PUBLIC COMMENTS NEEDED:
East Kentucky Power Cooperative
Certificate of Convenience and Necessity (CPCN)
& Demand-Side Management
You are a part of East Kentucky Power Cooperative if get your power from:
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It seems like our utilities are obsessed with building new gas plants. It's an easy way for them to make money for their shareholders and meet future demand without giving any consideration to what best or lowest cost for us in is the long run.
New Request to Build Gas Plants + Not Enough Demand-Side Management
Natural gas power plants are expensive, dirty, and risky investments. They leave ratepayers on the hook for footing the bill of the plant and to fluctuating fuel costs as the price of natural gas changes. We don't want or need these plants. There are better solutions that can lower our electric bills and make better long-term decisions for our energy system.
Instead of first focusing on lowering demand through energy efficiency and Demand-Side Management (DSM) programs, they chose to include their DSM proposal in the same case as their request for new gas plants. |
Background for CPCN Case:
Eastern Kentucky Power Cooperative is gearing up to bring a lot of new generation online. They just got approval for two new solar plants, they just requested to build a gas-fired "mega generator" unit in Casey County, and now there is another request already submitted to build a "combined cycle" natural gas plant and add "co-firing" at two other locations.
What is EKPC proposing?
What is EKPC proposing?
- Request to build (CPCN)
- A Combined Cycle Gas Turbine at Cooper Station near Somerset (currently coal-fired). Total cost: $1,317,000 billion/$1.3 billion
- Requests to build (CPCNs):
- Co-firing (the ability to burn both natural gas and coal) at Cooper Station,
- Co-firing at Spurlock Station in Maysville (currently coal-fired).
- Total cost: $260.8 million
- New Demand Side Management (DSM) programs that make up less than 1% of their revenue.
See Sample Talking Points for your comment below
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This plan is expensive and unnecessary
This process was at best not transparent, at worst it was intentionally confusing
Once again, EKPC, like other utilities, didn't even consider alternatives.
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Demand-Side Management (DSM)is a set of programs that allows electric utilities to manage and control energy consumption by consumers. DSM programs, such as demand-response programs, can offer financial incentives, education, or pricing schemes to encourage consumers to reduce their energy demand, especially during peak hours. DSM programs can provide benefits such as lower utility bills, improved service quality, reduced environmental impacts, and increased grid reliability [From Wikipedia] Certificate of Public Convenience and Necessity (CPCN)Utilities that are regulated by the Public Service Commission are required to get permission to build new infrastructure (power plants, transmission grid updates, etc.) A Certificate of Public Convenience and Necessity (or CPCN) is the official label for legal authority to spend money on capital investments. The PSC reviews the proposed project and determines whether there is a need for the new infrastructure, whether it is in the public interest, and whether or not the utility can pass those costs on to customers. Investor-Owned Utilities (as opposed to cooperatives) are also able to earn a return on investment, which is one way that they make money for their shareholders. |
Tips for Writing Your Comment
The Commission wants to hear how the decisions your utility makes affect your life and your family. You don’t have to be an expert for your input to matter.
Please write your comment in your own words. You are welcome to use the talking points below but try not to copy and paste them word for word. The Commission gives more weight to unique comments over form responses. Don't overthink it. Your comment can be simple.
Please write your comment in your own words. You are welcome to use the talking points below but try not to copy and paste them word for word. The Commission gives more weight to unique comments over form responses. Don't overthink it. Your comment can be simple.
Talking points to inform your comment
Hover over the talking points to see them better
Demand-Side Management Talking Points
Demand-side management (DSM) and energy efficiency (EE) are almost always the cheapest and most equitable way to lower bills, protect homes, and address energy demand. Before requesting to build new power plants, utilities should show that they are committed to lowering our bills and electricity demands through real, and meaningful investments in these programs.
DSM is supposed to offset expensive and risky investments in new generation - like the gas plant(s) EKPC is proposing!
- DSM must be treated as a primary resource instead of an afterthought. DSM and energy efficiency is the most effective and cheapest resource that can minimize investments in new infrastructure.
