Clark Public Utilities invites its customer-owners to participate in the conversation and inform the IRP through development and updates/progress report milestones by submitting comments and questions during the state-mandated public comment period and beyond. Clark Public Utilities customers are always encouraged to participate in the conversation around the IRP and any other utility business by attending regularly scheduled commission meetings.

Please note that comment submissions may contain links to external sites reflective of the commenter’s views. Links in submitted comments will take you away from our website and may expire in the future. Utility policy and direction is determined by the elected board of commissioners and implemented by staff. Many variables impact power planning so please note both comment and response dates and source when reviewing entries on this page, as responses or positions may shift.

Submitted on 7/21/2022


Thanks as always for giving your ratepayers a chance to comment!

Going to the end first, here are a few initial questions:
1) Does the EV analysis in Appendix E include only passenger vehicles and not fleet and other non passenger vehicles?
2) Do we know what the energy requirements for a full electrification of transportation would be? (Maybe total sales of gasoline and diesel would be a good proxy? I think we are a ways off from rail electrification but it wouldn’t hurt to throw that in too. My understanding is that most locomotives are already diesel electric hybrids already.)
3) Is there any sense if fleets are moving to electrification? There are lots of reports about Amazon, UPS, and USPS considering electric delivery vehicles and I believe CTRAN and the Vancouver Schools are piloting electric buses. But again, do we know how significant electrification in these areas would be or do passenger vehicle energy requirements swamp these uses?
4) The financial case for high mile per day vehicles seems more compelling than for low mile per day passenger vehicles. But much probably depends on vehicle manufactures being able to produce sufficient quantities at a price point which works. Any predictions?
5) Any initial thoughts on how to take advantage of emerging low priced power around noon due to more solar being deployed? I believe the Transportation Electrification Plan had some funding for workplace charging?

Thanks for considering my questions and thanks again for all of your hard work!


Thank you for submitting your questions related to the draft updated IRP. Below you will find answers to your specific questions from staff.

1) Does the EV analysis in Appendix E include only passenger vehicles and not fleet and other non passenger vehicles?

The analysis in Appendix E encompasses passenger vehicles, fleet vehicles and non-passenger vehicle data.

We track Clark County EV registration data that is provided monthly from the WA Department of Licensing which includes all of these EV categories. We use the historical adoption rate and then adjust forward adoption scenarios based on state and federal transportation policies, corporate efforts and announcements, and other factors.

2) Do we know what the energy requirements for a full electrification of transportation would be? (Maybe total sales of gasoline and diesel would be a good proxy? I think we are a ways off from rail electrification but it wouldn’t hurt to throw that in too. My understanding is that most locomotives are already diesel electric hybrids already.)

A past staff analysis estimated that full electrification of the fossil fuel powered passenger vehicle segment in our county would result in average demand for electricity increasing by roughly 30%, or 150 average MW of new demand.

We have not performed an analysis for the electrification of the complete transportation sector.

3) Is there any sense if fleets are moving to electrification? There are lots of reports about Amazon, UPS, and USPS considering electric delivery vehicles and I believe CTRAN and the Vancouver Schools are piloting electric buses. But again, do we know how significant electrification in these areas would be or do passenger vehicle energy requirements swamp these uses?

We do see indicators that private and public agencies are considering or beginning to electrify their fleets as these customers contact us to assist in their planning and service needs. Washington state law also mandates carbon reduction efforts for public agency fleets which is leading to greater local electrification across a variety of public agencies located in Clark county.

That said, as a public utility we must wait until actual projects materialize before making significant infrastructure upgrades. As our customers do electrify their fleets we are ready to assist them and provide financial incentives when possible and will make all necessary system updates to accommodate service needs.

4) The financial case for high mile per day vehicles seems more compelling than for low mile per day passenger vehicles. But much probably depends on vehicle manufactures being able to produce sufficient quantities at a price point which works. Any predictions?

The bulk of the cost savings associated with converting from a fossil fuel powered vehicle to an EV is in the reduced fuel costs. Therefore, high mile drivers will not only provide the most carbon reduction benefits by converting to an EV, but also realize the most economic benefit. Additionally, we are certainly seeing the automotive industry responding to the different driving habits in our society, each month it seems a new EV model is introduced, as well as a wider variety of plug-in hybrid EVs (PHEVs).

5) Any initial thoughts on how to take advantage of emerging low priced power around noon due to more solar being deployed? I believe the Transportation Electrification Plan had some funding for workplace charging?

As more Clark county drivers adopt EVs it will be in the best interest for the utility to develop programs that encourage customers to charge EVs when it is most economic for them, and also during times of reduced demand which will assist flattening our peak demands and therefore reducing utility incurred costs. The introduction of advanced metering infrastructure (AMI) will greatly assist in developing and implementing future programs. Ultimately, any new programs like this will require approval by the board of commissioners.

Submitted on 7/24/2022


As a Vancouver resident with considerable expertise in Sustainability and Renewable Energy, the IRP still falls short of an aggressive effort to eliminate as much CO2 emissions as possible. Some great work has been done, but while commenting on the increasing air conditioning loads and diminishing rainfall in the region, the report shows little urgency about reducing CO2 emissions that have caused this change.

Progress on Demand Response is slow. There are automated solutions in place that adjust thermostats and lighting in thousands of retail and industrial facilities and achieving savings of 20% on 50% of the load, so about 100MW for Vancouver. Why aren’t these being implemented here? What about time of use pricing to reduce demand on the River Road plant? The benefit-cost ratio clearly does not put a value on CO2 emissions reduction. In future, please show the same analysis using a carbon price of $50-100 per ton of CO2 emissions avoided.

Programs to encourage Heat Pumps and other energy savings are weak and poorly promoted. Why isn’t CPU doing more?

Home solar (I have 4 KW on my house) is not promoted. I understand the issues of variability, but Solar combined with demand response can eliminate summer residential peak demand, as solar homes have no demand during the day, and if air conditioned during the day, can tolerate having AC curtailed during the late afternoon when PV is unavailable.

I would like to see more aggressive engagement on offshore wind, especially considering the economic benefits to the region of having a construction port in Astoria.

As the owner of two EV’s, I’d like to see more aggressive promotion of EV’s, and engagement on programs to use EV batteries for home power by the second half of this decade.


Thank you for your comments and questions about our 2020 IRP Update. We thought it would be helpful to answer your questions by topic, below:

Energy Conservation:

  • Clark Public Utilities has a long history, going back more than 40 years, of promoting energy conservation and offering heat pump incentives. Our annual residential conservation budget is nearly $3 million dollars and we have a strong track record of exceeding WA State conservation targets. Since the pandemic began, we’ve been offering increased heat pump incentives in an effort to increase heat pump installations while many of our customers are working and spending more time at home. Clark Public Utilities adopts a Conservation Potential Assessment (CPA) every two years and that analysis includes the social cost of carbon. The latest CPA can be found in the Current Planning Documents section of the IRP page. Lastly, Clark Public Utilities offers a low interest loan program, to qualified customers, helping further assist with the adoption of energy efficiency measures.

Electric Vehicles:

  • Clark Public Utilities Commissioners adopted our first Transportation Electrification Plan (TE Plan) during the spring of 2021 and that formal step allowed the utility to develop and offer incentives that encourage customers to adopt electric vehicles (EVs). The WA legislation regulating TE Plans and the associated EV programs, sets a maximum budget for these programs that cannot exceed one quarter of one percent of the utility’s annual revenue. At Clark Public Utilities we’ve developed plans and programs that aim to maximize impact and EV promotion with a limited budget. Our Communications team recently launched a marketing promotion to highlight these programs. You can find these promotions in print and digital ads, in the local papers and online, as well as in a television commercial currently running on different platforms. You may have even seen one our multiple billboards around town promoting EV incentives. Our current portfolio of EV programs is focused on charging infrastructure, community education, and limited income customers. As EV technology advances we will certainly consider new program designs and approaches.

Demand Response:

  • Similar to the biannual CPA document, we also perform a demand response potential assessment and that effort has identified cost effective demand response opportunities. You can find the latest report in the same section of the IRP page as the CPA. However, most of those opportunities require the deployment of advanced metering infrastructure (AMI). While Clark Public Utilities currently does not have AMI deployed, there are plans underway. Commissioners recently earmarked $30 million in budget funds to embark on this effort over the next several years. Once AMI is deployed, the utility may begin offering demand response programs if required or under direction of our board of commissioners.

Residential Solar & Net Metering:

  • Clark Public Utilities currently offers the net metering program to all distributed energy resource customers, including for roof top solar PV systems. Our utility loan program is also available for customers to use to finance solar PV systems at their homes. Additionally, Clark Public Utilities is currently scoping out a new community solar program for development that will create more opportunity for renewable energy participation for our customers.

Price on Carbon:

  • Last year the WA State Legislature passed the Climate Commitment Act that includes a cap-and-invest program that places an economy wide price on carbon. The program is currently going through the rulemaking process with the Department of Ecology and is slated to formally begin next year. For more information on this program please see the Ecology webpage.

Submitted on 7/25/2022


I urge you to move as quickly as possible to producing 100% of Clark County electricity via renewable energy sources. Phase out the River Road Gas Plant ASAP. Purchase and/or produce solar electricity.


Thank you for your suggestions on the 2020 IRP Update. Clark Public Utilities is committed to providing reliable electricity to customers affordably, but also responsibly. We’re following mandates set under the Clean Energy Transformation Act (CETA) and are happy to report that we are doing so ahead of schedule and are on track to meet and exceed the milestone goals set for 2025, 2030 and 2045.

Included in further detail in the IRP, here are some highlights about what we are doing to add additional renewable and non-emitting energy sources to our resource portfolio, and how we plan to lower emissions from the River Road Generating Plant (RRGP) in the very near future:

  • The RRGP flex product is coming in 2024. This will allow us to ramp the plant down further lowering emissions. In turn, we are increasing the amount of carbon-free hydro power we purchase from BPA by 123 aMW (average megawatt) during the next contract period which begins in 2028. The 123 aMW purchase will replace RRGP as generation ramps down following CETA mandates.
  • We are adding a 50 aMW of Box Canyon hydro to our resource portfolio beginning in January 2026.
  • We have the first right of refusal to extend the Combine Hills II wind project beyond 2029.
  • Clark Public Utilities keeps a close eye on solar opportunities and we will continue discussions with solar developers regarding future projects.

Submitted on 7/31/2022


Dear Clark County PUD Commissioners:

I live in a neighborhood above Fruit Valley and the lowlands of west Vancouver and the River Road Gas Plant. I hope that as you review the draft update to the 2020 Integrated Resource Plan, particularly the part outlining the “flex plan” for the River Road Gas Plant, you will take into serious consideration our concerns over the present and potential air pollution generated by the plant, the significant inequities in Vancouver when it comes to neighborhood air quality and the effect of air pollution on public health – that you will balance these concerns with what seems to be only modest rate reductions that the flex plan promises. Not to say, of course, that the flex plan itself will be extremely expensive to implement.

Thank you for hearing our concerns and hopefully taking them into account, as you debate the issues raised by the draft update to the Integrated Resource Plan.

Submitted on 7/31/2022


The IRP is an opportunity to promote more clean energy. Then why is 29.87 percent produced at River Road natural gas-fired generating plant?

Clark PUD should do better, especially as Vancouver pursues an impressive Climate Action Plan. Clark PUD can and should be a strong partner in moving the CAP goals forward for our city and region.


Under Washington law, integrated resource plans are produced by utilities for meeting peak energy needs while holding some resource margin in reserve. These plans consist of forecasts of future load, identification of probable resource options to meet loads and details of power costs and resource management. Clark Public Utilities is one of 18 utilities in the state that are subject to this law.

The IRP is aimed at delivering customers the most reliable and affordable power possible while staying compliant with federal and state laws, being good stewards of the environment, and remaining flexible in an era of rapidly evolving technology and marketplace realities.

We have been tracking the city of Vancouver’s Climate Action Plan closely, have participated in the CAP community roundtable meetings and continue to work with and have conversations with the CAP team at the city as they develop their plan.

Submitted on 8/2/2022


I’ve heard staff mention that RRGP is nearing the end of its life expectancy.  That seems to fit with industry assessments. But the IRP seems to indicate that RRGP would continue to run until 2045.  Is this realistic?  What is a reasonable life expectancy for RRGP.  Thanks!


Thanks for the question around River Road Generating Plant as it relates to the IRP Update. Here’s further information from staff around life expectancy of the plant.

While there are many variables involved such as how it is operated, how it’s maintained, etc., we would consider RRGP to be about mid-life based on the current condition. Barring unforeseen circumstances, 2040 – 2045 is a reasonable expectation. With the gas turbine modifications planned along with expected standard maintenance/repairs in the future, another 20 years or so is a reasonable expectation.

Submitted on 8/7/2022


Power Purchase Agreements (PPAs)

At the beginning of section 4, you mention the potential use of Power Purchase Agreements (PPAs).  These types of contracts are widely used in the utility industry and by large corporate purchasers.  I suspect that like a lot of utility specific terms, this term is not immediately familiar to many ratepayers. Could you please provide a little more background on PPAs?  What are typical terms?  Duration?  How many megawatts?  Is the output guaranteed?  Are there examples of past CPU PPAs?  What are the advantages of PPAs vs actual ownership of the resource?  I think any further info would be helpful.  Thanks!


Thank you for the suggestion to add background information on Power Purchase Agreements (PPAs). We will add some background language on PPAs to Section 4 of the IRP. Below, you will find answers to your questions on PPAs:

PPA terms (duration), quantities and conditions vary widely. In general, PPA terms are typically as short as 1 year and as long as 20 years. PPA purchase quantities can be expressed in megawatts (maximum contract right) and/or megawatt-hours (annual energy and/or total energy delivered over the contract term). Typically PPA quantities are not less than 1 MW. PPA quantities can be relatively large but typically do not exceed 200 to 500 MW.

PPAs can be for a flat purchase (e.g. 100 MW delivered each hour) or for the actual hourly output of a specific generating resource. An example of the latter, is Clark Public Utilities’ PPA with Eurus Energy for the actual hourly generation of the Combine Hills II wind project. The PPA has a 20-year term, which is typical for a wind PPA. PPAs can have fixed contract prices (same price every year) or escalating contract prices (prices increase each year at a fixed escalation rate or at an escalation rate that is pegged to the Consumers Price Index or another index). Our PPA with Eurus Energy includes a fixed contract price. Many PPAs include guaranteed energy delivery amounts. In these cases, a minimum amount of energy must, by contract, be provided to the buyer even if the specific resource does not generate the minimum contract amount. The PPA with Eurus Energy includes a minimum annual purchase quantity. The advantage of a PPA compared to resource ownership is that a PPA comes with significantly less risk. The disadvantage of a PPA is cost. The cost of the risk absorbed by the resource owners is built into the contract price. Simply put, buyers in a PPA pay a premium to avoid risks associated with ownership.

Submitted on 8/7/2022


Wind energy

It’s impossible to take a trip through the gorge without noticing all of the wind turbines.  We also were recently near Milton Freewater and not far from the Combine Hills II wind farm but not close enough to see if the turbines were spinning (it was the hottest day in July so I hope they were!).  I know there are a lot of issues and limitations with wind power and many early developments were motivated more by lucrative production tax credits rather than actual regional needs but it does seem like wind can plan an important role in our energy future especially when coupled with other clean resources, storage, and demand side strategies.

