HomeMy WebLinkAbout11-17-20 Public Comment - J & W Swearingen - Climate Plan PrioritiesFrom:Michael Wallner
To:Agenda
Subject:FW: Priorities
Date:Tuesday, November 17, 2020 12:14:14 PM
Attachments:10.25.20 Conservation Group Comments on Bozeman Climate Plan FINAL.pdf
From: Will Swearingen [wds59hp@gmail.com]Sent: Monday, November 16, 2020 12:39 PMTo: Michael WallnerCc: Jennifer Swearingen; Will SwearingenSubject: Re: Priorities
Hi Michael,
Here are our priorities. I've also attached the combined comments from some of Montana's
major environmental groups for background, which we helped draft. Thank you for giving usthis opportunity.
Best regards, Will and Jennifer
-------------------
COMMENT SUMMARY for Commissioner Wallner, November 16, 2020
Our comments focus on Chapter 3, Focus Area 2, Responsible and Reliable Renewable Energy
Supply, pp. 60-77, since electricity usage accounts for the greatest share of the City’s
greenhouse gas emissions.
· All references to NorthWestern Energy’s misleading carbon intensity metric
must be removed from the plan. As explained in our group comments (attached), a
reduction in carbon intensity does not necessarily lead to carbon emissions reductions,
and in fact, can obscure emissions increases. While we understand the role that
“emissions factors” play in tracking emissions inventories, all goals for emissions
reductions should be expressed in terms of carbon emissions (tons of carbon dioxide
equivalent). We support the wording changes proposed by staff (related to Solutions),
but those wording changes must be integrated into the entire body of the plan.
· The plan should acknowledge that our utility’s current goal for reducing carbon
emissions will not allow the City to achieve its short-term carbon emissions target.
In addition, all references and links to NorthWestern Energy’s extremely misleading
document, “Our Vision for Montana,” should be eliminated from the plan (see
especially, Appendix A, where it is cited as the baseline scenario).
· Firm, quantifiable, verifiable benchmarks must be established at regular
intervals to monitor progress on carbon emissions reduction goals. The City must
devise an active strategy for dealing with any shortfall on those intermittent goals.
Without regular, consistent monitoring, the plan will lose its integrity. To support this
effort, we strongly encourage the addition of expert staff.
· “Additionality” must be a prerequisite for any green tariff. In addition, any such
project should be “local,” that is, within NorthWestern Energy’s grid. We appreciate
and support staff proposed revisions on this aspect of the plan, especially its renewed
focus on cooperative agreements with the cities of Missoula and Helena.
· The quantitative analysis provided by the Brendle Group is seriously flawed
and must be revised. The analysis is based on highly unrealistic and optimistic
assumptions about NorthWestern Energy’s future energy portfolio. This critical part of
the plan (Focus Area 2) is really one big math problem. If you have flawed inputs, your
conclusion is not going to be valid. Moreover, much more transparency is needed in
this crucial part of the plan.
· The City of Bozeman must become a strong advocate for climate action and the
adoption of renewable energy and storage technologies. We are encouraged by the
City’s recent statement in support of making climate action a legislative priority, and
we urge the City to redouble its efforts to advocate for policies in support of climate
mitigation, energy efficiency investments, and renewable energy development.
Despite the current political reality in Helena, investments in advocacy can lay a strong
foundation for future gains.
On Sun, Nov 15, 2020 at 8:07 PM Michael Wallner <mwallner@bozeman.net> wrote:Will,No problem thank you!
Best,
Michael P. WallnerBozeman City CommissionerCell-406-595-2273
On Nov 15, 2020, at 6:35 PM, Will Swearingen <wds59hp@gmail.com> wrote:
Hi Michael,
Thank you for giving us the opportunity to give you our priorities on the Climate Plan. Iknow that Jennifer told you we'd forward those this weekend. As it turns out, we wereburied with other commitments. We've been reviewing the revisions by the staff andconsultant and are trying to sort out the remaining problems. We'll have to fall back to youroriginal deadline and will plan to get you the priorities by noon tomorrow, Monday. Weapologize.
