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Integrated Resource Plan (IRP)What is an IRP? Every three years a utility company is required to submit an Integrated Resource Plan to the Public Service Commission for review. An Integrated Resource Plan, or IRP, is supposed to be a utility’s projected plan for the next 15 years. Once it's submitted the Public Service Commission will review it, ask questions, and provide suggestions. Unfortunately, under Kentucky law (unlike some other states) the commission does not get to approve or reject the plan. However, the PSC can take the most recent IRP into consideration in future cases when considering whether or not to approve a rate increase or allow a utility company to build a new power plant.
What is an Integrated Resource Plan?The Integrated Resource Plan (IRP) is a blueprint for our electric utilities for the next 15 years. If taken seriously, it can help our utilities make smart decisions. Unfortunately, our electric utilities don't always consider what is most important to customers when making their plans. |
We need utility companies to take this process seriously: Utilities must make realistic projections for the next 15 years. In recent years it seems like utility companies are not taking this process seriously, which is a waste of our time and the Public Service Commission’s time and results in IRPs that don’t actually reflect a utility’s real plan for the next 15 years.
Utilities must allow modeling systems to consider the full range of options for how to meet future electricity needs at the lowest cost to customers. Utilities have been manipulating the modeling systems to only select for the type of future they would most like to see, for example excluding energy efficiency or demand-side management from the equation, excluding the retirement of expensive, aging power plants, or giving preference to building new gas infrastructure over more affordable ways of meeting future demand, like distributed generation (ie. rooftop solar).
Utilities must include all stakeholders in the planning process. Currently stakeholders are only given an opportunity for input after a plan is proposed to the commission. This needs to change. Utilities must seek input during development of their IRP.
In order to ensure that our utilities are really thinking ahead and planning for the most resilient, reliable, and affordable energy system, they need to take this process seriously, incorporate stakeholder input, and choose to invest in us instead of business as usual.
Utilities must allow modeling systems to consider the full range of options for how to meet future electricity needs at the lowest cost to customers. Utilities have been manipulating the modeling systems to only select for the type of future they would most like to see, for example excluding energy efficiency or demand-side management from the equation, excluding the retirement of expensive, aging power plants, or giving preference to building new gas infrastructure over more affordable ways of meeting future demand, like distributed generation (ie. rooftop solar).
Utilities must include all stakeholders in the planning process. Currently stakeholders are only given an opportunity for input after a plan is proposed to the commission. This needs to change. Utilities must seek input during development of their IRP.
In order to ensure that our utilities are really thinking ahead and planning for the most resilient, reliable, and affordable energy system, they need to take this process seriously, incorporate stakeholder input, and choose to invest in us instead of business as usual.
Tips for Writing Your Comment
The Commission wants to hear how the case will 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.
Sample Talking Points
The Integrated Resource Plan is an important process that must be taken seriously by utilities and provide a clear path forward towards the energy future that Kentuckians need.
- The Public Service Commission is responsible for ensuring that utilities use this planning process to examine all reasonable options for the future and make responsible decisions that move us towards energy systems that are more reliable and resilient as well as affordable.
- We agree with the Commission that Integrated Resource Plans are more important than ever in a changing energy system and climate and need to see that the utilities are taking the process seriously, not wasting our time and the Commission’s time by not fully utilizing the planning tools available.
- We cannot allow utilities to cherry-pick the options that they are most interested in or that will result in the most return for their shareholders over newer technologies that are better for customers.
- If utilities continue to use this process as a “planning exercise” instead of using to to develop a real and well-thought out plan, the commission must hold them accountable in future cases by not allowing them to make decisions that are not inline with the future direction that we need utilities to be moving.
It is time for utilities to move past business-as-usual and false solutions to invest in solutions that keep energy prices affordable, make our energy system more resilient and reliable, and lessen our need for expensive future energy infrastructure.
- We need utilities to stop investing our money in risky fossil fuel infrastructure that will end up becoming stranded assets as we move towards truly sustainable options.
- We need utilities to invest in energy efficiency and Demand-Side Management tools that realize the full potential of reducing future energy needs. The most affordable energy is the electricity we never have to produce.
- We need utilities to acknowledge the full benefits of rooftop solar and other distributed resources to both customers and the utility company and to incentivize these programs through fair compensation.
- We need to see plans that incorporate battery storage to make our energy system more reliable and resilient in the face of changing weather.
Stakeholders and customers need to not only be considered in the planning process, but they also need to be included in the planning process.
- Planning should be based on an understanding of the customers being served, not just general planning for the “average” customer
- Include data on the income levels and energy burdens of customers, disconnection levels, and plan with this in mind
- Include data on the housing types and conditions of customers being served
- Recognize the economic development needs in the service territory
- Include data on the income levels and energy burdens of customers, disconnection levels, and plan with this in mind
- Stakeholders and the general public should be at the table during the planning process and given the tools and resources to engage meaningfully in shaping the plan.
More Definitions:
Demand Side Management (DSM): is a strategy used by electric utilities to manage and control energy consumption by consumers. DSM 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
Distributed Generation: energy sources that are not centrally located like a large power plant. Distributed generation includes things like rooftop solar and battery storage at our homes and businesses.
Energy efficiency: measures are programs, products, and tools that help us to lower our energy usage and our energy bills. This includes weatherization and upgrades to our homes and appliances/heating and cooling systems that reduce the amount of energy needed to keep our homes safe and comfortable.
Virtual Power Plants: A new technology that allows utility companies to access and deploy a set of distributed energy resources (such as rooftop solar, home batteries, and smart appliances enrolled in demand-response programs) to work together to balance out the supply and demand for electricity on a large-scale.