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

Question:

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!

Answer:

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

Question:

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.

Response:

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

Comment:

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.

Response:

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

Comment:

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

Comment:

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.

Response:

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

Comment:

I’ve heard staff mention that RRGP is nearing the end of its life expectancy.  That seems to fit with industry assessments.  https://sargentlundy.com/wp-content/uploads/2017/05/Combined-Cycle-PowerPlant-LifeAssessment.pdf. 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!

Response:

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.