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New IRP rules streamline process, encourage sharingIn the first update of its integrated resource planning (IRP) rules since 2000, Western is implementing three proposed revisions. Western's decision follows a public process that began with the publishing of a Federal Register Notice on Aug. 21, 2007. The changes are:
The Energy Policy Act of 1992 requires Western's firm power customers to submit an integrated resource plan to Western every five years and provide annual updates, forecasting their future electric power demand and thoroughly evaluating ways to meet it. The program is designed to extend Western's existing firm power resource commitments, and to promote energy diversity and efficient practices. "The IRP is also a tool to help utilities determine the most cost-effective measures and resources for serving their customers," explained Energy Services Manager Ron Horstman, who led the review process. "It's important that IRP requirements reflect changes in resource options, technology, environmental issues and more that have occurred in the industry." "Our goal was to make it easier for our customers to address emerging trends and shifting conditions in their IRPs," said Western Administrator Tim Meeks. "We believe these revisions to the rules will help make the planning process more effective and efficient." Dialogue with customersBuilding a better planning process required input from those who will be using it. A 90-day public comment period, from Aug. 21 to Nov. 19, 2007, gave customers and other interested parties the opportunity to weigh in on the proposed changes. At a public forum Western held in Denver Sept. 6, about 20 people attended including representatives from Platte River Power Authority and the Colorado Association of Municipal Utilities who provided comments for the record. Western also received written comments from Colorado River Energy Distributors Association, Delta-Montrose Electric Association, Irrigation & Electrical Districts Association of Arizona, Kansas Electric Power Cooperative, Platte River, Salt River Project, Tri-State Generation and Transmission Association, Utah Associated Municipal Power Systems, Utah Municipal Power Agency and Arizona Municipal Power Users' Association. "The public participation period is not just about complying with Federal law," said Horstman, "For Western, it's about listening to our customers' concerns and looking for the best way to balance customer needs with the law requiring them to do IRPs." Speeding up approvalSimplifying processes is a need that many an overstretched public utility employee can agree on. The first change, eliminating the need for all members of an MBA to approve the MBA's IRP, is intended to provide some relief. Under the new rule, the IRP only needs the approval of the governing body of an MBA, which represents the interests of each member. "That requirement tended to bog down the approval process for MBAs with large, diverse memberships," Horstman acknowledged. "Getting all members to agree and sign the plan could take up to a year. By that time, the issues changed." This revision will significantly shorten the IRP approval process, ensuring that the IRP is relevant for the period it covers. "This is a valid concern as conditions change quickly in the energy industry," said Horstman. Small customers will continue to have as strong a voice in their MBA's plan as they always have. The revision will put greater emphasis on the public participation process, observed Horstman. "That's the main forum where members can present their concerns." Member utilities also have the option of creating their own IRPs tailored to their unique circumstances. This could reduce the workload for members that actively participate in developing their MBA's plan, because individual power providers may qualify for one of the other IRP options such as the small customer plan, the minimum investment report or the energy efficiency/renewable energy report. "And the utility will have the opportunity to get a real handle on its needs," added Horstman. Encouraging regional planningThe second rule adds a paragraph to IRP regulations to encourage utilities, both Western customers and non-customers, to work together on regional IRPs. This is a clarification, rather than a change, to the current IRP requirements. Utilities have never had to be part of an MBA, or even a Western customer, to be included in a regional IRP submitted by Western customers. "Most IRPs have not typically considered regional issues," Horstman said, "which is a shame because coordinated efforts can often yield greater benefits than individual, piecemeal measures achieve." Cooperation among regional utilities is a natural, Horstman asserted, since they often share conditions that affect demand, such as customer demographics, climate and local economy. The hope is that the new language will open the door to more utilities collaborating on regional plans that include both supply-side and demand-side activities. Wind farm development and expanding the transmission system are examples of projects where several neighboring utilities could share the risk, work and rewards. "They could team up on the required environmental clearances, testing and permitting, and the whole region would benefit from the jobs, clean power and stable energy costs," said Horstman. Same rule, new mediaThe third change to IRP requirements allows Western to post current customer IRPs on its Web site so the plans are readily available to the public. This rule received the most comments of all the proposals; understandable since security and protecting confidential information are growing concerns in the utility industry. Customers may request that confidential commercial and financial information not be disclosed when they file their IRPs. If Western agrees that the information is exempt from disclosure under the Freedom of Information Act (FOIA), those sections would be deleted from the plan before it is posted on the Western Web site. Horstman pointed out that, under FOIA, Western has always had the right to determine what can be deleted from IRPs. "The law requires the IRP process—and all changes to a plan—to be open to full public participation. That's nothing new," he said. What is new for Western is making IRPs available to the public through the Internet. Responding to customer comments, Western modified the original proposal to give customers a choice. The customer may post its IRP on its own site, and Western's site will link to the plan. Alternatively, if the customer chooses not to post its IRP on its own Web site, Western will post the IRP on its Web site. Interested parties may also submit a FOIA request to Western to obtain a copy of the IRP. Western shares customer concerns about preserving confidential information in IRPs filed with the agency. "Western, consistent with existing rules, will continue to seek our customers' views on whether information in an IRP is exempt from disclosure under FOIA," said Western Attorney Advisor John Kral. More sharing, better planningThis new rule has the potential to create a valuable reference for customers developing IRPs. "Customers will be able to look up similar utilities and see what programs and measures worked for them," said Horstman. "It could even facilitate regional collaborations or other types of partnerships." Sharing information: It's how Western and Energy Services help customers manage their power resources more effectively. In return, customer input helps us shape the rules that ensure that Western continues to provide low-cost, reliable electricity. We thank everyone who contributed comments. If you have further questions about the revisions, contact Ron Horstman at 720-962-7419.
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Previous issues
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ResourcesColorado Association of Municipal Utilities Public comments on proposed IRP changes |
Resources (cont.)Kansas Electric Power Cooperative Tri-State Generation and Transmission Association Utah Associated Municipal Power Systems |
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