Best regards, Will
On Thu, Nov 12, 2020 at 6:23 PM Michael Wallner<mwallner@bozeman.net<mailto:mwallner@bozeman.net>> wrote:
Jennifer and Will,I hope you are both doing well!
As you know, we have the Bozeman Climate Plan coming before the City Commission
Tuesday night.
I still have the feedback and document that you shared with Terry and I during our meeting.However, I'd like to ask that you give me your six most important priorities that you'd like to
see incorporated Tuesday night. If you have time, please send me your six highest prioritiesbefore noon Monday.
With that being said, I've been critically analyzing the Bozeman Climate Plan. I'm frustrated
with the lack of action and concrete policy outcomes the current Bozeman Climate Plan willachieve in the future. At this time, the plan doesn't have my support. Put simply, I feel as
though the plan is more of a vision statement that lacks funding and actionable steps thatwill actually make a difference in Bozeman:)
Thank you both for your time!
Have a wonderful weekend!
Best,
Michael WallnerCity of Bozeman emails are subject to the Right to Know provisions of Montana’s
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related to individual privacy may be protected from disclosure under law.City of Bozeman emails are subject to the Right to Know provisions of Montana’s
Constitution (Art. II, Sect. 9) and may be considered a “public record” pursuant to Title 2,Chpt. 6, Montana Code Annotated. As such, this email, its sender and receiver, and the
contents may be available for public disclosure and will be retained pursuant to the City’srecord retention policies. Emails that contain confidential information such as information
related to individual privacy may be protected from disclosure under law.
Families for a Livable Climate
Montana Chapter of the Sierra Club
Montana Environmental Information Center
Northern Plains Resource Council
350-Montana
October 26, 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:
We appreciate the City of Bozeman’s strong commitment to addressing climate change and its
commendable goals for reducing carbon emissions. The City of Bozeman has demonstrated this
commitment by adopting Commission Resolution No. 4866, a resolution that shows Bozeman’s
desire to be a leader in attaining a clean energy future and to meaningfully reduce greenhouse
gases. The Draft Bozeman Climate Plan for 2020 (Draft Plan) attempts to exemplify this
commitment. Throughout the plan, the City of Bozeman remains steadfast in its dedication to
adopting a plan that sources 100% of Bozeman’s energy from clean resources. The Draft Plan
also continually emphasizes the commendable goals of protecting the environment, human
health, and promoting equity by ensuring that Bozeman’s residents pay a fair rate as the City
transitions to clean energy.
However, we are very concerned that these aspirations will not reduce greenhouse gases and this
Draft Plan, as currently written, will not succeed in helping Bozeman attain its climate goals. The
overreliance on the assumption that NorthWestern Energy (NorthWestern) will reverse course
and embrace clean energy raises red flags about the future success of Bozeman’s plan.
Actions speak louder than words. NorthWestern has repeatedly argued to legislators, the
Montana Public Service Commission, and the courts that it cannot increase renewable energy
and can only move toward increased fossil fuel reliance.1 Its representative recently expressed
1 NorthWestern has committed to significantly expand its fossil-fuel generation.
• NorthWestern Energy is exclusively seeking to acquire more coal and gas-fired power plants. In fact, it
is the only utility in the country that is seeking to expand its coal-fired generation. (See SB 278 and SB
331 from the 2019 Legislative Session, and PSC Docket D2019.12.101 in which NorthWestern is
proposing to acquire a larger share of Colstrip Unit 4, one of the largest greenhouse gas emissions
sources in the country).
