Why Utility Planning Must Be Inclusive

October 27, 2021
ALUC 15/PIXABAY
Joseph Daniel
Senior Energy Analyst

I grew up in Kansas during a time of change. When corn and soybean fields were being replaced by suburban sprawl. And now, some 20 years since I moved away, the landscape has continued to change, with thousands of wind turbines popping up across the state.

Those wind turbines represent significant economic development for Kansas in the form of new jobs and an important secondary source of income for farmers. It has also meant that the state has replaced dirty, expensive power sources with cleaner, more affordable ones.

Sadly, many state residents are still overburdened by pollution and high energy costs. That is why I was so excited when CleanAirNow, a Kansas City-based environmental justice group that advocates on behalf of the local communities, agreed to partner with UCS to try and improve the state’s energy planning. Link to our commments here. What I found was an unnatural disaster.

Engagement? Not even a mention

In 2018, Kansas’s two largest utility companies merged to form Evergy. As a condition of the merger, the state utility regulator, the Kansas Corporation Commission (KCC), ordered the company to file an integrated resource plan, or IRP. The IRP could have been an amazing opportunity for community engagement, but the utility took a different approach.

No doubt, the tone was set early on when the commission denied the Sierra Club’s request to help shape the IRP process, even though the Sierra Club and other groups were granted intervenor status once the IRP began. This initial exclusion was followed up by a total lack of proactive engagement by the utility to reach out to local organizations. Instead, the utility only engaged stakeholders that were also intervenors.

And that is a big problem.

Intervening takes resources. Time and money. It also takes skill and experience. That means the only type of people who tend to be able to engage in intervenor processes are, well, people like me: a professional advocate whose 9 to 5 job is to review utility filings, intervene in proceedings, and advocate for improvements. UCS has the resources to pay for local council. And we had the resources to pay for Synapse Energy Economics to conduct a review of the Evergy IRP (more on that later). But individuals don’t have the resources to do that.

If you are a working mom or a student with a full course load, how can you be expected to engage in this type of process?  

When the floor becomes the ceiling

Evergy seems to be fixated on a narrow scope for the IRP, where the commission’s minimum standards became the de facto maximum boundary. This was true when it came to the key metrics Evergy tracked in the IRP, the analysis the company did (or didn’t) conduct as part of the IRP, and any number of other components of the IRP.

The company’s decision to exclude anything that wasn’t explicitly required by the commission created a situation where the floor became the ceiling.

This type of handwringing is frustratingly common. The only good thing about it is that we know what the solution is: The commission should set the minimum standards to be the best practices. Or, at the very least, elevate the standards to be much much higher.

Already reversing course

What is perhaps most disturbing, and possibly unprecedented, is Evergy’s recent announcement to effectively revise the stated plan as identified in the IRP before the IRP process is even finished. As has been reported by others, Evergy has started backpedaling its plan to shut down coal and build renewables.  

Now, I have seen utilities make modifications during an IRP process (sometimes even in response to stakeholder input) and file an extension and revised plan. If the company wishes to make revisions to its resource plan, it should make those revisions in the IRP proceeding and include notice to all intervenors and the public at large.

But that isn’t what Evergy did.  

Instead, the company proposed these revisions in a separate proceeding. Which means intervenors in the IRP proceeding weren’t notified unless they were closely watching filings at the KCC. Plus, in this new proceeding, the company has proposed altering its plans arguably in the wrong direction. The plan in the IRP was to shut down a coal-fired power plant at Evergy’s Lawrence facility. In the revised plan, the company plans to burn natural gas at the plant once it stops burning coal. The original IRP plan also included a moderate build out of solar (700 megawatts (MW) over two years). Now the company plans to reduce that significantly (to less than 200 MW of solar).

All this at a time when natural gas prices are spiking. If anything, utilities like Evergy should be moving away from gas and doubling down on renewables.

All of this is a tacit admission by Evergy that the IRP plan is not a prudent course of action and raises serious questions about what actions the commission should take in response to the IRP filing. An IRP should represent the company’s most up-to-date resource plan and yet prior to this docket even being completed, the company has already suggested modifications to its plan. These revisions severely undermine the legitimacy of this and future IRPs and simultaneously erode trust with stakeholders.

A learning process

The Evergy Kansas IRP process was problematic. The approach the utility decided to take when it came to equity and inclusion was nonexistent. But, on a personal and professional note, that isn’t how UCS approached the process, and I was really glad to see that.

UCS’s energy team hasn’t really done any work in Kansas up to this point, so we were very glad to be able to work with CleanAirNow, given their local experience and expertise driving for people-driven solutions to improve public health. I’m really grateful that we worked with them because it helped shape the way we approached this IRP and will undoubtedly shape the way we engage in IRPs in the future. Evergy and the Kansas Corporate Commission should also be striving for an inclusive process, that doesn’t shut out important community voices in planning the state’s energy future.

Posted in: Climate Change, Energy

Tags: IRP, Kansas

About the author

More from Joseph

Joseph Daniel is a senior energy analyst and manager of electricity markets with the Climate & Energy program at the Union of Concerned Scientists. In his role, he serves as the primary point person for coordinating UCS’s utility regulatory work at state public utility commissions, independent system operators, and the federal energy regulatory commission.