I’m glad to see you included a section on offshore wind.  It remains to be seen if offshore wind can be made cost effective but it is a far more emergent technology than say SMRs and at least deserves the same level of consideration.  No SMR has ever been built and the cost effectiveness is very uncertain.  There are already many examples of offshore wind already in place throughout the world and cost estimates can at least be attempted.  As with other renewables, the fuel is free and not subject to international markets or world events.  I’ve read that the jobs created by offshore wind are typically high paying and I know that many of our small ports (like Ilwaco) would welcome the opportunity to serve as a base for installation and service.  When possible, I think we should consider the regional economic development impacts of our energy purchasing and keep things as local or regional as possible.

I also think you could improve the section on onshore wind by broadening the discussion.  We don’t analyze NW hydro just through the lens of the Packwood Hydro facility.  Combine Hills is an interesting real world example of wind energy in the NW but how much can it really tell us about regional wind as a potential resource?  I notice that a disproportionate amount of monthly wholesale operations discussion is devoted to just Combine Hills in isolation and I worry that this has more to do with an disliked regulatory mandate from 15 years ago and less an attempt to advance the commission’s and ratepayers’ understanding of regional wind as a potential resource.  Possible areas of discussion:

  • How does Gorge wind compare to other locations?  Are there complimentary locations (other than offshore) that could help mitigate the variability?
  • How predictable (and at what time scale) is wind?  Seasonality?  Wind output during extreme weather events? (okay during heat dome, not so good during polar vortex?)
  • It seems that variability is less of an issue than planability and usability as we develop better storage and demand response solutions.  As an example, a typical EV only needs 15 hours of level II charging per week for normal driving needs.  Could that charging be set up to take advantage of any peaks in wind production?  Are there other ways ratepayers could benefit from variable but cheap power?
  • Can we buy wind directly from BPA and avoid the hassle and uncertainty of trying to integrate the output of just one wind farm?  According to the NW Power Plan, wind is still one of the cheapest, clean sources of new energy even if you include the BPA integration charges.


Thank you for your comments and questions on wind energy. Since you’ve clearly outlined 4 detailed questions, we thought it would be most helpful to answer them in a QA format:

Question 1: How does Gorge wind compare to other locations?  Are there complimentary locations (other than offshore) that could help mitigate the variability?

Answer: Gorge wind generates less energy than wind located further east, such as Montana. According to the NW Power and Conservation Council’s 2021 Plan, the capacity factor of a typical Gorge wind project is 39.8%, compared to a 45.5% capacity factor for Montana wind projects. That means that a typical 100 MW wind project in the Gorge would, on average, generate 39.8 megawatts each hour. A typical 100 MW Montana wind project would, on average, generate 45.5 megawatts each hour. Over the course of a year, the 100 MW Montana wind project would generate 398,580 MWh, or 14 percent more energy than a typical 100 MW Gorge wind project, which would generate 348,648 MWh.

Combine Hills II is one of many wind projects located in the Columbia River Gorge. The same storms and weather patterns impact each Gorge wind project. The entire Gorge wind fleet ramps up and down as if it were one generating plant. Because of the lack of diversity of Gorge wind resources, Combine Hills II provides an excellent proxy for Gorge wind generation.

Question 2: How predictable (and at what time scale) is wind?  Seasonality?  Wind output during extreme weather events? (okay during heat dome, not so good during polar vortex?)

Answer: Wind generation forecasting depends heavily on meteorological information and has, over the past 15 years, improved substantially. However, because there is uncertainty in weather/wind forecasting, wind generation is still, by far, the most unpredictable form of energy currently relied upon to serve load. Wind generation’s seasonality varies by region. Gorge wind is typically greatest in the spring. March through June have the greatest projected generation. Gorge wind generation is also greater during off-peak hours. Off-peak hours are 10 p.m. through 6 a.m. Wind generation has historically been low during both very cold weather (such as polar vortexes) and very hot weather (such as June 2021’s heat dome). Wind flow during these extreme events has been relatively low.

Question 3: It seems that variability is less of an issue than plannability and usability as we develop better storage and demand response solutions.  As an example, a typical EV only needs 15 hours of level II charging per week for normal driving needs.  Could that charging be set up to take advantage of any peaks in wind production?  Are there other ways ratepayers could benefit from variable but cheap power?

Answer: The predictability of wind generation is relatively low compared to other forms of renewable generation such as hydro and solar. However, wind forecasting has improved and there may come a time in the future when electric vehicle charging could be linked with projected high wind generation periods. If the two become linked, this could potentially allow EV owners to be incentivized to charge during periods of high wind generation through  dynamic rate structures. The technology is not currently in place to implement such programs. However, Clark Public Utilities’ planned investment in Advanced Metering Infrastructure is a step in the right direction.

Question 4: Can we buy wind directly from BPA and avoid the hassle and uncertainty of trying to integrate the output of just one wind farm?  According to the NW Power Plan, wind is still one of the cheapest, clean sources of new energy even if you include the BPA integration charges.

Answer: Clark Public Utilities currently purchases a small amount of wind generation from BPA. BPA signed PPAs to purchase shares of the output of four wind projects, all located in the Gorge. Under the current BPA power contract this wind generation is included in Clark Public Utilities’ Tier 1 energy purchases from BPA. BPA has indicated that it would like to retain the tiered rate structure in the next BPA power contract which begins in October 2028. BPA has also indicated an interest of purchasing the output of wind, solar or other non-emitting projects on behalf of customers to serve load that is above customers’ Tier 1 energy allocations. Under the current BPA power contract these purchases are known as Tier 2 purchases. Under the current contract construct, purchasing utilities must inform BPA of how much of their above-Tier 1 energy requirements they wish BPA to acquire on their behalf. BPA aggregates customer utilities’ purchase nominations, which are provided to BPA 4 to 5 years in advance of the actual energy flowing, and acquires the energy.

Submitted on 8/7/2022


Capacity Factors

Thank you for taking public comments and I really appreciate your thoughtful responses to already submitted comments.  Also, it is really nice having all of the IRP information (original IRP, supporting docs, past comments, acronym lists, etc.) easily accessible on one web page.  Thank you!

I’m confused by your use of capacity factors in sections 4 and 5.  My understanding is that a capacity factor for a generating resource is useful for comparing like resources (with all else being equal).  Comparing resources with very different characteristics like wind, solar, gas, and nuclear doesn’t provide any meaningful information.  Also, you seem to  imply that a higher capacity factor across unlike resources is somehow better and this is potentially misleading to ratepayers.  I think it would be better to use Levelized Cost of Energy (LCOE) or the amount that CPU would actually pay under a PPA when comparing different resources.

On page 33 you compare Gorge wind to Montanna wind capacity factors and this makes sense as a way of deciding where to install similar wind turbines though we would want to know the characteristics of the Montanna wind and especially any seasonality issues as well.  A bunch of spring wind energy is not going to be that helpful.

But on page 35 you note offshore wind has a higher capacity factor than onshore wind and solar.  Perhaps you mean to stress that offshore wind is more consistent or planable?  You do note the advantageous seasonality of winter offshore wind.  While both wind resources, onshore and offshore wind have very different cost structures.  At present, offshore wind is much more expensive to install and this shows up in the LCOE for each.  So even a very high capacity factor for offshore wind may not make up for its other higher costs.  But LCOE is also not a perfect comparison as consistency may be much more valuable than simply unit cost if that unit cost, while low, is still variable and difficult to plan for.

Solar in general has a very low capacity factor compared to other resources but this is an artifact of solar panel nameplate ratings (max output at noon on a sunny day) and everyone in the solar industry understands that average output is often an order of magnitude less than nameplate rating.  Comparing solar capacity factors with wind or nuclear really tells us nothing.  Again, perhaps you are instead trying to highlight the variability of solar compared to other resources?  It is widely understood that solar production is variable and does not occur at night or very much in January.  But solar may have adequate predictability or plannability in order to make it an attractive option.

On page 36 you compare solar capacity factors on the west side vs the east side and this makes sense as similar types of panels will produce more on the east side and all else being equal should produce a lower LCOE.  But comparing east side solar to existing wind doesn’t make any sense unless you are trying to stress the better predictability or consistency of east side solar?  West side or local solar does have the advantage of potentially avoiding some transmission costs and risks.

On page 37 it is nice to see you note that even very low capacity factor westside solar is helpful to meet summer loads.  I would also offer up that west side solar for the most part is very predictable (we are predictably dry and sunny mid June through mid Sep) and solar production tends to align with use (though lots of spring production is not so helpful).  Sunny days with good solar production are warmer and more AC is used.  Solar production drops dramatically on cloudy or rainy days but so does AC use.  But this doesn’t always hold and the 2021 wildfire smoke is a good example of lower local solar production but probably higher AC use since folks were told to stay inside.  Local solar generation could be modeled fairly quickly against National Weather Service data and then compared to historic loads to see if there are any other potential benefits or problems to local solar.

One more example of capacity factors possibly causing rate payer confusion.  My understanding is that very low capacity factor gas peaker plants have a very high LCOE but are very valuable right now as we transition to more and more renewables.  Flexibility and dispatchability are very important.  In a sense, CPU is planning to spend a large amount of money to lower the capacity factor of RRGP as part of a flexibility plan (section 2) but the predicted benefits of flexibility (and lowered capacity factor) outweigh the costs.  This makes sense as producing power at a high capacity factor when that power is not needed or cost effective is not beneficial.  A higher capacity factor is not necessarily better than a lower capacity factor.  Am I misunderstanding capacity factors in some way?


Thank you for your questions on capacity factors. You are correct in your statement that capacity factor can cause some confusion for some customers. Let’s start with a basic definition of Capacity Factor, that may be helpful for other readers. Capacity factor is defined as the average generation across all hours in a given period (typically a month or a year) divided by maximum project generation.

The projected capacity factors of offshore wind projects are greater than the capacity factors of onshore wind and solar projects. This means that offshore wind projects with the same maximum generating capacity as onshore wind and solar projects will generate more annual energy than their counterparts. For example, a 100 MW offshore wind project with a 57% capacity factor would generate 43% more annual energy than a typical 100 MW Gorge wind project with a capacity factor of 39.8% (typical Gorge wind project capacity factor per NWPCC 2021 Plan). In addition, a 100 MW offshore wind project with a 57% capacity factor would generate 75% more annual energy than a typical 100 MW east of the Cascades solar project with a capacity factor of 32.5% (typical east of Cascades solar project capacity factor per NWPCC 2021 Plan).

If renewable projects are similarly sized (i.e. same capacity), the renewable project with the highest capacity factor will generate the most annual energy. This is why capacity factors are important when comparing renewable projects. Like onshore wind projects, offshore wind projects have variable, intermittent generation that is difficult to forecast due to the difficulty of predicting wind speeds.

Solar generation is much easier to forecast than onshore or offshore wind. Solar generation can be counted on to provide generation during specific hours of each day of each month. Solar generation varies with cloud cover, however, the dampening of cloud cover on solar generation is fairly predictable. The other advantage of solar is that it can be counted on to provide generation during high market priced summer peak demand hours. The same cannot be said of wind generation during any season.

Because the fuel supply (e.g. natural gas) can be managed, the capacity factors of thermal/fossil fuel-fired resources vary with the operational plan rather than the fuel supply. A natural gas-fired plant can have a capacity factor of near 100% if the operating plan is for the resource to provide a flat block of power. This type of operating plan is called baseload. If a natural gas-fired plant is operated to serve load only during peak load periods, which, depending on the season, fall within the 7 a.m. to 10 a.m. and 4 p.m. to 8 p.m. time periods, the resource will have a much lower capacity factor because the amount of energy generated is significantly less than a baseload resource. This type of operation is typical of a peaking resource. When discussing thermal resources, such as natural gas-fired resources, a higher capacity factor is not necessarily better than a lower capacity factor because the capacity factors are driven by the resources’ operating plans, not by an intermittent fuel supply such as wind or solar.

Submitted on 8/10/2022


Dear PUD-
In light of ever accelerating climate change, I’m writing to you to ask that you urgently do two things:
1- take River Road plant offline asap to decrease further carbon emissions
2- invest in small residential solar and wind units (this will both be renewable, and also more reliable during main system failures)
The livability of this planet partially depends on YOU. Please act accordingly.


Thank you for your comments on the 2020 IRP Update. If you would like to learn more about how Clark Public Utilities plans to meet clean energy goals, including information about plans for River Road and renewable generation sources such as solar and wind, please take a look at our Clean Energy Implementation Plan (CEIP), that was developed around the Clean Energy Transformation Act (CETA). On our CEIP page, you will find additional links to complementary information. One of those links allows customers to view previously submitted questions and comments from the CEIP public comment period this past Fall 2021.

Submitted on 8/10/2022


I would like for the renewables to be increased by installing more solar arrays in Clark county, including installing solar canapes at the PUD locations, and purchasing both solar and wind power from sources in Washington and other states and to lower the use of the River Road plant to help Vancouver meet its climate objectives.

Submitted on 8/10/2022


Comment 1:

I hope you will move forward with your 1-megawatt community solar proposal as soon as possible, and begin to plan for the next one.

Comment 2:

I hope you will move forward with AMI as soon as possible.

Comment 3:

I hope that you will immediately promote the Federal incentives for solar. Promote solar in the energy advisor, in your monthly billing insert, and in display ads.

Submitted on 8/11/2022

Comment 4:

Your IRP says nothing about planning for the California Advanced Clean Trucks Rule which has been adopted by Oregon and Washington.  Amazon has ordered 100,000 electric delivery trucks and Walmart has ordered 2000 electric semis, and electric semis are being built on Swan Island by Daimler Freightliner.

Several states have sued EPA to prevent California from setting the standards in their Advanced Clean Trucks rule.   Assign staff to track these trends, and report their findings.  I believe the market has shifted and there is no turning back.  The manufacturers can’t keep up with demand.
A large utility in Southern California has planned to spend $350 million for truck charging stations.   Consider working with PGE, the Port authorities, Amazon, Walmart, the US post office, C-Tran, the school districts, C-Tran and WSDOT to prepare.

Comment 5:  

Question: I’m excited that BPA wants to be the provider of choice for the region, and they want to do that with new Tier-2 non-federal power generation.

What does that mean?

If it means they are likely to sign purchase power agreements with large scale solar developers, that will be a challenge because people east of the Cascades resent giant renewable energy facilities.  Consider mid-scale solar and wind projects in Clark County on brownfields, commercial rooftops, and on existing parking lots.

Place a value on the resiliency and cost savings provided by local resources.   See the article linked below.

