BEFORE THE COLORADO PUBLIC UTILITIES COMMISSION

COMMISSIONERS
ERIC BLANK, CHAIRMAN
MEGAN GILMAN, COMMISSIONER
TOM PLANT, COMMISSIONER

IN THE MATTER OF THE
APPLICATION OF TRI-STATE
GENERATION AND TRANSMISSION
ASSOCIATION, INC. FOR
APPROVAL OF ITS 2023 ELECTRIC
RESOURCE PLAN.

PROCEEDING NO. 23A-0585E

On April 11, Tri-State Generation and Transmission filed its 120-day Implementation Report in the above-referenced docket. In it, Tri-State assesses six separate portfolios, comparing generation and transmission costs, reliability, emissions reductions, and revenue requirements among criteria it evaluates. Tri-State uses these metrics to select a “least-cost” option that includes construction of a new 307-megawatt (MW) gas plant in Moffat County as its preferred portfolio (called FLEX-SR).

As member-owners of rural electric distribution cooperatives that buy their wholesale power from Tri-State Generation and Transmission, and interested members of the public from across the state who care deeply about Colorado’s future, we are writing to correct the record and urge the Commission to recognize how Tri-State is putting its thumb on the scales to arrive at a pre-determined outcome that favors gas, when in fact, there is a no-gas portfolio that is superior to Tri-State’s on multiple metrics.

It is evident that Tri-State has cherry-picked one set of ambiguous data and ignored far more certain variables to select a portfolio (FLEX-SR) that includes development of both a new gas plant and extended life for one of its existing gas resources, the JM Shafer plant in Fort Lupton. Despite scoring better in multiple metrics, Tri-State disregards the fact that the no new gas portfolio that still allows for the revamp of the Shafer plant (NNG-SR) is significantly less expensive on new generation and transmission costs without sacrificing any reliability. It also outperforms Tri-State’s preferred portfolio in cutting emissions, both greenhouse gases and harmful criteria pollutants. And it is better economically for rural communities, spreading more projects across Tri-State’s service territory than the gas plant option.

Tri-State’s insistence that its preferred portfolio is “least cost” is predicated on two measures that are completely speculative. The Present Value Revenue Requirement and the Total Annual Revenue Requirement both factor in a dozen unknown projects that will be built AFTER 2031. There are no bids on wind, solar, storage and transmission on which to base costs for these placeholders, and since they are outside the scope of this resource plan, they are completely speculative. No one knows if they’ll ever be built or not. Tri-State seems to think that this guesswork is strong enough for a claim that it will be cheaper for its member co-ops, but it has no idea what renewables will cost, or what’s going to happen with inflation or fossil fuel pricing. Tri-State’s claim of “least cost” was made with its thumbs firmly on the scales.

What we do know for certain is that the cost of building the new wind, solar, storage and transmission projects in this resource plan is far less expensive than Tri-State’s gas plant option. And it’s not even close. The cost of the 13 new wind, solar and storage projects in the NNG-SR portfolio is $272 million LESS expensive than the nine projects plus a gas plant that Tri-State is pushing. Similarly, the cost of transmission for connecting the 13 renewables projects to the grid is $16 million LESS than Tri-State’s preferred portfolio. That’s $288 million cheaper for a portfolio that doesn’t include a 307-MW gas plant but still allows Tri-State to retool one of its existing plants.

If the Commission factors in the social cost of carbon, as it should in its decision-making, then even Tri-State’s cherry-picked cost data points also become unrealistic. The NNG-SR portfolio is $331 million less expensive than Tri-State’s preferred FLEX-SR option, which would emit millions of tons of greenhouses more as it burns methane through the mid-2040s. Colorado is a national leader on decarbonization. Authorizing a gas plant – especially one that so clearly is NOT needed for reliability – makes zero sense. Explicitly factoring the social cost of carbon into your decision-making is the appropriate mechanism to arrive at this conclusion. 

All the above being said, we still are encouraged by the direction that Tri-State is taking with this ERP. The addition of new renewables will be transformative to all of Tri-State’s member cooperatives, helping keep rates low and protecting the climate at the same time. It will just be far better if that is done without fossil gas being added to the mix; the difference between an A+ and a B-.

The Commission’s duty is to select the plan that is best for Colorado, and there is no question which one that is, even according to Tri-State’s own analysis. If you are truly looking at “least-cost,” there is only one option. If you are looking at decarbonization, there is only one option. If you are considering cutting other harmful pollution, there is only one option. If you are factoring in economic development for rural communities spread most widely across Tri-State’s service territory, there is only one option. Water conservation: only one choice. The option that is best for Colorado is Tri-State’s No New Gas – Shafer Replacement option, Portfolio No. 6. 

Thank you again for the opportunity to comment on this vitally important issue. 

Respectfully submitted: