In keeping with our commitment to transparency and excellent customer service, we invite our customer-owners in Clark County to participate in the conversation around both the development of the utility’s Integrated Resource Plan (IRP) and the rulemaking process related to Clean Energy Transformation Act (CETA) compliance. This webpage will host public comments submitted via both pages, along with responses from staff as appropriate. 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 1/17/2020 via IRP status page

I am very concerned about climate change and it’s impact on communities and believe we must act now to make changes to renewable, non polluting sources for our power. I applaud the steps CPU has already made, especially encouraging conservation. What additional steps is CPU doing to add solar and wind or other less impactful sources to its roster?

Clark Public Utilities currently serves customer retail load with electricity that is 65% to 70% carbon free depending upon the year.  You can see all utilities’ fuel sources for the state of Washington here:

The majority of the remainder of our supply that does produce GHG emissions is from our combined cycle combustion turbine (CT) generating plant.  Of course, we wish it did not produce any CO2, but a consolation is that it emits about 40% of the emissions that a coal-fired plant produces per Megawatt-hour.

We are currently taking actions to green up our retail load by bringing more wind generation to load than we have in the past.  Additionally, we run our CT only when it makes economic sense and with the thought that when it is not running we are buying power from the market with less emissions per MWh such as wind or hydro.

Per recent state legislation called the Clean Energy Transformation Act (CETA), we will be moving toward a carbon neutral supply portfolio in 2030 and by 2045 we expect to serve all of our load with carbon free electricity.  This integrated resource plan is a step in that direction.

You can learn more about CETA on our website here:

Submitted on 2/11/2020 via CETA status page

The above discussion does not mention that eliminating coal emissions and much of tailpipe emissions can probably be justified just from local health impacts. Also, CPU’s current carbon emissions are not clearly stated anywhere on this website. It’s hard to reduce something if you don’t acknowledge it clearly and publicly.


We appreciate your comments and will do our best to address them.

Clark Public Utilities takes very seriously the health impacts of its resources used to serve our customers electric requirements. All of Clark Public Utilities’ owned and contracted resources meet or exceed the local state and federal requirements with respect to air, land, and water. As these requirements change, Clark Public Utilities will adjust its portfolio and operations accordingly to continue to bring electricity to our customers in the most efficient and least-cost manner as possible.
To be clear, Clark Public Utilities has no authority to regulate emission levels of any resource except for those where Clark Public Utilities may wish to impose stricter rules on emissions from the generation plants it directly owns and operates such as River Road Generating Plant.

Coal Emissions
Buying electricity directly from coal-fired resources has never been nor will it ever be part of Clark Public Utilities’ long-term resource portfolio, with one exception.

Due to our contracts and business interaction with Bonneville Power Administration, Clark Public Utilities does end up with a small percentage of electricity delivered to load from coal-fired resources. BPA sells all of its power with a singular fuel mix, removing the opportunity to selectively remove a small amount of coal-fired electricity from the largely GHG-free generation portfolio that BPA manages.

As of the 2018 Washington State Fuel Mix report, the percentage of electricity delivered to CPU’s load was 2.13% or roughly 11.81 average MWh.

Keep in mind that the fuel mix report is for power that serves Clark Public Utilities’ load directly.  In 2018, Clark Public Utilities also purchased roughly 19 average MW of GHG-free wind power that did not serve load. Other consumers used this GHG-free electricity.

Loads and resources must be in continual balance, essentially every second of every day. For very short-term durations usually next-day or next-hour, Clark Public Utilities may purchase “unspecified electricity” to put it in balance. This means that we do not know the origin of the fuel. The alternative is not purchasing any electricity at all, which may put Clark Public Utilities into serious noncompliance with the rules surrounding operations and reliability, subjecting Clark Public Utilities to large fines and sanctions.

As weather conditions can be extreme and unpredictable, the region can find itself sometimes in no other position but to rely upon any and all resources, including coal-fired plants, to keep the grid up and running.  The region has not yet transformed into a grid that can rely upon 100% GHG-free electricity 100% of the time.

Coal-fired resources in the region have been retired and are scheduled to retire in significant numbers.  The following table shows how the resource picture has changed in the region over the past 20 years.

Coal plant planned retirements are shown on the table below.

















From these planned retirements and Clark Public Utilities’ plan to not purchase any long-term coal-fired electricity, the percentage of electricity from coal-fired resources delivered to Clark Public Utilities’ load will continue to shrink over the next decade. At that point, Washington State Clean Energy Transformation Act requirements will start and these mandate a 100% carbon free neutrality.

Tailpipe Emissions
To be clear, Clark Public Utilities has no authority to regulate tailpipe emissions. We are assuming this reference in your comment regards the potential of Electric Vehicles to displace gasoline-fired internal combustion engines in vehicles. Given the GHG-free nature of the grid in the Pacific Northwest, the expectation is that emission reductions from this switch to EVs provide health benefits.

Clark Public Utilities expects a transition to EVs to continue over the years. See our draft paper on this. Also, we are here to help immediately anyone who is interested in EVs.

Carbon Emissions
Clark Public Utilities fuel mix information can be found on our IRP webpage.

For specific information regarding GHG emissions from the River Road generating plant you can visit the following links:

Both of these links can also be found on the IRP page referenced above on our website.

Submitted on 2/14/2020 via CETA status page

Is any staff member assigned to make an inventory of energy conservation opportunities in the commercial sector?

Thank you for submitting your question.

Clark Public Utilities has a team of Key Account Managers that help our commercial and industrial customers identify conservation projects and assist them through the implementation process to secure incentives and measure the savings.

Additionally, the Conservation Potential Assessment (CPA), addresses conservation opportunities for all sectors and can be found on our Integrated Resource Plan web page here:

The conservation targets identified in the CPA are based on regional and local assessments that account for shifting technologies/market transformation, changes to building codes and available opportunities. Our staff uses this data to evaluate and identify existing opportunities and set the conservation target, which our board of commissioners votes to adopt.

Submitted on 3/16/2020 via CETA status page


I am really looking forward to not having any of my power coming from methane. We definitely need more solar in this county and even some of those smaller cylindrical wind turbines with all the wind we get thanks to the Columbia. Can new builds be required to have solar or even the wind turbines put on larger buildings along the river? What about Bill Gates’ nuclear power that uses spent uranium? He was going to try it in China until Trump’s trade war stopped it.


Methane is by far the largest component of a mixture of gases that are collectively known as “natural gas”. When natural gas is burned to produce heat for a home furnace, water heater, industrial process, or in a combustion turbine to produce electricity, carbon dioxide is emitted. Clark Public Utilities owns and operates a Combined Cycle Combustion Turbine that produces electricity for our customers. Because it is a CCCT, it is very efficient when compared to most other fossil fueled power plants on a Megawatt-hour per Metric Ton of CO2 basis.

Clark Public Utilities is committed to meeting the mandates of the recently passed Clean Energy Transition Act. This law requires all electricity delivered to Washington State customers be sourced from Greenhouse Gas free power sources by 2045. Also, utilities must be what is called “Carbon Neutral” by 2030 within certain cost considerations.

Solar and wind power in Clark county has made progress over the years. Renewable energy, mostly in the form of rooftop solar, has grown to just under 10 MW of installed capability. We expect renewable production to continue to increase and Clark Public Utilities stands ready to help integrate these resources to the distribution grid.

Clark Public Utilities is a customer owned utility subject to the Revised Code of Washington, specifically RCW 54. Under the RCWs, the utility has no authority to mandate any new or existing construction to include any generating resources. Clark Public Utilities is obligated by the state to provide a mechanism in place to accommodate “behind the meter” resources such as solar rooftop. We provide loans and advice regarding these resources.

Clark Public Utilities is exploring all sorts of alternatives to get to a low, or GHG free resource portfolio. These include several varieties of plants that are fueled by nuclear energy. These will be discussed in our upcoming 2020 integrated resource plan.

Submitted on 4/13/2020 via CETA status page


Hello all,
Comment: After studying the CETA and many comments on CEIP on Commerce’s website — I’m humbled by the complexities you have to deal with.

Comment: I’ve been told there are many conservation opportunities within the realm of demand-response if staff is assigned to work it. I believe I understand what demand-response is.

Q: Could you describe your demand-response program and whether or not you have more opportunities in that realm?


We appreciate the opportunity to expound upon our efforts around demand-response.  It is a topic that is gathering momentum as we look for opportunities to reduce our consumption and in turn reduce the need for generating resources.  Before diving into particular Clark Public Utilities programs and plans, let’s define some terms associated with the demand-response and conservation in general.

These definitions are extracted from the Northwest Power and Conservation Council’s 7th Power Plan Glossary 

Conservation: According to the Northwest Power Act, any reduction in electric power consumption as a result of increases in the efficiency of energy use, production or distribution.

Demand Response: A voluntary and temporary change in consumer use of electricity when the power system is stressed.

Conservation has both a power planning definition and general definition as well which can lead to confusion as we discuss measures to reduce consumption.  To help us delineate and to align with our general requirements under various federal and state laws, when we discuss these measures in context to any power planning, we use the definitions above.

We’ll address your question assuming it’s a general question regarding our efforts to reduce energy consumption both through efficiency measures (Conservation) and through customer agreed upon short-term curtailments (Demand Response).  Hopefully, these two areas will answer your questions.

Clark Public Utilities Conservation Program

Clark Public Utilities has a long and successful conservation program that really started in earnest in 2005.  Our most recent Conservation Potential Assessment is an excellent resource for not what only are plans are for the future regarding energy efficiency programs but how we have done in the past as well.  Page 18 of the CPA is particularly informative.  It shows approximately cumulative 30 average MW of conservation accomplished for years 2014-2018.  This 30 average MW of conservation in 2018 represents a roughly 5% reduction in energy consumption versus having no programs at all during that time frame.

Clark Public Utilities Demand Response Program

Clark Public Utilities demand response program is not as mature as its Conservation program.  Demand response is a much more customer-by-customer focus. In the past, the economics of load curtailment in the residential, commercial, and industrial sectors have not been enticing enough to start any particular efforts on a large scale basis. Nor has there been any particular need for additional capacity that load reductions on demand could help meet.  With the upcoming retirements of thousands of MWs of coal-fired electric generating plants and upcoming new constraints on existing natural gas generating plants, electric capacity is no longer readily available. Capacity prices are rising and thus demand response is becoming more viable.

Clark Public Utilities has commissioned a Demand Response Potential Assessment to be completed this summer along with our 2020 IRP.  It will inform the utility on the particular opportunities and what we might expect in contributions toward capacity.  It will be in very similar form and function as the existing CPA.  Once that document becomes final, we will post it to the same section on our webpage as the CPA.  Please keep checking back for it.

Clark Public Utilities has also participated in two demand-response pilot projects in recent years in response to the perceived coming capacity crunch.   Below are summary descriptions and results.

Residential Water Heater Demand Response Pilot

In 2017 and 2018 Clark Public Utilities participated in a regional residential water heater demand response pilot that was organized by the Bonneville Power Administration (BPA) and Portland General Electric (PGE).  Clark Public Utilities participation included the recruitment and involvement of twenty residential customers utilizing heat pump water heaters (HPWH’s) in their homes. Utility staff worked with the participating customers to install the required communication equipment to the water heater and register the systems to the online project portal. Other participating utilities recruited standard electric resistance water heaters but Clark Public Utilities recruitment was focused on HPWH homes exclusively. This approach resulted in a good mix of HPWH’s and standard electric water heaters.

BPA and PGE were responsible for scheduling and calling the demand response events, which took place multiple times per week over the program period (approximately one calendar year). The strategy behind the event schedule was focused on using surplus wind energy in early morning hours to pre-heat the water heaters prior to the utility morning peak hours. Participating utility staff managed the customer experience and were responsible for managing all customer communications throughout the pilot program.

The pilot program results were somewhat mixed but overall encouraging. We found that both standard electric water heaters and HPWH’s are an effective appliance for residential demand response programs; both technologies can act as a battery in storing surplus energy and provide peak relief to utilities. The challenges identified upon the completion of the pilot program were primarily focused on technology issues; the program involved retrofitting the existing customer water heaters which proved difficult to troubleshoot if issues arose and generally required a customer site visit to resolve the issue. The most valuable finding was the need for water heater manufacturers to include communications technology within the water heaters when being manufactured. Since then, the Washington State legislature has passed a statute requiring this in the future for units sold within our state.

Commercial Customer Demand Response Pilot

The Bonneville Power Administration contracted with EnerNoc to develop a commercial demand response pilot program for their territory in 2015. Clark Public Utilities participated in this program by facilitating conversations with our customers and providing access to metering data. EnerNoc was able to run the winter portion of the program for two years. However, the summer program did not gain enough regional enrollment to be viable.

For winter of 2015, Clark Public Utilities had two participating customers with 6 metered loads. These loads combined for a total nomination of 600 kW. One additional customer joined the program for winter of 2016 adding an addition 2 metered loads and 870 kW. Each of the participants were very successful in meeting the requests to shed loads with 20-minute notice.

Clark Public Utilities had several key take-aways from this pilot program work:

  • Providing a product to our customers that provides day-ahead notice would greatly increase the number of manufacturing companies willing to participate.
  • Monetary compensation is only one piece to recruiting companies into these programs. Our customers are concerned about the impact to their employees if they curtail production, along with potential delays in supplying product to their customers.
  • Specific segments are a good fit for certain times of the year, fresh water in the winter and waste water in the summer, as examples.

BPA has not moved forward with commercializing a demand response product within their territory. There continue to be targeted contracts to relieve specific transmission congestion constraints; however, broader demand response need has not been identified.

Submitted on 4/16/2020 via IRP status page


Where is the power mix published for Clark PUD and how often is it updated? Quarterly?

Thank you!


Thank you for submitting your comment. Our fuel mix is posted on the Integrated Resource Plan webpage on our website in the subsection entitled Fuel Mix Fast Facts on the right hand side of the page. The fuel mix is updated annually once we receive BPA’s fuel mix information.

Submitted on 4/16/2020 via CETA status page


Hi again,
I think I heard staff imply that heat pump water heaters were required in new construction.
Did I hear correctly?


Thanks for submitting your question. Current code does not require heat pump water heaters to be installed in new construction. Full code details can be found on the Washington State Building Code Council’s webpage here:

Clark Public Utilities does offer an incentive to customers for both existing and new construction for the installation of a qualifying heat pump water heater. You can find all the details on our webpage here:

Submitted on 4/16/2020 via CETA status page


I support the clean energy transformation act!!!!!! Please transition to and let us have clean electricity by 2045!

Submitted on 4/17/2020 via CETA status page


The Clean Energy Transformation Act is a great plan and I welcome it — even if it costs a little more, it is definitely worth it! I just wish we could get the job done sooner. I urge you to comply with this mandate and meet the 2030 deadline. I own 21 units in Clark County and am thrilled we are moving to protect the environment with renewable energy.