• NorthWestern’s 2019 Resource Procurement plan details its plan to build a billion-dollar fleet of
new natural-gas generators within the next five years. The Plan concludes that only “thermal
the same concern in a Bozeman Daily Chronicle article. NorthWestern is an outlier among
utilities in the west. While other utilities successfully move toward cleaning up the grid,
NorthWestern bullishly moves in the opposite direction. Its recently adopted 20-year resource
acquisition plan includes the addition of no new renewable energy and an enormous and
expensive increase in fossil fuel generating facilities. NorthWestern’s current behavior at the
state level and in the courts will lock in increased greenhouse gas emissions for generations. This
is a partner that Bozeman should engage with cautiously, with serious and quantifiable short-
term benchmarks, with firm commitments from NorthWestern upfront, and with strategies to
either force NorthWestern to clean-up its grid or to work around NorthWestern if it fails to meet
Bozeman’s goals. Again, hoping NorthWestern will behave differently than it has in recent years
is aspirational but unrealistic.
The Draft Plan, developed by an extraordinary group of committed volunteers, contains much to
applaud. Of the six focus areas, most contain actions that can be taken by the City and
community members. The City should immediately move forward with adopting and
implementing those sections. This letter will focus on the need to improve Focus Area 2.
resources,” such as coal and natural gas, will meet its needs. These actions would more than double
our utility’s carbon emissions.
• NorthWestern has manipulated its modeling to avoid adding renewable resources to its portfolio.
NorthWestern claims that renewables are unreliable and economically infeasible yet the PSC’s
independent expert0.. found that the utility manipulated its modeling data to reach that erroneous
conclusion. (“Comments on NorthWestern Energy’s Final 2019 Electricity Supply Resource
Procurement Plan, Prepared for the MT Public Service Commission by Synapse Energy Economic,
February 14, 2020)
• NorthWestern has lost multiple lawsuits regarding its efforts to illegally block affordable
renewable energy projects, including two recent Supreme Court cases in which the court called
NorthWestern’s arguments against solar unsupported. Vote Solar v. Montana Department of Public
Service Regulation; 2020 MT 213. MTSUN v. The MT Department of Public Service Regulation,
2020 MT 238.
• NorthWestern has consistently failed to meet Montana’s modest renewable portfolio standard
(RPS) since it went into effect in 2012, repeatedly requesting a waiver from the PSC for the
community renewable energy projects provision of the law.
• NorthWestern has been a fierce opponent of solar energy in the legislature. Last year, it spent
hundreds of thousands of dollars on a study that proposed eliminating net metering, a move that would
have destroyed our state’s growing solar industry. It has also repeatedly lobbied against lifting
Montana’s cap of 50kW on solar systems, severely limiting solar capacity for schools, municipalities,
and businesses.
• In order to block a solar-plus-storage project proposed in Montana, NorthWestern appealed to
the Trump-appointed Federal Regulatory Energy Commission. The resulting decision on Sept. 1,
2020, not only granted NorthWestern’s request to disqualify the project, but reversed 40 years of
precedent supporting the addition of renewable energy on the nation’s electrical grid. This decision is a
staggering setback for increasing the reliability and economic feasibility of clean energy projects.
Focus Area 2: Responsible & Reliable Renewable Energy Supply
As a fundamental matter, it was inappropriate to have an undisclosed member of the Board of
Directors of NorthWestern Energy as a consultant involved with developing and facilitating this
section of the Draft Plan. The conflict of interest created by engaging a Board member of
NorthWestern, who has a fiduciary obligation to the corporation, (in addition to the appointment
of two high-level NorthWestern employees to the Climate Team), fundamentally undermines the
credibility of this section. One is left to wonder if the bias in favor of NorthWestern that is
evident throughout in this section of the plan would exist had this conflict not occurred. To put it
mildly, this section needs work and should be revised before being considered by the
Commission.
Focus Area 2 is slated to attain the greatest greenhouse gas reductions, but unfortunately, it
contains the most significant flaws.2 Electricity usage accounts for the greatest share of the
City’s greenhouse gas emissions. The critically important Focus Area 2, “Responsible and
Reliable Renewable Energy Supply,”3 proposes the following solutions:
• Solution (D) Increase Utility Renewable Energy Mix: Support NorthWestern Energy
to meet and surpass their 2045 goal to reduce the carbon intensity of their generation
by 71% to 0.14 MT CO2 per MWh.
