Tri-State Generation and Transmission Association is considering undertaking the Southern Colorado Transmission Improvements Project as a stand alone endeavor. They initiated a short public comment period ending May 11th. Below is the Renewable Communities Alliance's comment submitted on behalf of our members and affiliates......
The Renewable Communities Alliance is pleased that TriState is seeking input from the public on alternatives to address reliability concerns in the San Luis Valley. As a haven of renewable energy innovation, we believe the valley has the potential to become a model for the nation as we enter a new era of decentralized energy generation 1, 2, 3.
The remoteness of the San Luis Valley is at once a challenge and an opportunity. For the past 75 years we've relied on electricity generated from remote fossil fuel power plants and imported over an extensive long distance transmission infrastructure. New technologies, energy markets and the need to reduce greenhouse gas emissions are moving us rapidly towards a decentralized, local renewable energy based future.
This is good news for the San Luis Valley, as we are blessed with an abundance of diverse renewable
energy resources. Our research indicates that the valley has the potential to approach 100% energy
self-sufficiency through the strategic application of energy efficiency
and demand management technologies, local distributed renewable generation coupled with new cost-effective storage and carefully planned smart grid upgrades to the existing transmission infrastructure.
An added advantage is the maximization of local renewable energy economic development opportunities that will truly renew our SLV communities. Such an approach is aligned with the local, not-for-profit, consumer-owned, democratically governed, community friendly values of TriState.
EFFICIENCY and DEMAND MANAGEMENT
Currently, the SLV is at risk of blackout when demand is above the 60 MW red line represented on the above graph. To reduce and level out demand curves, TriState/SLVREC should prioritize energy efficiency and demand management options, including:
1) Improving Energy Efficiency. Providing on-bill financing for home and farm energy audits and energy efficiency improvements that reduce energy demand through improved irrigation, soil moisture management, optimal pump sizing, use of low pressure sprinkler systems, premium efficiency pump motors, improving warehouse refrigeration efficiency and other measures that collectively, could reduce peak demand by as much as 30-40%.
2) Cycle irrigation load. Farming is an adaptable business capable of responding robustly to economic incentives. Providing meaningful incentive payments to irrigators to turn pumps on and off for brief (1-2 hour) periods on a coordinated rotation cycle could easily reduce peak summer pumping loads by 10-20 MW.
More than 80% of electricity demand in the San Luis Valley is from irrigation agriculture. The pilot Energy Efficiency Assessments in Agriculture (E2A2) funded by a grant from the Colorado Department of Agriculture’s Advancing Colorado's Renewable Energy (ACRE) grant program should be adopted as a model for farm efficiency programs. The U.S. EPA AgStar Program and USDA Rural Energy for America Program (REAP) have also offered resources for improving farm energy use.
Combined, EE and demand management measures could rapidly and cost effectively reduce peak load requirements and immediately reduce the risk of blackouts in the event of a transmission line failure.
STORAGE and GENERATION
We encourage TriState to embrace a local, renewable energy future for the SLV through the following measures:
1) Diversifying existing gas turbine generation. Combined cycle conversion of the two
existing dual-fuel combustion turbines near Alamosa and increasing the fuel oil
storage capacity would provide a local reliable primary baseload power source until additional renewable generation and large and small capacity storage systems could be implemented.
2) Local generation. The San Luis Valley has the potential to generate 100% of its energy needs from local renewable energy sources. Local solar PV sources have already improved energy reliability through the combined generation of 85.22 MW (8.2 MW SunEdison, 30 MW Iberdrola, 17 MW Greater Sand Hill and 30 MW Cogentrix) that meet 100% of the San Luis Valley's average daily electricity needs. There have been few integration problems even with this high percentage of solar.
We would like to see TriState build on this trend by supporting the development of even more widely distributed solar PV generation (on farm crop circle corners throughout the SLV, for example) and integration of base load renewables like small hydroelectric, geothermal, and biomass generation.
3) Storage. 10 MW sodium sulfur or zinc bromide flow batteries can be located at the Cogentrix, SunEdison, Iberdrola and SunPower solar PV facilities to effectively counter potential single large cloud shut downs and provide post sunset energy if needed. Additional small scale 25kWh Community Energy Storage units could be clustered in outlying communities. The addition of residential and agricultural warehouse thermal
storage technologies could further reduce night-time base load demand.
FINANCING, LOCAL ECONOMIC DEVELOPMENT and RATEPAYER IMPACTS
Despite widespread interest, access to financing is a major limitation to the adoption of efficiency measures and local renewable generation. TriState and SLVREC should seriously consider implementation of an on-bill financing program and extension of renewable energy power purchase agreement options to all interested members equitably, be they large or small.
The widespread adoption of efficiency and local, renewable energy generation measures will result in a more robust, resilient and reliable energy system. Opening up local RE markets could also create an unprecedented economic development opportunity for the San Luis Valley (see chart below).
Such a program would generate a multitude of quality local jobs and put energy revenues into the pockets of SLVREC members and owners instead of absentee corporate owners of utility and industrial scale facilities.
By eliminating the need for a costly new transmission line and additional remote generation (from the proposed Holcomb coal-fired generation plant, for example) these programs will more than pay for themselves. Such an approach is in keeping with TriState and SLVREC's goals of minimizing rate increases to its members.
In closing, we request that TriState include a local efficiency, demand management and distributed generation alternative in its analysis to address reliability concerns in the San Luis Valley. We would like to see a detailed comparison of the long term impacts on residential and commercial rate-payers of all alternatives presented in the draft and final reports.
1. John Farrell, Democratizing the Electricity System - A Vision for the 21st Century Grid, 2011, http://www.ilsr.org/democratizing-electricity-system-vision-21st-century-grid/
2. Amory Lovins, Small is Profitable: The Hidden Economic Benefits of Making Electrical Resources the Right Size, 2002, http://www.rmi.org/Knowledge-Center/Library/U02-09_SmallIsProfitableBook
3. Jeremy Rifkin, The Third Industrial Revolution: How Lateral Power is Transforming Energy, the Economy, and the World, 2011, http://www.thethirdindustrialrevolution.com/