Response: BPA has indicated that it would like to retain the tiered rate structure in the next BPA power contract which begins in October 2028. BPA has also indicated an interest of purchasing the output of wind, solar or other non-emitting projects on behalf of customers to serve load that is above customers’ Tier 1 energy allocations and to help utilities meet the clean energy requirements of CETA. Under the current BPA power contract these purchases are known as Tier 2 purchases. Under the current contract construct, purchasing utilities must inform BPA of how much of their above-Tier 1 energy requirements they wish BPA to acquire on their behalf. BPA then aggregates customer utilities’ purchase nominations, which are provided to BPA 4 to 5 years in advance of the actual energy flowing, and acquires the energy. It is anticipated that a similar construct will be included in the next BPA power contract that begins in October 2028. However, it is very early in the BPA provider of choice (aka post-2028 contract) discussions. BPA has not yet indicated the renewable technology or the location of  the resources that will provide Tier 2 renewable energy.

Comment 6:

Question: Could you be so kind as to take the time to explain how you calculate the cost-effectiveness of conservation projects, particularly if you include the health and environmental benefits and other avoided costs. (?)

Consider the PAE Living Building in Portland.  It produces more energy than it needs with a combination of dedicated solar, batteries, and efficiency.

It is the world’s first-ever Living Building Certified project to be developed and funded as a speculative office building through the standard commercial real estate development model. The PAE Living Building was privately funded and developed.

The PAE engineers have shown how sustainable, replicable solutions for our environment are optimal for everyone, from the community to their investors, and they want more clients.

Furthermore, Clark PUD can achieve greater economies of scale than they did and cut the price of solar about 50% with a larger solar project, and the price of solar is expected to drop another 50% by 2030.  We don’t need to re-invent the wheel.

For more information:  Search for The PAE Building.

Response: As a public power utility customer of Bonneville Power Administration (BPA) the cost effectiveness determination of our energy conservation programs is largely dependent on BPA’s Implementation Manual (IM). The IM identifies a variety of cost effective conservation programs across the residential, commercial, industrial and agriculture sectors and is used by public power utilities across the state and region. These programs have specific measures related to each program; as an example, there may be a heat pump program that has a variety of different measures related to different heating systems the heat pump might replace. To identify cost effective programs and measures to offer to their customers, BPA relies on both internal cost effectiveness analysis and third party analysis. The primary third party is the NW Power and Conservation Council (NWPCC) which includes the Regional Technical Forum (RTF) that employs a team of analytical experts who study and determine the cost and benefit ratios of energy conservation programs. These different analyses do include the consideration of non-energy benefits. Further, Clark Public Utilities performs a Conservation Potential Assessment (CPA) every two years to determine the amount of local cost effective opportunities for our utility to pursue. That analysis includes the social cost of carbon and ultimately is used to set short and long term conservation targets.

Comment 7:

According to RCW 19.405.020

(31) “Renewable energy credit” means a tradable certificate of proof of one megawatt-hour of a renewable resource. The certificate includes all of the nonpower attributes associated with that one megawatt-hour of electricity and the certificate is verified by a renewable energy credit tracking system selected by the department.

From your IRP, you write that under CETA,

Between 2030 and 2045 the remaining 20 percent of retail load can be met with alternative compliance RECs.

Question: Please describe how an alternative compliance REC will help us in Clark County reduce emissions community wide. (?)

Response: Under the Clean Energy Transformation Act (CETA), the statute requires an alternative compliance, including unbundled RECs, to be used for any emitting generation used by a utility beginning in 2030. All future purchases of alternative compliant RECs will be done in compliance with CETA. To learn more about how Clark Public Utilities plans to meet clean energy goals, and reduce emissions community wide, please see our Clean Energy Implementation Plan (CEIP).

Submitted on 8/11/2022


Thank you for providing excellent utility service Thank you for helping the public learn the benefits of electric vehicles.

Please omit nuclear energy/Small Nuclear Reactors from the 2022 update of the 2020 IRP because there is no solution to the problem of nuclear waste. Nuclear waste containers less than 100 years old are leaking throughout Washington, the USA and the world. Nuclear waste is dangerous and lasts thousands of years.

I agree with the 2020 IRP that “The cornerstone of any IRP is a forecast of incremental future electric power requirements.” Please use the quickest predictions of transition to electricity from fossil fuels when making predictions. Buildings and transportation are about to transition quickly to electricity.

The 2020 plan included “Buy all available Bonneville Power Administration Tier 1 power in 2021-2040 to cover load growth”. While an excellent clean energy plan, dams are likely to be removed making a reliance on hydro power less certain. Hydro power is also harmed by decreasing snow and increasing drought.

The 2020 plan also continues to rely on River Road Generation. Clark PUD should recognize that goals are being set to decrease dependence on methane because of the extreme effects on climate. Clark PUD should recognize that increased costs and disincentives will make methane power less viable in the very near future.

Non-carbon renewable energy generation is more reliable than methane or nuclear power according to the 7/2020 Yale study. The Yale study states “System Average Interruption Duration Index” (SAIDI). Based on this metric (SAIDI), Germany — where renewables supply nearly half of the country’s electricity — boasts a grid that is one of the most reliable in Europe and the world.” Other countries like Finland, Switzerland, France and Sweden which also rely heavily on wind and solar have SAIDI far better than USA. USA has 5x the outages of Germany. From 2010 to 2020 as Germany decreased reliance on fossil fuels and nuclear energy, reliability grew. Similar reliability increases were found in Japan when nuclear power was suspended after the Fukushima melt-down. All power plants have down time; a mix of carbon free renewables has been found to increase reliability.

Nuclear power is found to be especially unreliable being shut down 7-12% of the time. The Yale study states,  “Every French nuclear plant was, on average, shut down for 96.2 days in 2019 due to “planned” or “forced unavailability.” That rose to 115.5 days in 2020, when French nuclear plants generated less than 65 percent of the electricity they theoretically could have produced.”

Please actively seek out much more carbon-free energy. Wind, solar, geothermal, water currents have good reliability at certain times and will help deal with variability, uncertainty, asynchronous operations, cost and Washington/US/world climate goals.

Submitted on 8/15/2022


I appreciate that public comments for the 2020 IRP update are on the website and staff responses are included. This provides an ongoing resource that supplements the draft report, allows a window into the thinking behind what is in the draft, and also allows the public a chance to ask questions, express concerns, and offer suggestions and feedback. Our comments give staff and Commissioners a window into public thinking, an opportunity to get feedback that can help our PUD move in the right direction within the context of our city and our community’s present and future energy needs.

Comments submitted during the Clean Energy Implementation Plan’s public comment period reflected many customer questions, comments and suggestions that, while not necessarily showing up in specific changes to the CEIP when submitted to the Department of Commerce, are nevertheless showing up now in decisions being made for clean energy advancements – as utility staff was heard to say in an energy forum earlier this year, “Here’s what we’re hearing from our customers, and we’re listening.” Hence the adopted motto: “Cleaner, Faster.”

Our PUD makes it clear that it is fully committed to “staying compliant with federal and state laws”, which is the minimum required of any utility, investor owned or public. But we all know that often legislation that will ultimately serve us best moves slowly, subject to the kind of countervailing forces that can hamstring and delay the best outcomes based on the interests of well funded, lobbying efforts not always reflecting the greatest public good. We are a public utility and the greatest public good should always be our guiding star.

Our city has spent significant time and resources developing a Climate Action Plan that shows Vancouver “takes seriously its responsibility to provide a safe, healthy, affordable, and prosperous community for current and future residents.” Our elected City Council listened and responded to our community, crafting a framework setting aggressive goals for reducing climate and health harming emissions, not afraid to take leadership and ask that it’s partners join them in going beyond the minimum state requirements, laws that we have seen move slowly but that are more than likely to move faster given the nature of the climate impacts we have witnessed.

A recent comment on the IRP update said: “Clark PUD can and should be a strong partner in moving the CAP goals forward for our city and region.” Staff responded that they “continue to work with and have conversations with the CAP team at the city as they develop their plan.” I would like to see Clark PUD embrace the city’s framework not as “their plan” but as “our plan” since in reality, our public utility is a key partner in this effort that encompasses both the city and wider community served by Clark PUD. This is an an opportunity to step up with an “all in, can do” attitude as the guiding principle that moves us all forward together.

Our PUD has a strong track record with the JD Power Customer Service award and I would like to see Clark now pursue the JD Power Certified Sustainability Leader Program. This makes sense as a next step in utility leadership that would enhance Clark as key partner to our city (the program emphasizes consumer awareness, engagement and advocacy” for a local utility’s climate sustainability programs and goals.)


We’d like to provide further insight around our ongoing participation with the city, and how Clark Public Utilities will continue to support them in the development of their Climate Action Plan/Framework (CAP). Our utility has a longstanding relationship with the local municipalities we serve, and staff has been participating in this process since it began, serving as a resource to city staff and providing context and clarification throughout. In addition to ongoing conversation and information sharing with City of Vancouver staff on the CAP team, we have participated in community round table discussions and attended council meetings and workshops, including the most recent Climate Strategies Review on 8/8/22. We have also offered to have Clark Public Utilities staff attend a council meeting or workshop where CAP will be on the agenda to be available for program or planning related questions.

For nearly 85 years, Clark Public Utilities has been committed to responsibly providing all customers in Clark county with safe, reliable and affordable electricity under the direction of our elected board of commissioners. We also understand and support the urgency around transitioning to a zero-carbon future, for all of Clark County, as mandated by the Clean Energy Transformation Act (CETA) – and current plans put us ahead of schedule in meeting these mandates. “Cleaner, Faster” is less a motto than a description of future plans. You can find information about our roadmap to carbon-neutral electricity for all utility customers by 2030 and zero-carbon electricity for all customers by 2045 in our Clean Energy Implementation Plan (CEIP). The CEIP is updated at regular intervals, every four years, just like the IRP; this allows for ongoing adaptation and revision based on evolving forecasts as we move closer to meeting CETA goals.

Additional planning documents that outline conservation potential and transportation electrification programs are also available.

Thank you again for the interest and engagement in the utility’s IRP process and for the opportunity to detail better our ongoing participation in and support of the City’s Climate Action efforts.

Submitted on 8/16/2022


I recently received my latest Home Energy Report. Compared to 100 similar homes in my area, my home energy use was rated Great. My home is all-electric, including a ductless heat pump system for heating and cooling, a hybrid heat pump water heater, and LED lights, and the results show in my Home Energy Report. Meeting the growing demand for energy through conservation and energy efficiency causes no environmental damage and costs less than building new power plants. What energy efficiency incentives, rebates, and programs will Clark Public Utilities be offering for energy efficiency, especially those that increase equitability and affordability? Is energy efficiency being undervalued compared to the dazzle of new technologies, particularly its lack of risk? Is the timing of conservation gains considered, such as heat pumps producing most of their savings when power prices are the highest?

I also invested in the immensely popular Community Solar Project because my home did not lend itself to rooftop solar due to shading from the trees surrounding it. I have been waiting for an announcement of new community solar projects. How can Clark Public Utilities incentivize future community solar projects? When can we expect to hear about new community solar projects?

It seems like Clark County has a lot of big box stores, warehouses, and large buildings like schools that could host solar and battery storage. Is there anything that Clark Public Utilities can do to increase the rate of residential and commercial solar and battery storage installations? Does Clark Public Utilities have any programs to incentivize installation of backup battery storage?


Clark Public Utilities has a long history of offering conservation programs and incentives (over 40 years) and strongly believes in the value of energy conservation programs and our robust annual program budgets reflect that principle. We currently offer over 40 individual conservation measures across a variety of technology areas; including, heating system upgrades, weatherization upgrades, water heating upgrades, behavior based approaches, new construction and more. Conservation incentives and programs are available to residential, commercial and industrial customers.

Over the last decade we have had a successful history of exceeding our energy conservation targets that are identified in the Conservation Potential Assessment (CPA) and we look forward to continuing that trend into the future. When designing our portfolio of energy conservation programs we evaluate the cost effectiveness of each measure, as well as the capacity value each measure brings to our system. As an example, over the last few years we’ve focused on promoting the adoption of heat pump water heaters (HPWH) because beyond the conservation savings, they also offer significant demand reduction during winter mornings, a peak consumption period for our utility. All of Clark Public Utilities’ conservation programs can be found on our public website. Residential programs can be found here and commercial/industrial programs can be found here.

On July 19th of the this year, staff presented two different new community solar concepts for our Board of Commissioners consideration and the Board directed staff to pursue and design a one megawatt project that will include participation options for low income customers, standard income customers, and business customers. While this project has not yet been formally approved, staff is working on scoping the project and looks forward to bringing a detailed proposal back to the Commissioners later this year.

Clark Public Utilities does offer the Net Metering program to customer-owned solar generation systems that provides the retail rate credit for each kWh generated by the solar system. Customer-owned generation systems that exceed the statutory net metering size threshold are eligible for the avoided cost rate which is calculated using the average monthly market cost of electricity. The utility does not offer any battery storage incentives at this time.

Submitted on 8/16/2022


I support the City’s ambitious Climate Action Plan, which goes further than state minimum requirements. The City’s goal is a city-wide 80% drop in greenhouse gas emissions (GHGs) by 2030. That’s just eight years from now. The City has another goal to achieve community-wide carbon-neutrality by 2040. I want to see Clark PUD be a good partner with the City. Clark PUD should do better, and be more forward-looking for our community, which suffers from poor air quality throughout southwest Washington (as the Washington Health Disparities Map shows us).

Clark PUD invested $10 million dollars on making the risky, gas-powered River Road generating plant (RRGP) “flexible,” instead of spending that money on wind and solar, energy storage, and demand-response measures. I do not support Clark PUD facilitating our ongoing reliance on natural gas in this way. Can Clark PUD tell us how much pollution this plant emits, and what health impacts that pollution has on our communities? Is it true that there was an outage at RRGP during a cold snap recently?  

Instead, I want to see Clark PUD looking forward to sourcing enough clean electricity to transition Clark County to a future without gas. Clean energy does not include nuclear, which is overly expensive and fraught with toxic waste issues. Nor does clean energy mean Renewable Energy Credits (RECs), which are a lot less effective than actual renewable energy at reducing GHG emissions.

Here’s what your website says about the Green Lights program: it’s a BPA program and it’s “earth-friendly” “clean energy.” Please be more transparent about what this program is. Customers should know what they’re really getting. I want this energy to be local, truly clean, and verifiable.

I love the idea of a “Parade of Efficiency” instead of a “Parade of Homes” that is gas-centric.

Finally, I think Clark PUD should be leading on expansion of high-quality broadband. COVID had taught us that a lot of commuting hours can be saved by working online from home. Broadband should be available to everyone.

Thank you for your work on behalf of Clark County.


Thank you for your questions and comments on the 2020 IRP Update. To provide clarity for readers, we have bolded your questions above. You will find our responses below:

For more information on what we’re doing to support  the city’s Climate Action Plan/Framework, please see our posted response to the public Comment on 8/15/22.

For information about RRGP emissions, please visit the IRP page under reference documents and related links. It links to this EPA page: You can view the latest published numbers. Clark Public Utilities has not had a recent cold-snap related outage at RRGP.