• Solution (E) Increase Community Participation in Utility Green Power Programs:
Collaborate with NorthWestern Energy to introduce a subscriber-based green tariff.
• Solution (F) Increase Community-Based Distributed Renewable Energy Generation:
Work across the community to increase the adoption of distributed renewable energy
on public and private properties.
The Draft Plans primary solutions, (D) and (E), and (F), largely rely on NorthWestern Energy to
proactively add more renewable energy to its portfolio, phase out fossil fuel generation, support
expanded distributed generation, and embrace meaningful “green” energy policies. While these
are laudable goals, as previously stated, NorthWestern’s current practices are exactly counter to
the City’s goals. The Draft Plan should include far more information on what the City can and
will do to move clean energy forward with or without NorthWestern.
Section (D) is the primary mechanism to achieve carbon neutrality by 2050 and the second
leading mechanism to meet the City’s 2030 goal.4 Yet it contains numerous flaws. First and
foremost, the only solution listed on page 60 for increasing renewables is “Support
NorthWestern Energy to meet and surpass” its climate goal. As explained below,
NorthWestern’s climate goal is deceiving and runs counter to climate goals set by other utilities
across the west. Furthermore, increasing the utility’s renewable energy mix requires far, far more
than simply supporting NorthWestern’s efforts.
2 Figure 17 (p.16), which illustrates needed carbon reductions over time appears to be divorced from the plan; It
lacks any context, legend, reference to data, and is not discussed in the text of the Draft Plan.
3 Draft Plan, pages 60-77.
4 Draft Plan, Appendix A, p. A2
NorthWestern’s climate goal is a gimmick that allows it to increase emissions
One of the most concerning aspects of the plan is that the City of Bozeman adopts
NorthWestern’s misleading metric to calculate carbon emission reductions. Instead of
committing to reduce greenhouse gas emissions by a date certain as other western utilities have
done,5 NorthWestern uses a novel and misleading metric called “carbon intensity.”
Unfortunately, Focus Area 2 of the Draft Plan also relies on this metric to attain its reduction
goals.
In December 2019, at the same time that NorthWestern announced plans to buy more of the
Colstrip plant and thus increase its emissions, it also announced its new goal – to reduce carbon
intensity by 90% by 2045.6 This novel approach allowed NorthWestern to immediately claim
that it was already half-way to its 2045 goal despite adding a gas plant to its fleet and continuing
to rely on the same amount of coal-based electricity during that period. The addition of the
hydroelectric system allowed NorthWestern to claim the percentage of greenhouse gas emissions
compared to its overall portfolio’s megawatt output had declined – yet not a single ton of
greenhouse gases was reduced or avoided. NorthWestern used “carbon intensity” to claim it was
doing its part to address the climate crisis despite doing nothing to decrease real-world
emissions.
While other utilities state their climate goals in terms of emission reductions – usually in terms of
tons of carbon dioxide equivalent reduced – NorthWestern uses a term that allows it to claim a
50% reduction in greenhouses gases in the last decade, despite its increasing reliance on fossil
fuels. And moving forward, NorthWestern has publicly said it intends to add no new renewables,
to increase its share of Colstrip, and to add 800 megawatts of gas. Reducing carbon intensity
does not require reduced emissions. Tackling climate change does. NorthWestern’s metric is
simply a sleight-of-hand accounting trick.
Unfortunately, the Draft Plan follows NorthWestern’s lead. Instead of establishing goals that
reduce real and verifiable greenhouse gas emissions, Focus Area 2 establishes carbon intensity as
the “Performance Measures” in each strategy. As stated in the Appendices, “NorthWestern
Energy’s carbon reduction plan presented in ‘Our Vision for Montana’ was used as the baseline
scenario. This report projects emissions reduction through 2045.”7 By using “NorthWestern
5 Examples of other western utilities carbon reduction goals includes, but is not limited to, the following:
Idaho Power has a goal of 100% clean energy by 2045 (https://www.idahopower.com/energy-
environment/energy/clean-today-cleaner-tomorrow/);
Avista has a goal of carbon neutrality by 2027 for its electricity supply and 100% clean energy by 2045
(https://www.myavista.com/about-us/our-commitment).
