The state’s largest electric cooperative Intermountain Rural Electric Association (IREA) issued a strongly worded repudiation of Xcel Energy’s proposed “Colorado Energy Plan Portfolio” (CEPP) in comments published last week on the Colorado Public Utilities Commissions Web site. In their 14-page comments on Xcel’s required 120 day report, the non-profit electric provider cites the Coalition of Ratepayers and our expert witness Charles Griffey numerous times. Including these quotes:
IREA agrees with the Coalition of Ratepayers that any projected NPV savings that are not modeled to occur until decades out and not until after the retirement of Comanche Units 1 and 2 are highly speculative….
Mr. Griffey has raised several unanswered questions concerning instances in which it appears the Company has either intentionally or unintentionally favored the Preferred CEPP in order to project illusory savings versus the Preferred ERP.
As one of the nation’s fastest growing electric cooperatives, IREA’s comments are important and, hopefully, highly influential with the PUC because it serves over 150,000 members across 11 Colorado counties. IREA also purchases power wholesale from Xcel and is a partial owner of Comanche 3, which will remain operating for now regardless of what happens with units 1 and 2.
IREA also calls out CEPP supporters build at any cost mentality while also acknowledging that if not for “certain parties” — the Coalition of Ratepayers — all Colorado ratepayers, not just Xcel ratepayers, would be paying hundreds of millions of dollars more.
However, the stipulating parties’ fixation on retiring 650 MW of economic coal generation a decade ahead of schedule and at any cost has been a deeply flawed proposal from the outset. If not for the advocacy of certain parties and the analysis of their respective experts, Colorado ratepayers would have certainly been on the hook for hundreds of millions of dollars in hidden deferred tax asset costs and unnecessarily re-purposed RESA funds. Accounting for these dollars demonstrates that the Company’s efforts to portray the Preferred CEPP as cost-effective lack merit. The CEPP requires ratepayers to pay a premium for renewable generation levels that significantly exceed already-satisfied Renewable Energy Standard levels and is based on a deeply flawed model that inaccurately projects cost savings decades from now. The record before the Commission does not support the early retirement of Comanche Units 1 and 2…
Where would those hundreds of millions of dollars have gone? Into the pockets of Xcel’s stockholders. The Colorado Energy Plan is nothing more than a redistribution of wealth from captive ratepayers to Xcel stockholders and executives. A more appropriate title is the Corporate Enrichment Plan.
Perhaps the most compelling comment from IREA is this short but pointed statement:
In sum, it is not in ratepayers’ best interest to be burdened with the risk of retiring economic coal generation a decade early based on speculative assumptions of cost-savings that will only occur well after the units’ scheduled retirement.
We thank IREA for recognizing that.