Clark Public Utilities’ Green Lights Program: Washington State law (RCW 19.29A.090) mandates that electric utilities offer a green power voluntary program. Clark Public Utilities’ Green Lights program was developed in response. The program allows customers to purchase Renewable Energy Credits (RECs) for as little as $1.00 per month. We can look to the EPA who defines a REC as “a tradable, market-based instrument that represents the legal property rights to the “renewable-ness”—or non-power (i.e., environmental) attributes—of renewable electricity generation.” A REC is only produced when a renewable generator produces one megawatt of electricity. The RECs we procure for the Green Lights program are sited in the Pacific NW and are also Green-e certified. All Green Lights program RECs are retired in the WREGIS database which ensures there is no double counting of the environmental attributes.

Thanks again for your participation in the 2020 IRP Update process.

Submitted on 8/16/2022


I have been following the progress our state is making with climate action planning, and was happy to see that our city of Vancouver is close to adopting a strong plan to lower greenhouse gas emissions to keep climate disasters from getting worse and to improve air quality for all of us. I know in order to achieve the goals we are setting, it will be so important for our PUD to help with transportation and building electrification, and some wonder if you are up to the challenge, which means doing so much more than you have been doing, especially with more conservation and energy efficiency, expanding local renewables, and supporting increasing electrification in our transportation and buildings. What are you doing to support our City Council with leadership that engages our community in pursuing the necessary capacity to meet the goals Vancouver is committing to, for our present and future health and well being?
It seems you give mixed messages about helping our community with the transition from gas (unhealthy for us) by spending so much money on keeping the gas plant running indefinitely rather than on healthier and safer alternatives to transition us off gas sooner than in your plan. How are rising gas prices figuring in to the cost-effectiveness of this strategy? How is our PUD letting us know the trade-offs we make as we continue having so much gas in our energy mix?
I have an older gas furnace and water heater and stove and I’m worried about being able to afford replacing these with electric, which would actually be healthier for me. I was hoping the legislature would pass the bill that would allow our PUD to help me with incentives for the switch – will our PUD actively support this legislation when it comes up again?
I am glad to see my PUD talking more actively about the clean energy transition and as a customer I support you being an active partner with the city in getting us what we need to meet climate goals. This is equally important to the focus on reasonable rates, because our health and future well-being are at stake and we lose in so many ways if we drag our feet. How will you reassure us in the community that you are an active partner with our city to pursue the electrification capacity we will need as we go forward?
Finally, I see that you still have nuclear power as a possible future resource consideration in your longer range planning. I believe the costs and risks with this technology, even in the “newer” forms make this a non-starter and would like to see wiser and more realistic thinking in it,s place.
Thank you for giving us the chance to share our concerns and thoughts, and thank you for caring about how we see a healthier clean energy direction for all of us in our local community


For more information on what we’re doing to support the City of Vancouver as they develop their Climate Action Plan/Framework, please see our posted response to the public comment on 8/15/2022.

Additionally, here is some information to help answer your question on keeping River Road Generating Plant (RRGP) running and rising gas prices: Clark Public Utilities’ investment in the RRGP flex product has an estimated payback period of 3.5 years. The flex product will reduce Clark Public Utilities’ power supply costs because it will allow us to reduce RRGP generation down to 90-95 MW during hours when it is not economic to run the plant. For example, the plant is not economic to run during off-peak hours (10 pm to 6 am and all day Sunday) during many months of the year. There are also days, typically in the spring and fall, when the plant is not economic to run for 2 to 3 consecutive days. During those days we will ramp down plant generation for the entire day(s). The other value of the RRGP flex product is that when we reduce generation during periods in which the plant is not economic to run, we also reduce carbon emissions and local criteria pollutants. The value of those reductions is not included in the estimated payback period. The RRGP flex product is one of the tools we plan on using to reduce RRGP generation and associated carbon emissions in order to comply with both the Clean Energy Transformation Act (CETA) and the Climate Commitment Act (CCA). The RRGP flex product will provide cost savings and carbon emission reductions while, importantly, allowing the plant to be available to serve loads during peak demand periods such as cold snaps and hot summer days. As a west-side generating resource RRGP is extremely valuable to the region from a grid reliability standpoint. The relatively high natural gas prices we are currently experiencing in the natural gas market are having little impact on Clark Public Utilities’ power supply costs. All of the gas required to generate energy at the plant in calendar years 2022 and 2023 was purchased months and even years ahead of time at fixed prices based on a programmatic gas hedging strategy we have used for many years. We purchase gas to fuel the plant from different suppliers at different fixed prices and in relatively small quantities as we move through time towards the impacted gas purchase period. At this point in time we have also purchased 60 percent of the gas needed in 2024 and 25 percent of the gas needed in 2025, all at fixed prices. This strategy shields us from purchasing large amounts of gas during high priced periods.

Submitted on 8/16/2022


Thank you for encouraging your ratepayers to provide feedback and questions on the IRP update.  The current energy transition is exciting and full of opportunity.  There is a real possibility that we can improve our local air quality, lower our carbon impact, keep our rates low and stable, and increase local and regional economic opportunity if we take advantage of developments in clean energy, energy management, energy efficiency, and conservation.  We need as many people working on this transition as possible and your encouragement of ratepayers to get more involved is very welcome.  Thank you for responding to questions!

Capacity Factors Follow Up

I appreciate the discussion under the comments and questions about capacity factors but you seem to miss the basic point being made – capacity factors on their own may tell us something about how much power a particular resource will produce over the course of a year (at a particular location, under a particular “operating plan”) but nothing about the important part, how much does that power cost.  Using Levelized Cost of Energy (LCOE) estimates (with embedded capacity factor estimates) such as the one in Figure 4.14 seems to be a much better way of comparing disparate resources at a high level.  And again, it’s understood that LCOEs are only a starting place and that cost then needs to be weighed against risk, consistency, usability, plannability, seasonality, etc.

Section 5

The discussion under Section 5 Comparative Evaluation of Renewable and Nonrenewable Energy Resources is confusing and you only cite one possibly biased source.

In the second paragraph you note that renewables are not able to provide many important resources needed to operate a reliable grid.  Are you excluding hydro and batteries in this discussion?  Also, NREL has been experimenting with using wind turbines for grid stability?

Also, I think one of the underappreciated benefits of our hydro system is the ability to “black start” or restart our grid without needing a backup source of power.

In the third paragraph you rightly note that LCOE does not tell the “whole story” and reiterate the point that BPA charges $18-20/MWh to flatten or integrate wind.  That is a significant cost but if the wind can be bought very cheaply and is useful then it might still be a good deal.  But forcing a comparison to 95% capacity factor baseload power doesn’t make any sense. Is more baseload power needed in the Northwest?  Isn’t block loaded baseload power in some ways as problematic as variable output renewables (lots of power produced when it is not needed)?  Isn’t our hydro system able to provide most baseload needs?  Based on staff comments from commission meetings it seems that what is needed is more flexibility and reserve capacity?  If more baseload was needed then why are existing coal and nuclear plants not more economically competitive?  Why are we pursuing an expensive flex plan for RRGP if more baseload power is what is needed?

Carbon, localized pollution, and other economic externalities really should be included in any cost comparison between resources and you rightly note that in paragraph 4.  Is CPU able to include economic externalities when deciding to “economically” displace River Road output?

Paragraph 5 is very problematic and could you please provide supporting documentation from Energy Northwest (ENW) for table 5.1?  The inclusion of a carbon cost is helpful but how a 95% capacity factor is applied to wind and solar is a mystery.  Also, why would we rely on analysis in this section from ENW instead of more prominent organizations such as EIA or NREL?  I have no knowledge of ENW (formerly Washington Public Power Supply System or WPPSS) but it’s clear from their financial statements that the vast majority of their revenue comes from operating the Columbia Generating Station, a conventional nuclear power plant.  They appear to only have dabbled in wind, solar and hydro.  ENW seems to be a very enthusiastic supporter of both conventional and SMR nuclear power and it makes sense that they would try to come up with an analysis that makes nuclear look more cost effective.  Nuclear may have an important role to play in our energy transition but it certainly isn’t cheap and I have not been able to find any other analysis that supports the conclusions in Table 5.1. If flexible capacity is needed, then why not force a baseload pl

I think we need to be consistent when discussing nuclear power and especially SMRs.  Low cost estimates for SMRs use a high capacity factor but then that means that they aren’t being used as a flexible resource.  Table 4.14 notes the higher costs of SMRs as the capacity factor goes down (and flexibility goes up).  Either SMRs are being positioned as a way of incorporating more solar and wind or as an around-the-clock resource.  The two operating plans don’t seem compatible?


Thank you for your further comments and questions. We have bolded the questions above, that you’ll find the following response for:

For purposes of the discussion in Section 4, “renewables” refers to solar and wind generation. Hydro and batteries are included in the analysis only to the extent that they can be used to firm up wind resources. BPA uses its hydro system to firm up wind projects and charges Resource Support Service (RSS) costs to do so. As you noted, BPA’s RSS product adds $18-20/MWh to flatten or integrate wind. If a BPA customer wants to use wind to serve its load growth (above its Tier 1 energy allocation) the resource must, under the current BPA contract, be brought to load as a flat block of power. BPA’s requirement that wind and solar generation be transformed into flat blocks of power is in lock step with the levelized cost of energy comparison shown in Table 5.1, which is correctly sourced to Lazard in the IRP, not Energy Northwest. It is difficult to compare intermittent renewable resources, baseload resources and peaking resources on an apples-to-apples basis. All of these resources are needed to operate a reliable, low-carbon electric system. Adding the cost of carbon to emitting resources and the cost of integrating renewables and assuming all resources have the same operating plan (i.e. capacity factor) allows us to make an apples-to-apples comparison, as Lazard has done.

Submitted on 8/17/2022


Thank you for working to address climate issues.

I would like to see a more definite commitment to expanding community solar.  The IRP mentions “exploring” community solar projects.  P. 53.  But the IRP doesn’t identify any time frame for making a decision or moving forward. The CPU information addressing community solar (7/19/22) gives numerous reasons why CPU should be doing more than “exploring” expanded community solar projects.  Not the least of these reasons is the interest in the community, as the 7/19/22 information spells out.  There is customer demand.  And there is public agency interest, both to partner with CPU or host a solar installation.

Because it will take time to achieve a fully functioning community solar project, the IRP should state a specific time frame to move forward with additional community solar.  Having more solar is good for CPU.  As the IRP explains when discussing rooftop solar, “distributed generation, such as rooftop solar installations, decreases Clark Public Utilities’ system loads.”  IRP, p. 8.  Additionally, as the 7/19/22 information describes, there is state incentive money for community solar that will benefit low-income customers.  That’s a win/win for customers and CPU.

At several points, the IRP states CPU will rely on RECs when available to meet its state GHG reduction goals.  IRP, pp. 7; 46.  The plan doesn’t explain whether the RECs CPU will purchase are bundled or unbundled.

I understand CPU can meet its state goals by purchasing RECs, but purchasing unbundled RECs does nothing to measurably reduce GHG emissions.  CPU should commit to not purchasing unbundled RECs to meet its GHG emission reduction goals.  The IRP should clearly state that commitment.

CPU must reduce its reliance on the RRGP as quickly as possible.  The gas plant is one of the biggest GHG emitters in Washington and is currently supplying nearly 1/3 of our power.  Even if the flex equipment CPU is considering reduces reliance on RRGP, the plant will remain a major supplier of customer power for many years.

The decreased reliance on the gas plant is too slow.  The IRP makes it clear CPU intends to operate the plant until 2045.  Continued operation of RRGP will result in CPU having to purchase RECs, likely unbundled RECs, to “offset” its RRGP emissions.  Unbundled RECs don’t “offset” anything in any measurable way.  Unbundled RECs don’t reduce GHG emissions in any measurable way.

Keeping RRGP open without a plan to shut it down much sooner than 2045 isn’t a plan to address climate issues as quickly as we need to.  I understand the RRGP output must be replaced to provide reliable power to CPU customers, but CPU needs to act with more urgency identifying and contracting for renewables to replace RRGP long before 2045.  The IRP should reflect that urgency and should not continue to state CPU will operate RRGP until 2045.

Submitted on 8/17/2022


When it comes to the climate emergency, time is of the essence. I implore you to move quickly towards all renewable clean solar energy for Clark County.

Submitted on 8/17/2022


I am a Clark PUD customer with solar panels, heat pumps, an induction stove, a heat-pump condenser dryer, and EVs. We also have deciduous trees to help reduce summer heat in our house as well as using blinds and opening or closing windows strategically to keep our home comfortable. I can speak to how well these technologies/strategies work to reduce energy use on our property of two homes! I will send in several comments to address these various items, but I will start with solar. Our solar panels are great so we are currently looking to add more. We will also have to swallow the cost of battery backup because we are on a well and septic system so need a way to run these when the power goes out. Solar is excellent in this area because it produces most when the PUD is relying on gas from RRGP. Focusing on solar with battery storage will help eliminate the need for the RRGP because our hot, dry summers bring less hydro power, but it also comes with clear skies for generating solar power. All government buildings (including schools) should be covered in solar panels. I truly wish that we would have more parking that was covered by solar panels too — we need to cool these asphalt hot spots while generating electricity! EV charging stations can be hooked up to these solar parking spots. All new construction should be ready to use power from solar panels. I also suggest combining community solar programs with sustainable farming. If the panels are mounted in coordination with a local farmer, that land is serving dual purpose. Land for farming is quickly disappearing in our county. We need both more solar production and more affordable land available to our local farmers to sustainably grow our food. You could have an agreement where the farmer keeps the panels clean, and the water used runs onto the crops. When it comes to the climate emergency, time is of the essence. I implore you to move quickly towards all renewable clean solar energy for Clark County.

We use heat pumps exclusively to heat and cool the two buildings on our property. They are extremely energy efficient and work great. I had never heard of a heat pump before we bought our house in 2013, but now I don’t know why they are not standard in homes. They really are so simple to have installed and to operate, and they take only minimal maintenance to remain as efficient as possible. I can’t recommend them highly enough! There is no risk from a gas flame (as is on a gas furnace) explosion or a toxic gas leaking into our home. We can rest safely knowing this. No one should have a fossil fuel being pumped into their house in this modern time! Consider this: In the year 2022, why on Earth would we cook with an OPEN FLAME created by pumping in and burning greenhouse gases??? When we bought our house over 9 years ago, we had never used or heard of an induction stove. I cook A LOT and had just come from a new home with a gas range which I enjoyed. I loved the instant temperature adjustment it would give me. When we bought this house and saw that it didn’t have a gas stove, we considered running a gas line up the driveway. Then I started using this induction stove and quickly realized what a superior stove it was. It also has instant temperature adjustment like a gas stove, but it also is much easier AND SAFER to work with. It has a solid piece of glass for a top which has advantages. For instance, if my pot of pasta water boils over, I turn down the heat and throw a kitchen towel around the base of the pot to absorb the water. I can lift the pot to wipe down the glass surface. It is infinitely easier to clean and keep clean than a gas stove for this reason. A gas stove wastes heat. As I write this, it is projected to reach 97 degrees today. Why would I want to have a flame from a gas stove further heating my home in the summer? There is so much residual heat when one cooks on a gas range. When I cook on my induction stove, I can hold my hand over the pot to see if the food is hot — I can’t do this on a gas range because the heat from the flame is flooding the area, being wasted. It is so much easier to gauge the temperature of what you are cooking on an induction stove. An induction stove is safe. There is no flammable gas being pumped into my home for an induction stove. Gas stoves ALL come with a warning that you should ALWAYS run the hood fan when they are in use — this is because those companies know of the toxic concoction that is being emitted from that flame! Also, risk of fire from an induction stove is minimal. Our stove actually shuts off if we forget to turn off the burner and the pot boils dry (yes, we know this from experience). Plus, as i stated earlier, I can literally wipe the stovetop while I am cooking without worry that a towel or potholder will catch on fire. I think if customers knew how great cooking on induction stoves was, they would LOVE using induction stoves instead of gas stoves.