Public Service of New Mexico eliminate carbon emissions from its power supply by 2040
(https://www.pnm.com/042219-pathto100);
Arizona’s largest utility APS will remove coal from its portfolio by 2031 and be carbon-free by 2050
(https://www.aps.com/en/About/Our-Company/Clean-Energy/Stakeholder-Perspectives);
Colorado-based Xcel energy committed to reducing emissions by 80% by 2030 and providing carbon-free
electricity by 2050 (https://www.xcelenergy.com/company/media_room/news_releases/xcel_energy_aims_for_zero-
carbon_electricity_by_2050)
6 N. Ouellet, Montana Public Radio, NorthWestern to Increase Colstrip Unit 4 Stake by 25 Percent for $1, available
at https://www.mtpr.org/post/northwestern-increase-colstrip-unit-4-stake-25-percent-1.
7 Draft Plan, Appendix A.6
Energy’s carbon reduction plan,” the City then conflates carbon intensity with carbon emissions.
This deprives Bozeman’s citizens of a meaningful plan to reduce emissions. Adopting
NorthWestern’s strategy, the City of Bozeman then validates NorthWestern’s flawed metrics by
creating a Plan that does not necessarily result in actual emissions reductions.
Action 2.D.3. Support Policies to Expand Renewable Energy and Just Transition Initiatives
This section provides a laundry list of policies the City will consider supporting to reach its
goals. Unfortunately, this incomplete list reads more like a NorthWestern wish-list and not an
independent list of policies that will truly help the City meet its goals. For example:
• The list contains no mention of the City working to expand net-metering or other
renewable energy policies, let alone whether NorthWestern has indicated a willingness to
support such measures.
• It fails to mention that the City should oppose NorthWestern’s efforts to increase fossil
fuel reliance. Instead it only mentions eliminating small, but admittedly filthy, qualifying
facilities that NorthWestern has repeatedly tried to remove from its portfolio through
legislation. This omission is notable as NorthWestern attempts to buy a larger share of
one of the dirtiest coal plants in the nation and significantly increase its reliance on new
gas plants.
• This section mentions a decline in coal in Montana as if somehow that impacts
NorthWestern customers. NorthWestern’s coal reliance has not changed in over a decade
and has not resulted in any decrease in greenhouse gas emissions in its portfolio or
decreased air or water pollution near any coal mines. It’s bizarre that this statement is
included since it is patently false on many levels, particularly when it comes to
NorthWestern’s resource mix.
• We strongly support just transition initiatives, but NorthWestern has opposed them every
time they have been proposed.8 Other utilities that own the Colstrip plant have
contributed $13 million to the community and workers in Colstrip for transition purposes.
NorthWestern has refused to make such a commitment despite having had numerous
opportunities to do so. Furthermore, transition funding should be qualified to guarantee
that the funding goes toward workforce development and retraining programs and
impacted tribal entities and is not used to punish utilities for their efforts to move away
from fossil fuels, as was unsuccessfully proposed in the 2015 and 2017 legislative
sessions.
The first solution in Focus Area 2, calls for Bozeman to “Support NorthWestern Energy to meet
or surpass” its 2045 goals. The City’s primary reduction strategy depends on NorthWestern
moving in a direction that it has already told the PSC that it will not go. The Draft Plan fails to
acknowledge that the City may need to push NorthWestern in the direction of clean energy
instead of simply supporting NorthWestern’s nonexistent clean energy proposals. The Draft Plan
should incorporate language that makes it clear that it will work with NorthWestern to meet
8 NorthWestern filing opposing transition funding in PSC Docket No. D2018.4.24; HB 489 2019 MT Legislature;
2018 Rate Case PSC Docket D2018.8.12, NorthWestern Energy’s Reply Brief, Aug. 28, 2019 and NorthWestern
Energy’s Opening Brief filed Aug. 10, 2019.