- We don’t want to spend $300M of our money on a risky 40-year investment in a natural gas plant; its cheaper to invest in hard working Kentuckians and our communities through energy efficiency, smart appliances, and battery storage instead
- Studies show that Virtual Power Plants (VPPs) are 40-60% cheaper than gas peaker plants, and deliver more benefits to ratepayers as well! We need and deserve that
- Utilities can earn a higher return on DSM investments than new generation. KPC has a chance to give their customers exactly what they need most, and make a profit doing it. We must demand that they do that.
DSM makes our communities more reliable and resilient.
- We don’t have to choose between affordable energy bills and sustainable communities anymore. The answers we need are available, affordable, and shovel ready.
- Energy efficiency reduces the absolute level of load on the energy system, even during extreme weather events (times of peak demand). This makes our energy system more reliable and more resilient (less vulnerable to outages).
- Demand Response can reduce load specifically during peak demand, also making our system more resilient.
- Virtual Power Plants (VPPs) are an important way to meet energy system needs. VPPs are systems of distributed energy resources (including battery storage and demand response programs) that work together to balance energy supply and demand on a large scale. We need to invest in new technology to be more resilient–NOT old, outdated fossil fuel infrastructure.
Our utilities need to be taking DSM seriously.
- That means investing at the rates that other utilities around the country are, the national average is around 2% of revenue.
- We need to see at a minimum an investment of 1% or at least half of what they are proposing to spend on new gas
Kentuckians need energy efficient homes.
- Kentuckians are facing high bills and frequent rate increases. Many of our most vulnerable friends and neighbors are having to make tough choices to keep the electricity on each month. Energy efficiency helps keep our electric bills low and our homes warm, safe, and comfortable.
- Energy Efficiency and home upgrades, like weatherization, helps lower the risk of mold and mildew in our homes, which is important for vulnerable people, especially those with asthma.
- Energy efficient and well insulated homes help protect our families from extreme heat and cold by keeping the temperature regulated and keeping us more comfortable.
New Gas Plant Proposals (CPCNs)
These plans should have been separated into two separate cases. First a Demand-Side Management proposal that takes reducing electricity seriously. Then a Certificate of Public Convenience and Necessity (CPCN) if new generation is still needed after DSM reductions.
We all want to make sure that our energy system is safe, reliable, and resilient. The way that we do that is by investing in real solutions for Kentuckians, not expensive new power plants.
- We need to invest in energy efficiency and Demand-Side Management programs that actually lower our need for new generation and lower customers’ monthly bills. This should be a top priority for utilities. Until this happens, utilities should not be allowed to build new generation.
- We make our electric grid more reliable and deliver benefits directly to customers by incentivizing rooftop solar and batteries at homes and businesses which also benefit utility companies by reducing the need to purchase or produce expensive electricity during peak demand.
- We have to be smart about how we get more electricity on the grid by making the best long-term decisions using the newest technology available.
- This includes batteries and Virtual Power Plants. Studies show that Virtual Power Plants (VPPs) are 40-60% cheaper than gas peaker plants, and deliver more benefits to ratepayers as well!
Building expensive, polluting gas plants is not a smart idea and it leaves customers on the hook to pay for the utility's bad decisions. We know better and they can do better.
- It's not smart or safe to lock customers into paying for new gas plants when we know we need to move away from fossil fuels, and this will almost certainly be required in the coming years
- Renewable energy, storage, and energy efficiency can affordably, safely, and reliably provide electricity for Kentucky. By delaying the transition away from fossil fuels we are only increasing the cost of making that transition.
- Gas plants face carbon policy threats during their 40-year life cycle, increasing the risk of stranded assets (customers being on the hook to pay for gas plants that are no longer useful)/ bad debt for customers.
- Gas prices fluctuate. We have to consider that fuel costs will go up and make gas plants more expensive to run. Renewable energy sources have no fuel costs.
- If utilities are allowed to build fossil fuel plants, they should assume risk of fuel cost volatility, rather than passing costs through via the fuel adjustment charge
- If utilities are allowed to build fossil fuel plants, they should assume risk of fuel cost volatility, rather than passing costs through via the fuel adjustment charge