Submitted on 4/17/2020 via CETA status page


I think CETA is a wonderful thing. One would hope it could be speeded up to protect clean air faster.

Submitted on 4/17/2020 via CETA status page


I am a resident of Vancouver WA, and I support the goal of achieving the transition to 100 percent clean electricity by 2045.

Submitted on 4/17/2020 via CETA status page


CETA legislation is an important victory to celebrate and move towards. It is crucial that we embrace the challenges it brings and apply creativity and forethought to the task of 100% clean, renewable electricity by or before the required dates. Working towards an outcome that is healthy and sustainable is good work.

Submitted on 4/17/2020 via CETA status page


I wanted to voice my strong support for this legislation. As a customer, I would be happy to see an increase in my rates to support the transition to new energy sources. There are a wide variety of options, including increasing residential solar, adding time of use incentives to switch loads to better match renewable production curves, supporting electric cars and charging networks, and using those cars for storage, and of course adding wind, solar and hydro generation assets

Submitted on 4/17/2020 via CETA status page


I did not realize that “electricity production is the third-largest source of carbon emissions in the state.” Clearly, Clark Public Utilities is in a position to make a difference in a clean-energy future — for our county and region and planet. Please make choices for a cleaner and healthier future. Thank you.

Submitted on 4/17/2020 via CETA status page


We want you to do everything possible to be carbon neutral as soon as you can. Even if utilities are slightly higher, it’s worth it the future of our children and children’s children. Please push forward and ignore the greedy science deniers. Thank you!

Submitted on 4/17/2020 via CETA status page


I fully support CETA. I am very concerned about air pollution personally as I struggle with asthma and allergies and notice that when the air quality is worse my symptoms are worse. My husband and I are trying to do our part and bought an electric car and installed solar panels on our house. I know that changes need to be done as soon as possible to minimize the impact of climate change on future generations.
I am glad that provisions have been made to consider the impact of any changes on low income neighborhoods.

Submitted on 4/17/2020 via CETA status page


Energy Northwest is clean energy. If Clark PUD is a member, thank you! If Clark PUD is not a member, please look into it.


Thank you for submitting your comment. Clark Public Utilities is an active member of Energy Northwest and one of our elected Commissioners, Jim Malinowski, serves on the Executive Board.

Currently, Clark Public Utilities has a power purchase agreement with Energy Northwest on the Packwood Hydro Project. Additionally, Bonneville Power Administration purchases the output of the Energy Northwest owned nuclear power plant and as such, we receive some of that power through our contract with BPA

Submitted on 4/18/2020 via CETA status page


We need a responsible climate future. We need to reduce our carbon footprint. Please meet the CETA goals. We are fortunate that we have access to BPA hydro. Let’s use more of that and burn less natural gas at the River Road plant. Thanks!

Submitted on 4/17/2020 via CETA status page


I completely support the clean energy transformation act for Clark county. In fact I’d like to see the entire world support green energy and keep our skies clear as they are now during he pandemic.

Submitted on 4/17/2020 via CETA status page


I’m a Vancouver resident and ClarkPUD Customer. I support the transition to combustion free sources of energy and the plan outlined by the CETA. We must ensure that we actually take the necessary steps to make this happen and not push it back as has been done in the past. The time for action is now. Even if utility rates go up slightly in the short run to enable/fund this transition, it will be better, cheaper, and necessary in the long run.

Submitted on 4/17/2020 via CETA status page


I generally support the actions taken to reduce and eliminate carbon based energy. If anything, the current plan is not aggressive enough.

Submitted on 4/18/2020 via CETA status page


We need a responsible climate future. We need to reduce our carbon footprint. Please meet the CETA goals. We are fortunate that we have access to BPA hydro. Let’s use more of that and burn less natural gas at the River Road plant. Thanks!

Submitted on 4/18/2020 via CETA status page


Challenge your self to move even faster.

Submitted on 4/18/2020 via CETA status page


I am writing in support of the Clean Energy Transformation Act.

Climate change is the biggest challenge we have and there is no excuse for not moving forward with the CETA.

Washington already has a head start with our hydropower ability. It should be made clear that there will be no extension of the 2022 deadline that electric utilities have to prepare and publish their clean energy and implementation plans. This would only set us back and continue the decades-long pandering to corporate interests whose sole motive is to maximize profits no matter what the damage to human or animal life. Penalties for delay must be so severe that a delay is not even considered.

Implement the Clean Energy Transformation Act. NO excuses.

Submitted on 4/19/2020 via CETA status page


I am so happy to see this! I do hope Clark Utilities will seriously consider expanding electric vehicle charging grid. I am seriously considering buying an electric car for my family’s next vehicle and seeing more charging stations around town would be a definite incentive for us and I think for other people. Thank you so much!


Thank you very much for taking the time to review the Clark Public Utilities CETA webpage, we appreciate your comments regarding transportation electrification. We wanted to provide a little more context and information so you have a better understanding of Clark Public Utilities efforts to accelerate and assist in customers adopting electric vehicles (EV’s). We are currently in the process of developing a high level Transportation Electrification (TE) Plan for Clark County.

In 2019 the state legislature passed a new statute that specifically allows electric utilities to invest in TE plans and programs; historically there have been legal barriers around incentivizing the switching of fuels, which is the reason for the delay in a robust plan and programs. That said, we have invested significant time and effort around educating our customers on the benefits of switching to an EV. We have a public EV website that boasts a fuel comparison calculator and emission reduction information, we partner with Portland utilities to promote EV’s at the annual Portland Auto Show and we are a member of the EV non-profit, Forth.


Submitted on 4/27/2020 via CETA status page


This sounds like a great opportunity to move ahead with some new and innovative technologies. For example, a lot can be done with solar panel placements in places not usually used for panels, like highway medians. I am looking forward to your clean energy implementation plan in 2022.

Submitted on 4/29/2020 via CETA status page


How can there be doubt that we must transition to all clean energy — and now! Our health and our economy depend on adapting to future systems. Let’s be in the forefront and not play catch-up. Washington is The Evergreen State! I’ve already divested my investments, now let’s do this locally. Thank you.


Thank you for your interest in CETA and the IRP process – we appreciate your comments and share your enthusiasm about looking to the future.

Many interests must be balanced while pursuing our energy future. Reducing GHG gas emissions, reliability, affordability, and stable rates are all factors. While we don’t believe these are mutually exclusive interests, pursuing just one factor without taking into account all other customer priorities would likely have many unintended consequences. Studies by the Public Generating Pool and others have shown a ‘hockey stick’ cost of electricity as we move towards 100% carbon free. This fact is a major contributing factor to that goal being set for a 25-year target. Through the process of transitioning to a 100% GHG emission free portfolio, deliberate and sober choices must be made that balance these interests and get to our goals with as little disruption to customers. All of which have these interests in common.

You are correct that Washington is the Evergreen state and the facts back up this claim. In the link below you’ll find that Washington and Oregon both lead the nation in the lowest emissions per unit of energy produced.

This is not a surprising fact when we consider the amount of GHG-free electric power that is exported from our state to neighboring states. With Grand Coulee Dam and all the other hydro generation plants along the Columbia River along with a 1,000 MW nuclear plant in Central Washington, we produce more GHG-free electricity in Washington state than any other state. However, the credits associated with these GHG-free electricity plants are the property of the participants in those plants and many of those participants are from out of state.

To put Clark Public Utilities into some context, here is a link to the fuel mix of all utilities in the state. You will notice that most other consumer-owned utilities with near 100% renewable supply are due to their own hydro-generation or power purchases from the Bonneville Power Administration and their mostly GHG-free power supply. However, Clark Public Utilities is not one of those utilities. We diversified from BPA in the 1990s as it appeared at the time that BPA rates were getting out of control. To retain local control, Clark Public Utilities built a clean combined cycle natural gas plant which boasts roughly half the CO2 content as the Centralia Coal Plants. Our Fuel Mix reports filed with the state show that Clark Public Utilities averages around 65% GHG-free resources. This percentage is currently higher than the three Investor owned utilities which serve the majority of electricity consumed in the state. We are fortunate to be starting at a good spot when compared to the large investor owned utilities in the state and will get this number to above 80% by 2030 and to 100% by 2045 per the recent legislation passed and signed into law.

Much of any utility’s electricity portfolio is timing as much as anything else and these investments are not directly comparable to stock or bond investments. Generation resources are long-lived, long-financed, electricity producing facilities that are often one-of-a-kind due to location and fuel supply. They require continual maintenance, ongoing investments in new parts, maintenance, training, and daily monitoring to meet copious environment, industrial safety, and demands of the electric grid. While individual stocks and bonds are traded almost instantaneously these days at little to no additional broker costs, divesting a power portfolio to meet any particular goal is not easy and not without significant costs.

The marginal cost to generate power at our River Road Generating Plant natural-gas fired power plant is projected at around $0.017/Kilowatt-hour for the foreseeable future. It would not be possible for Clark Public Utilities to replace that quality of power with newly built renewable energy at that cost. Just as the large drop in US and world emissions can be attributed to the rise of natural gas generation on the heels of closed coal plants, Clark Public Utilities’ investment in natural gas has become a bridge resource; turn off the coal, use natural gas as a transition resource to cover electric loads while we continue to add new, intermittent, variable resources to the grid.

Under CETA, starting in 2030 Clark Public Utilities will be allowed to use the River Road gas plant 5 months each year, compared to the currently allowed 12 months. Clark Public Utilities will reach the end goal as outlined in the Clean Energy Transformation Act. It may not happen overnight, but progress will continue. Under CETA, Clark Public Utilities will be producing a Clean Energy Implementation Plan along with our bi-yearly resource plans. We encourage you to track our progress using these reports.

We hope this helps provide context and we hope you will continue to express your comments, ideas, and participate in this process.

Submitted on 5/5/2020 via CETA status page


It light of the recent IPCC climate reports regarding the climate crisis, it is imperative that Clark Public Utilities, CPU, to be carbon neutral by 2030 and carbon free by 2045.

Thank you for your consideration.

Submitted on 5/13/2020 via CETA status page


I am proud that My Utility Company is supporting cleaner energy now! Thanks and stay safe!

Submitted on 5/15/2020 via CETA status page


Hello Clark Public Utilities – a few years back, you constructed your first community funded solar project. Some of us have been waiting patiently for an announcement of the next one. Hope to hear something soon.

Anything that you can do to improve / enhance / strengthen the electrical grid – to include renewable solar and wind and associated battery technologies has my support.

The US needs to modernize rail transportation. By beginning to plan to support it / facilitate it now, Clark Public Utilities will be on the forefront of a new frontier.

All of these initiatives are important to establish energy conservation targets higher than required by the law.

Thanks for reaching out.


Thank you for participating in the process and submitting your comment. In order to best respond let’s take a closer look at each subject.

Community Solar:
In late 2014 Clark Public Utilities commissioned the construction of community solar arrays at the utility’s Operations facility in Orchards. The five solar arrays were funded in whole by over 700 utility customers that opted into the program by purchasing “blocks” of the system. Each customer participant was, and continues to be, eligible to collect the Washington State Cost Recovery annual incentive through June 30, 2020. Clark Public Utilities staff worked hard to design a program that provided maximum benefits for our customers and was structured to include “virtual net metering” and flexible payment plans. That said, the State Cost Recovery Program was one of the key drivers of the program’s success. Because the annual state incentive was quite generous, participants in the Community Solar program will likely recover a substantial return on their original participation fee. While we know customers participate in this program for many different reasons, including environmental, we also know the financial return has been a key motivator.

Soon after the construction of the Clark Public Utilities Community Solar arrays the State Cost Recovery Program funding was exhausted, which in turn limited the ability to develop new community solar projects. Over the next several years the State Legislature introduced and passed a new renewable energy incentive program, but reductions to community solar incentive rates limited the ability to advance new projects. During the 2020 legislative session a new community solar program was passed by the legislature, however, the legislation was recently vetoed by Governor Inslee. While we were disappointed by this outcome we are hopeful this a legislative topic that can be addressed in the future. We will continue to track legislative developments.

Clark Public Utilities staff will continue to look for community solar opportunities into the future; as installation and construction costs for solar arrays fall we may be approaching a future where community solar projects are cost-effective without government subsidies and incentives. The cost of our existing Community Solar arrays averaged just over $4.00 per watt installed at the time of installation and recent case studies have shown costs below $1.00 per watt installed for large scale solar.

Distributed Generation & Net Metering:
Washington state law requires utilities to provide the Net Metering benefit to customers who participate in distributed generation (primarily roof-top solar) programs, up to a specific level of installed capacity. Net Metering is the process of providing the retail rate value for all energy produced, whether consumed at the customer’s home or pushed back onto the electric grid, by the customer-owned generating system. While this billing methodology is required by state law, Clark Public Utilities has consistently set internal targets for Net Metering that exceed the state’s mandated levels. The Clark Public Utilities Board of Commissioners twice approved increased Net Metering targets in a show of support for local renewable energy.

Transportation Electrification & EV Efforts:
Clark Public Utilities recognizes the many benefits that come with electrifying the transportation sector and has been working to better educate and inform our customer base on these benefits for several years. While our efforts have not specifically focused on rail transportation, we have focused on personal vehicles, mass transportation and school busing. On our electric vehicle webpage you can find information related to the financial and environmental benefits that come with EV ownership in Clark County. We use the Clark Public Utilities actual emissions values to calculate the potential emissions reductions possible by switching to an EV. We currently have a partnership with the EV charging company ChargePoint and offer both Level II and DC Fast Charging stations at our facilities. Additional efforts include:

  • Portland Auto Show: For the last three years Clark Public Utilities has been proud to partner with Portland General Electric and PacifiCorp (the two Portland, OR electric utilities) to promote and highlight EV’s at the show. This effort has provided an opportunity to educate our customer base on EV technology and highlight the benefits of using clean electricity as a transportation fuel.
  • Electrify America Funding: Electrify America is an entity that was created to allocate the Volkswagen settlement funds with a focus on increasing EV adoption. Clark County was included in the Portland-metro grant funding and received a DC Fast Charger site in our service territory with six individual charging units.
  • Washington EV Grants: Over the last several years, staff at Clark Public Utilities has worked with customers, and internally, on efforts to obtain state EV grant funding. Earlier this year the Vancouver Public School district was awarded a state grant to procure electric school buses. Clark Public Utilities will continue to partner with them on charging and electrical infrastructure needs to facilitate the new e-buses.

Conservation Targets & Achievements:
The Pacific Northwest has long been a leader in the world of energy conservation and Clark Public Utilities is proud to share in that regional success. Clark Public Utilities has a history of not only exceeding our mandated conservation levels, but doing so in a cost-effective way that improves customer satisfaction. In the residential sector we boast a robust portfolio of home heating, weatherization, behavioral and water heating incentive programs. Additionally, our team often pilots emerging technology programs when opportunities arise. Our commercial and industrial sector programs focus on lighting, process improvements and custom program projects. Within the last few years the industrial sector achieved the second largest conservation project in state history, an achievement staff is very proud of.