Submitted on 8/17/2022


I sure hope we can get beyond using the natural gas at River Rd. That’s a step backwards.

Submitted on 8/17/2022


Demand for electric energy will grow as the goals of the state and the City of Vancouver are met. Increasing sources for clean energy as quickly as possible is a necessary goal for the PUD. Conservation could be an important part of meeting the new demand. Are there ways to increase conservation efforts in low income neighborhoods for both owners and renters? What financial assistance could be increased to the folks who have the least resources to take advantages of savings that conservation would offer? These are often the same people who have been most adversely affected by fossil fuel pollution. Perhaps targeted financial help with conservation (insulation, heat pump installation, etc) would be appropriate.


Clark Public Utilities is ready to meet the demand for electricity that will grow as state and local energy and carbon reduction objectives are met. We agree that energy conservation programs will continue to be a vital component of meeting the current and new demand for electricity. Clark Public Utilities has a long, successful history of offering cost effective energy conservation programs and exceeding the conservation targets developed in our Conservation Potential Assessment (CPA). We believe there are opportunities to increase conservation efforts in low income neighborhoods and are required to decrease energy burden as a regulated electric utility under the Clean Energy Transformation Act (CETA). Our team is currently developing a strategy that will include targeted conservation programs, low income renewable energy program participation options, and more. Details can be found in our Clean Energy Implementation Plan (CEIP). We also have employed a successful strategy of using federal and state grant funding to provide no, or low-cost energy conservation solutions for moderate and low income customers.

Submitted on 8/17/2022


Please consider nature in the IRP:
— Please use down-lighting. It is better for birds and less glaring for humans, also.
— Please follow other cities’ leads and have Lights Out on public buildings to (1) reduce emissions and (2) protect dark skies for migrating birds.

Submitted on 8/18/2022


To Clark PUC, please increase energy efficiency, conservation, EVs, heat pumps, induction stoves, solar panels, LED lights, etc., and to be an active partner with the city of Vancouver’s Climate Action Plan.

Submitted on 8/19/2022


I am writing to comment on your future energy needs planning document.. I would like to see you spend resources and funds on lookinig at how to make all new buildings energy efficient using electric power.. also how to get current large residentail apartment units to upgrade to more efficient heating systems and use funds for that purpose. i also note you mention the possible use of micro nuclear power as a possible energy source for the PUD in the future. I do not see this as a reliable source and would like to see the PUD move to renewable and most important conservation of energy by your customers

Submitted on 8/19/2022


I think that Clark PUD should make customers aware of and incentivize new, energy-saving technologies and extoll the virtues of old-school methods of drying laundry. After years of not owning a dryer, we bought a heat-pump condenser dryer. New construction should include this efficient appliance that does NOT need to be vented outside. It has never made sense to me why a dryer wastes so much heat by blowing air outside. The heat pump condenser dryer uses a heat pump to heat the air inside the dryer, and the warm air remains inside the dryer while the moisture from the clothes is pulled either into a chamber to be emptied by the user (which you can pour on dirty dishes if you are feeling inspired) or it can be hooked up to a drain like a washer is. No need to vent this dryer outside! It can be put in an interior room! The real energy-saver is hanging clothes outside to dry. It also helps your clothes last longer. The hard part is making it acceptable or even cool. Maybe you could have a contest where people photograph their laundry hanging outside or write fun poetry about seeing their clothes waving in the wind? Encourage apartment complexes to have areas for laundry to hang outside. If people don’t want their underwear seen hanging outside, it can be strategically placed to hide on a drying rack or just be hung inside for the day. In summary, traditional dryers use tons of electricity. They should not be part of new construction and should be replaced in apartment complexes and laundromats at least.

This comment is about EVs and charging. I run an EV event here in Vancouver. Most people’s worry is about charging (especially if they don’t own their own home so don’t have access to a charger). I will say that as an EV owner, many times charging stations are not in working order. We also have had the experience of the cords being CUT at quick charging stations — probably people who don’t like EVs sabotaging things. For the record, EVs DO pay taxes even though we avoid gas tax. We are taxed heavily when we buy our WA state license registration annually! OK, back to charing stations. I know that a lot of people would feel better about buying an EV if they could have access to a charger, especially a charger with PUD’s inexpensive electricity! When we charge at home, we can drive 100 miles for about $2 in energy. That rate goes up if I have to find a private charger (but it is still much cheaper than gas). We need many, many more affordable, RELIABLE chargers for this technology to be accepted. It’s a bummer that a person of lower income who lives in an apartment complex either feels that they can’t get an EV because of the lack of charging or that they are charged more for electricity at a private charger when they are people who would benefit MOST from cheaper transportation due to your cheap electricity. So many people are interested in buying EVs. We need many, many more charging stations. Let’s fill hot parking lots with shade from solar panels that power EV charging stations. Who is going to build the next generation of “fueling” station along I-5 that can charge dozens of vehicles while patrons come inside to drink coffee or have a meal cooked with local ingredients? Maybe they could grow crops out back under solar panels! This could be a great model for the country to follow, and we have tons of traffic heading north and south along I-5 who are NEEDING to charge their vehicles. Speaking of the I-5 corridor, there will be MANY E TRUCKS needing to charge. They will want to stop before hitting Oregon traffic and need massive amounts of electricity to power chargers. This technology is HERE and will multiply quickly — are you ready to provide the CLEAN energy necessary to move this forward?

Does being a Conservative mean one is supportive of conserving electricity? That would be nice! There are many conservation measures we consumers can take that reduce the amount of energy we use. Clark PUD needs to creatively glamorize/promote such activities! Temperature of our homes: Why would our homes be the same temperature year round? When it is cold outside, our homes should be a colder temperature. We can easily put on more clothes; after all, our homes are not cold, WE are cold. If it is going to be hot out, open windows at night to let in cooler air, close them in the morning, and close the blinds/curtains to keep out the sun. Possibly use a small fan to blow on you if you need to cool down — you can avoid using the AC with these methods. If possible, plant deciduous trees on the southwest and west sides of your house. Even if we heat our homes with an energy-efficient heat pump, making that heat pump work less will save more energy. Do laundry less often! Washing your clothes lots not only uses lots of energy, it also breaks your clothes down more quickly. Hang clothes outside to dry when possible. Take shorter showers. Heating water uses lots of energy. You could also finish by rinsing with cold water. Cold water shock is great for your immune system as a bonus! Drive less — walk, bike, or take a bus if you can. If you are going to drive, combine your trips so you are driving less. Try to carpool. This will save electricity once everyone is driving EVs. If you aren’t in a room, turn the lights off in there. Plug devices into a power strip and turn it off when you go to bed. Every bit counts!

Least Cost Option — I would like to comment on the idea of wanting to save money when it comes to switching to 100% renewable, sustainable, clean energy and energy efficiency. It might seem expensive to switch to 100% clean energy rapidly, but the cost of dragging our feet and inaction has already cost our nation billions annually in climate-related disasters. In this area of the world, we have had recent summers and autumns choked by air pollution from wildfires. These fires are made worse from longer, hotter, drier summers. Local farmers struggle to grow food for us with unpredictable and harsh weather. Yes, global action is required, but all we can do is fix ourselves to do our part and set a good example. After all, it is our nation that has contributed the most historically AND per capita to greenhouse gases. Exxon’s own scientists knew that burning fossil fuels was causing global warming back in the late 70’s and early 80’s and warned company executives about catastrophic consequences of continued use of fossil fuels. Please read about it here in this Pulitzer-Prize-winning investigation: The RRGP is using fossil fuels. Natural gas lines going into buildings is more fossil fuels used. We need to make the switch. It should have been done already. The sooner, the better! It’s only going to end up costing us more!

Submitted on 8/19/2022


I support IRP to be as strong as possible, knowing that climate challenges which affect us right now, will be worse with every passing year. Too late to prevent. Not too late to lessen. Energy efficiency by consumers has not yet been fully realized, for example, and the utility should be in total harmony with City of Vancouver’s plans. Be visionary, and determined.

Submitted on 8/19/2022


Dear CPU Board:

I am a Vancouver WA resident, and CPU customer. Per the IPCC Sixth Assessment Working Group Report (2021/2022) (1) “it is only possible to avoid warming of 1.5 °C (2.7 °F) or 2.0 °C (3.6 °F) if massive and immediate cuts in greenhouse gas emissions are made”

I urge you to move as quickly as possible to
> producing 100% of Clark County electricity via renewable energy sources
> Phase out the River Road Gas Plant
> Purchase and/or produce solar electricity.

(1) McGrath, Matt (9 August 2021). “Climate change: IPCC report is ‘code red for humanity'”. BBC News. BBC. Archived from the original on 13 August 2021. Retrieved 9 August 2021.

Submitted on 8/19/2022


I am a mother, a wife, a environmental activist, and a janitor. I am trying so hard to save my son’s futures. I am involved with 13 different environmental and social justice groups and I am willing to do anything for a better future for my son’s and the community. I don’t want to look back at my life and say that I didn’t try. I love my son’s more than I ever thought I could love. I want them to know that mommy tried. Please know that everything that we do effects the future and we should be implementing solutions that are sustainable and clean. I have amazing friends who also submitted comments that are more technical and I admire them so much. I am submitting my comment from a mother’s prospective and I don’t want my children or any child or animal to suffer because of greed and thinking we should stay with business as usual. If we don’t invest now there will be no future. I send you all the biggest hugs and thank you for all that you do but we need to do more.

Submitted on 8/19/2022


Its time for the PUD to commit to progressive energy commitments and to quit the dishonesty that is evident in their thinking.I just want to get on the record my disappointment in the attitudes being expressed in the PUDs policies

Submitted on 8/19/2022


I support renewable energy and incentives for commercial and residential electricity use as the primary focus of the Integrated Resource Plan.

We have a ductless heat pump which not only provides heat in the cold weather but also cools in the hot weather. In addition, our water heater went out recently and we replaced it with a heat pump water heater. With the rebates we received from Clark PUD, we are lowering our electricity usage and doing our small part to help global warming, the units will pay for themselves over time. A win-win for all concerned!

Submitted on 8/19/2022


It is most urgent that we act in a sensible manner to achieve and/or exceed the State’s goal of eliminating fossil fuels, including “natural” gas. Educating the consumer on the benefits of investing in efficiency, self-sufficiency, renewable resources, and incentives is first and foremost. Secondly, assure the grid is capable of handling the increased demand for energy without creating fire hazards or necessity for “rolling blackouts” as occurs in California. PacifiCorp is now being sued for causing the deadly McKinney Fire in Siskiyou County. One way to manage the demand on the grid would be promotion of residential rooftop solar with battery backup. There are acres if not square miles of properly oriented rooftops in Clark County where panels could be installed. With good incentives (tax credits from State and Federal), a reasonable payback time can be is all it would take to convince those “on the fence” into making the investment. The homeowners that do will be able to harness the energy stored in their batteries during peak demand time thus reducing the demand on the grid. EV’s will create more demand but are only clean if they are charge from renewable sources. Solar and wind are now the least expensive sources of electrical energy. The issue is storage and meeting peak demand. Both batteries and EV’s could help with storage for peak demand as well as outages. Think Texas, winter of 2020-2021 when people died, homes were flooded after pipes froze and bills went through the roof because of their crazy supply/demand pricing. The number one way to reduce our demand is through efficiency, as the least expensive energy is the energy we do not use. Promote saving by doing everything we can such as: sealing and insulating our homes; installing more efficient windows and doors; purchasing energy efficient appliances, especially hot-water heaters and heat-pumps: and, make sure the public is aware of efficiency incentives when making decisions about purchases. EV charging infrastructure build-out will be essential in assuring acceptance of EV’s and overcoming consumer “range-anxiety”. Stations should be accessible and affordable! Renewables should be incorporated where-ever possible when considering location for charging infrastructure such as parking structures with solar rooftops, etc.
Thank you, and I hope You will take my comments into consideration.

Submitted on 8/19/2022

I am very glad to see how you are planning ahead for more electric vehicles and I love that your advertising on TV includes both new and used EV’s. We have a plug-in hybrid (Prius Prime) which gives us amazing mileage although the electric range is only about 30 miles. People ask us if our electric bill went up when we got it, but it hasn’t. I think electrifying is the way to go and will help us with the climate chaos that using fossil fuels for too long has caused.

Submitted on 8/19/2022

In the Integrated Resource Plan, I support renewables such as solar, wind, tide, and wave energy for sources of energy as global warming and climate change get worse.

I do not support keeping the River Road gas plant running any longer than is absolutely necessary. This plant puts out methane, CO2, and other pollutants which not only exacerbate global warming but also aggravate breathing problems for many people. Also, the extraction of gas uses fossil fuels to get this gas to pipelines which transport it to its destination. Many times these pipelines are at the end of their expected lifetimes. When a pipeline leaks or breaks, the result many times is a horrendous explosion, such as the two pipeline explosions on February 9, 1997, a Sunday night, near Kalama, Washington. The causes were listed as ground failures and luckily, no one was hurt or killed. However, there are no guarantees future ruptures on any of the lines in Washington will be so harmless.

Submitted on 8/19/2022

I support the use of renewable energy instead of petroleum fuels and natural gas. Also, I do not support the use of nuclear reactors as a source of electric power.

There is talk of building SMRs (small modular reactors). These still use radioactive fuels that require petroleum fuel to get out of the ground, transportation to processing facilities, and delivery to the reactors. Once there, after generating electricity by using steam turbines, the radioactive fuel rods must be stored, with no good final disposal process or site developed. Hanford, up the Columbia River, has waste tanks leaking now with the radioactive material getting into the groundwater and spreading toward the Columbia. Is the solution to take the SMR waste up to Hanford?

The Proceedings of the National Academy of Sciences (PNAS), on May 31, 2022, had this article. “Nuclear waste from small modular reactors.”

“Small modular reactors (SMRs), proposed as the future of nuclear energy, have purported cost and safety advantages over existing gigawatt-scale light water reactors (LWRs). However, few studies have assessed the implications of SMRs for the back end of the nuclear fuel cycle. The low-, intermediate-, and high-level waste stream characterization presented here reveals that SMRs will produce more voluminous and chemically/physically reactive waste than LWRs, which will impact options for the management and disposal of this waste.”

Why should we create more nuclear waste when we cannot take care of the waste we already have? SMRs are a bad idea

Submitted on 8/19/2022

Thanks for the opportunity to comment on the Integrated Resource Plan and thank you also for all the innovative programs the PUD has set up to encourage conservation. This year we were beneficiaries of a heat pump rebate, one of the many incentives you offer consumers to save electricity and make good decisions about energy saving investments.

