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​Submit a Public Comment in Eastern Kentucky Power 

​Cooperative's Integrated Resource Plan!

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Eastern Kentucky Power Cooperative (EKPC), which generates and transmits electricity for its 16 member rural electric co-ops across the state,  just submitted its resource plan for the next 15 years to the Public Service Commission. The plan ignores the need to help people lower their bills, make our homes and businesses more energy efficient, and transition to clean, renewable energy. If your co-op is a member of EKPC, this will be your cooperative’s plan for the next 15 years. 

What is an IRP and why should you care

An Integrated Resources Plan (IRP) process is a chance for our utilities to show the Public Service Commission that they are planning adequately for our future energy needs. Utilities must submit these plans every 3 years. The public has an opportunity to weigh in on these plans through providing public comments. 

This is your opportunity to help shape this plan! If the PSC doesn’t hear from you, they will only hear from EKPC. Submit your public comment using the form below before December 15th.

Two Ways to Comment:

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  1. Sign up for an oral comment: ​​​9am on 12/13 (can be in person or virtual).
    1. To sign up for a virtual comment email psc.meeting@ky.gov and include case #2022-00098 , your name, phone number, and address.
    2. To give an in-person comment, arrive at the PSC office 30 minutes prior to the start of the hearing.​
  2. Submit a written comment using the form below! Comments should be submitted no later than December 15th.

Don't overthink it. Your comment can be simple

See more extensive sample talking points below if you want to include more specifics.

Ready to submit?

Sample Talking Points

EKPC is ignoring reality – despite the fact that costs are rising, technology is changing and we are now regularly faced with extreme weather events.
As a rural electric cooperative, EKPC says it is driven by the mission “to serve its member- owned cooperatives by safely delivering reliable, affordable and sustainable energy and related services.” As such, EKPC should be true to this mission in everything it does – or it shouldn’t say it! 
This mission is in line with what Kentuckians know we need for our electric sector and what this moment calls for; it means lowering customer bills and energy demand through the strongest energy efficiency programs possible, increasing grid resiliency, improved reliability through such technologies as battery storage and creating microgrids, setting and achieving detailed, actionable sustainability goals, and overcoming hurdles to participation in community efficiency and solar programs. 
Instead, what we see in this plan is a continued commitment to business as usual. For an investor-owned utility behaving this way (while not smart), might be logical, what is EKPC’s excuse? Now is the time to do the work of putting a strong transition plan in place instead of waiting 3,6,9 years down the road when costs have escalated and reliability has deteriorated. 
What to consider saying in your comment:
  • EKPC should create an integrated resource plan that is true to its mission of delivering reliable, affordable and sustainable energy. That means investing in energy efficiency, renewable energy and battery storage, and supporting customer owned solar, and not continuing to rely on outdated fossil fuel infrastructure.
  • EKPC’s sustainability plan is a lot of words with minimal action. We need to see a real plan to reach ambitious sustainability goals in the near-term.  Investments in sustainability initiatives like energy efficiency and rooftop solar can actually lower system costs for everyone. For example, Ouachita Electric Cooperative in Arkansas has done exactly this over the last decade and lowered rates for every customer by 4.5 percent. They have proven that energy efficiency investments and rooftop solar not only help the customer but also help the utility and the entire community.
EKPC should help me save money – but does it? ​
Energy efficiency just makes good sense. By both helping people lower their bills and reduce the need for future energy demand it is a win-win for cooperatives and their members. But EKPC’s IRP sets efficiency goals that are well under what their own studies say are feasible. Again, why? 
What to consider saying in your comment:
  • Energy efficiency is the cheapest and safest way to cut demand and meet future energy needs. EKPC should be committed to the best energy efficiency plans and programs that increase efficiency and lower customer bills. 
  • EKPC has low participation in its existing energy efficiency programs. We need them to promote and increase participation.  They should help customers, including low income customers, take advantage of Inflation Reduction Act funding,and improve their website and other customer outreach activities.
  • EKPC must improve and expand their energy efficiency programs.  For example, they need: in-home (not online) energy audits (including for manufactured homes); rebates for heat pumps and other technologies linked to strong efficiency standards; expanded opportunities for small businesses.  And they need to more actively participate in the PAYS program (which allows clients to pay for efficiency retrofits through their energy bills, while simultaneously lowering bills). 
  • EKPC must do a legitimate full benefit cost analysis of energy efficiency programs. Their current analysis ignores essential benefits of energy efficiency including:
    • Benefits to participants such as:
      • Increased personal health and safety: less mold and drafts in homes; reduced  medical costs and sick days due unhealthy air and heat or cold related illnesses; less reliance to unsafe space heating
      • Increased economic well being and housing security:  fewer disconnections, and less risk of eviction and moving.  
      • Increased value of homes
      • Reduced water use
      • Increased productivity
    • Benefits to Society such as
      • reduced fossil fuel pollution and greenhouse gas emissions that threaten public health, climate, and the environment 
      • reduced costs related to health, environmental and climate impacts
    • Benefits to the utilities such as 
      • increased reliability because energy efficiency reduces peak load,
      • reduced costs connected to environmental compliance and fuel price volatility  
      • reduced risk related to future carbon regulation
Is EKPC really doing enough to provide you with the lowest cost electricity?
EKPC, as a cooperative, should be committed to providing the lowest cost option to their customers. However, their plan fails to demonstrate that they have developed the least cost plan. Instead of studying the cost-benefits of retiring their coal aging coal plants or looking into buying lower cost electricity from their regional transmission organization, PJM, they just pretend like there aren't any other options to consider. EKPC should take the time to study the options before locking customers into potentially higher priced options. They should also maximize opportunities for energy savings that lower the need to produce high-priced peak demand electricity through energy efficiency. 