Bozeman’s goals instead of relying on NorthWestern to meet its false reduction standard. The
language should read, “Encourage and Move NorthWestern to meet Bozeman’s climate goals.”
The Draft Plan also states that the City will support policies to address NorthWestern’s “electric
capacity shortfall.”9 This statement is loaded and does not belong in this document.
NorthWestern claims to have a very large capacity shortfall that requires it to own more of
Colstrip and to add another 800 megawatts of gas generation. NorthWestern’s analysis has been
severely criticized by many experts, including the Montana Consumer Counsel, experts hired by
the MT PSC, and other entities involved in PSC proceedings. This statement is fraught with
assumptions that have no support in the Draft Plan. It is inappropriate for the Draft Plan to
reference this without additional explanation, detail, and supporting evidence. If the City
includes this statement it must put sideboards on what types of projects the City is willing to
support and why it agrees that NorthWestern has a capacity shortfall.
For NorthWestern to be a partner with Bozeman, it should embrace Bozeman’s goals, prove that
it is interested in decreasing the utility’s reliance on climate-altering fuels such as coal and gas
and expanding its reliance on clean energy sources such as efficiency, conservation, and
renewable energy.
Decoupling: Section 2.D.3 and Action 2.F.3
Section 2.D.3 mentions support for “decoupling utility revenue from electricity sales” but fails to
mention that decoupling without an explicit and enforceable requirement for the utility to
increase energy efficiency will only be a mechanism to increase revenues for the utility without
increasing the deployment of clean energy. Any decoupling mechanism must be tied to a clear
and enforcement obligation for the utility to increase energy efficiency.
Action 2.F.3 which discusses decoupling for distributed renewable energy generation is of
serious concern.10 NorthWestern has repeatedly lost in its quest to require net-metered customers
to pay more. Decoupling of these resources could very well be a backdoor mechanism to achieve
NorthWestern’s goal of charging net-metered customers more than the legislature has
established. Decoupling may be appropriate for increasing energy efficiency resources in certain
circumstances, but Bozeman should be extremely skeptical of any proposal to decouple
distributed generation. More detail should be provided to allow the community to understand
how such a proposal would work and to guarantee it would not undermine residential or
commercial net-metering customers.
Solution E. Increase Community Participation in Utility Green Power Programs.
This section poses important questions that should be answered before the adoption of the Draft
Plan to give the community the information it needs to evaluate the efficacy of the program and
the City staff the direction it needs to negotiate new green tariff programs with NorthWestern.
Given that NorthWestern has repeatedly objected to any renewable energy investments in the
next 20 years, much of the Draft Plan’s success falls to the Solution E: a “subscriber-based green
9 Draft Plan, p. 65
10 Draft Plan, p. 74.
tariff.”11 The Draft Plan identifies this notion as “a key strategy to meet the City’s aggressive
short-term goals.”12 Yet very little information is provided on how a green tariff could work,
how much it may cost, and what limits there would be to the City’s involvement in such
programs.
According to NorthWestern’s presentation on this topic,13 some green tariffs are sourced from
new renewable projects and some are not. Some are simply purchase agreements sourced on the
open market and passed on to clients. The document makes vague references to additionality but
does not commit to guaranteeing that outcome. The Draft Plan should clearly state that any
participation would require the energy to come from new projects located in NorthWestern’s
service territory.
This section leaves the consumer with many questions: What could the structure of a green tariff
be? What would be considered clean energy? What are other cities in our region doing in this
regard? Would there be a cost cap on tariff costs for the City of Bozeman and its taxpayers?
Would it be affordable to low-income households? Would it result in the remainder of
NorthWestern’s system, including customers in Bozeman, be more reliant on dirty electricity
sources? Unfortunately, the Draft Plan fails to answer any of these questions.
The City of Missoula’s recently introduced “Missoula’s 100% Draft Options Report,”14 and it
does a fantastic job of describing the different types of green tariffs, the drawbacks of
NorthWestern’s existing E+ Green program, additional resources on the topic, and program
structures. The City and County of Missoula later sent a letter to the Montana Public Service
Commission detailing that any green tariff program must include additionality.15 The Draft Plan
should provide the same level of detail for Bozeman and commit to the same.