I am concerned that we are still getting such a large percentage, around 30%, of our power from the River Road Generating Plant. I understand also that electricity production is the third-largest source of carbon emissions Washington.

Such reliance on a fossil fuel power source is not a good idea in this time of rapid climate change and I hope we are able to move away from it more quickly than 2045.
We all know the problems associated with fracked gas: not only carbon dioxide emissions, but also methane and nitrous oxide, all dangerous greenhouse gases.
In addition, they are responsible for respiratory health issues in neighborhoods like Fruit Valley, an area without nearby air monitoring stations.

Burning fracked gas is harmful in itself, but everything from the fracking fields to the mode of transportation to storing the gas is responsible for leaks. Fracking itself uses far too much water (ca 1-1/2 gallons to produce 1 gallon of gas) to justify its further use in this time of drought.

There are other ways we can develop the power we need. Solar is readily available. How about installing rooftop solar on Port rooftops and using the transmission lines already in place at River Road? In addition, there are acres of commercial roofs around Vancouver and up the Gorge that could provide solar and dispersed solar and thereby safeguard against outages at River Road. Community Solar is widely popular as well and I hope you are able to find new venues for it.

In addition to Combine Hills, have we investigated off-shore wind? Not only would it generate hundreds of new jobs, but it would be an economic boost to any small oceanside communities used as bases for equipment and supplies.

Despite the Flexibility Plan coming in 2024, I think the best course is to phase out River Road as soon as we can. This is not the time to consider only the economic impact on ourselves. We must do all we can to lessen our impact on the worldwide climate, one effort at a time.

Thank you.


To answer your question related to offshore wind that is bolded above, offshore wind is a resource technology that wasn’t included in the 2020 IRP. However, because offshore wind discussions in the region have intensified over the past two years, we added a discussion of offshore wind to section 4 of the IRP update this year. Of particular interest are two sites off the southern Oregon coast have been identified by the federal government as potential leasing sites for offshore wind energy. Offshore wind capacity factors are 39 to 57 percent, which is significantly greater than the capacity factors of on-shore wind and solar in the region. Another attractive feature of offshore wind is that projected generation is winter peaking.

Clark Public Utilities will continue to track the offshore wind projects as some projects could achieve commercial operation at approximately the same time that Clark Public Utilities’ load/resource balance transitions from an energy surplus to an energy deficit. A Power Purchase Agreement with an offshore wind developer may be a good addition to Clark Public Utilities’ resource portfolio at that time.

Submitted on 8/19/2022

Small Scale Modular Reactors are considered to be an “emerging” technology and I am very glad one of them is not a part of your power production mix, at least not yet. I think there are many reasons to mistrust this new technology.

These reactors are not exactly carbon-free. Nuclear material must be mined and transported to the reactor at Hanford and it is well-documented that Hanford is the most contaminated site in the Western Hemisphere. Decades-old nuclear waste is stored in leaking barrels, most of which have developed leaks, and this waste is working its way to the groundwater and to the Columbia River. The completion of the cleanup making this area safe for the future is still years away and we cannot add more nuclear to such a precarious situation. A much better choice for Hanford would be a huge solar installation – it has plenty of sun and transmission lines going almost every direction. Let’s make Hanford a leader in renewable energy instead of a threat to our future.

Whether through a Power Purchase Agreement or ownership, this technology should be avoided at all cost. We should concentrate instead on technology that will help us forever to keep our climate problems as manageable as possible. Thanks for letting us weigh in on this important issue as you plan for our sustainable future.

Submitted on 8/19/2022


Hi! I’ve been keeping an eye on the progress of the IRP and I’m happy to see that renewable energy and changing the transportation sector to EVs is a very active conversation right now. However, I do have to agree with others who have left comments that this still isn’t aggressive enough. We need to be moving faster on creating more cleaner sources for energy and phasing out any reliance on natural gas.

I do have one question. Will there be any incentives included for updating apartment complexes to support EVs? I want to buy an EV in the near future but I also live in an apartment complex and have no way of charging an EV here. Also there must be some incentives for updating appliances, windows, and fixtures as well as considering central Air Conditioning. The two apartments I’ve lived in here in Vancouver have no ceiling fans, use outdated appliances, use the cheapest light bulbs, and have poor insulation. Are these things being taken into consideration as ways to conserve energy? Incentivizing these things would help middle to low income families a great deal especially as the summers are becoming hotter and more brutal. Thank you in advance for taking the time to respond.


Thank you for your comments and for your participation in the 2020 IRP Update process.

For more information on what we’re doing to support the City of Vancouver and the Climate Action Plan/Framework, please see our response to the public comment on 08/15/2022. You can find a link to the IRP public comments here.

Clark Public Utilities has a long history of support and promoting solar generation systems. Clark Public Utilities currently offers the net metering program to all distributed energy resource customers, including roof top solar PV systems at homes and businesses. Our utility loan program is also available for residential customers to use to finance solar PV systems at their homes. Also, In addition to our first successful Community Solar project, Clark Public Utilities is currently scoping out a new community solar program for development that will create more opportunity for renewable energy participation for our customers. More to come on this soon!

Submitted on 8/19/2022


I’d like to submit comments for the Integrated Resource Plan:
1. The City of Vancouver is approving an ambitious climate action plan (CAP) and I would like to see Clark PUD become more of an engaged partner so we can meet these greenhouse gas emission reductions by the target deadlines. How can Clark PUD take action to support the City’s CAP?
2. How has Clark PUD included the recent Inflation Reduction Act into this IRP? How will this bill support Clark PUD to become more energy efficient and reduce GHG emissions?
3. What is Clark PUD doing to support modifications for more energy efficient vehicles like electric motor conversations for gas-powered vehicles?
4. Please provide more ways that Clark PUD can support cleaner energy like solar – it seems like there isn’t much forward momentum in this area.
5. How can Clark PUD bring indigenous voices to the decision-making table? Most of our energy comes from dams that severely impact those ecosystems and the creatures of the rivers like salmon.


For more information about what we’re doing to support the city and their Climate Action Plan/framework, please see our posted response to the like question on 8/15/2022.

The Inflation Reduction Act, signed into law just last week, creates a variety of new energy efficiency, renewable energy, electrification and electric transportation programs. However, it will take time for the concepts within the law to materialize into actual programs that customers can participate in. Specific details on the different programs that will be created by the law are currently limited, but we do have a general idea on the scope of the different developments and programs. Like many federal statutes, much of the federal funding for these programs will flow to different departments and agencies at the state level, and each state will create programs for their citizens to access. Many of the new programs are designed to be tax credits and all interested customers should consult with a licensed tax professional to determine eligibility.

Clark Public Utilities also offers a variety of energy conservation rebates and a conservation loan program. To learn more about the utility programs currently available please call our Energy Counselor of the Day at (360)992-3355 or email [email protected].

Below you will find a summary of the information we have related to the new Inflation Reduction Act.

Residential Energy Efficiency Programs and Upgrades

Sec. 50121 Home Energy Performance-Based, Whole-House Rebates

  • Appropriates $4.3 billion for a program to award grants to State Energy Offices to develop and implement a HOMES rebate program for whole-house energy saving retrofits. A State Energy Office seeking a grant under this section must submit an application that includes a plan to implement a HOMES rebate program, including a plan related to a variety of program design and deliverability topics. For Washington State, the agency will likely be the WA Dept. of Commerce.
  • Tax Credits: 30% credit with a $2,000 cap, applicable for HVAC, weatherization, water heating and shell measures
  • Financial Incentives: Up to $14,000 in lifetime rebates depending on household income levels

Sec. 50122 High-Efficiency Electric Home Rebate Program

  • Appropriates $4.275 billion for a program to award grants to State Energy Offices to develop a High-Efficiency Electric Home Rebate Program. An additional $225 million is appropriated for a program to award grants to Indian Tribes to develop and implement a High-Efficiency Electric Home Rebate Program. A State Energy Office or Indian Tribe seeking a grant under the program must submit an application that includes a plan to implement a High-Efficiency Electric Home Rebate Program.

“Qualified electrification project” means a project that:

  • Includes the purchase and installation of:
    • An electric heat pump water heater;
    • An electric heat pump for space heating and cooling;
    • An electric stove, cooktop, range, or oven;
    • An electric heat pump clothes dryer;
    • An electric load service center;
    • Insulation;
    • Air sealing and materials to improve ventilation; or
    • Electric wiring.

Renewable Energy Related Tax Credit Programs

Sec. 13102 Three-year Extension and Modification of the Investment Tax Credit

  • This section of the bill extends the tax credit for qualified residential clean energy projects for solar electric, solar water heaters, small wind and geothermal heat pumps. The tax credit reduces over time from 30 percent through 2032, to 26 percent in 2033, to 22 percent in 2034, after which it would expire.

Electric vehicle Related Tax Credit Programs

Sec. 13401 Clean Vehicle Tax Credit

  • This section of the bill extends the $7,500 tax credit for qualified clean vehicle purchases and creates a new tax credit for used clean vehicle purchases (for used clean vehicles that cost up to $25,000). The tax credit has restrictions based on the clean vehicle purchase price (maximum price limit of $55,000 for cars and $80,000 for trucks/SUV/vans) and the clean vehicle battery manufacturing process and geographic location. The IRS has released updated guidance on this tax credit.

Clark Public Utilities will continue to track the development of these new programs created by the Inflation Reduction Act and will update our public website as new information becomes available. Please also see information for residential and commercial EV charging incentives on our website.

We thank you for your thoughtful questions and for your participation. We invite and encourage all customers to participate in public process whether it is thru the IRP, or our bi-monthly public commission meetings. We are always looking for ways to improve- including looking at ways we can engage more of the public in comment periods when they happen.

Submitted on 8/19/2022


Commissioners and PUD Staff,

I’ve been a full-time resident of Clark County for 60 of my 67 years. I am grateful to be served by a public utility district. Clark Public Utilities has been a reliable service provider and I appreciate the low cost of electricity here.

The most important thing I want to say is that our plans need to acknowledge the true challenges climate change will put before us by recognizing the pace at which they will confront us. Our ambition level needs to match what the science says. Anything less will have a very high human and economic cost beyond the inevitable cost of a just transition to extremely low C electricity.

In 1984 I bought a home in Clark County that I still live in. It still has the plate near the front door documenting the involvement of Clark Public Utilities in the construction of the home. The heat pump that came with the home kept us comfortable until we needed to replace it a few years ago with a newer model. In 2018 we had the great privilege to be able to add rooftop solar and have benefited from the net metering program of the PUD. This net metering program makes a great deal of sense by increasing your portfolio of extremely low C electricity, avoiding the waste of this generating capacity, and improving the climate for private investment in rooftop solar.

Will you be able to use funding from the inflation reduction act to provide more residences with the chance to enjoy the savings and benefits from rooftop solar? This seems like a great place for cooperation with the City of Vancouver as it implements its climate action plan. PUD’s cooperation with the city is essential for them to meet their goals. How will you partner with the city?

As a 33 year survivor of two heart transplants, I am always alert to the impact of air pollution on health, mine and the public’s. This week another new scientific report from shows the devastating health impacts of PM2.5 and NOx pollution. “Air pollution is responsible for 1 in 9 deaths worldwide and accounts for 6.7 million deaths in 2019 alone… Exposure to air pollution is linked to increased hospitalizations, disability, and early death from respiratory diseases, heart disease, stroke, lung cancer, and diabetes, as well as communicable diseases like pneumonia.” Please prioritize reducing the PM2.5 and NOx pollution from the RRGP by increasing non-fossil fuel electricity in our portfolio.

I appreciate the service I receive from Clark PUD. Thank you for considering my comments


Thank you for your thoughtful comments and for your participation in the 2020 IRP Update process. We have received some similar questions and comments during the public comment period, both around the City of Vancouver’s Climate Action Plan/Framework and also another on the Inflation Reduction Act. Below, we’ve outlined where you can find those answers we’ve posted in our prior responses;

  • For more information on what we’re doing to support the Climate Action Plan/Framework please see our posted response on 8/15/2022
  • For more information on what we know so far about the Inflation Reduction Act, please see the newly posted response just before yours on 8/19/2022

Submitted on 8/19/2022


I am a senior on a limited income with an aging gas furnace and a water heater that also quit working just this summer. I am glad Clark provides incentives and assistance for electric appliances, but am frustrated that “fuel-switching” has been a barrier.
Last year the WA legislature considered a “Targeted Electrification Bill (HB 1767) that would have allowed public utilities, including Clark, to fund electrification retrofits, an authority already granted to private utilities, to expand clean energy opportunities to all utility customers.
I want Clark PUD to advocate getting the ability to consider funding to support customers like me, to replace gas with electricity. While private energy utilities are already able to provide incentives to customers moving to electric space and water heating, public utilities need additional legislative clarification in order to offer these kinds of incentives to customers and provide the same kinds of choices.
I was encouraged that this legislative bill could provide a way for Clark PUD to consider the needs of customers like me, so the incentives could be offered. I know there are many other customers in Clark County who are low income and vulnerable to the health impacts of continuing to use gas in their homes and who face replacing their gas appliances due to them aging out – as a public utility, I believe you should support having the authority to help your customers convert their gas appliances to high-efficiency electric equipment.
I was dismayed that WAPUDA opposed this legislation and only after persistent input to our Commissioners did they finally agree to support this bill last February, late in the session. Ultimately the bill failed, I believe due to lobbying by the gas industry and the opposition of organizations like WAPUDA. I am glad our PUD Commissioners finally decided to support the bill for their customers possible benefit.
This was not a mandate but an opportunity to offer choice to your customers like myself, and the policy would help support low-income customers transitioning from gas to clean, electric heating and appliances, enabling them to benefit from bill payment assistance programs required by the 2019 Clean Energy Transformation Act. No analogous requirements exist for gas utilities. Passing HB 1767 / SB 5666 would have provided an important source of funding for residential building electrification, a key part of the decarbonization puzzle.”
Given that decarbonization is a key focus for addressing public health and climate concerns, and electrification of buildings has been determined by our 2021 WA State Energy Strategy to be the most cost-effective way to decarbonize buildings, it is obvious that it would benefit your customer base to support legislation to remove the “fuel-switching” prohibition standing in the way of CPUD considering assistance/incentives for customers like me.
I am sure this legislation will be offered again until passed, and especially given Clark’s partnership with the city on developing sufficient electricity capacity to meet emerging electrification needs that our state and city are actively pursuing via climate action policy, with climate, public health and equity considerations, I would like to know how specifically this current IRP update incorporates providing our city and community with predictably increasing electricity needs (just like the most recent commercial building code update requires electric heat pumps in commercial and large multifamily homes, it is likely by the end of this year similar residential building code updates will be put in place.)
I want to know specifically how Clark PUD is planning ahead to accelerate building electrification – a recent article in the Columbian noted that Vancouver will need partners, including CPUD, to reach it’s carbon neutrality goals by 2040. This means each IRP update should reflect not just the increment but also how to successfully manage the whole pathway to reach 2040 carbon neutrality. This means going beyond what are currently minimum requirements in current state law, which will certainly change as we go along. How will Clark PUD demonstrate it is matching our city with leadership on reaching climate action goals