The Clark Public Utilities Board of Commissioners have an extensive history of allocating rate payer funds, in excess of mandates, to further fund conservation programs while maintaining a steady budget. In contrast, many Washington utilities only achieve the minimum regional mandated conservation targets using BPA funding exclusively. Clark Public Utilities consistently exceeds those targets and self-funds several million dollars of conservation annually.

Annual and Biennial Conservation Targets & Achievements:
2018/2019 Biennial Target: 9.70 aMW
2018/2019 Biennial Achievement: 14.63 aMW
Note: “aMW” is one megawatt of electricity every hour for each of the 8,760 hours in a year






















The Grid:
The electrical grid, much like the road system in the U.S., is a collection of electrical “interstates, state highways, city streets, and even some dirt roads” that are built, owned, maintained and operated by myriad utilities, agencies, and independent operators.

Within that larger picture, Clark Public Utilities is responsible for local distribution to retail customers in most of Clark County. Clark Public Utilities plans, builds, maintains, and operates the distribution facilities that make it possible to serve the 667 square miles that comprise Clark County. Reliability, efficiency, and excellent customer service are top priorities for the distribution system.

Clark Public Utilities always responds to the changing needs of our customers. At the distribution level this includes the installation of nearly 10 Megawatts of distributed resources, almost all of which are solar power. As customers continue to add renewable resources locally, Clark Public Utilities will make every effort to accommodate these needs while also considering the impacts to all customers. This includes upgrades to distribution feeder lines, substation equipment, and looking to new uses for batteries both at the customer site and at the substation level.

Submitted on 5/15/2020 via CETA status page


In your planning documents you describe a CCCT gas plant as dispatchable. How dispatchable is the River Road plant? My understanding is that it is run as a base load plant? Does BPA cover the load variability with hydro or is the utility required to use market purchases?

How long is CPU legally required by the BPA contract to run the River Road plant? Could CPU sell the River Road output to BPA or another utility? Could CPU purchase more hydro/nuclear from BPA right now or when the BPA contract is renewed?

Is there a market for resource adequacy? In other words, could the ability to vary the output from the River Road plant be sold as seasonal or emergency backup power? It seems like a paid for gas plant would make an excellent long duration battery assuming the availability of gas supplies. Perhaps River Road could be used to support the most aggressive adoption of new renewables?


We appreciate your interest and great questions. We will do our best to address them. Some of your thoughts and questions are key areas of our 2020 IRP that will be released for public comment soon.

Some Combined Cycle Combustion Turbines are dispatchable within a certain generation range when they are running. This dispatchability comes at a loss of efficiency. Most CCCTs are designed and tuned to most efficiently (MWh per MMBTU of gas) at the top end of their capacity output. So typically CCCTs are run at those levels and are not ramped up and down in short timeframes because it reduces efficiency and increases the $/MWh cost of production. You are correct that River Road Generating Plant has been historically run at its most efficient set point or as the term is known “block loaded.” This kind of binary operation has enabled RRGP to be a very dependable resource.

As you alluded, there are other resources such as our BPA Slice/Block Power Sales Contract which is backed by Federal Hydro Plants and other flexible resources that are available through market purchases to help Clark Public Utilities meet its load variations. Traditionally, Clark Public Utilities relied upon both of these types extensively to meet load obligations. The chart below shows the most recent month of hourly loads and the resources that meet those loads. We expect that flexible generation will become more and more costly to acquire and we are exploring additional means to attain generation flexibility.

Your questions regarding RRGP and its relationship to the BPA PSC and the obligations thereunder does not lend itself to an easy answer. RRGP is what is known as a 5(b)/9(c) resource under the Pacific Northwest Regional Power Act. Under this Act, much has been written, litigated, and interpreted regarding regional power resources especially those that were declared for use to reduce a utility’s purchase requirements under the BPA PSC. BPA provides a rather lengthy and legalistic interpretation and their application of 5(b)/9(c) here. The bottom line is that Clark Public Utilities may still have an obligation to provide energy in the same amount as RRGP regardless of the status of RRGP whether it has been sold to another party or retired. Clark Public Utilities is exploring all the options you have questions about and our 2020 IRP will have much more information regarding this topic. But, suffice it to say, Clark Public Utilities is hopeful that BPA will implement the 5(b)/9(c) policies in a manner that reflects the upcoming requirements under the recently passed Clean Energy Transformation Act and we look forward to working with BPA to explore this possibility.

Your third set of questions are very insightful. One of the high priority action items included in the 2020 IRP includes developing a business case to assess creating much more ramping flexibility at RRGP and comparing that to other alternatives such a simple cycle combustion turbines or storage resources that would include batteries or pumped hydro. This enhanced ramping capability at RRGP could serve many purposes but mainly the integration of renewable resources both our own and others in the marketplace.













Submitted on 5/25/2020 via CETA status page


Clark Public Utility Commissioners:

Please do all you can to help CPU transition to a fully renewable energy system. It’s a tall order but we’re living in times that require big actions. I’ve been a CPU customer since 1970 and I’ve always felt like PUD offered excellent service and good value for Clark County residents. The climate emergency and accompanying pandemic are encouraging both citizens and civic leaders to rethink the way we live and do business on this planet. Yes, humans have endured previous pandemics but right now we’re beginning to pay the price for pumping CO2 into the atmosphere for the last 100 years. Our habitat is out of balance as we careen from one environmental or health disaster to another. Both culminating in economic disaster. In order to survive we need to strive for homeostasis in our planetary environment.
This is a very tall order. As we try to reduce the emission of greenhouse gases , the very warming of the earth and oceans causes arctic permafrost to melt blowing massive amounts of methane into the atmosphere. Fix something here and something cracks over there. Thats’s the world we’re living in and sending on to our grandchildren and their children.

We can throw our hands in the air and prepare to die, or we can do what we can, where we can. Right now, in our river city we can rid ourselves of the fossil fuel culprit as best we can.
Let’s do it. It’s time for bold action and there’s an abundance of public support. Do you have the courage to boldly do the obvious?

It’s not a matter of Clark Public Utilities surviving, it’s a matter of all of us striving and surviving.

Submitted on 5/25/2020 via CETA status page


I encourage Clark Public Utilities to be a leader in clean energy, and to do more than the minimum required for compliance with the law. Please be creative in crafting solutions that will get us to 100% clean energy.

I also encourage you to have a solid commitment to equity in our community. Surpluses should be directed to helping low-income neighbors, especially in this time of crisis

Submitted on 5/26/2020 via CETA status page


I urge Clark PUD to work toward a clean-energy future. I have two suggestions. Thank you.

1. I already support the Green Lights program each month, which is a donation in addition to my monthly bill. I would like to have a fully “green” (renewables) option for my monthly bill. Please provide a way to do this.

2. I participated in the solar panel project a few years ago. I would do this again. Please reinstate this program.


Thank you for participating in the process and submitting your comment.

Soon after the construction of the Clark Public Utilities Community Solar arrays the State Cost Recovery Program funding was exhausted, which in turn limited the ability to develop new community solar projects.

Over the next several years the State Legislature introduced and passed a new renewable energy incentive program, but reductions to community solar incentive rates limited the ability to advance new projects. During the 2020 legislative session a new community solar program was passed by the legislature, however, the legislation was recently vetoed by Governor Inslee. While we were disappointed by this outcome we are hopeful this a legislative topic that can be addressed in the future. We will continue to track legislative developments.

Clark Public Utilities staff will continue to look for community solar opportunities into the future; as installation and construction costs for solar arrays fall we may be approaching a future where community solar projects are cost-effective without government subsidies and incentives.

Submitted on 6/11/2020 via CETA status page


Please commit to 100% Clean Energy. As a Board Certified Public Health and Preventive Medicine Physician I know and can see the effects of on going pollution and green house gas on our community’s health and wellbeing. It is important that the PUD lead the way to a healthy future for our community. Do the right and honorable thing. Go down in history as leaders in a new and healthier tomorrow for our children. Don’t follow the example of the tobacco companies with a legacy of suffering and death.

Submitted on 6/12/2020 via IRP status page


Thank you for soliciting public input and for answering many of the questions in a detailed manner. Per your planning documents the River Road Generating Plant (RRPG) produces roughly a225 MW or 225(8760) = 1971000 MWhs per year. Ignoring sunk costs, the marginal cost of that power is $22.50/MWh (IRP page 16) while market prices average $33.00/MWh (IRP page 44). Simple math says we save roughly $20 million running RRPG over purchasing from the market but that ignores the timing and pricing of purchase and sales. And this also ignores the social cost of carbon. Staff has indicated that we save more like $30 million per year. Could you help explain the difference? Are there times of day, times of year when RRGP is more valuable? Would it be possible to chart the savings similar to the Load and Resources by Day and Hour graph or at least see what market prices look like over the course of a year? Is a225 MW a large enough amount of power that it could move market prices? What are the minimum quantities that can be bought and sold on the wholesale markets? Sorry if I missed any answers in the IRP. I’m just trying to get a better understanding of the energy markets. Thanks!


We appreciate your interest and your questions. Please see the below response from staff:

Before addressing the first question regarding the valuation of RRGP, there are a couple preconditions placed upon it that need clarification.

The first precondition is that the timing and pricing of purchases and sales are ignored. It is not clear what timing and pricing elements are being referenced here. We hope this is addressed in the answer we provide regarding the apparent differences in savings regarding RRGP that have been discussed and projected in past conversations and meetings and in the IRP.

The second precondition regards ignoring the social cost of carbon. Clark Public Utilities is mandated to provide electricity at cost to its customers. In addition, Clark Public Utilities is charged with planning and operating in a least cost manner. Any cost incurred by Clark Public Utilities for operations must be real, auditable, and payable and must be for utility purposes only. Currently, there are no existing taxes or fees from local, state, or federal entities that are attached solely to a social cost of carbon. Adding a social cost of carbon to operations at RRGP does not serve a utility purpose, is not a real cost incurred, and would result in operations that are not least cost. Clark Public Utilities is not ignoring a social cost of carbon as it relates to RRGP. We are purely following the laws as a public utility district in the state of Washington.

This does not mean that Clark Public Utilities pays no taxes or fees on the operations of RRGP. Each year, Clark Public Utilities pays a 1.25% tax to the City of Vancouver based on the cost of natural gas that is burned to run RRGP. This comes to roughly $500,000 per year but is highly dependent upon the price of gas and how much RRGP runs during the year. The utility also pays a natural gas tax to the state of Washington in a similar manner and another tax that is called a “privilege tax” that are both based upon actual fuel burned. This amount that is paid to the state under normal operations is about $2,000,000 per year. These taxes and fees account for approximately 6.7% of the marginal cost of generation at RRGP.

Addressing the differences in value calculations.
Any marginal calculation performed by Clark Public Utilities, just as the one in your example, is based upon the current price marks for wholesale power and gas for the future series of time under consideration. So, the future period in time matters considerably when doing the calculation. A calculation of the savings for RRGP for 2021 only for instance will be different than the annual average savings for 20 years of projected levelized prices for 2021-2040. As future period wholesale power and gas prices can fluctuate significantly from day to day, the marginal economics for RRGP will also fluctuate. This likely accounts for the differences you have noted.

To answer your question, we need to step through some calculations and data. Please keep in mind that these annual calculations are rough approximations. Clark Public Utilities maintains several sophisticated models that account for all variable, i.e. marginal costs, that drive RRGP dispatch decisions on a monthly and daily basis. They are not available to the general public as they contain proprietary and commercial information that would divulge portfolio management information that could compromise wholesale commercial operations. The general approach on an annual basis here is a very reasonable facsimile of RRGP that could be discerned quite easily by those in the business with experience and access to market pricing.

Below is a chart for the wholesale power and gas prices for delivery in 2021 through time starting in Feb 2017.










From this data, we can calculate the incremental value of RRGP through time for the 2021 Annual delivery period. The economic heat rate for RRGP is ~7.5 MMBtu/MWh and is represented in the chart below as the horizontal black line using the right axis. The 2021 market heat is calculated each day as the MidC Around the Clock price divided by the Sumas price to get to MMBtu/MWh and is also shown on the chart as the blue line using the right axis. Anytime the blue line is above the black line, it indicates that RRGP is more efficient than the market. Said another way, if the blue line is above the black line and RRGP is not planned to run, not only is Clark Public Utilities losing economic opportunity, the replacement power provided by the market will be provided by a less efficient gas resource and thus will emit more CO2 into the atmosphere per MWh.












The green line on the chart below represents the incremental economic opportunity to Clark Public Utilities for 2021 for the particular point in time on the horizontal axis. This value is calculated by comparing the cost of wholesale power for that date to the cost for RRGP to produce power using the RRGP economic heat rate and the price of gas for that date. This shows how much the value of RRGP can swing and may answer the question regarding the differences between the IRP and staff’s earlier projections. They are time dependent.











Of course, these are just projections for 2021 and the actual conditions in 2021 will drive the dispatch decisions. If snow-pack is high and loads are down, then the relationship between gas and power prices may change enough that some months in 2021 will see RRGP come down for economics.

Addressing the RRGP Volume and market pricing.
Yes, RRGP’s size can affect the power markets. The power market, especially for longer terms of delivery, such as 2 year or more is thin. Buying replacement power for a unit the size of RRGP would move that market. The closer in time to actual delivery the less that becomes an issue. Clark Public Utilities’ models try to reflect this bid/ask spread but it is more art than science.

Addressing standard trading volumes in the wholesale market.
25 MW is the most common size trading block. Moving away from the lot size will influence pricing greatly. 5 MW blocks are about as small as can be done without incurring significant transaction costs on top of the going market price. 1 MW deals do happen but they are few and far between. No deals happen below 1 MW.

Submitted on 6/18/2020 via IRP status page


About four years ago if I remember correctly, Larry Blaufus told me the problem with property managers is that they don’t know how to program their perimeter lights. I’d like to add, they don’t care because they don’t have to pay the energy bills, the tenants do.

How can you change that? You could require they do that and if they don’t, CPU could do it for them and charge them for the service.


Commercial building wiring configurations can vary with different levels of lighting control access available to tenants. It is true that some tenants (and landlords) may not understand how to properly program their exterior wiring. In an attempt to educate tenants and landlords about energy conservation (including lighting), Clark Public Utilities offers free energy audits to commercial businesses. Further, the utility acknowledges dusk to dawn photo controls as a minimum best practice for exterior lighting. Dusk to Dawn photo sensors do not require programming and energize luminaires only when justified by low ambient light levels. For more advanced, networked lighting controls, the utility offers additional cash incentives ranging from $40 to $60 per fixture in order to encourage customers to employ the most energy efficient equipment.

