Northern Colorado Partners for Clean Energy (NCP4CE)

P.O. Box 672

Fort Collins, Colorado 80522

May 20, 2024

Platte River Power Authority Board of Directors

2000 E. Horsetooth Road

Fort Collins, Colorado

Dear Board Chair Gertig, Vice Chair Arndt and Directors Marsh, Peck, Hall, Bergsten, Marr, and Hornbacher:

On behalf of the Northern Colorado Partners for Clean Energy (NCP4CE), we are writing in regard to the Board’s evaluation of the proposals from the recent all dispatchable resources RFP.  The choices in front of you may be some of the most critical faced by the owner communities in our time and could have profound effects on our environment, climate goals, and communities.  As such, we respectfully request that you include the Social Cost of Carbon (SCC) in the decision-making process.

Inclusion of the SCC in new electric generating resources is required for other utilities such as Xcel by the PUC.   While PRPA is not PUC regulated, its strong environmental pillar and concerns voiced over the potential impact of carbon taxes, makes including this criterion a wise and insightful exercise and is allowed within the RFP’s language.   Specifically we ask that PRPA calculate the SCC using methodology outlined in (CRS 40-3.2-106) to ensure consistency with Colorado Statutes for each proposal received. 

Consideration of SCC can also help hedge against uncertainties of future carbon emissions regulation, as well as EPA’s updated Greenhouse Gas Emissions rule covering gas and coal fired electricity generation (https://www.govinfo.gov/app/details/FR-2024-05-09/2024-09233)

Meeting the need for a new dispatchable portfolio (per Black & Veatch modeling) to maintain reliability, while acknowledging the zero carbon goals set by the owner communities, and PRPA itself, will be challenging.   Incorporating the SCC can help differentiate the long-term value of the proposals and help the board choose the optimal mix of proposals to create a portfolio that is cost effective, reliable, and with the lowest possible carbon intensity.   The inclusion of SCC also levels the playing field between fossil fuel and non-fossil resources, such as the Saga battery storage proposal, and helps consider future impacts of carbon pricing and its potential financial impact for our communities. 

Respectfully,

Northern Colorado Partners for Clean Energy

Co-conveners

Peter Eberle

eberlep@yahoo.com

Fred Kirsch

Cforse.fred@gmail.com

Fred Kirsch

Director

970-412-6295

www.cforse.org