What to consider saying in your comment:
  • EKPC has a responsibility to look at all the options for providing the lowest cost electricity to its members. They are shirking this responsibility by not studying  the cost-benefits of retiring their aging coal plants and replacing them with more cost-effective renewable assets or purchasing more electricity from the market. 
  • EKPC has also failed to maximize opportunities to reduce future energy demand through energy efficiency programs which would both lower operating costs and customer bills. 
  • At the very least, EKPC should have in place a well thought through transition plan that takes into account generation and transmission needs and with the specific aim of retiring it’s existing coal-fired plants.
EKPC says it’s committed to providing reliable electricity to you. Its current plan won’t deliver this.
EKPC has done very little to show that their plans for the next 15 years actually deliver the most reliable electricity to its members. They have not studied the continued reliability of their aging coal-fired power plants, they have not modeled that their plan is reliable in the face of increased extreme weather, they have not fully implemented how expanded energy efficiency increases reliability by reducing the likelihood of outages at peak times, and they have failed to evaluate battery storage. How can they claim that they have chosen a path forward that is reliable when they have done nothing more than assume that systems that were once reliable 15 years ago will stay that way indefinitely?
What to consider saying in your comment:
  • EKPC makes the claim that its fossil fuel infrastructure is required for “reliability” but its coal-fired power plants are on average nearly 50 years old and past the median life expectancy of similar plants in the U.S. Nearly 40% of operating coal fired power plants with start dates similar to those of EKPC have been scheduled for retirement. This is in addition to the 5.7 GW of coal fired capacity that has already been retired. How can EKPC claim that these outdated power plants will continue to remain reliable as they continue to age and undergo increasingly expensive maintenance?
  • EKPC has also not shown that their existing power supply is reliable in the face of more extreme weather, which can be expected over the next 15 years. Instead of modeling projections based on historical weather patterns, shouldn’t they be modeling using the last 5 years? Or even use a model with increased extreme weather in order to get the most reliable projections?
  • EKPC fails to consider the value of energy efficiency and distributed energy resources (e.g. roof top solar) in addressing its load and reliability concerns. Distributed energy resources, like rooftop solar and energy efficiency, can reduce load at peak times, and can reduce threats to system reliability and grid resilience in other ways.
​EKPC should recognize the value of community and rooftop solar and plan for more!
EKPC should be planning for more community and customer-owned rooftop solar and building out their existing solar farm program that is currently underperforming. Rooftop solar provides significant benefits to customers by increasing resiliency and lowering electricity bills and, with new incentives through the Inflation Reduction Act, it is reasonable to assume there will be more rooftop solar installations in the next 10-15 years. Further, rooftop solar can provide key benefits to the utility as well by reducing peak demand and increasing the reliability and resiliency of the grid. EKPC should consider this in their plan. 