Though Clark Public Utilities is prohibited from performing work on the customer side of the meter, we will continue to offer energy efficiency incentives to remove as many financial hurdles as possible for customers interesting in installing energy efficient equipment.

Submitted on 6/18/2020 via IRP status page


Again I’m humbled by the complexities you have to deal with. Comparing new vs existing manufactured homes it seems odd that the percentages of types of heating systems is the same for new and existing. Both have 55% electric forced air and 3% baseboard heat.

Anyway, it seems to me that is low hanging fruit for conservation with ductless heat pumps. I’ve heart that manufactured homes on average leak more energy than most others, with leaky or poorly connected ducts


Yes, the data we used in our conservation potential assessment was the same for existing and new homes heating /cooling system saturations. The source of that information is based on a regional building stock assessment (RBSA) that includes a sample of homes in Clark County. That data is the best source of randomized, non-biased data available to us. Staff has worked on getting updated data from individual customers over the last 3 years so that we can improve those characteristics but as you can imagine, with over 179,000 households, this takes time.

We agree that one of the low hanging fruit for conservation is ductless heat pumps (DHPs) and in fact, we have provided 2,416 rebates for DHPs through our standard incentive program in the last 5 years. During that same period of time, we also created a specific program for moderate income customers in which we paid for 100% of the installation of another 263 DHPs. In that program Clark Public Utilities funded ½ of the cost and the other ½ was funded using grant funds awarded to us by the State of Washington.

Yes, we see a difference in the efficiency of manufactured homes built before the HUD code took effect in 1976 and the manufactured homes built after that year. We’ve been offering weatherization programs for manufactured homes since the 80’s and have rebated 36 weatherization projects and 206 duct sealing projects in manufactured homes within the last 5 years.

In 2020, we started offering a new program for new construction manufactured homes sited in Clark County. We are hopeful to see increased uptake in that program as we offer a rebate of $1,200 or $1,400 depending on the efficiency standard used to build the home.

Lastly, we are very aware of the energy efficiency opportunities that exist within our customer’s existing manufactured homes. Staff created a new program using the grant funds mentioned above that will pay 100% of the costs to install approximately 170 DHPs in manufactured homes along with a pilot to provide 10 roof caps for homes with leaky roofs. Unfortunately, the launch of this program has been put on hold due to COVID-19.

Submitted on 6/18/2020 via IRP status page


Trump has rolled back 3 efficiency standards recently. How will you mitigate that?


Federal energy efficiency standards are an important factor for Clark Public Utilities when designing energy efficiency programs and we’ve been tracking recent developments in that area closely. While Federal Standards are important, they are one of many factors the utility takes into consideration for conservation planning and we are fortunate to be located in a state that has a long history of mandating more stringent standards than the Federal levels. We can find an example of that in the 2019 Washington Legislative accomplishments; our state passed HB 1444 which was designed to mitigate the federal government’s refusal to implement new energy efficiency standards that were slated to go into effect, nationally, on January 1st 2020. With the passage of HB 1444 Washington State was able to ensure the adoption of most of the standards that were not instituted at a national level. This state law impacted several of Clark Public Utilities conservation measures and we’ve worked to ensure our utility is in compliance with the more rigorous state standards.

Additionally, Washington State mandates the most strict residential energy building codes in the nation and Clark Public Utilities offers an incentive program to reward local builders for exceeding those already challenging code levels. We’re fortunate to have a community and local builders who find value in focusing on energy efficiency and we credit that for the success of these programs. During the 2019 legislative session the state government also passed a statute (HB 1257) to address energy efficiency standards for pre-existing commercial buildings.

Lastly, we’d note Clark Public Utilities’ long term membership in the regional market transformation organization, Northwest Energy Efficiency Alliance (NEEA). NEEA has several initiatives focused on energy efficiency standards, energy building codes and increasing the adoption of the most energy efficient electrical appliances. Staff from Clark Public Utilities participate on the board, several NEEA committees and workgroups at all levels of the organization. We believe these efforts leave Clark Public Utilities well positioned to ensure the continuing adoption of energy efficient appliances and building methods in our community and service area.

Submitted on 6/18/2020 via IRP status page


What makes some conservation potential cost effective ten years from now, but not now?


Good question! While the cost effectiveness of energy efficiency can vary over time due to changing market prices, policies, and other factors, our conservation potential assessment (CPA) evaluates each measure based on the costs and benefits provided over a single 20-year program period.

In our CPA report, you may see tables where the potential is broken out in 2, 6, 10, and 20-year increments as well as figures where the potential is plotted by year. Rather than noting when this potential is cost-effective, these tables and figures are intended to show when the potential can be achieved.

Some measures may only be possible when a new home or building is being constructed, or when a piece of equipment is being replaced anyway. One example of this is our heat pump water heater program. In this program, our rebate is intended to encourage our customers to upgrade to a heat pump water heater when their existing water heater is ready for replacement. Water heaters typically last 12-13 years, so it would take at least this long to achieve all the potential energy savings available from this measure. Other factors, such as the state of the market for efficient products and program budgets influence how quickly the energy efficiency potential can be achieved.

Submitted on 6/22/2020 via IRP status page


I applaud your robust conservation program. I hope that the IRP will address ways to funnel more of those resources into disadvantaged communities and help them develop more local solar. Such an investment would accelerate a move to clean energy as well as promote economic justice for communities traditionally ignored. I also hope you will aggressively accelerate a move toward 100% clean energy. An investment in clean energy will better situate the county for the future.

Submitted on 6/24/2020 via IRP status page


What does the law or our state constitution say about providing incentives for heat pumps and heat pump water-heaters in NEW construction????


Thanks for submitting another question. Here are some details from staff:

Clark Public Utilities is unaware with any restrictions or mandates in the State Constitution regarding space or water heating technology. You might be referencing the restriction within the constitution regarding incentivizing fuel switching for heating systems? That restriction is more applicable in retrofit scenarios and generally does not apply to new construction projects. As an example; an electric utility like Clark Public Utilities is unable to provide a financial incentive if an existing home switches HVAC systems from a natural gas furnace to an electric heat pump. However, if a new construction builder exceeds the state energy codes by installing energy efficient appliances and measures we can provide a financial rebate.

Clark Public Utilities offers the Performance Path residential new construction program that incentivizes builders to exceed Washington’s strict energy codes. We also offer a new construction HPWH program that provides builders with a $300 incentive for the installation of qualified units. Both of those programs have been very active and successful over the last several years and we plan on supporting and promoting both programs into the future. Please let us know if you have any additional question regarding our new construction programs and our work with regional builders.

Submitted on 6/29/2020 via IRP status page


The City of Vancouver currently has 100 large commercial projects undergoing permitting review and most of them will be heating space and water with fossil gas.

This year, our legislature passed HB2311 establishing the goal of reducing emissions 45% below 1990 levels by 2030. I’m thinking it will be more difficult to do that if we allow emissions to increase before we begin?

What incentives can Clark PUD offer these builders this year to install heat pumps for space and water and EV charging infrastructure?


Thank you for the thoughtful question regarding commercial new construction in our community and the greenhouse gas reduction mandates included in HB 2311. Clark Public Utilities offers a variety of energy conservation rebates to the commercial sector including incentives for upgrading existing heating equipment to efficient heat pump technology. State energy codes mandate strict efficiency levels for all new construction in our state, if a commercial building exceeds state energy code standards, the utility offers cash incentives through the custom program to help offset that initial cost to the building owner. The utility has issued incentives for new construction custom projects, but most often, new construction incentives are generated for new construction lighting projects that have incorporated LED technology. If an existing commercial building is heated with natural gas Clark Public Utilities is legally prohibited from using public funds to incentivize fuel switching, and that adds to the complexity of managing commercial incentive programs. That said, the Clark Public Utilities team is always ready to work with a commercial customer on a “Custom Project” to analyze and measure any unique energy efficiency upgrades at their facility.

Clark Public Utilities is working on developing formal electric vehicle (EV) rebate and incentive programs and when those programs materialize we plan to include and address commercial and industrial customers and premises. We recognize the need for robust and broad EV programs to assist in meeting the greenhouse gas reduction goals included in HB 2311 and Clark Public Utilities looks forward to being a solution provider in that effort.

Submitted on 6/29/2020 via IRP status page


I was pleased to hear that we had strict energy codes. I checked my consultants to see how we compared with California. Jim Lazar said: “California, starting this year, requires Zero Net Energy (ZNE) in residential construction. The structures must either include on-site solar, or owned shares in a community solar project.”

So I asked about provisions for social justice. He said: “There are programs to assist low-income consumers that are not available to other customers.”

What programs do you have to assist builders of apartment complexes or “affordable housing” projects, several of which are under permitting review, that are not available to others? (For solar, heat pumps and EV charging?)


Clark Public Utilities conservation programs are generally focused on upgrading existing systems, buildings, equipment and processes. We capture and report conservation savings that are calculated using a “baseline versus upgrade” approach that is widely adopted in the utility industry. It’s challenging to offer programs for new construction because the state energy codes require builders to build very efficient buildings and exceeding those codes is often not cost-effective for builders to pursue. At this time Clark Public Utilities does not offer any formal multifamily new construction incentive programs. We have worked with multifamily builders on specific aspects of their projects and offered lighting upgrade incentives as applicable. Electric vehicle charging programs focused on multifamily structures will be included in Clark Public Utilities’ transportation electrification programs in the future but we currently do not offer any such programs. Clark Public Utilities does not offer any financial incentives or rebates for the installation of solar generating systems because solar PV systems are a generation measure and not a conservation measure. We do however, support solar generation through the net metering benefit, a loan program for residential customers, our community solar arrays and several educational efforts.

We’d also note that the Clark Public Utilities Board of Commissioners allocated $2,000,000 to create a limited income direct install thermostat/LED program. It includes installing efficient line voltage thermostats and LEDs in several of the Vancouver Housing Authorities’ income qualified multifamily properties. In addition, we are also installing efficient smart thermostats (Nest) and LEDs for single family and manufactured home owners that meet certain income requirements across Clark County. That project has led to both energy savings and increased comfort for approximately 1,300 limited income households to date.

Lastly, since 2010, Clark Public Utilities has received 6 grants of varying sizes from the Washington State Department of Commerce for the Community Energy Efficiency Program (CEEP). In that program, we have assisted moderate income customers with the installation of attic, floor and wall insulation, ductless heat pumps and we’ve provided energy saving kits (e.g., LEDs, showerheads and advanced power strips). Additionally, these funds have assisted non-profit businesses with the retrofit of more efficient lighting. The intent of CEEP grant dollars are to create a new program that doesn’t already exist in the utility’s existing program offerings.

Submitted on 7/6/2020 via IRP status page



I’m writing these questions and comments from the perspective that rapidly transitioning to 100% clean energy should be a tremendous economic opportunity for Clark County. Climate change, health concerns, and a desire to use regional and sustainable energy all push towards making the transition as quickly as possible. In addition, the direction of state and national law keeps moving towards less pollution and a cleaner environment which is a typical trajectory as a society becomes richer. Current WA state law (HB 2311) requires that we reduce greenhouse gas emissions by almost 50% by 2030. CPU is in an excellent position to help lead that effort while at the same time keeping rates affordable. 100% clean energy would make Clark County more competitive as a destination of choice for companies and people moving into the area. Clean energy has the potential to be more price stable and available. Transitioning to clean energy creates local jobs and investments both in infrastructure and in the knowledge and professional services industries. Distributed generation, demand management, conservation and efficiency, and transportation electrification will all require new knowledge, software, processes and equipment. These are growth industries and we should position ourselves to obtain as many of the new jobs and economic benefits as possible.


Use more BPA power
On page 61 of the IRP, CPU sketches out a scenario where CPU could acquire all of the unused BPA highwater mark power and use RRGP more or less as back up power. This seems like an excellent win-win solution and I applaud staff for thinking creatively about how best to use RRGP. If additional flexibility was added to RRGP it seems likely that much of the economic benefit from RRGP could be obtained by operating it only during those times when it is really needed or when economic benefits meet a certain threshold. It seems likely that a judicious use of RRGP could significantly reduce the estimated $27M cost to ratepayers while delivering a very clean and reliable energy solution. Additionally, if CPU is seen as actively trying to help the region meet its dual goals of carbon reduction and resource adequacy, instead of simply sheltering behind narrow CPU specific regulatory carve outs, then CPU could gain valuable planning time and increased regulatory certainty.

Explore voluntary demand management
As a public entity, it seems like CPU has an advantage over investor owned utilities in that customers may be more willing to engage in behavior for the common good (other ratepayers). There may be untapped civic altruism and the ability to exploit social pressures when it comes to reducing peak demand and supply emergencies. You already see programs like this with regard to summer water usage or curtailing wood smoke during air pollution alerts. Right now most CPU rate payers have no clue when it costs more for their utility to provide them with power. Simple education about loads, peak loads, and how customers can help, may have small but useful impacts. Maybe alerts could be used to notify ratepayers when usage is getting extremely costly. As an example, most EV owners also own a ICE vehicle and might be willing to forgo driving electric for a weekend or even a week if they knew they were contributing to keeping rates low for all ratepayers. Time of day, seasonal and block pricing (equity pricing) should all still be explored but a voluntary program could be implemented with simple communications and marketing and wouldn’t require any new equipment, processes or systems.

Develop more local solar for resiliency
It’s disappointing that frequently the tone of the IRP is dismissive of new renewables, especially solar. It is clear to most observers that solar power is mostly a seasonal resource here in the NW. There is no need to belabor that point. What is missing is an analysis which looks at solar and wind in combination with existing hydro and perhaps a more flexible RRGP. It seems likely that the value of solar production is actually higher than average considering when it is produced both during the day and seasonally. Staff has indicated that power prices are higher in the summer due to CA demand and it is too bad the IRP did not include a quick analysis of the economic value of solar production along with Figure 4.6. Figure 4.6 does indicate that local solar is actually a pretty good match for 5 months of the year. Utility scale solar keeps dropping in price and other parts of the county are probably a better match for large scale solar production but an argument can be made for some amount of local, distributed generation (especially if coupled with short duration storage) simply from a resiliency standpoint. Base load plants and concentrated transmission are very reliable until they aren’t. I think it makes sense to try and produce a certain amount of supply from local sources in the case of natural disaster or some other calamity (transmission problems, cyber attack, terrorism) even if the cost is somewhat higher. Right now solar is the most widely available, cost effective and best understood local renewable but other small scale renewables such as hydro, biomass, and backup generation using ethanol or biodiesel should also be looked at. Also, local generation creates local jobs.

