or action.
"I will take Rocky Mountain power at its word that it's a plan not etched in stone. More will be needed going forward to justify the individual applications that are likely to flow from even the action plan," Throne said. "Ample testimony in the record to support that we can't rely on IRP to make decisions going forward."
The commission has also yet to accept the IRP for filing. It plans to consider it at a future open meeting.
Near the end of the meeting, Commissioner Mike Robinson took issue with the commission typically accepting integrated resource plans at face value and posited that it might be time to revisit the approach. He said the increased complexity of these documents may require more participation from the commission itself.
"This is more of a kind of heads up to the company because I think this is an issue for the rule-making," Robinson said. "I think there needs to be a means to integrate participation of commission staff into the IRP process beyond simply the stakeholder meetings."
A Pacificorp representative said the utility appreciates the commission's comments, but that it would need time to review the determinations before commenting on them in detail. Several of the directives, he said, are already being incorporated into the 2021 IRP.
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