HomeMy WebLinkAbout10-27-20 Public Comment - S. Nelson - Montana Sierra Club comments on Draft Bozeman Climate PlanFrom:Summer Nelson
To:Agenda
Cc:Michael Wallner; Terry Cunningham; Cyndy Andrus; I-Ho Pomeroy; Jennifer Madgic; Greg Findley
Subject:Montana Sierra Club comments on Draft Bozeman Climate Plan
Date:Tuesday, October 27, 2020 11:09:50 AM
Attachments:SC Comment Letter - Bozeman Climate Plan.pdf
Please find attached a comment letter on the Draft Bozeman Climate Plan from Montana
Sierra Club.
Thank you,Summer Nelson
--
Summer Nelson
Director, Montana Chapter Sierra Club
pronouns: she/her
summer.nelson@sierraclub.org, (406) 544-4948
*Please note I am working part-time and variable hours especially during the coronaviruspandemic, and it may take some time for me to respond. Thank you for your patience and
understanding.
Become a member of the Montana Chapter today!Support us with a monthly donation!
October 23, 2020
City of Bozeman
Attn Natalie Meyer or Jon Henderson
P.O. Box 1230
Bozeman, MT 59771
Sent via email: agenda@bozeman.net
Dear City of Bozeman Representatives:
While it is admirable that Bozeman has committed to strong climate goals, the new draft Climate
Plan fails to put forth a plan to meet those goals, and if adopted, it will guarantee the goals are
not met. We support Bozeman’s goals as a starting point, and encourage the City Commission to
reject this Plan as is, and strengthen it before adopting a final plan. We also support and urge
Bozeman to set even stronger goals, those that are in alignment with what scientific experts
advise as necessary to combat the climate crisis - specifically, codifying the Mayoral
proclamation to transition to 100% clean electricity by 2030 as a City Commission commitment.
Without a path to meet the goals, the goals are meaningless.
We truly appreciate the time and effort the City has put into drafting the plan, but we urge the
City to go further and strengthen the plan before it is finalized. The Plan must be corrected to
ensure it forges a path to meet the City’s current goals and the even more ambitious goals it must
set.
The Plan contains many good ideas but fails to lay out the steps to actually accomplish the City’s
stated goals or what is necessary to mitigate the climate crisis from the local level. The Plan has
no details on activities, timelines, or budget requirements. Instead, the Plan estimates what the
City could accomplish if it copied unspecified actions of other cities, “a best in class estimate of
potential impact … calculated from leading communities around the country,” while providing
no details on the steps Bozeman would need to take to achieve these estimates, or why Bozeman
could only achieve a percentage of what these “best in class” cities accomplished. There is no
how or what, no specifics on which of these actions other cities have completed that Bozeman
should follow, to guide the City forward.
The Plan’s greatest failing, however, and the one that dooms it to failure, is that it is based
on an assumption that NorthWestern Energy will reduce its emissions and provide
Bozeman with enough clean electricity for the City to meet its goals, even while
NorthWestern’s own public plans show they will increase emissions, not cut them.
Bozeman’s Plan based most of its emissions reductions on “NorthWestern Energy’s carbon
reduction plan presented in Our Vision for Montana. . . This report projects emissions reduction
through 2045,”
(http://www.northwesternenergy.com/docs/default-source/documents/colstrip/carbon_statement_
2019-12-10.pdf). Unfortunately, NorthWestern makes no mention of cutting emissions in this
document, and instead commits to reducing their “carbon intensity,” not their carbon emissions.
Carbon intensity and carbon emissions are not the same thing, and NorthWestern has no public
plans to reduce emissions. Emissions are measured in pounds or tons of CO2 emitted, and it is
emissions that are accumulating in the atmosphere and causing climate change. Carbon intensity,
on the other hand, is a relative measure used to compare the percentage of emissions in a unit of
energy that says nothing about the actual amount of CO2 emitted, and therefore it has no impact
on climate change.
As an example, if Bozeman’s city vehicle fleet gets on average 20 mpg, and the city updates its
fleet to now get an average of 50 mpg, both the carbon intensity and the emissions have been
reduced, as long as the total vehicle miles driven stays the same. But, if the vehicle miles driven
increases many times over, the emissions would go up even as the carbon intensity goes down.
It is clearly quite possible to cut carbon intensity (amount of CO2 in a unit of energy) while
increasing emissions, and it appears that this is exactly what NorthWestern Energy is planning to
do. NorthWestern’s plans, as seen in their current attempt to purchase an additional share of the
high emissions Colstrip Unit 4 so they can keep it open until 2042, and their 2019 Electricity
Resource Procurement Plan that says they need to build 800 mw of new 30-year lifespan fracked
gas power plants and not add any new renewable generation, show that their emissions will
increase, not decrease, until at least 2042, their proposed Colstrip closure date.
Reliance on Renewable Energy from Northwestern Energy Guarantees Bozeman’s Goals of
26% reduction in GHG emissions by 2025 (below 2008) and 100% Net Clean Electricity by
2030 Will Not Be Met.
Bozeman’s Plan counts on more than half of its 26% emissions reduction by 2025 to come from
“supporting NorthWestern Energy’s plan to invest in renewable energy.” To meet the 100%
clean net electricity by 2030 goal, the Plan says “NorthWestern Energy will need to continue
to meet its emissions reduction targets.” Unfortunately, as seen above, NorthWestern Energy
is doubling down on coal and natural gas electricity and has no plans to invest in more renewable
energy and it has no emissions reduction targets. The Bozeman Climate Plan’s reliance on
Northwestern Energy guarantees that the City’s goals will not be met.