Some of the advantages of local solar:
Can be added to supply in very small increments (avoid mega project and overbuilding risk)
Can match load growth pretty precisely with correct incentives and program design
Takes advantage of local private capital
Positively received by the public
Lots of discussion by other public entities (cities, schools, ports)
Solar and other green features are often used as valuable marketing tools

While very valuable, current net metering program does not maximize local solar potential
Projects are constrained by customer usage and not designed to maximize efficiency of installation (rooftop or ground mount area)

Encourage more ratepayers to try EVs
Ratepayers do not seem to understand the large fuel savings possible by switching to EVs (and lower total cost of ownership). Current marketing efforts don’t seem to be breaking through to the public that driving electric is much cheaper than ICEs. Some suggestions:

Incent all CPU employees to try driving electric (free workplace charging, no risk temporary loaners?)
Focus more on home and workplace charging. Public chargers are nice for emergencies and tourists but 99% of charging will occur where the car is parked the most. Home charging infrastructure is much cheaper than public chargers. Workplace charging should be encouraged from an equity standpoint and possibly for demand management strategies.
It’s cheap to add charging infrastructure at time of build. A 50a RV plug might add $100-200 to the cost of a new home and can also be used for a RV or welder. People love them.


New renewables
Why are renewables analyzed in isolation and not in combination? The NW is blessed by lots of hydro and how can that hydro be used most effectively in combination with new wind and solar? Also, what is the potential for increasing hydro output either through modifying and upgrading existing dams or from new hydro such as run of the river or adding turbines to existing non generating dams?

Local solar
Could the utility design a small solar purchase agreement that would pay local solar producers some amount between wholesale and retail that would ensure a steady supply of solar projects coming on board? The rate could be tweaked to obtain the desired level of new supply. Also, there seems to be a lot of ratepayer interest in more community solar. Could the utility gauge actual public interest by say collecting refundable deposits on a potential non-subsidized community solar project?

Regulatory risk
What is the possibility that recent research and science will demand increased emissions regulations in the near term? It seems that CPU has been caught off guard in the past by public pressure to regulate GHG emissions and clean the environment.

A 100% clean product
Does CPU have the ability to provide a 100% clean energy product for an organization or large commercial customer? Could it create a residential product if there was sufficient demand? Would it mostly use RECs? What if a City, Port, University or business like a Microsoft branch campus wanted to be 100% clean? The current Greenlights program is dated and doesn’t appear adequate for other organizations wanting to market themselves from a clean energy or green perspective.

Merger or sale of the utility
A bullet point on page 83 of the IRP states one of the alternatives to an unsuccessful new BPA contract would be “Partnering with or being acquired by other non-federal multi-state and low GHG emitting utilities”. The language is pretty specific and implies an investor owned utility. Would CPU actually consider being acquired? Is this a warning to BPA or state regulators? Has CPU been approached by or approached any IOUs about the possibility?

In a response to a previous set of questions, staff indicated that much of the utility’s operations are simply constrained by state law but what wasn’t mentioned is that CPU actively tries to influence laws and their implementation. How does CPU communicate to the public what its lobbying positions are? What is the nature of CPU lobbying by staff and commissioners? Does CPU’s unique position of being the only PUD with an emitting resource make it difficult to create a statewide public power consensus? What was CPU’s lobbying position regarding CETA?

Electrification of Clark County
This supporting document is helpful in quantifying the amount of extra power CPU would need should Clark County opt to entirely switch away from fossil gas. The qualitative analysis is less helpful. It is a fact that renewables emit less emissions than burning gas even with the most tortured life cycle analysis. Most discussions of electrification center around not including gas in new projects — fuel switching laws don’t apply to that scenario. Also, it would be helpful to note that fuel switching laws are not symmetric — Northwest Natural can advocate for fuel switching to existing all-electric households (we receive marketing materials advocating a switch at least once a month).

What is the basis for the following lead sentence “Recent building trends in Clark County, WA indicate consumers prefer natural gas fueled appliances due to their low operating costs compared to electric fueled appliances.”? Is there any market research to support these assertions? Are natural gas appliances really more cost effective? Has CPU surveyed customer satisfaction in households that are all electric? How much of a subsidy does Northwest Natural provide to builders and developers to include gas in their offerings? Could CPU provide more incentives to build all electric? Has staff looked into the health impacts of combustion appliances in a tight building envelope? Are there demand response benefits from all electric buildings (utility controlled residential hot water heaters are a commonly cited example)?

It seems the more important question that this document didn’t answer was what would be the impact on load if going forward all new buildings were fully electric? The data presented on page 23 of the Conservation Assessment (Table 1) must be in error since new homes have exactly the same numbers as existing homes. Could we get updated numbers? Staff has indicated that the main reason we have not seen more residential load growth is because most new residential construction relies heavily on gas. This may not be indicative of true customer preference but more one of Northwest Natural winning a marketing and subsidy battle and CPU willing to cede market share in order to avoid load growth. Existing gas infrastructure may be valuable in managing the transition to cleaner energy supplies but the likelihood of a ban on new gas hookups should not be casually dismissed.

Thank you for allowing the public to participate in the IRP process!


As a public entity, it seems like CPU has an advantage over investor owned utilities in that customers may be more willing to engage in behavior for the common good (other ratepayers).

State law prohibits public utilities from charging costs to its customers that are not specifically for the purpose of utility operations. This includes projects that are for the common good.

Why are renewables analyzed in isolation and not in combination?

Clark Public Utilities’ base portfolio meets the needs of the customers on an average energy basis. Contractual obligations require Clark Public Utilities to purchase additional energy requirements from BPA through the year 2028.

Clark Public Utilities’ most pressing need is for dependable dispatchable capacity to meet peak requirements. Renewables in any combination produce energy only, not capacity. Combining renewables will not lower the per unit cost of that combination, nor will it increase the dependability or dispatchability to the level needed by Clark Public Utilities to meet peak requirements.

Adding battery storage will help to some extent, but will not create the necessary dependability and dispatchability needed to meet peak requirements at a defendable cost. Much is made about natural gas plants being “replaced” by renewables plus a battery pack that is the same MW size as the max output of the renewable energy. However, this “replacement” provides nowhere near the dispatchability or dependability provided by natural gas plants. Adding batteries would make the comparison more even, but the added costs become very high.

The NW is blessed by lots of hydro and how can that hydro be used most effectively in combination with new wind and solar?

We are blessed by lots of hydro. Clark Public Utilities purchases over half of its power needs from Bonneville Power Administration (BPA) who markets the power from the Federal Columbia River Power System (FCRPS).

The amount of planning, coordination, communication, and operations surrounding the Columbia River is mind-boggling. The following links will help the reader get a sense of the history of coordination of the river, the interests of stakeholders and the balancing that needs to be done with respect to river operations:

The flexibility of the FCRPS has been optimized under the requirements placed upon it for higher purposes than just power production, such as flood control, fish passage, recreation, and irrigation. BPA is continuously looking for ways to extract additional revenue from the capabilities of the system and we applaud them for this as it results in lower rates for us and the other consumer owned utilities. Clark Public Utilities believes that within the constraints the system is placed, that those blessed with hydro generation have done tremendous work integrating and enabling renewable generation to flourish here in the PNW and we have confidence that this work will continue.

Also, what is the potential for increasing hydro output either through modifying and upgrading existing dams or from new hydro such as run of the river or adding turbines to existing non generating dams?

Clark Public Utilities is not able to answer this question. Clark Public Utilities does not own or operate hydro facilities nor has it done any specific research on the topic.

Could the utility design a small solar purchase agreement that would pay local solar producers some amount between wholesale and retail that would ensure a steady supply of solar projects coming on board?

Clark Public Utilities has a net-metering program that is not fully subscribed which pays for solar energy at the retail rate.

To the extent that a developer wishes to go beyond net metering, Clark Public Utilities stands ready to offer the same excellent customer service and assistance provided in each interaction with the District. The price for such supply is set at the utility’s avoided cost rate, as directed by the Public Utility Regulatory Policies Act.

Could the utility gauge actual public interest by say collecting refundable deposits on a potential non-subsidized community solar project?

Yes. This will be discussed and decided upon in the near future.

What is the possibility that recent research and science will demand increased emissions regulations in the near term?

Clark Public Utilities staff cannot opine on this question. The IRP deals with the current set of regulations, laws, and recommends commercially available solutions to meet the various known requirements in the least cost manner.

Does CPU have the ability to provide a 100% clean energy product for an organization or large commercial customer?

It depends upon the customer’s definition of 100% clean energy. From a purely physical standpoint, there is no way any utility can guarantee 100% clean energy. Electrons flow through the path of least resistance and unless the entire grid is 100% clean, then there is no guarantee that some of the “dirty” power is not getting delivered to the customer. Different definitions of “clean” exist. To the extent that an existing or potential new customer wishes to explore ways to be “cleaner”, of course Clark Public Utilities will do everything possible to make that happen.

A bullet point on page 83 of the IRP states one of the alternatives to an unsuccessful new BPA contract would be “Partnering with or being acquired by other non-federal multi-state and low GHG emitting Utilities”. The language is pretty specific and implies an investor owned utility. Would CPU actually consider being acquired? Is this a warning to BPA or state regulators? Has CPU been approached by or approached any IOUs about the possibility?

The language is not specific and is not implied to mean any particular type of entity. It is not a warning and Clark Public Utilities has not been approached by any organization. It is merely an expression that Clark Public Utilities will look at any means to meet the CETA requirements. Clark Public Utilities will give reconsideration to this item and may delete it from the final publication of the IRP.

In a response to a previous set of questions, staff indicated that much of the utility’s operations are simply constrained by state law but what wasn’t mentioned is that CPU actively tries to influence laws and their implementation. How does CPU communicate to the public what its lobbying positions are? What is the nature of CPU lobbying by staff and commissioners? Does CPU’s unique position of being the only PUD with an emitting resource make it difficult to create a statewide public power consensus? What was CPU’s lobbying position regarding CETA?

While outside the scope of the IRP process, Clark Public Utilities will endeavor to answer these questions.

Clark Public Utilities’ does try to influence laws and their implementations. This influence is directed by the publicly elected Board of Commissioners who actively and openly discuss their strategic policies in public meetings. The Board of Commissioners, of course, represent the voters in their Districts. The CEO/GM directs and manages the execution of these directives through the best means available which sometimes includes the use of lobbyists in certain situations.

Clark Public Utilities’ position regarding CETA was to help the state develop a law that gets the electric utility industry to greenhouse gas neutral and beyond while limiting economic impact to our customers. A very balanced position that reflects the makeup of the customer base.

Please be aware that any future discussions this particular topic are better addressed outside the IRP process.

What is the basis for the following lead sentence “Recent building trends in Clark County, WA indicate consumers prefer natural gas fueled appliances due to their low operating costs compared to electric fueled appliances.”? Is there any market research to support these assertions?

We have observed through interactions with our customers that the building trends in Clark County are moving toward gas appliances. As a result, it would not be a good use of customer revenues to perform further research in this area.

Are natural gas appliances really more cost effective?


Has CPU surveyed customer satisfaction in households that are all electric?


How much of a subsidy does Northwest Natural provide to builders and developers to include gas in their offerings?

This question would be best answered by reviewing NW Natural’s website.

Could CPU provide more incentives to build all electric?

No. Also per Article 8 Section 10 of the Washington State Constitution, publicly-owned utilities are expressly forbidden to provide dollars to incentivize fuel-switching. IOUs do not have the same limitations.

Has staff looked into the health impacts of combustion appliances in a tight building envelope?


Are there demand response benefits from all electric buildings (utility controlled residential hot water heaters are a commonly cited example)?


Submitted on 7/7/2020 via IRP status page


I’m trying to get a better understanding of wholesale power markets, the social cost of carbon and the implications for CPU’s operations. In answers to previous questions you have provided much detail, analysis, and education. This is greatly appreciated!

In the IRP, when you refer to Market prices (figures 4.10 and 4.11) is this the Mid C day ahead peak price, futures prices, or some combination estimated by TEA? A quick internet search only turns up numbers from EIA . Is the Mid C Peak price listed what CPU actually faces for next day purchases? Staff has indicated that longer duration and future contracts are typically more expensive than the spot market. Is that still holding? Does this indicate a temporary glut (short term cheaper than long term)? Do these Mid C prices actually tell us anything or are the amounts traded just too small (the problem of a thin market)? For the first 6 months of 2020 the average for Mid C Peak is $17.98/MWh. This seems artificially low. Has CPU compared RRGP costs vs historical spot market prices to see how planning estimates compare with actuals? Do we know how TEA estimates compare to historical actuals?

What do we know about the carbon intensity of market purchases? For conservation cost effectiveness staff has indicated that the market is 80% clean and 20% emitting but when asked what power would replace RRGP output staff indicated that it would be either dirtier gas or coal with market purchases (Figure 4.11 indicates a dirtier market as well). Could you please explain this discrepancy? Is it because conservation results in relatively small market impacts? Is RRGP output of a225 MW (or 5400 MWh/day) larger than can be sourced from the spot markets or would that amount move market prices? From the EIA data it looks like for the first 6 months of 2020 around a1100 MW (or 26219 MWh/day) was traded? The IRP does indicate that relying on market purchases for that much power would be risky.


I’m trying to get a better understanding of wholesale power markets, the social cost of carbon and the implications for CPU’s operations. In answers to previous questions you have provided much detail, analysis, and education. This is greatly appreciated!

In the IRP, when you refer to Market prices (figures 4.10 and 4.11) is this the Mid C day ahead peak price, futures prices, or some combination estimated by TEA?

It is a 20 year level-ized cost projection for 24/7 around-the-clock power that melds current available pricing for forward-market contracts and a long-term capacity expansion model that predicts necessary build-out of power plants based upon an assumed set of policy constraints across the west, all tied back to the Mid-C market. No day ahead pricing is involved. Day ahead pricing as the name implies is only available during the daily pre-schedule period for the next day or in the case of weekends or Holidays, next 2 to 4 days. It changes every pre-schedule day.

A quick internet search only turns up numbers from EIA . Is the Mid C Peak price listed what CPU actually faces for next day purchases?

The ICE index is a collection of trades made for following Pre-Schedule day and CPU’s Pre-Schedule transactions may or may not be included in the make-up of this index depending upon how CPU’s Pre-Sched transactions were accomplished. But, generally yes, the Daily Pre-Sched price we realize after trading is done for the day is usually very close to the ICE index.

Staff has indicated that longer duration and future contracts are typically more expensive than the spot market. Is that still holding?

In general yes. However, recent and past disruptions to the market have shown that daily and short-term markets can have excursions beyond what the forward markets would have been available for in prior months for the same delivery period. Those excursions while mostly short in duration, can be very expensive and painful for those who have not prudently planned ahead either by purchasing forward contracts to fix their costs and/or setting aside financial reserves to absorb the high prices. However, there may be times when money cannot solve the problem in the near-term as resource development does not happen overnight, Thus, load curtailment must happen. If the load curtailments are protracted and chaotic, the consequences can be catastrophic.

Does this indicate a temporary glut (short term cheaper than long term)?