I am concerned that the draft update continues to include nuclear power for long range planning, in the form of small nuclear reactors (SMR’s). I am disappointed that staff continue to pursue this as a resource that is not cost-effective (the industry has always been plagued with cost overruns and there is no clear evidence, other than pro-industry driven projections, that small modular nuclear reactors will be any different in the long run), generates high-level waste that still has no safe federal waste disposal repository, and includes risks that are not acknowledged or addressed in the proposals advanced by pro-industry sources. In addition, the industry continues to be propped up by huge taxpayer subsidies while allowing limited liability to the industry, with taxpayers on the hook when the worst happens. Non-emitting (carbon) at the generating site still does not make this clean or green, and the time and staff resources spent chasing this as a resource option diverts time and resources away from pursuing more economical, readily available, and less risky alternatives, should we need them eventually.
Our local PUD can do better. I urge you to remove SMR’s from the Alternative Portfolio #2 since it clearly does not belong in the “Least Cost Considerations” and it is not “carbon-free” in spite of how the CETA legislation included it by defining it as “non-emitting.” It concerns me that the nuclear power and fossil gas options are framed here as a binary, either/or choice for our longer range resource considerations. I would prefer to see us actively pursuing a mix of safer, cleaner, renewable and storage/demand response/DER/etc. options that do not keep us locked into this form of binary “solution.” I support a RRGP phase-out but not with SMR’s as a meaningful part of the replacement resource mix. Again, please look beyond pro-industry generated sources for your SMR numbers (the 5.1 table, “sourced” to Lazard but I believe not actually supported by Lazard, and it would be more helpful to see the latest (I believe this one is 3 years old.)
Finally, there is much out there being studied, researched, written and reported, on both sides of the proposal that nuclear power is needed and is a “clean” energy solution to fight climate disruption and to supply reliable safe and cost-effective power. What I see happen is for proponents of small modular reactors to dismiss any challenges or criticism as simply “anti-nuclear” or not “science-based” and to dismiss any concern or opposition as not credible. I believe that public utilities owe it to their customers to pay attention to and weigh all information carefully in order to decide whether or not this merits inclusion in our long range resource mix, and to honestly address up front the risks and liabilities as well as presenting the potential “benefits”


This is my last comment, and I want to thank all the staff who have been working so hard on the IRP update, for their willingness to provide a space for us to express our thoughts/questions/concerns/ideas/suggestions and to respond back with staff explanations and perspectives on integrated resource planning. This is a learning experience, and I trust that it works both ways for all of us. Your time, attention, and patience are much appreciated.
The past several years have shown us here locally just how compromised our air quality can get, with smoke from wildfires (2019) and the oppressive air descending on us with the heat dome (2021) and the elevated temperatures this summer. The work done by the state in producing the Washington Environmental Health Disparities Map has revealed what is not always apparent to us in our everyday lives when we are not noticing poor air quality. Our city and county (where I live, close to downtown Vancouver right by the I-5 and HWY 14 juncture) rates at the top of this map, and is alarming with regard to the pollution impacts that we breathe in daily, making those of us who are older, our children and grandchildren, and those in our most vulnerable neighborhoods (close to the industrial areas, especially Fruit Valley neighborhoods) at risk for health impacts that are exacerbated by all the ways we continue to burn fossil fuels. I appreciate that our city, Port and PUD are all now acknowledging, with consistent input from citizens, that a transition away from burning fossil fuels to drive and heat our buildings/homes etc. is not only necessary to address climate disruption, but also to address equity and health impacts that some of us are more burdened with than others.
I appreciate that our PUD is in conversation with our City staff and elected representatives as a partner in the Climate Action Framework that we are all working to develop, and recognize that PUD staff are working to listen and work towards solutions that will reduce our transportation and building emissions and protect us from worsening climate and health risks. I offer my thoughts not as criticisms but as a way of contributing to that underlying effort.
I continue to be concerned about the way in which the health and climate impacts of the River Road Gas Plant are not being fully and transparently addressed. I realize that the place the plant currently holds in our resource mix cannot be changed overnight and our PUD thinking is built around making the case for keeping it in operation, but would like to see two things happen.
First, an honest and direct accounting for the air quality impacts of continuing to run the plant indefinitely (through 2045). If the specific data is not available, please advocate for getting it, to better inform your customers. We are being told that carbon and local criteria pollutants are reduced when the plant is not economical to run, but the other side of that coin is that phasing it out and replacing it with other resources is actually the MOST protective from both a public health and a climate perspective. We sell surplus power (“economical to run”) to other parts of the region and California, but clearly at an expense to us who live here, locally. I would like to see our PUD pursue and share the actual numbers for the specific air quality impacts as well as any other drawbacks and trade-offs we are subject to, in order to continue operating the plant in some way through the next two decades.
Second, I would like to see an active assessment of alternative ways to pursue rapid deployment of local storage to combine with community and commercial rooftop solar (offering net metering that makes this worthwhile, along with being willing to provide power to commercial developers who see the value in renewable installations) along with creative distributed resources that might overcome the belief that the only reliable resource is our fossil gas plant. I appreciate staff for focus on affordable and reliable resource planning and the worry that in emergencies our community wants a back up resource to prevent outages. I understand that RRGP has had it’s share of outages, which the community may not be aware of. Keeping the plant shuttered but with an emergency capability (as a backup for extreme events that may or may not require it’s use) could be a viable alternative to the large price tag being considered to out fit the plant to continue operating.
Finally, I realize that RECs are offered as a supplemental way to achieve targets for reducing ghg emissions, but these do nothing to solve the public health and climate disrupting impacts that will continue to harm us locally with a slow transition. Both the city and our PUD are addressing equity concerns in their efforts to address climate disruption, and the question of affordability for the transition to renewables over fossil fuel generated electricity for transportation and buildings is a factor frequently offered to slow the transition. I believe that our community deserves an honest accounting of the costs of health and safety impacts if we are continuing to burn fossil fuels, and would see PUD rate issues from a different perspective if they knew the truth of what they are actually paying in addition to dollars and cents each month for their electricity. Especially our location here in the Pacific Northwest, with plenty of hydro and opportunities to perhaps purchase abundant renewable generated power from the east side of our state to supplement what we can expand generating locally.
Again, thank you for listening and offering back your thinking on these ideas and concerns.

Submitted on 8/19/2022


I am a GreenLights subscriber and given that I am now retired and on a fixed income, I have to weigh where my dollars go each month. I support the renewable energy educational activities and wonder what form these now take, since renewable energy and conservation have taken on an increasingly significant role in our thinking about how a safe and healthy future can be assured for our young people, who are more and more alarmed/concerned about climate and their future. What are the current educational offerings and how can these be incorporated into providing ways for young people to be both educated about and actively engaged in city and community efforts to address climate issues locally (eg the city’s CAP work)?

I have heard Commissioners occasionally express some skepticism about how large corporations use RECs as a way to “greenwash” their environmental footprint, and I as an individual using GreenLights want something real and if possible local, not a greenwash. I am concerned about what the GreenLights RECs actually provide in the way of verifiable and meaningful investments in local renewables, and I know others who are asking these same questions and reconsidering the GreenLights program as a meaningful way to spend limited dollars.

The article in Energy Advisor in March said: “About two thirds of the funds support the purchase of renewable energy credits — tradable energy commodities that represent 1 megawatt-hour of electricity produced by a renewable energy source located in the western interconnect, including the Clark Public Utilities community solar array.” I am not sure based on this that I am investing in local enough “regional renewable energy development” and would prefer verifiable credits connected to renewables that lower emissions here in Clark County, since the “western interconnect” is vast and the idea of “tradable energy commodities” seems vague and could possibly mean recycled credits that do not actually mean I am compensating for my consumption with additional renewable power generation that we really need to invest in here.

Given that many customers are increasingly aware of the need to shift to renewables, and want to contribute to developing local renewables that can support increasing our electricity generation capacity to meet the needs for our city and community, can the GreenLights investment of customers like myself be directed to support these local installations rather than something that comes from far away and may be simply “reshuffling” the output of existing projects elsewhere that do not benefit us locally?

I realize that the current program is longstanding and many customers may be volunteering their dollars simply because they trust CPUD to provide a meaningful way to do something about their consumption. The Energy Advisor article said “The Green Lights program has supported several renewable energy projects in Clark County” – given the increased interest in local renewables development, how can the current program (a) better inform prospective and current customers about the nature of what their investment actually supports and (b) restructure the program as much as possible to ensure meaningful, local investment in renewables.


We appreciate your questions about educational offerings and what we are doing to educate young people about the impact we all have on our environment. Clark Public Utilities has a long history of education engagement at the utility. For years, we have offered 4th graders an on-site tour to learn about safety around electricity, our environment, and locally, the importance of our watersheds. Additionally, we support teachers with curriculum.

Recently, we launched an amazing educational platform called the PowerZone as a complement to these efforts. It offers a way for young people to engage age-appropriately not only with the world of energy, but also with our environment. There are 5 main sections on the website;  Electricity, Water, Careers, Environment and Renewables. Each section offers a wide variety of information and a way for kids to interact. There are also links to books, podcasts and ways to get involved. The goal for this site was for it to be accessible Kindergarten all the way through high school- Even as an adult, I enjoy the content and activities on the site!

Here is a link and please share it with anyone you think would enjoy it.

As you pointed out, much of the great work the City of Vancouver is doing with the Climate Action Plan/Framework focuses on making Clark county a better place for us all. We believe the content presented on our PowerZone website nicely complements their work as a way to engage and educate our youth. To learn more about what Clark Public Utilities is doing to support the City of Vancouver, please see our response to the post on 8/15/2022.

Additionally, Here is some information about our Green Lights program that we previously posted as a response on 8/16/22, to another comment: Clark Public Utilities’ Green Lights Program: Washington State law (RCW 19.29A.090) mandates that electric utilities offer a green power voluntary program. Clark Public Utilities’ Green Lights program was developed in response. The program allows customers to purchase Renewable Energy Credits (RECs) for as little as $1.00 per month. We can look to the EPA who defines a REC as “a tradable, market-based instrument that represents the legal property rights to the “renewable-ness”—or non-power (i.e., environmental) attributes—of renewable electricity generation.” A REC is only produced when a renewable generator produces one megawatt of electricity. The RECs we procure for the Green Lights program are sited in the Pacific NW and are also Green-e certified. All Green Lights program RECs are retired in the WREGIS database which ensures there is no double counting of the environmental attributes.

Lastly, Our Green Lights program also helps to support education. Each dollar invested in the program purchases the environmental attributes associated with 100kWh of renewable electricity generation. Further, a portion of that money is allocated to fund local educational programs and activities that are related to renewable electricity generation. In the past those programs included “demonstration solar PV projects” at local schools, but now focus on educator workshops and student events, like the Solar Car Challenge.

Submitted on 8/19/2022


To: The Honorable Clark County PUD Board of Commissioners
Public Comment on the Draft IRP
After reviewing the draft IRP, I am alarmed that you plan on running the RRGP for another 20 years. I am a mother and a grandmother and I am concerned about how climate change will be affecting them. After reviewing the Integrated Resource Plan- Clark Public Utilities summary page, you focus on reliability, sustainability, affordability and efficiency which are all admirable goals, but there is no plan to reduce your CO2 emissions.
Burning fossil fuels releases CO2 which in turn creates a greenhouse effect causing the planet to warm. The RRGP emits 635,084 mt of GHG annually. According to the data I have, the RRGP is the 3rd largest emitter of CO2 in Washington state and the 10th largest in the northwest.
Scientists say, “If we are to avoid the worst impacts of climate change, we need to reduce our CO2 emissions by almost half by 2030 and reach net zero by 2050.” It will be impossible to reach that goal if utilities like yours don’t reduce their CO2 emission as quickly as possible. Your plan to pour money into upgrades and maintenance for the RRGP in order to continue operating it until 2045, is not only a threat to humanity, but a waste of tax payers’ money. In 2021 the Washington State legislature passed The Climate Commitment Act, which will be regulating carbon emissions for businesses and industries. It will be increasingly difficult for RRGP to meet the new carbon emissions standards and RRGP will be forced to shut down early. It would be wise to study this law before you make plans to continue operating RRGP for another 20 years.
I expect my PUD commissioners to be intelligent and accept what the scientist are telling us about climate change. The science says, burning fossil fuels is causing our planet to warm. You must stop burning fossil fuel and embrace the future of clean, green, energy. Not only is green energy cleaner and safer it is becoming increasingly cheaper to produce, thus saving the utility money in the long run, all the more reason to transition to green energy as soon as possible. I like your plan to increase, the amount of carbon-free hydro power you purchase from BPA, and adding a 50 aMW of Box Canyon hydro to your resource portfolio. This is an excellent plan and I’d like you to have a goal to replace the 30% power generated from RRGP with renewables as quickly as possible.
To reduce CO2 emissions in the area of transportation, you should develop a program giving subsidies to help people buy electric vehicles and build more charging stations. Buildings are the source of 40% of CO2 emissions. To cut CO2 emissions in the building sector, there should be a program to replace all oil and natural gas furnaces with electric heat pumps in buildings and houses as soon as possible. In addition, there should be a program to aid with the proper insulation of all buildings and homes.
I have another concern besides climate change and reducing CO2 emissions and that is for the people who live in Fruit Valley area who are being exposed to pollutants generated by the RRGP. By continuing to run the RRGP for another 20 years you are jeopardizing the health of the Fruit Valley residents. The main pollutants from natural gas plants are nitrogen oxides or NOx. According to the Washington Physicians for Social Responsibility, “when NOx reacts with other substances it produces particulate matter which cause an extensive list of health problems such as shortness of breath, asthma, heart attacks, and premature death.” Before you plan on a prolonged operation of the RRGP you need to take into consideration the health and well- being of the Fruit Valley community. An air quality study needs to be done in the area surrounding the plant and the Fruit Valley area in order to determine exactly what is in the air. A study needs to be done to determine the health risks involved with the continued operation of the RRGP. Someday the Fruit Valley residents may file a class action law suit claiming health problems due to the RRGP pollution.
If we are to succeed in fighting climate change it will take a united effort across this nation and around the world to reduce CO2 emissions. Unfortunately, your failure to do your part combined with other community leaders who fail to do nothing to reduce CO2 emissions will cause the planet to continue to warm. Future generations will be living on a planet that is so warm there will severe drought, making it difficult to grow crops causing a food shortage resulting in massive starvation. There will be a shortage of water. The air will be so hot and polluted you have to wear a mask and cannot be outside for longer than 6 hours. There will be extreme storms worse than anything we have seen so far and happening so frequently, that before recovery is complete another storm hits. There will be an increase of diseases such as, malaria, dengue fever, cholera, respiratory illnesses, and malnutrition. As our planet continues to warm, forests will no longer exist, and wildlife has all but disappeared, the ocean so acidic marine life cannot survive, and vast areas of land will now be uninhabitable. There will be fierce competition for food, land and water causing human conflict.
It doesn’t have to be this way. We still have time to stop the climate from spiraling out of control, but only if leaders like your selves do your part in reducing CO2 emissions. I believe in the science of climate change and that is why I implore you to shut down the RRGP as soon as possible and replace the energy produced by the RRGP with renewables. Future generations are counting on you to do the right thing. Their fate is in your hands. Please don’t let them down.