The document fails to explore why NorthWestern’s existing E+ Green program has failed to
attract customer interest. That is likely because people do not want to pay more for a less costly
product and green energy is not additional. NorthWestern customers pay more for Colstrip each
year than clean energy resources.16 As clean energy prices continue to plummet it is increasingly
unlikely that people would be willing to pay more to acquire a less expensive resource. Bozeman
needs to be transparent in its Plan regarding the requirements of a green tariff program that is so
heavily relied upon to reach the community’s goals.
SOLUTIONS
The citizens of Bozeman deserve a sound, strong plan that reflects Bozeman’s commitment to
protect our climate and leave a livable planet for future generations. Moreover, the plan created
by Bozeman will become a model for other cities in Montana. It should embrace and embody the
words used to define the elements of this plan in the introduction: bold, robust, innovative, and
11 Draft Plan, p. 60.
12 Id.
13 NorthWestern Energy Presentation to the Green Power Stakeholder Advisory Committee, February 20, 2020.
14 Missoula’s 100% Clean Electricity Options Report, v2. Updated February 13, 2019. Pages 13-14
15 Letter from the City of Missoula and Missoula County to the MT Public Service Commissions. July 9, 2020.
16 “Residential Electricity Rates of NorthWestern Energy Through June 2018.” Prepared by Jason Brown, Montana
Consumer Counsel
actionable. To that end, we offer several suggestions for improving and strengthening the
“Responsible and Reliable Renewable Energy Supply” section:
• Reject NorthWestern Energy’s “carbon intensity” metric. “Carbon intensity” is not a
valid or accurate measure of carbon emissions reductions. Relying on this misleading
metric will lead to distortions in future calculations and the entire process of accounting
for carbon emissions will lack integrity. Bozeman’s plan is rightly based on reductions in
carbon emissions, not on reductions in the intensity (or rate) of carbon emissions, and that
metric should be maintained throughout.
• Set firm benchmarks for carbon emissions reductions over time. The City must chart
a course—with or without collaboration with the utility—with a specific time and
reduction targets that are actionable and achievable. Short-term and long-term
benchmarks are necessary. If NorthWestern fails to comply, there must be consequences,
whether in the arena of public opinion, in alternative actions by the City, or the
negotiation of subsequent contractual agreements.
• Commit to “additionality” as a prerequisite for a green tariff. Paying a premium for
electrons from existing renewable projects will not lead to carbon emissions reductions. It
is essential that any green tariff be sourced from a new, local renewable project. (“Local,”
in this instance, means within our utility’s transmission area.) Transparency will be
crucial for successful adoption by residential subscribers, and the City of Bozeman
should reject any proposal, such as a “sleeved” power purchase agreement, that does not
meet the criteria of “new” and “local.” The City must also determine and inform the
public of the costs, fees, commissions, etc., related to the initiation and ongoing expenses
of entering into a green tariff contract. Finally, a green tariff should not leave those that
do not or cannot take advantage of the program with dirtier electricity.
• Strengthen incentives for rooftop solar energy and adopt enabling building codes.
The opportunity to expand residential solar energy is huge. Systems now have a very
short payback period—often less than 8 years. What is really needed to support that
demand is subdivision design that enables an advantageous orientation and regulation
from the City to protect residents’ investments in solar systems. The City should also
advocate for the expansion of state tax credits for solar installations. Bozeman does not
need to reinvent the wheel in this regard; many cities (and some states) are years ahead of
us, and we can learn from them.
• Establish sideboards and enlist the assistance of independent renewable energy
experts to strengthen the City’s position when negotiating the Memorandum of
Understanding with NorthWestern Energy. NorthWestern has co-opted the process
thus far with the extensive participation of management personnel and even a corporate
board member guiding the meetings. When it comes time to negotiate the MOU, the City
must provide clear guidance for its representative and be represented by an impartial,
experienced expert on green tariffs.