Yes, but some of the “glut” is by design to insure load service. There are two reasons that a “glut” is created by design resulting in spot market and short-term power that is typically less expensive:

1. On most days, the spot market pricing, meaning Pre-Schedule and Real-time pricing, is generally reflective of the marginal cost of generation of the most expensive resource in the stack of resources needed to meet projected loads. This is called the dispatch or resource stack. The dispatch stack starts with the lowest marginal cost resources such as wind, hydro, and solar and builds from there. Each resource that has a marginal cost associated with running compares the that marginal cost with the price it can get in the marketplace. If the marketplace is cheaper than the marginal cost of running, the resource should not run since it would lose money compared to market.

Why does the spot market usually reflect just the marginal cost? Most resources are built for the long-term and their capital costs are rate-based with the utility that owns the resource. Rate-based means that these capital costs are paid by ratepayers whether the resource runs or not. Since most utilities are prudent and responsible by nature, resources are built for long-term commitments, 30 to 50 years, and are built to meet not only current load forecasts but as part of a portfolio to meet long-term load needs as well. Most resources are very capital intensive and only make sense when looked at for long duration run-times. Similar to a house purchase that is financed with a 30-year mortgage.

Since most utilities build for these future commitments and are obligated to serve any and all load placed upon them (“obligation to serve”), there typically is plenty of capacity at any given time to meet the aggregate load of a local utility, state, region, and/or large swath of the western United States. Provided transmission is available, the resource owners and utilities see that it makes sense to optimize and trade to reduce their operating costs. With excess capacity most days, the capital costs associated with any given resource become irrelevant, or sunk. The marginal cost of running becomes the means by which the resources compete for market share.

2. Another reason that the short-term or spot market prices are less expensive is related to the fact that renewable energy (including and especially hydro) cannot be depended upon to produce the same amount of power from year-to-year. So, to ensure enough supply, output from hydro power is planned for on a less than average basis. This helps to make sure there is enough fuel supply in below average run-off years. Statistically, there will be more years than not that the hydro supply is more abundant than planned and will be available as “surplus”, “secondary”, or “non-firm” power. This is power that was not planned for from load-serving perspective and oftentimes occurs just when the power is needed least. Thus the low spot market prices. This has been the case for hydro planning for at least 60 years.

In general, the spot market is the clearing price for the highest cost marginal resource that can be dispatched and not lose money. The forward market is the all-in fully loaded cost of capital amortized over a period of time for the lowest cost new resource build. However, the spot market, can in times of scarcity, be irrational as uncommitted resources go to the highest bidder who does not have sufficient capacity to cover its needs and desires to keep service to its customers.

Do these Mid C prices actually tell us anything or are the amounts traded just too small (the problem of a thin market)?

They are an indication of the business being done in the daily pre-schedule market. A snapshot each day of the current configuration of all the resources and loads on the margin at that time.

For the first 6 months of 2020 the average for Mid C Peak is $17.98/MWh. This seems artificially low.

These prices are not out of line with historical price levels for MidC next day PreSchedule. Here are the average 24/7 flat power prices at the MidC (“ATC” or around-the-clock) for the first six months of each year as we have recorded and tracked them. The large excursion in 2019 was due to the pipeline explosion in Canada that drove gas prices to record levels in Jan-Mar and impacted power pricing.







Has CPU compared RRGP costs vs historical spot market prices to see how planning estimates compare with actuals?

Not to any great extent. Spot market energy is not a dependable, dispatchable resource and is based upon marginal fuel cost economics. Past performance of spot markets are not an indication of future performance and are not recommended as a significant component of any prudent utility’s portfolio.

Do we know how TEA estimates compare to historical actuals?

No. You may ask “why not”? The daily pre-schedule historical prices are indicative of the market as it existed at the margin for that time in question. Many things affect that price, temperatures, precipitation both long and short term, wind, cloud cover, unit availabilities, gas and power transmission disruptions, and the price of natural gas.

Forward market pricing is a reflection of the expectations of all these variables which for the most part are based upon averages except for the case of hydro generation plus the fully allocated cost of capital of new generation capacity that may be necessary to meet higher load. Over time, the daily preschedule pricing and forward pricing may converge on average, but there never seems to be an average year. Hence the need for safety margins, in MW, MWh and $.
What do we know about the carbon intensity of market purchases?

It depends upon the market purchases being made. It is not a mature understanding and the rules vary from state-to-state. Washington state is beginning a detailed look at Markets and how they should and could work w.r.t. carbon intensity. The following website chronicles the discussions and progress.

For a great overview of the current status, click on documents and review the presentations made on April 24, 2020.

For conservation cost effectiveness staff has indicated that the market is 80% clean and 20% emitting but when asked what power would replace RRGP output staff indicated that it would be either dirtier gas or coal with market purchases (Figure 4.11 indicates a dirtier market as well). Could you please explain this discrepancy?

When conservation is considered to be economic, it is based upon the premise that is can be done more cheaply than purchasing from the forward market price projected for the life of the program. Because conservation is often done at the programmatic level which results in each program having its own cost and its own amount of MWh saved is typically not large from a wholesale market perspective, a forward market price is usually the bellwether for comparison’s sakes. The unspecified forward market in the PNW typically is expected to be about 80% GHG free over time. Once the program is implemented, you get the savings all the time.

RRGP is, for now, a baseload plant meaning that if it is on-line, it stays on unless we can with a high degree of confidence, replace the power produced by the plant at a lesser price from the market for at least two weeks or longer once it is shut down. Because its heat rate (the amount of natural gas needed to burn per MWh produced) is very efficient and the fact that its location provides a significant transmission savings, RRGP is among the most efficient natural gas plants in the PNW. If RRGP is running, it is a signal that the Market Heat rate is higher (less efficient) than RRGP’s economic heat rate. If RRGP were to trip off-line or it was decided to not run the plant even if it were economic at the time, there would be no other cheaper, more efficient gas or coal-fired resources to replace it as they would all be in the dispatch stack already. Only a more expensive (i.e. less efficient/higher emitting) resource that was not already running would be available to fill the void.

Is it because conservation results in relatively small market impacts?

Yes, plus other reasons. See above.

Is RRGP output of a225 MW (or 5400 MWh/day) larger than can be sourced from the spot markets?

Depends on the time of year. In the spring of a high run-off year on a short-term basis, no problem in finding spot market that is mostly a combination of hydro, wind, and solar. On a cold day in December, depending upon how cold it is and what other circumstances exist around the system, the answer is possibly.

Would that amount move market prices?

In the above examples, No and yes, respectively.

From the EIA data it looks like for the first 6 months of 2020 around a1100 MW (or 26219 MWh/day) was traded?

That sounds about right. Much of this is surplus hydro or wind power being exported to other regions to help balance load and renewable resources or to back off more expensive thermal units.

The IRP does indicate that relying on market purchases for that much power would be risky.

Risk is something we try to reduce and eliminate to the extent possible within cost parameters that are acceptable.

Submitted on 7/8/2020 via IRP status page


Thank you for working toward implementing CETA. The majority of citizens believe we are in a climate crisis and want to transition off fossil fuels. Thank you for prioritizing renewable energy sources. Thank you for your education, incentive and conservation programs. Please do everything in your power to incentivize electrical appliances over those requiring fossil fuel. Strengthen your Performance Path New Construction program to incentivize electrical and discourage gas. Your electric vehicle webpage is great. Please also incentivize electrical charging in new and existing residential and commercial buildings. Please continue working on developing formal electric vehicle (EV) rebate and incentive programs and prioritize commercial buildings. Thank you for your conservation programs focused on upgrading existing systems, buildings and equipment. Please make sure these include gas to electrical conversion not just upgrades of existing electrical systems. Please continue to pursue transportation electrification programs. Thank you for providing solar net metering benefit, a loan program for residential customers, our community solar arrays and education. As we work to make electricity cheaper than gas, Clark PUD is well positioned to play a major role in the electrification needed.

Submitted on 7/20/2020 via IRP status page


Dear CPU Commissioners:

Thank you for allowing me to comment on the DRAFT IRP, addressing power resource development in Clark County from 2020 through 2040.

Having just the past week to read, digest, and respond to the IRP, I will
• expand on CPU’s energy resource planning history that has been omitted in the report;
• offer a Resource choice with RRGP; and
• refocus of Renewable Energy beyond 203..

My interest in the energy sector began in 1979. I finished college in 1981 and attended several of Clark PUD Board Meetings when WPPSS (Washington Public Power Supply System) was front page topic in Clark County and the Northwest. As I discovered, Commissioner Ralph Fisher represented the utility on the WPPSS Board. In fact, he was WPPSS Board Chairman! I attended one PUD meeting where he stated the nuclear plants overspending their budgets would be built no matter what (even though BPA did not guarantee power purchases as was the case for WPPSS 1). Well that didn’t happen and WPPSS became the largest public bankruptcy in American history.

Inside Section 4, Wholesale Supply-Side Resource Options Assessment, the PUD’s history is reviewed without mention of the WPPSS fiasco. Covered are a variety of topics including RRGP, Conservation and Renewable Assessments, and the Cost of Carbon.
Yet the IRP authors have omitted the PUD’s experience with the nuclear industry!

This topic may seem very old news (1983) but the IRP asks the Board to endorse joining a nuclear energy consortium, Small Modular Reactor (SMR). Perhaps you feel the SMR may produce carbonless energy in a decade or so, but why has the WPPSS history been omitted from this report? It seems to me that if the PUD cannot acknowledge and learn from the WPPSS experience its future relationship with the nuclear energy development cannot be trusted by CPU customers.

In addition, the report describes the operation of the RRGP as possibly ending in a decade due to CETA and the goal of being Carbon neutral by 2030. This appears to coincide with SMR development. The RRGP location is mentioned as a valuable site for a generation project, however the power source of generation is not mentioned. Yet if CPU endorses joining the SMR consortium, isn’t the Board considering building a small nuclear plant at the current RRGP location? If so, why isn’t this mentioned in the DRAFT IRP?

Add in the fact that the report does not endorse continued power purchases from the Columbia Hills Wind Farm after 2028, I don’t think this plan has not been flushed out adequately. With CETA also being considered, the fact is carbonless, renewable power will be at a premium through and beyond the next decade.

Other renewable energy projects may also be developed such as solar energy collected outside our biosphere. This concept may be a few decades away but the resource is endless and manageable. The Board needs to consider this and other potential renewable energy concepts.

Having read through the IRP my recommendation to the Board is to:

1- not join the SMR consortium unless CPU can Face Up to the WPPSS experience and risks involved with Nuclear Energy;
2- adopt the aggressive conservation alternative but with consideration of continued operation off RRGP through 2029; and
3- consider extending the Combine Hills project or other Renewable Energy project beyond 2029.


Good afternoon,

We truly appreciate the historical and thoughtful perspective provided in your comments. Please see the below response from staff:

You are correct that Clark Public Utilities was a member of the Washington Public Power Supply System more well-known as WPPSS, which was derisively pronounced “whoops”. In fact, Clark Public Utilities is still a member of Energy Northwest as it is known today. Of the 5 nuclear power plants on the drawing board in the late 70’s only one, WNP-2, now known as Columbia Generating Station made it to completion. It still generates power today. To say we don’t or cannot acknowledge our nuclear history simply because it was not included in the IRP is inaccurate. To this day, Clark Public Utilities still pays debt and interest on the remaining 4 nuclear plants that never made it to completion. The largest municipal bond default in history will never be forgotten and will always be a reminder of our inabilities to truly forecast the future and to the huge and costly errors that can happen under central planning and large-scale generation construction.

The idea that River Road Generating Plant would become a site for a small modular nuclear reactor (SMR) has never been recommended by or even considered by staff or management at Clark Public Utilities. Building a nuclear reactor in a populous area like the Portland/Vancouver area is a non-starter. The Trojan nuclear plant just downstream from RRPG and across the river in Oregon was not acceptable for many reasons, location being high on that list. Trojan is yet another example of the inability of planners and forecasters to “see” the future. Trojan was decommissioned after only 17 years of operations in 1993, just seven years before the west coast energy crisis, which was driven in large part by lack of alternative fuel power plants during a historically low run-off year. Trojan would have been a good GHG-free asset to have in the region during this time. Instead, diesel generators were commissioned and run to meet the generation deficiencies.

An SMR has basically one thing in common with the old large-scale nuclear power plants of the past and that is they are both fueled by nuclear elements. SMR’s are smaller, more flexible, and from their name, they are modular. The modules are 50 to 60 MW in size and can be added to and subtracted from the grid as needed. These attributes are exactly what will be needed to integrate more and more renewable power. Compared to the large-scale nuclear generating stations of the past in the 1100 MW range and binary in nature, SMRs are quite nimble. Nuclear waste management is an issue. Cost may be another issue. This is why the IRP is recommending that Clark Public Utilities consider joining a consortium or coalition of utilities to examine these challenges and to defray the costs. Of course, this type of scenario and path should raise eyebrows for those who remember or studied the WPPSS fiasco. Parallels between WPPSS and this consortium can be drawn. We appreciate your effort to remind us of the pitfalls of “groupthink” and the lessons that we can always learn from past efforts.

Clark Public Utilities is a long way from making any decisions about nuclear power and we will only do so after careful and very public consideration. The challenge ahead of us to be GHG-neutral by 2030 and serving all of our load with GHG-free resources by 2045 requires us to assess all the fuel-source options that meet that requirement, including the ones that, in the past, cost us so much money, time, and harm to the electric industry’s reputation.

Turning to Combine Hills II, our wind power purchase agreement that expires in 2029, we have assumed that the contract will not be renewed in the IRP. Much study and analyses will be made prior to making the decision to actually do so but even if Clark Public Utilities were willing to renew the contract, there is no guarantee that would happen. Under the terms of the contract, the buyer or seller can walk away from the agreement after the first 20 years. Plus, if the contract were to continue, a new price would be negotiated to reflect the current market at the time.

Right now, the best and least cost way to meet the CETA requirements in 2030 appear to be through increased purchases from Bonneville Power Administration. However, that is not guaranteed either and thus backup plans need to be ready to go, such as SMR, additional renewable, and perhaps some other fuel for RRGP such as hydrogen. The IRP points us in a direction with ideas and plans that are not guaranteed to come to fruition. As we have learned from the past, we cannot get locked into one mindset or one approach to solve our problems. Diversity, flexibility, and keeping options open as long as possible are very important attributes in meeting our goals.

Thanks again for the thoughtful and gentle reminder regarding the lessons we have learned.

Submitted on 8/18/2020 via CETA status page


Clean energy is paramount to any CPU plan. Climate change is real & everyone should be addressing it. I cannot think of any other issue with impacts for every person on the planet.

Submitted on 9/1/2020 via CETA status page


Here is my Public Comment at the Commission Meeting on 9/1/20:

My name is Cathryn Chudy and I am a longtime resident of Vancouver.