EKPC has a solar farm that is supposed to help people who either can’t afford to install solar on their roofs or who’s homes do not have good access to solar. However, the program is not designed in a way that makes it accessible to low income folks or people who don’t have access to upfront cash to pay the lease. There are better models that can be used to make this program more accessible and help people access the full benefits of community solar. 
What to consider saying in your comment:
  • EKPC’s solar share program is currently undersubscribed and they have no plans to increase subscriptions or make the subscription more affordable. Here are some ideas that could be included in a plan to reach the full potential of this program.
    • EKPC should help members participate in their community solar farm by offering financing options for buying-in. Currently, the full lease price is due upfront which is a barrier for folks who don’t have disposable income or savings. Instead, EKPC should allow folks to pay their lease in installments, or offer an on-bill financing, such as the “Pay As You Save” model.
    • EKPC could set aside a percentage of the project at a lower price for folks who meet low-to middle income ranges. Or offer partial panel leases, like Trico Cooperative in Arizona which offers a quarter-panel option. 
    • EKPC could also allow for participation by multi-family units, shelters, and nonprofits with the explicit goal of saving money for low-income customers. 
    • Fails to fully assess and value rooftop solar
  • Rooftop solar can offer significant energy and peak demand savings and contribute to a more reliable, resilient grid. And these benefits can be achieved at low cost to the utility since the investments are made by the customer.
    • The IRP does not adequately forecast adoption rates or adequately account for avoided costs that will occur with the buildout of rooftop solar. It is important for EKPC to plan for rooftop solar, especially since, with the passage of the IRA, tax credits will make rooftop solar even more affordable in coming years.
​EKPC should take advantage of tax incentives and credits to lower the cost of electricity to its customers.
Since the EKPC Integrated Resource Plan was developed the entire landscape has been changed by the passage of the Inflation Reduction Act. The assumptions and planning scenarios that were used to develop the plan are no longer the best assumptions. As such, EKPC should re-run their analysis instead of waiting three years and missing key opportunities that the IRA will provide. 
What to consider saying in your comment:
  • The IRA creates a program for Rural Electric Cooperatives to access funding to help them pay down their coal debt and transition more quickly to renewable energy, EKPC should take advantage of this opportunity.
  • The IRA creates incentives that many low-to-moderate homeowners can access to increase their energy efficiency. This will have a direct impact on future energy demand and EKPC should take responsibility for helping its members access these programs.
  • The IRA extends tax credits for residential rooftop solar which may change the projection of distributed resources available on the grid
  • The region served by EKPC will qualify for many of the Environmental Justice programs in the IRA
  • EKPC will now have access to direct payments for the development of renewables and storage that were previously unavailable to tax-exempt, non-profit utilities.

Electric Cooperatives Served by EKPC

  • Big Sandy RECC
  • Blue Grass Energy Cooperative
  • Clark Energy Cooperative
  • Cumberland Valley Electric
  • Farmers RECC
  • Fleming-Mason Energy Cooperative
  • Grayson RECC
  • Inter-County Energy
  • Jackson Energy Cooperative
  • Licking Valley RECC
  • Nolin RECC
  • Owen Electric Cooperative
  • Salt River Energy Cooperative
  • Shelby Energy Cooperative
  • South Kentucky RECC
  • Taylor County RECC
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