We’d like to offer a bit of information about what we’re doing to reduce emissions, including changes at River Road Generating Plant (RRGP). Below, we’ve included some brief information and also some links to further information.

  • In the short term, with our new RRGP flex product coming in May of 2024, we are reducing RRGP from 30% of load to 20% of load by 2030.
  • We have plans to meet the goals set under the Clean Energy Transformation Act (CETA) as soon as we can, before 2030- More information can be found in our Clean Energy Implementation Plan (CEIP)
  • We will not be running RRGP in 2045 unless we are using clean gas or hydrogen
  • The Climate Commitment Act (CCA) sets a reduction target for the entire state of Washington including RRGP, the CCA and CETA are working hand in hand
  • During the transition we are investing in RRPG to allow it to be reduced in real-time when renewables and non-emitting resources are available, reducing both greenhouse gasses (GHG) and local criteria pollutants
  • Increasing our BPA purchase, which is 90-95% carbon-free, and Box Canyon hydro to our resource portfolio allow us to reduce RRGP generation – those strategies are linked
  • We do have subsidies for low income EV car purchasers- more information can be found here including information for other residential programs
  • We have a variety of programs for both residential and commercial/industrial customers- more information on commercial/industrial programs can be found here
  • We also update our Conservation Potential Assessment (CPA) every 2 years
  • As a requisite in the CCA air quality in areas will be assessed by the state and CCA allowances for all utilities can be adjusted to meet air quality standards

Submitted on 8/19/2022


Clark PUD,

Please follow the lead of the  Vancouver City Council and support them with genuinely forward-looking plans that further a greener, cleaner future for Clark County.

The times we face require more than superficial plans.  Business as usual is not good enough at this critical juncture, so the gas plant needs to be shut down.  Gas is a fuel of the past, with deleterious health and safety risks in addition to its CO2 impact on our already unstable climate.

I understand that the PUD has discouraged significant solar operations recently, saying that we do not have adequate storage capacity for them.

What we need to do is to focus intensely on building up that battery storage capacity. Doing so will help us support renewable electricity generation from local sources in support of the electrification policy adopted by the Vancouver City Council.  I think Vancouver has the old-fashioned can-do and know-how to provide  the energy storage required.

finally, I do not think nuclear energy is a reasonable electricity-generating alternative.  The record of nuclear energy is a disaster.  It is unsafe, and its hair-raisingly polluting waste is an unthinkable price for an altogether flawed alternative energy source.  Small nuclear reactor technology may eventually be promising, but in the meantime it is unproven and risky as well as costly.  Nuclear plants are outrageously expensive to build and maintain, and the bill usually lands on taxpayers.

The concrete necessary in such construction has an unacceptably high CO2 level attached to it, and so it doesn’t even solve the problem it’s supposed to fix.

Nuclear has one last, lesser-known  but utterly intolerable aspect: nuclear plants use an ungodly amount of water.  Considering that drought appears to be the new normal for the western US now, we also need to be sure that we are reserving our water usage  for real priorities for citizens, fishing, agriculture and the like.

Please find in yourselves the courage required to face these times with the intelligence and ingenuity necessary for urgently-needed positive change.


For more information on what we’re doing to support the City of Vancouver and the Climate Action Plan/Framework, please see our response to the public comment on 08/15/2022. You can find a link to the IRP public comments here.

Clark Public Utilities has a long history of support and promoting solar generation systems. Clark Public Utilities currently offers the net metering program to all distributed energy resource customers, including roof top solar PV systems at homes and businesses. Our utility loan program is also available for residential customers to use to finance solar PV systems at their homes. Also, In addition to our first successful Community Solar project, Clark Public Utilities is currently scoping out a new community solar program for development that will create more opportunity for renewable energy participation for our customers. More to come on this soon!

Submitted on 8/19/2022


Northwest Environmental Advocates’ Comments
on Clark PUD’s Draft 2020 Integrated Resource Plan Update
Progress Report August 31, 2022

Overall, Northwest Environmental Advocates (NWEA) is encouraged to see the “Progress Report” confirm the conclusions of the 2020 Integrated Resource Plan (IRP). We are especially encouraged to see that the Clark PUD will have “sufficient annual average energy to meet its annual average energy requirements” through 2034. The same can be said for Clark’s commitment to “all cost-effective conservation” as a sound business practice, regardless of need. NWEA’s position is that the cleanest energy facility is the one that doesn’t get built.
Since this plan is merely an update, NWEA did not expect a complete rewrite but we were surprised by some inconsistencies, which we detail below. NWEA does looks forward to the 2024 IRP and hopes to see Clark PUD broaden its vision so its customers can reap the benefits of the innovations occurring in the energy field, innovations that will assure stable rates and a resilient public utility.

Section 4 – Wholesale Supply-Side Resource Options Assessment

Under the heading of “Nuclear,” the document contains the following statement:

Recent protests have focused on saving Diablo Canyon, as climate change activists have become disillusioned with the slow pace of the transition to clean energy and are resistant to the idea of shutting down a large, non-emitting resource. Connecticut, Illinois, New Jersey, and New York recently allocated clean energy transition funds formerly reserved for wind and solar to keep existing nuclear plants open.

It is unclear what the purpose of including this statement here is other than to promote nuclear power. To what “protests” do you refer? Yes, there have been groups advocating for keeping Diablo Canyon open just as there are those advocating to maintain adherence to the closure plan. And while some “climate change activists” are calling for delaying the closure there are other equally committed “climate change activists,” such as the Natural Resources Defense Council (NRDC), that are defending the original reactor closure plan. If Clark PUD wants to use this Progress Report to make policy statements and random observations, why not include facts about how nuclear plants are uneconomical and need state governments to provide them with financial bailouts.

The analysis on Batteries in this Section is useful so long as technology and economics are stagnant, but we know that they are not. NWEA urges Clark PUD to use the 2024 IRP to expand your view on batteries given that this is a 20-year plan.

Section 5 – Comparative Evaluation of Renewable and Nonrenewable Energy

It is unclear if Table 5.1 was the work of Energy Northwest or Lazard V13; please clarify the source. In any case, it will help with public transparency to have references to the detailed data relied upon for the analysis. For instance, given that Lazard V13 has a lot of charts and data, without detailed references in the Progress Report, a reader cannot discern what the source of the information in table 5.1 is. In addition, why use Lazard V13from 2019 rather than a more updated version such as V14 or 15? Given the lack of clarity, we are left guessing that you are you using the Council’s 2021 Plan for solar and wind or Lazard V13. If that is the case, it appears you are not also using the Council’s plan for the nuclear plant, which as you point out in the previous section uses 80 and 60 percent capacity factors for nuclear. Further you state in Section 4:

The SMRs that were considered in 2021 were designed to work with renewable generation including being able to ramp up power quickly enough to meet high evening demand when solar generation ramps down. In addition, adding more non-emitting generation to Clark Public Utilities’ resource portfolio and SMR would allow for more frequent displacement of the RRGP plant.

Such uses would result in a lower capacity factor below the 95 percent assumed by Clark PUD, instead a capacity factor of 60 percent as indicated in the Council’s plan or lower seems more realistic.

Based on your statements in this Section, we can only conclude you relied on the NuScale estimates for nuclear capacity factor and cost. Did Clark seek out capacity factor and costs estimates from renewable developers as well? If not, why not?


Please see below for responses to your questions from staff.

There are groups advocating for keeping Diablo Canyon open just as there are those advocating to maintain adherence to the closure plan. The first paragraph under the “Nuclear” heading in Section 4 notes that many nuclear plants have shut down over the past decade and several more are scheduled to shut down. That’s where things stood when the 2020 IRP was drafted in 2020. Since this is an update of the 2020 IRP we felt it was important to note that there are on-going conversations within the CA state government and in public spaces regarding re-opening the question of whether or not Diablo Canyon should be shut down. The protests comment was based on an May 2022 article which noted a protest in December 2021 to “save diablo canyon”.

The source of the data in Table 5.1 is Lazard. The data was provided to Clark Public Utilities in a May 2022 Energy Northwest presentation.

Clark Public Utilities’ staff typically relies on the renewable energy capacity factors and cost estimates included in the most recent NWPCC power plan. In this case, we have reviewed the capacity factors and cost estimates included in the 2021 Plan. Staff also has conversations with renewable energy developers in the region. When possible the developers have provided data that has assisted us in assessing renewable capacity factors of regional renewable resources and assessing how renewable resources will fit within our existing resource portfolio.

Submitted on 8/19/2022


*Please note, Clark Public Utilities has removed referenced “screenshots” that accompanied this customer comment to avoid including any potential personal identifying information*

Thank you for the chance to comment on the Draft 2020 Integrated Resource Plan Update.

In October 2021 Tesla installed a 10.6 kW solar roof (glass PV & non-PV roofing tiles) on our home, as well as two Powerwalls (batteries).  I am pretty sure ours was the first Tesla solar roof in Clark county, and probably about the fourth one in Washington state.  This was my first experience with solar and with the Tesla roof. Here are some things I have learned thus far:

Here is the screen from the Tesla app showing power that we have pulled from the grid (blue) and pushed to the grid (yellow) since the beginning of the year.  I expect that months 8-12 will be roughly a mirror image of months 1-6.  It is pretty clear that in total there will be more yellow than blue.  Which is good news because we plan to purchase an EV (maybe two) in the next 4 years.  Also when our AC dies (probably soon as well), we plan to replace it with a heat pump.  When those things happen we will probably consume more than we produce

Together the batteries provide 27 kWh of storage.  We mostly use them during outages, but we also use up to 20% of their capacity on a daily basis, just to keep them active.  Tesla actually recommends using up to 80% of the batteries on a daily basis but I worry what that will do to their lifespan.  I’m not really sure what setting is best for us.  Future solar + battery homes will have to wrestle with this as well.  And if you switch to a time-of-use (TOU) model I will be switching to the “Time-Based Control” feature that you see in the screen below.  More on that later.

Here is our daily home usage on a typical sunny day.  From midnight to about 2AM the house is running off the battery (green).  2AM-6AM, from the grid (gray). 6AM-6PM, from the roof (yellow).  6PM-midnight, from the battery (green).

This shows how the power from the roof is distributed on that same day.  Blue to the house, green to the battery, gray to the grid.  Obviously the bulk of it goes to the grid.

  • Anyway my point is by having batteries, I have a lot of flexibility.  As batteries become cheaper (need to get past supply chain issues first), most new solar installations will include batteries.  This will eventually have a major impact on your business model.
  • Regarding business models, as you probably know, many investor-owned utilities in sunny states are seemingly scared to death of rooftop solar + batteries, and are fighting hard to kill rooftop and community solar.  At the same time, legislatures are working hard to increase the amount of rooftop and community solar.  More and more homeowners and communities are wanting rooftop and community solar.  The grid is switching to a distributed generation model, whether the utilities like it or not.  Tesla is ramping up their virtual power plant (VPP) capabilities, in fact their new VPP in California was first called into service on Thursday.  It was small of course (16.6 MW) but the technology seems to work fine and the crazy high payment they are giving ($2/kWh) will certainly attract more people to consider it.  I plan to participate in a VPP if one is offered and if it makes at least some economic sense.  Back to business models – as I mentioned there are huge battles all over the country which are basically the old centralized generation model vs. distributed generation + demand response + storage.  IMHO it is time to just throw out the old model and fund ongoing research into a new model which gets us off fossil fuels as quickly as possible.  In other words, come up with a model which makes economic sense for all parties:
    • Local utilities such as yourself.  Make it economically viable to continue to provide a local grid, local repair service, some grid-scale storage, upgrade your equipment when needed, etc.  Maybe also have your own VPP and demand response, or provide it with a partner such as Tesla.
    • Regional power transmission such as BPA – maybe transmit solar from sunny areas to the whole west coast during the day, and from the Columbia river and storage to the whole west coast at night.
    • People with solar & batteries.  Use VPP incentives to help people have a decent payback time for maxing out their roof with solar, and to purchase batteries (and let them be used in VPPs).  Maybe also have incentives to the utility to be able to receive that extra power.
    • People with electric cars.  Make it economically viable to let your car do “vehicle to grid” (V2G) when it is plugged in, while ensuring that it is full when you need it.  e.g. plug it in at work, let the grid use some from 4-5pm, drive home, plug it in, let grid use more from 6-9pm, then use the grid to charge the car 9pm-6am, and from 9am-4pm while it is plugged in at work to take advantage of excess solar from people like me.
    • Employers.  Provide incentives to employers to maintain charging stations for lots of employees, to enable the previous scenario.
    • Long-term storage providers.  Obviously we don’t get much sun in the winter.  Make it economically viable to store excess summer energy for use in the winter.
  • I’m pretty sure that researchers are working on financial business models which provide all of the above (as is Tesla, I’m sure).  You should start following these.  Obviously things are very dynamic (congressional actions, supply chain issues, R&D breakthroughs, etc.) so the models will also need to be dynamic.  But over time they will become more stable.
  • Touching on business models and TOU pricing.  I am sure you are feeling pressure to switch to a TOU model, it seems that most utilities use it.  It would certainly spur more people to include batteries with their solar purchase, which could in turn be utilized in VPPs.  However switching to a TOU model will be very confusing for people who have never experienced one.  I worry that lower income and elderly people especially may have trouble understanding it and thus won’t adjust their usage to minimize their costs.  So maybe demand response devices for those people could be included in the TOU rollout?  I.e. the device automates or warns them about using a lot of power during peak demand hours.
  • A prime example of confusing TOU models is SDGE in San Diego.  e.g. imagine reading through this page, explaining all the choices to me, and tell me which option is best for me, in less than 5 minutes. This page just oozes “corporate greed and obfuscation” when I read it.
  • Back to my lessons learned, I was able to get quite a few more PV tiles on my south facing roof by having one of my bath vents moved from the south roof to the north roof.  Homeowners should know that that can be done and it may be worth the expense.
  • Related to that, architects and builders should be designing and building homes which have simple south-facing roofs which have few projections, yet are still attractive from the street.  If the house has gable ends, route all the vents to the gable ends if possible.  Tesla actually put a lot of PV tiles on my north facing roof as well.  Counterintuitive, but with a relatively low roof pitch, a north facing roof gets a lot of sun in the summer.
  • It is obvious but worth mentioning that you can get more solar with solar tiles vs. panels because the tiles are smaller and thus can fit onto smaller roof planes.  Although panels are also a bit more efficient that tiles.  Many factors to consider when making decisions.

I had hoped to finish reading through and making specific comments your plan update, but it is very late so this will have to do.


Thank you for sharing your experience with solar and the Tesla roof. It looks like that product offers customers some good insight into their energy usage, thus making it easier to manage. Clark Public Utilities is excited that our board of commissioners has recently approved 30 million towards Advanced Metering Infrastructure (AMI). AMI will allow customers similar visibility into their energy use, so they can make informed changes in their energy use, should they choose to.

At this point in time, the utility does not have any plans for time of use (TOU) rates, however in order to deploy TOU rates, a utility must have AMI in place first. AMI deployment is a long process; At this early stage, we are working through the plans of what that will look like.