I appreciate Clark PUD for your willingness to hear feedback and to consider our input when it comes to your planning for Clean Energy Transformation Act compliance.

My understanding from your CETA explanation is that all electric utilities must prepare and publish a clean energy implementation plan with targets for energy efficiency and renewable energy in 2022. Meeting carbon standards for the lowest reasonable cost is the challenge facing us in transitioning to a carbon neutral electricity supply by 2030, as the law requires.

I believe that Clark PUD is on the right path in recognizing that we need to continue all efforts to assess ways to increase conservation and focus on renewable energy sources.

I am concerned that there is a temptation to consider the controversial assertion that somehow nuclear energy holds part of the answer to address climate change, and here in the Pacific Northwest the research and development of Small Modular Reactor designs has added to the temptation to see this as a viable path to pursue.

A review of different major SMR designs under development concludes that “ it seems none meets simultaneously the key challenges of costs, safety, waste, and proliferation facing nuclear power today and constraining its future growth. In most, if not all designs, it is likely that addressing one or more of these four problems will involve choices that make one or more of the other problems worse.”

Just this month NuScale, which is considered to be the frontrunner in SMR designs, encountered setbacks in Utah where its first municipal power customer pushed back the timeline for potential operating reactors until 2029 at the earliest, due to rapidly escalating construction costs and missed deadlines.
The Utah Taxpayers Association said the UAMPS project will lock in 27 municipalities in Utah and several surrounding states for a share of billions of dollars in costs associated with SMR’s.”

I know that Clark PUD is committed to considering cost and protecting its customers from taking on unnecessary risks, and I believe the truth behind the curtain is that the costs and risks of nuclear technology far outweigh potential benefits of an industry that has a long history of promising much and in the end not being able to deliver a cost effective, safe power source.

In essence, nuclear power DOES have a carbon footprint, plants take far too long to build, we cannot build enough plants in time to make a difference in addressing the urgency of climate change, the plants consume too much water, and ultimately government susidies for this industry deplete essential funding for the rapid deployment of proven, reliable and marketable renewable energy.

The pursuit of nuclear energy as a climate change solution ultimately inhibits the necessary rapid development of solutions that are effective, available, less expensive, safer and more environmentally acceptable.

Submitted on 9/11/2020 via CETA status page


Dear friends: I urge the PUD to step up the time table on CETA. As a doctor I see the human toll due to this latest round of forest fires and their smoke, plumes extending a 1000 miles and I am heart sick about the environmental devastation. Do we want to see fires descend on Vancouver too? We can’t act soon enough. Please take action now. 2045 is too slow and too late. Thank you

Submitted on 9/14/2020 via CETA status page


Northwest cities’ air quality ratings are the worst in the world now (see And rampant fires are a sign that climate change is catching up with us. Amid these developments, CETA is even more critical, as we need to work urgently toward a clean-energy future.

Submitted on 9/14/2020 via CETA status page


It is clear that the majority of citizens submitting comments to CETA and the IRP want CPU to more aggressively pursue renewable energy sources and make every effort to end or reduce dependence on burning fossil fuel at the RRGP. I agree. One way CPU could reach these goals sooner would be to retain more of the annual budget surplus to use for conservation incentives or other investments in renewable energy. Another avenue would be for CPU to more aggressively market all electric homes and commercial buildings for new construction (thus avoiding any claim of illegal fuel switching). CPU should encourage and subsidize commercial builders to use ground source heat pumps so the capital costs will eventually come down as more are installed. CPU could also engage in sponsoring all electric construction, as is done in some cities in Europe, and electrification of off shore ships and on-shore work at the Port of Vancouver. There are great opportunities to work with HP in the development of Block 30 and with New Blueprint Partners in the development of the former HP campus, both huge proposed developments that have the potential to be ZNE or, if not built with sustainability in mind, large GHG emitters. I encourage you to reach out to those developers and others to collaboratively achieve net zero construction and operation. Please be more positive and creative about ways to reach CETA’s requirements.

Submitted on 10/2/2020 via CETA status page


My name is Cathryn Chudy and this is my public comment at the Oct. 6 Commission meeting:

I provided comment at your meeting on September 1 expressing my concern about Clark PUD’s interest in considering nuclear energy as a viable path to pursue in meeting our energy needs going forward, specifically in the form of Small Modular Reactors that are being developed here in the Pacific Northwest and pursued under the guise that the technology is somehow cleaner and that benefits somehow outweigh the costs and risks.

The presentation by UAMPS at your power supply workshop on September 21 painted a rosy picture of the small modular reactor project promoted by Oregon-based Nuscale Power , but I would like to encourage you to look deeper, recognizing that due diligence requires an honest and thorough assessment of whether or not the claims offered by the proponents that are heavily invested in selling their project can withstand closer scrutiny.

Dr. M.V. Ramana, a leading world expert on small modular reactors, issued a report on September 2, 2020 that cited significant concerns including rising project costs, schedule delays, electricity cost compared to renewables, nuclear waste, regulatory uncertainty, funding issues and problems with Nuscale’s parent company. His report concludes that the municipalities’ investment in the NuScale SMR nuclear project is “simply not prudent.”

Dr. Ramana’s report, entitled “Eyes Wide Shut” can be found on the Oregon Physicians for Social Responsibility website: .

This report includes a statement by Dr. Edwin Lyman, Director of Nuclear Power Safety at the Union of Concerned Scientists, who points to serious design flaws that run contrary to the company’s claim that the reactor is “inherently and passively safe.” Dr. Lyman notes that “NuScale has aggressively sought exemptions from critical safety and security requirements to try to reduce the reactor’s high price tag. But as Dr. Ramana has demonstrated, cutting corners has only increased NuScale’s safety risk without making it affordable.”

The urgency of the climate emergency that we are in means that we cannot afford to flirt with investing in a risky and expensive “solution” whose commercial operation is at least a decade away.

Our state of Washington is on the right path with the Clean Energy Transformation Act, and as I said on Sept. 1, I believe Clark PUD will best serve it’s customers by resisting the siren call of the risk and cost-laden SMR proponents, and instead doubling down on conservation and using its resources to pursue truly clean and renewable energy sources going forward.

Additional links when considering the efficacy of SMR’s:

Submitted on 10/19/2020 via CETA status page


What is Clark PUD doing to promote Building Electrification?

According to new analysis from Rocky Mountain Institute, the cost of building all-electric homes was cheaper compared to building with gas. In Seattle, for example, an all-electric home would save $4,300 and 28 tons of CO2 emissions over a 15-year period. (See

Please prioritize and incentivize all-electric new construction in Vancouver. Consider working cooperatively with new projects, such as Vancouver Innovation Center ( at the former HP campus in East Vancouver.

Please use your influence to help move our city and state to a cleaner future by shifting to electricity and away from fossil fuels.

Submitted on 10/22/2020 via CETA status page


As Clark PUD considers future infrastructure, I would like to inquire about reducing light pollution.

This idea came to me after watching a program on bird migration. I am utterly amazed at how birds can travel thousands of miles — literally from one continent to another. But I am saddened to learn that birds’ ability to navigate is disturbed by city lights.

After a few Google searches, I realized that reducing light pollution can help humans as well as birds. For example:

– Bird-friendly LED street lights also reduce pollution, while saving energy and money.

– “Downlighting” and smart streetlights reduce bright glare for everyone.

– The technology has been applied in certain “Smart Cities,” and mandated through some city ordinances.

– Reference materials exist for bird-safe building guidelines as well.

Another innovation — while not helpful to birds — is turning light poles into EV charging stations.

With 21st century infrastructure developments, I hope we can reduce light pollution — for safer travel for birds and for improved livability for the rest of us.

Please advise how to carry this idea forward: Through Clark PUD? Through the Vancouver City Council? In cooperation with other organizations or builders?

Thank you.


Thank you for your question in regard to light pollution and what Clark Public Utilities is doing to address this problem. Here’s some pertinent information about the topic from one of our staff members that works in commercial lighting programs.

You are correct that street and exterior area lighting over time has created a significant problem with light pollution and light trespass. Traditional High Intensity Discharge (HID) lighting used for street and area lighting featured products that provide illumination by sending current to a gaseous arc tube encased in glass. The HID lamp is a radiant source, emitting light in all directions. High Intensity Discharge luminaires typically control the light emitted from the lamp through reflection or refraction. Though these methods helped reduce glare and trespass, they are far from perfect. It is not uncommon for a cobra head style light with a drop lens to create a glare zone of 90 degrees or more from nadir (the point directly below the light). Decorative HID lighting (street lights that have a gas lamp appearance) without an internal optical system can create a glare zone of 360 degrees.

In the past decade, street and area lighting utilizing Light Emitting Diode (LED) technology has slowly emerged as the preferred technology. LED street lights are a solid state lighting source that employ chips to provide light. Typically, LED chips are configured in an array designed to create a very specific and deliberate lighting pattern on the ground. This approach creates a tighter “cut” on both the front and back of the luminaire, greatly reducing light cast on houses, unintended spaces and the night sky. LED street lighting technology is the new construction standard for every municipality in Clark County.

I am happy to report that in addition to LED installations for new construction projects, every municipality in Clark County has engaged in large street lighting retrofit campaigns. Over the past five years, 31,494 HID street lights ranging from 100 – 400 watts have been converted to LED. Not only have these retrofits resulted in energy savings of over 60%, but they have also resulted in a significant reduction in light pollution and light trespass throughout Clark County. In addition, Clark Public Utilities has replaced over 2,500 HID flood lights and residential area lights with LED luminaires. Clark Public Utilities plans to remove all HID lighting from the system over the next several years.

Additionally, here are a few more resources for you that may be helpful in your efforts to carry your efforts forward:
• International Dark Sky Association:
• Illuminating Engineering Society (sets lighting standards):

Submitted on 11/3/2020 via CETA status page


I urge you invest more in efficiency and renewables, because our whole planet needs you to do that! Seriously!

Submitted on 11/3/2020 via CETA status page


I urge you invest more in efficiency and renewables, because credible climate scientists have warned us that we are running out of time to reduce our green-house gas emissions before our climate goes into chaos.

Thank you for listening to my comment.

Submitted on 11/3/2020 via CETA status page


The public will conserve if they are given more reasons to conserve. Please consider doing a public disclosure on the monthly bill to include three elements:
1. How much money we sent out of the country that month for fossil gas,
2. The greenhouse gas emissions associated with all of your burning of fossil fuels that month and add the caveat that it could be much higher depending on methane leaks prior to the burner tip.
3. The greenhouse gases emissions associated with that month’s use by each customer.

Submitted on 11/6/2020 via CETA status page


I urge you to invest more in efficiency and renewables, because our planet is dying. We all need to wake up!

Submitted on 11/6/2020 via CETA status page


I accept “Climate Change” as a fact. I urge you to commit to the goals of the Clean Energy Transformation Act because one day someone going to ask What did you do in light of the feedback loops that are already manifesting themselves.
Thank you.

Submitted on 11/6/2020 via CETA status page


I urge you invest more in efficiency and sustainable energy sources because global climate disruption is already here, costing billions of dollars in damage every year. Wind and solar are already proving to be less expensive than fossil fuel, and without the devastating pollution that accompanies oil, coal and gas.

Submitted on 11/6/2020 via CETA status page


The Pacific NW is a particularly unique environment in comparison to more populated states. Our energy grid was originally set up to run on water power. Using gas of any kind severely endangers the forests. I don’t think we need a reminder about forest fire conflagration after 2020 do we? All statewide PUDs should reject moving petro or natural gas into or through our area. We are all blessed to live here and we must replenish the earth in our little corner.

Submitted on 11/6/2020 via CETA status page


Climate change is real: I support the CETA commitment to transition to 100 percent clean electricity by 2045.

Submitted on 11/6/2020 via CETA status page


Renewables, in all forms, are the future. One proof is the fact the coal industry is still going downhill despite the best efforts of President Trump to revive it. All forms of renewable energy are now becoming more economical than fossil fuels. Solar power is rapidly becoming more appealing all the time due to its greater efficiency as research advances and thus becomes cheaper.

The greatest reason to embrace renewables is climate change. Each summer huge fires engulf large areas to our south. California had savage fires in the last two years and Oregon this summer had record fires too. We are next in line as climate change dries out our forests and we had bad fires this summer too. What will next summer bring?

To sum up, renewables will bring down the cost of electricity for both the utility and individual customers. Climate change with its increased CO2 and pollution will necessitate renewables or the fires will remove any need for electricity.

Submitted on 11/6/2020 via CETA status page


I fully support the transition to carbon free energy and I am wondering if anything is being done to encourage people to move away from wood burning stoves to heat their houses. Several of our neighbors heat with wood. Some stoves burn pretty cleanly, but some emit a lot of smoke. When you are walking in some neighborhoods, you hit a pocket of smoke that makes it difficult to breath. I have wondered many times if there couldn’t be some kind of encouragement to get them to make the transition to another source of heat, one that doesn’t emit smoke and dangerous particulates.

Submitted on 11/6/2020 via CETA status page


When we tried to buy a new home with electric heat here in Clark County, five years ago, all we could find were homes with natural gas heat and appliances. Clark County needs to reduce fossil fuel emissions and having all new homes with natural gas defeats that purpose. Back in the 1950’s in King County the PUD had a program for home buyers called “All Electric” which promoted electric heat and appliances for all new homes. I’m not sure but I think there was a bonus offered to builders when they built all electric homes. Builders today build natural gas homes because the cost is cheaper. Someone told me that this is illegal because it discriminates against natural gas. Is this true?
If this is true, there must be another way to promote electric homes. All the new homes with natural gas homes increase fossil fuel emissions. We only have 11 years to keep climate change from spiraling out of control. You need to promote green energy. Do you have a plan for reducing fossil fuel emissions within the housing industry? If not you need to do so right away. Surely if you put your heads together and sit down with the building industry you can come up with a plan. I realize the natural gas industry is very powerful and it will take courage and guts to stand up to them and do what is right for our county, nation, and the world. Do you have children, grandchildren? Their future is on the line. You need to develop a green energy plan for all new housing. You need to create a public interest brochure and persuade future buyers the importance of electric heat versus natural gas. Is stating the facts about climate change and fossil fuels illegal? Isn’t this considered free speech? If the people are informed they will demand that builders provide homes with electric heat. If you don’t like this suggestion then for heavens sake come up with another plan to end the building of homes with natural gas. You must stand up to the natural gas industry. Our children’s future is at stake.