Both goals also depend on Northwestern Energy “to expand green power purchase programs and
to add a green tariff program.” Northwestern Energy’s current E+Green program, where
customers choose to pay an additional “$1.25 extra a month for 100 kilowatt-hours of renewable
benefits of wind, solar and biomass from the Northwest, Montana or Wyoming,”
has not been very successful, and there is little evidence that this can meet the City’s goals.
For one thing, according to the International Energy Agency’s World Outlook 2020,
(https://www.carbonbrief.org/solar-is-now-cheapest-electricity-in-history-confirms-iea), solar is
now the “cheapest electricity in history.” BloombergNEF states that “Wind and solar power are
the cheapest form of new electricity in most of the world today”
https://www.bloomberg.com/news/articles/2020-10-19/wind-solar-are-cheapest-power-source-in
-most-places-bnef-says). Why should customers have to pay more for something, energy from
wind and solar, that is actually cheaper than what they currently get?
Also, in order to meet the City’s goals and have an impact on climate change, the clean power
from this tariff program must be additional, as in new renewable energy projects, and not just
existing energy production that is shifted to Bozeman in an accounting process. If new clean
energy is not produced in Montana this program would do nothing to meet the City’s goals of
addressing the climate crisis.
Perhaps most concerning, a voluntary program like this shifts the responsibility for cutting
emissions from the investor-owned corporation that profits greatly from its state-guaranteed
monopoly status that allows it to emit ever more carbon emissions, onto the individuals who
choose, or don’t choose, to participate in the program. Because the program would be optional,
and at additional cost to ratepayers, it is doubtful whether it will attract many takers, especially
residents with lower income. If the plan fails to attract many customers, NorthWestern could
shift the blame for our greenhouse gas emission to those customers who didn’t choose to
participate, deflecting responsibility from themselves.
A green tariff might be an intermediate step to help cut emissions, but the details are extremely
important. Until those details are finalized, counting on this to meet Bozeman’s goals is
premature, and should not be included in the plan.
The Most Effective Actions to Achieve Climate Goals include energy efficiency, electrifying
everything that can be electrified, and sourcing that electricity from clean renewable
resources.
According to Bozeman’s emissions accounting, nearly 95% of Bozeman’s emissions come from
buildings and transportation. As Bozeman grows, there will be many more buildings and more
vehicles, and vehicle miles driven annually will increase. Electrification of building heat, water
heat, cooking, etc., and switching to electric vehicles and electric public transportation could
mitigate these emissions, even with growth, but only if the electricity used to power them comes
from a clean grid.
Because NorthWestern intends to increase the emissions on the grid, Bozeman will not meet its
climate goals, and the City must take matters into its own hands to get clean electricity for
Bozeman. The Plan must include details on how Bozeman will advance electrification and
energy efficiency, and move the community entirely off fossil fuels. This will require the City to
pursue means of securing clean electricity (and all energy) whether NorthWestern cooperates or
not, and will require the City to use all it’s influence on NorthWestern Energy to change its
practices and the grid in Montana. The Plan needs to reflect such commitments.
Actions Bozeman Must Take to Meet Its Climate Goals.
Bozeman should not approve this plan until it has a way to clean up its electricity supply. To
accomplish this, Bozeman must push NorthWestern Energy to commit to decrease emissions.
The City must push and prod NorthWestern Energy to close Colstrip 4, to meet peak power
needs through energy efficiency and policies to cut peak energy use rather than build new
30-year fracked gas power plants, and to commit to producing 100% clean electricity no later
than 2030. Bozeman must also publicly comment to the Public Service Commission requesting
that NorthWestern be denied preapproval to purchase more of Colstrip 4, and testify and
comment at every other opportunity as more fossil fuel projects or additional investment
proposals are advanced by the utility.
Without real commitments from NorthWestern Energy to reduce emissions, Bozeman must take
matters into its own hands and focus heavily on cutting emissions itself through energy
efficiency and by lobbying the State Legislature to allow community solar, to increase net
metering limits, and to allow Bozeman to change building codes to require that all new homes
are electric only, among many other difficult steps.
The City must pursue multiple pathways to achieving 100% clean electricity by 2030, including
Community Choice Aggregation (CCA), and municipilization, as NorthWestern Energy has no
public plans to generate new renewable energy. CCA would allow the Bozeman community to
purchase clean power elsewhere, and municipalizing the electricity supply would allow the City
to decide to purchase or produce the renewable energy that NorthWestern is not generating.
While these options would be slow and challenging, they are better than the increased emissions
offered by NorthWestern and could provide a path to carbon neutrality.
Bozeman must make its climate change goals the focus of every planning decision made by the
City. The climate goals must be included in growth plans, parking plans, traffic and road
planning, and every other decision made by the City. They are essential to our survival and must
be central to every decision.
The Plan is a critical roadmap that will determine if the City has a realistic path to meeting its
goals. We urge the City to remedy the deficiencies in the Plan before finalizing it, or Bozeman
will not be able to meet its climate goals.
Unfortunately, rejecting this draft plan means another year has passed with no real plan or action
to meet Bozeman’s climate goals. But if the Commission approves this Plan, Bozeman’s goals
become nothing more than “sound and fury, signifying nothing,” and they will fail to be reached
at all. Bozeman can, and must, do better. Thank you so much for all your work on this, and the
attention and commitment to getting it right. We look forward to working with you, through our
Bozeman members and supporters, to strengthen the Plan and make it something the community
can be proud of and feel confident will bring about the change that is needed.
Sincerely,
Greg Findley, Montana Chapter board member
Summer Nelson, Montana Chapter Director
On behalf of the Montana Chapter of the Sierra Club