• Do not allow NorthWestern Energy to force concessions on issues such as
decoupling and increasing its generation capacity. The utility should not be leveraging
its larger policy agenda against our local interests in renewable energy, and the City must
avoid any efforts to force Bozeman’s support for flawed policies.
• Collaborate with Missoula and Helena to increase our clout. Whether it be our
interactions with NorthWestern Energy, or our engagement with the Public Service
Commission and the state legislature, Bozeman’s voice will be stronger if we join with
like-minded cities seeking common purpose. We suggest setting up quarterly meetings to
update each other, share ideas, and strategize on our common agenda.
• The City of Bozeman must become a strong advocate for climate action and the
adoption of renewable energy. NorthWestern Energy has a large team of lobbyists for
the legislative session, and it has highly paid executive positions devoted solely to
influencing public policy related to its corporate interests. In order to compete, the City of
Bozeman must devote more personnel resources to advocate for policies in support of
climate mitigation and for energy efficiency investments and renewable energy
development. For decades, renewable energy advocates have been losing to
NorthWestern Energy in the legislature, as its lobbyists kill good bill after good bill.
Uniting with Missoula and Helena to create a “climate lobby” that could harness public
pressure and educate legislators and voters would be a good start. Further, the City of
Bozeman should be participating in the hearings going on now at the Public Service
Commission on our utility’s application to get pre-approval for its Colstrip expansion. If
approved, this expansion would make the City’s carbon emissions reduction targets more
difficult to achieve. The city should also explore the use of the Community Renewable
Energy Project provision of Montana renewable energy standard to further its goals.
• The City of Bozeman must seize every opportunity to strengthen awareness of
climate change—in our actions as citizens and as a community. We were pleased to
read in the October 13th Bozeman Daily Chronicle about the City’s decision to expand
the solar array on the new public safety center, yet no mention was made of climate
change, or the resulting long-term reductions in carbon emissions enabled by the
technology, or the imperative to raise the 50kW cap on solar installations. We must not
shy away from addressing this issue head-on. There is no “controversy” about the climate
crisis and acknowledgement will help with public education on the topic.
• Leverage the power of public opinion against our utility’s worst behaviors.
Earlier this year, BlackRock Capital Investment Corp., the world’s largest asset managing
investment firm, announced that it was taking a close look at utilities’ plans for
addressing climate change. Its CEO told investors it would be divesting from companies
earning 25% or more of their revenue from coal—a metric that would have been hard for
NorthWestern to meet even before it sought to expand its ownership of Colstrip.
BlackRock owns one-sixth of NorthWestern’s shares and therefore has tremendous
power over its financial viability, and BlackRock is not the only Wall Street firm setting
expectations for ethical climate-related decisions by utilities. Many of the world’s largest
banks have adopted similar guidance on climate change. Bad investment ratings cause
NorthWestern’s stock price to sink and make it harder and more expensive to borrow
funds for its ongoing operations and capital expenditures. In other words, NorthWestern
Energy has an interest in portraying itself as “green,” and it can do that by helping the
City of Bozeman meet its carbon emissions reduction goals. By providing Bozeman clean
renewable energy, it receives favorable media coverage and evidence of its commitment
to climate sustainability to use in its annual report and other marketing tools for the
financial sector and potential investors.
We urge the City of Bozeman to take more time to define and strengthen the portion of the plan
that requires the greatest reductions in greenhouse gases. The Draft Plan is a critical document
for meeting the community’s goals and deserves to be done thoroughly the first time. The
community of Bozeman wants real, verifiable reductions in greenhouse gases. It is important for
the City to provide that pathway.
Thank you for this opportunity to comment. Please let us know if you have any questions or
comments. We look forward to Bozeman achieving its climate change goals.
Sincerely,
Anne Hedges
Montana Environmental Information Center
Signing for
350-Montana
Northern Plains Resource Council
Families for a Livable Climate
Montana Chapter of the Sierra Club