Thank you for participating in the process and submitting this comment! Your comment has been received and shared with staff. Based on the content and subject matter of your comment we’d suggest this is a topic best addressed in an open public meeting such as our regularly scheduled Commission meetings rather than through this avenue. You can find more information about public meetings, including Commission meetings, on our website here:

Submitted on 11/13/2020 via CETA status page


Hello again. We heat our home with Daikin heat pumps, and their energy use ratings are so low that the electrician who installed them actually took a picture of the rating because he was shocked at how great it was. In addition, we use an induction stove in our kitchen which works instantly like a gas stove, is easier to clean, doesn’t have the massive wasted heat of a gas stove, and has no emissions (depending on if our solar panels, your hydro power, or your fracked gas is generating the electricity). There are fantastic ways for us to reduce our energy consumption at home that does not involve sacrifice. People just need to hear about it. Why don’t you have a big campaign about such things — maybe even have a reporter from the Columbian do an article monthly on ways to reduce energy usage and cutting ties to the fossil fuel industry?


Thanks for the comments – we really do appreciate your thoughts and time taken to engage regarding CETA.

You are very correct in your statement that there are many ways to reduce energy consumption that do not involve sacrifice and we currently utilize many different avenues to promote these types of opportunities. As you are probably aware, we do offer and promote several incentive programs around energy efficient home updates for things like heat pumps, weatherization, windows, water heaters, smart thermostats, etc. Along with that we’ve also been happy to implement several programs to reduce energy in homes at no cost at all for qualifying customers through things like our limited income smart thermostat program. Programs like these are promoted in many ways but notably during different times of year we things like billboards, digital and print ads in local publications, radio spots and TV commercials.

Past these larger ticket update items we also frequently promote “low cost/no cost” ways to save energy in several ways. Many of the mentioned outreach avenues listed above are employed and in addition, we actually do already have a weekly column in the Columbian called the Energy Adviser. This is a long standing partnership where we tackle many utility topics but much of the time it focuses on smart energy use. Here’s a search link to check out some of them from the last few years on the Columbian’s website:

Submitted on 11/13/2020 via CETA status page


Hi. I just looked at your going green section on this website under the EV section. As the owner of 2 EVs, I found this section to be totally lacking in information that would encourage people to buy EVs. Was it written by someone who doesn’t own EVs? I’m happy to help make it better.


Thank you for your comments and questions regarding the EV webpage on the Clark Public Utilities public website. The webpage was developed by utility staff from our Communications and Energy Resource departments with the goal of providing general information regarding EV’s and highlighting the economic and environmental benefits of switching to an EV. Our research on EV adoption found two of the foundational drivers for consumer EV adoption are one, the economic benefit in fuel costs savings, and two, the immediate carbon reduction switching to an EV provides. The website was built to highlight those two aspects through the “Fuel Comparison Calculator” and the Carbon Emissions comparison table between a gas powered vehicle and an EV.

We’d also like to take this opportunity to highlight the additional work Clark Public Utilities has done around EV and EV charging, we agree that the website does not tell the complete story. In 2019 the WA State Legislature passed a law that allows consumer owned utilities to develop Transportation Electrification (TE) Plans; this was a welcomed change because previously WA utilities faced legal constraints related to incentivizing any form of fuel switching. Since the statutory change Clark Public Utilities has been working to develop a comprehensive TE Plan that will allow us to begin incentivizing EV adoption and EV charging infrastructure. Staff presented a summary of concepts regarding our TE Plan to our Board of Commissioners recently and we have requested a 2021 TE Plan budget. If approved by our Board, staff can begin implementing the TE Plan and EV programs as soon as early 2021. The objectives of the draft TE Plan include increasing the adoption of EV’s in Clark County, increasing the EV charging infrastructure in our county, aligning programs with other state energy policies like CETA and reducing GHG emissions in our service territory. Staff is optimistic and excited to begin work on meeting these objectives next year.

We believe the future for EV adoption in Clark County is bright but also want to summarize the historical efforts that Clark Public Utilities has taken to get us to this place. Clark Public Utilities installed the first public EV charger in Clark County back in 2013 and have been working to promote EV’s ever since. Last summer we upgraded all public Level II chargers from our older Blink units to new ChargePoint connected chargers at both of our facilities. This upgrade provides a fleet of reliable public chargers and they boast the lowest kwh rate in our service territory. Additionally, during the fourth quarter of 2019 staff developed and submitted a grant application to the Department of Ecology related to the installation of two new ChargePoint Level III (DCFC) charging units to be sited at our downtown Vancouver headquarters. In early 2020 we were notified that Ecology had accepted our application for funding and we are currently working on the deployment of these new charging resources.

Clark Public Utilities has also worked hard over the last several years to promote EV adoption and benefits through community outreach and education. We are a member of the regional EV Trade Organization, Forth and each winter we partner with Forth, Portland General Electric and Pacific Power to highlight and promote EV’s at the annual Portland Auto Show. The effort includes the “Electric Avenue” display at the show, informational brochures and other marketing material strategically placed at the convention center. We’ve also found success in the past by partnering with Forth to provide free “EV Ride and Drive” opportunities at our annual Home and Garden Idea Fair. That effort has been an effective tool regarding consumer education on EV’s and provides an opportunity for our customers to experience driving an EV.

Additionally, Clark Public Utilities has been an active partner with Electrify America, the entity responsible for distributing the Volkswagen settlement funds and executing on the objectives for those funds. The Portland-metro area was a target area for the Phase 1 funding cycle and Clark Public Utilities is proud to report we were able to secure the siting of a Level III cluster site that includes six fast chargers in our service territory. We’ve also been working with a local school district that is adding electric school buses to their fleet in an effort to facilitate the charging infrastructure needs. Staff is working with the local trash collection company who is adding an electric dump truck to their fleet and in discussions with C-Tran as they look to electrify passenger buses. The TE Plan in development will address these custom type situations to ensure we are providing reasonable technical and financial support as more companies electrify their fleet of vehicles.

While our work to promote EV’s has been substantial, there is a lot more to do. We look forward to continuing this effort and providing low carbon electricity to fuel more and more of the transportation sector. Lastly, your question noted you may have some ideas related to the EV webpage for our consideration, please feel free to send those to Matt Babbitts in the Energy Resources Department; Matt can be reached at [email protected] and would be more than happy to discuss any ideas you have.

Submitted on 11/13/2020 via CETA status page


Hi. I support a rapid transition toward 100% sustainable energy. As I understand it, your primary use of fossil gas is in the summer months, when the river is lower. This also thankfully is at the time of year when the sun shines more and higher in the sky here in Clark County. Think of how many times you to to park your car in a massive parking lot at a mall or grocery store in the summer, wishing you could find some shade. Why not incentivize solar installations in parking areas that can partially shade cars? So often you see that trees can’t survive living in these parking areas with such constricted areas for their root zones. We should have lots of solar panels in these vast, open spaces which are also right next to large electricity users (think of all those refrigerators and freezer spaces at grocery stores). Or if not in the parking lots, why don’t you install community solar on top of such massive, flat roofs as are on grocery stores and school buildings?


Thank you for participating in the process and submitting your comments. Your comment has been received and shared with staff. Please see below for a detailed response to your comment.

As you are aware, the State of Washington passed the Clean Energy Transformation Act (CETA) last legislative year and the new law requires one hundred percent net-carbon free electricity by 2030. The statute goes further than that however, and requires one hundred percent absolute carbon free electricity by 2045. Clark Public Utilities has been a supporter of this effort and is already planning and working to comply with the new mandates. In order to meet the 2030 standard Clark Public Utilities will certainly need to adjust the existing resource mix that supplies our county with electricity and that effort will include the procurement of additional carbon free generation, likely to include hydro power, as well as, wind and solar renewable energy. The CETA statute also mandates that utilities meet the standards using the least cost approach.

Clark Public Utilities does own and operate a natural gas power plant that is located in Vancouver, Washington, the River Road Generating Plant. However, electricity generated at the plant serves our county around the calendar and not just in the summer months. That said, the plant does produce more electricity during the summer and winter months compared to the fall and spring months. There are several reasons for this including annual maintenance, seasonal demand for electricity and indeed the water levels and flow of the Columbia River that fuels the BPA hydro system. Each spring, in May and June, when the hydro system is producing high levels of power and the solar farms are also ramping up production, we purposely schedule the annual maintenance for the plant in an effort to use as much carbon free power as possible.

As we look to expand ownership of renewable resources in order to comply with CETA we must do so in the least cost manner. This is especially important as it relates to wind and solar generation; wind and solar are both carbon free but also intermittent in their generation of electricity. The intermittent nature of these resources requires siting them at the most beneficial location in order to capture the maximum generation capable of the resource. As an example, a solar array sited on the eastern side of WA produces nearly twice as much electricity annually compared to a solar array sited on the western side of WA. Further, a solar array sited in the desert SW of our country produces nearly twice as much electricity compared to an eastern WA sited project. The below sun-index graph illustrates the wide range of solar production by state:
















This is an important reality when looking to add new renewable resources into the Clark Public Utilities portfolio and because solar has a wide range of production capability depending on the geographic location it is unlikely that Clark Public Utilities would build or procure any large scale solar facilities within Clark County. We appreciate the availability of physical space within our county, as you eloquently described, but siting solar locally would not be a prudent investment and would not align with the least-cost mandate within CETA. As our industry works to integrate more and more intermittent renewable generation we are finding the most impactful strategy is expanding regional, organized energy markets. Regional markets allow utilities to invest in renewables where they produce the most power, and ensures the clean electricity will be used rather than curtailed due to low demand. As the market footprint expands we are able to capture additional diversity benefit in both generation profiles and load profiles, and that results with more clean electricity serving customer demand.

In closing, we would note that Clark Public Utilities is a strong supporter of solar technology and especially community solar projects; in 2015 Clark Public Utilities built and launched the second public utility community solar project and at the time it was the largest solar array in the State of Washington. Further, on two separate occasions the Clark Public Utilities Board has voluntarily increased the Net Metering threshold for our service territory. Additionally, our Board and senior leadership at Clark Public Utilities have instructed staff to identify any future community solar opportunities and during the times the State Legislature has considered new renewable incentive legislation, Clark Public Utilities has been supportive.

Submitted on 12/1/2020 via CETA status page


I was pleased to read that Clark PUD is encouraging solar panels for homeowners. Indeed, solar energy offers several advantages, as outlined in the Energy Adviser article in the Nov. 28 Columbian.

As an apartment dweller (and a renter) I wish I had some kind of solar option. In the past, I participated in the community solar project. I would certainly participate in a future solar project. I also wish I could use “clean” energy from the grid for my residential account.

Thank you in advance for information regarding any future solar options for apartment dwellers.


Thank you for your continued participation in the conversations and for taking the time to submit your questions regarding solar technology and future potential solar programs. Please see below for a response from staff.

Clark Public Utilities has long history of encouraging solar adoption in Clark County and we look forward to a future where solar plays an even bigger role in serving the energy needs of our community. As the public utility serving Clark County, one of the most impactful actions we can take to promote and encourage solar technology is offering the Net Metering billing methodology that provides the retail rate credit for each kWh generated by customer sited solar systems under 100 kW. Net Metering credits solar customers with the retail rate whether the energy is consumed onsite by the customer, or delivered back to the Clark Public Utilities grid, ensuring the customer is receiving the maximum value for each unit of energy generated by the solar panels.

The WA State legislature requires WA utilities to offer Net Metering up to a specific volume of solar systems installed and we’re proud to report our Board of Commissioners has increased the minimum limit twice over recent years as solar has become more popular and accessible. We currently have over 10,000 kW (kilowatts) of installed solar capacity in Clark County and with our increased limit we have headroom to facilitate almost triple the existing solar capacity. To add some perspective to that number, the entire Community Solar system located at our Operations Facility is 319 kW.

That Community Solar program, in which you are a participant, is another example of Clark Public Utilities commitment to solar technology. We are fortunate to have passionate customers like yourself that helped ensure the Community Solar project was a success. Along with dedicated customers, the WA State renewable energy incentive program was a big reason we were able to build and offer the Community Solar program. Currently all the state renewable energy programs are closed but our team here at Clark Public Utilities tracks energy legislation closely and if another opportunity for Community Solar arises we’ll be quick to move forward and inform our Board and leadership team. We certainly understand the options for renters and apartment dwellers to participate in solar programs are limited and we’ll keep that important point in mind as we look to develop future solar projects.

Additionally, the Clean Energy Transformation Act (CETA) requires all WA utilities to be 100% net-carbon-free by 2030. Historically, Clark Public Utilities has been around 65% carbon-free due to the clean hydro-electricity we receive from the Columbia River dams. As we work to achieve 100% net zero clean by 2030 staff is developing plans to integrate more solar and wind resources into our portfolio. Because solar panels only produce electricity when the sun is shining, and wind turbines only produce electricity when the wind is blowing, we’re fortunate to have access to the clean hydro-electricity from the Columbia River to balance out the intermittency of the renewable resource output.

Unfortunately, there is no practical way to direct only carbon-free clean electrons to specific customers, but you can take some relief in knowing the bulk of the electricity consumed in Clark County does come from a clean, non-emitting resource. And by 2030, because of CETA, the electricity consumed in Clark County will be 100% net-carbon-free.

Thank you for your message and feedback, we greatly appreciate it.

Submitted on 12/28/2020 via CETA status page


Are there times of the day when the grid is likely cleaner than others? I assume peak use hours are more likely to be dirty. I would like to program my electric car charger to activate when the energy mix is greener.


Thanks for participating in the process and submitting your comment. The short answer is you are correct. In the Pacific Northwest, on average the grid is at its “greenest” between the hours of 11 PM and 5 AM on a daily basis. On most days these hours would be the best to charge your vehicle to capture the “greenest” electrons.

For a little more context: This is due to the tendency of the wind generators to produce more at night than during the day. Also, on many days the hydro-generating system is producing more than necessary during these hours as the hydro plants are required to operate at minimum instantaneous flow levels. In addition to this, the 1,100 MegaWatt Columbia Generating Nuclear Station operates as a baseload plant 24 hours a day. Depending upon your definition of “green” this project could land in either category. It is greenhouse gas free but also has the other obvious environmental challenges. All this greenhouse gas free generation is typically more than enough to meet the lower electrical demands in these hours. So, additional load added during these hours has a much higher likelihood of being served by greenhouse gas free resources than any other hours during the day.

Thanks for the inquiry and let us know if you have any follow up questions or comments.

Submitted on 7/8/2020 via CETA status page


I’d be happy to pay higher rates in order to meet, or exceed the goals of climate neutrality set out by CETA. We were previous customers of PGE and we opted to pay a bit more each month to invest in renewables. I’d like to see a similar option in Clark County.

Submitted on 12/2/2021 via CETA status page


Please consider solar panel installations on the roofs of most schools. Also a pumped storage hydro generating plant to use solar and wind excess electricity. A similar plant is projected near Goldendale in the Columbia gorge. A smaller scale but still worthwhile system could be put in place in several spots in Clark county. Our difficulty will be when wind and solar aren’t contributing and to efficiently use surplus when it is available. Lastly combined agriculture solar projects can provide enough economic incentive for area small farmers to pursue the dual use strategy for their property given enough education and incentive. I would like to be involved in some supportive fashion to these efforts please contact me if you should need volunteers.