PUBLIC COMMENTS NEEDED:
East Kentucky Power Cooperative
Certificate of Convenience and Necessity (CPCN)
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Public Comment Needed: Two proposed Solar PlantsEKPC has asked for a Certificate of Public Convenience and Necessity (CPCN) AKA Permission to build new infrastructure and recuperate their costs from customers
East Kentucky Power Cooperative is a generating and transmission cooperative supplying power to 16 distribution cooperatives, serving 1.1 million people across Central and Eastern Kentucky. EKPC is requesting permission to recover the costs for building two new utility-scale solar farms, one in Marion County and one in Fayette County (adjacent to their existing smaller solar farm). That means that they will charge us to build these new facilities and will bring 136 MW of new, clean power onto the power grid (enough to power 15,500 homes). Because EKPC currently buys a lot of its power from the regional transmission organization (RTO) PJM, building these new facilities should help lower energy costs for customers here in Kentucky. As a cooperative, this project would be community-owned solar. There is currently a lot of pushback in Fayette Co from people concerned about the loss of farmland. Let's make sure that this project is done right, including using best practices for building and decommissioning in a way that protects the land. |
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Background for CPCN Case:
Are These Plants In the Public Interest?
We know that bringing clean, renewable energy online makes our energy grid more reliable and resilient in the face of extreme weather. Utility-scale solar is just one part of how we meet our energy needs. We also need to make sure that EKPC is doing everything possible to invest in energy efficiency programs and demand-side management technology to lower our bills and lessen our need for building new generating infrastructure (ie. power plants). We also want to make sure that we are prioritize distributed renewable generation (ie. rooftop solar) which utilizes existing rooftops and land and provides more benefits for individual customers. EKPC is receiving funding from the federal governments' New ERA program to make these projects a low cost option for it's member-owners. It also means that there will be a required public engagement process. Let's ensure that EKPC is using best practices. There is a right way to build large-scale solar and it means making sure that the community is educated and involved in every step along the way, that we are choosing locations that make the most sense for the projects, and the project is planned and implemented in ways that lessen the long term impact of the site. You can learn more on the Kentucky Conservation Committee’s Solar and Lands webpage. See Sample Talking Points for your comment below |
What is Utility-Scale Solar?Utility-scale solar is a large solar installation (typically larger than 1 MW) that is owned and operated by a utility company. This is different from "Merchant Solar", which is a large solar installation that is owned by a third-party. It is also different from "distributed generation solar", which typically refers to rooftop solar and can be owned by homeowners, business owners, or utility companies. To build these plants EKPC needs a Certificate of Public Convenience and Necessity 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.
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We need more solar but let's make sure it's done right! Comments for Public Service Commission case due April 28th |
Talking points to inform your comment
Hover over the talking points to see them better
Renewable Energy is Affordable and Makes the Grid More Reliable and Resilient
- Solar is less expensive than new fossil fuel generating capacity and helps lower customer’s power bills.
- As we saw in recent winter storms which took fossil fuel power offline and left many people in the cold and dark, renewable energy such as solar and wind was not impacted by extreme low temperatures. We need more renewable energy on the electric grid to ensure that our grid is reliable and resilient to extreme weather events.
EKPC Must Have a Robust Community Engagement Plan and Utilize Best Practices
When utilities are planning new programs and projects community members and public advocates should be consulted and brought to the table in meaningful ways to shape the projects. We need to see that EKPC is committed to a robust and meaningful community engagement process that not only educates community members but gives them decision making power.
- These projects should include a community benefits agreement that includes fair compensation to the farmers whose land is being leased.
- There is a right way to build a solar farm and it includes using best practices to ensure that the land and wildlife are still preserved in the process and that the site is fully decommissioned at the end of it’s usable life. Some of these best practices include:
- A development and decommissioning plan that preserves the ability to farm the land afterwards (no concrete, no grading)
- Wildlife-friendly fencing (allows migration paths)
- Minimize impacts of grid access (building construction roads, gravel areas, etc)
- Preserve watershed areas
- Incorporate significant plantings and dual-use principles in the development.
In EKPC’s Next Integrated Resource Plan We Want to See More Energy Efficiency, Demand-Side Management, Battery Storage, Distributed Generation (Rooftop Solar), a new technology including Virtual Power Plants
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 rooftop solar. There is also a lot of promise in the new technology of Virtual Power Plants that helps lower electricity needs during peak demand. All of these options help us meet electricity demand while lowering bills for customers and preserving farmland.
- Demand-Side Management must be treated as a resource instead of an afterthought. DSM and energy efficiency is the most effective and cheapest resource that can minimize investments in new infrastructure. We need our utilities to INVEST IN US before they ask us to invest in them
- Rooftop solar is an important utility resource that helps us meet our current and future electricity needs and climate commitments. Utilities should do everything they can to encourage rooftop solar through continuing to offer strong net metering programs indefinitely.
- Distributed resources, like rooftop solar help us meet our energy needs while reducing the impact of large-scale solar on prime farmland
- Net metering of rooftop solar is a very low cost resource for utilities and their customers. At a time of increasing demand and concerns about grid reliability and the transmission system, customers who are willing to invest their own capital into solar generators on their own properties should be encouraged to do so.
- Virtual Power Plants (VPPs) are an important way to meet energy system needs. VPPs are systems of distributed energy resources (including 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.