SEACC submits comments on the Draft Integrated (Energy) Resource Plan for Southeast Alaska
Below is a highly condensed version of SEACC's comments submitted to the Alaska Energy Authority on the Draft Integrated Resource Plan for Southeast Alaska.
Attachments (solar energy, Kake wind)
SEACC supports the following aspects of the Southeast Integrated Resource Plan:
On-going regional energy planning efforts every 3-5 years.
Aggressive investments in energy efficiency and demand side management measures, and the development of a regional entity to assist with implementation.
The development of all the committed resources identified under the plan.
The prioritization of local energy projects that serve local needs over export related energy development.
The development of reliable and local renewable energy projects.
The integration of some biomass to meet regional heating loads. (discussed further below).
An energy portfolio that protects rate payers from uncertainties associated with mining and other speculative industries. The screened hydro list and reference load forecast highlight the uncertainties surrounding the permitting, timing and life of mines. We believe that this is reasonable approach that largely alleviates risk to rate payers. Mines generally don’t sign long term power sales agreements, and without these agreements other ratepayers would be forced to foot the bill for hydro and other projects built for a mine that fails.
Concerns and Recommendations:
The plan recommends very few energy efficiency and demand side management measures for rural areas
As previously stated, we fully support an aggressive investment in energy efficiency and demand side management measures in Southeast Alaska. Over the next three years, the SEIRP recommends that the region invest a total of $1,622,900 million on program implementation. However, of this investment only $13,300 dollars or less than 1% is recommended to increase efficiency in the region’s highest energy cost areas. (1.55-1.57)
Run the energy efficiencies measures that passed the Total Resource screening under a new model to determine the impacts on regional DSM/EE investment and/or programs in rural areas.
In recognizing the inherent challenges facing rural utilities, we request that the plan provide further guidance on potential actions that can be undertaken by the state to address the high non-fuel costs of rural utilities and ways to minimize concerns about inequities between participants and non-participants under the RIM test scenario. In particular, we feel that the avoided costs to the Power Cost Equalization program could be used to incentivize efficiency measures by shifting funding to offset more non-fuel utility costs.
Non- hydro renewables, particularly from solar should be evaluated more closely in the plan
The SEIRP very briefly addresses solar energy and concludes that it should not be used in meeting near-term energy needs of Southeast Alaska (11.9) This conclusion is largely based on its application in hydro-sourced towns and fails to evaluate its potential in areas with high cost diesel generated electricity.
SEACC recently completed a performance evaluation of a small residential solar application in Angoon that we have included with our comments. In our evaluation we found that the combination of relatively low residential loads (the typical rural customer in Southeast uses less than half the electricity as the non-rural customer) and very high electricity costs resulted in a significant offset of the household’s annual diesel generated electricity (30%), and a relatively short payback period (10 years).
The state should continue to study solar as a viable near term and interim way to offset diesel consumption in rural communities.
We also recognize that non-hydro renewable energy integration may pose unique economic challenges to rural utilities that need to be addressed. In particular, under the current Power Cost Equalization structure, rural utilities that add renewable power may not get the full economic benefit —because when they reduce the price of electricity by reducing their fuel use, they lose part of their PCE subsidy and also may also increase their operating costs. The SEIRP should include recommendations that the PCE program be analyzed to incentivize renewable energy production.
We request that section 11.2.2 be updated to include the refined results of wind data collected over an eighteen month period in Kake, represented in a recently completed wind resource report. The final data indicate that the site has excellent, Class 5 winds with an annual net capacity factor of about 44.1%.
The plan relies on a single source to address the region’s heating needs and fails to offer a comprehensive evaluation of other efficient technologies, such as ground and air source heat pumps
We believe that the SEIRP exaggerates the potential impacts of the Roadless Rule on energy related development in the Tongass. This is represented by various sections of the plan that possess either incomplete background information or unsupported statements regarding impacts of the rule.
Fisheries Impacts of Storage Hydroelectric Projects must be acknowledged in Generic Storage Discussion and Recommendations.
Despite its limitations, we are optimistic that the revised draft will provide a solid foundation that will help Southeast Alaskans begin to address high energy costs by guiding us to use energy more wisely and identifying cost-effective local renewable energy projects. We appreciate the opportunity to provide comments and look forward to continuing to work with the state and other regional partners on future planning efforts.
As a region, it is imperative that we set aside our differences and focus our attention on a common vision for our energy future. The list of committed hydro and transmission projects, identified energy efficiency and DSM opportunities, space heating improvements, and additional new hydro and other renewable projects are a good start to this common vision.