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In September, Kansas’ largest electric utility walked back an earlier announcement that it would close a Lawrence coal plant by 2023 and build 700 megawatts of solar capacity by 2024.
The utility, Evergy, is now proposing to keep one unit of the power plant open as a natural gas peaker, while scaling back its solar plans.
Clean energy advocates say the move undermines faith in a state-required stakeholder process known as an integrated resource plan, or IRP. The IRP isn’t binding, and Evergy says the shift represents a change in timeframe rather than ambition.
But advocates say what’s unique about this case is the utility is already departing from its IRP before it’s even been signed off on by state regulators.
‘Wrong as soon as it is finished’
Joe Daniel, a senior energy analyst with the Union of Concerned Scientists who has testified about numerous integrated resource plans — including this one — said utilities not uncommonly seek to modify their resource plans in midstream, and for good reason. These proceedings can take a long time, and pertinent factors, such as the price of natural gas or state or federal regulations, can change.
“What I’ve never seen is a utility opening a new docket while their integrated resource plan is underway, and asking for approval of the resource plan in the other docket,” he said. In so doing, he wrote in testimony filed with regulators, Evergy “severely undermines the legitimacy of this IRP and erodes trust with stakeholders. … The Commission should reject the current IRP and order the company to restart the IRP process, including stakeholder engagement.”
The Kansas Corporation Commission has not yet responded to that request.
Evergy spokesperson Gina Penzig said the company decided it needed to postpone some solar projects because some of them “are less mature in their development and lacked clear cost and timing aspects related to land control and interconnection of the solar generation to the transmission system.
“In addition, the solar supply chain faces some unique constraints.”
By 2032, the revised plan for adding renewables and closing coal-fired plants “will be in line with what was proposed in the IRP,” she said, although the transition will be slower.
Integrated resource planning is by nature “dynamic,” said Linda Berry, a spokesperson for the Kansas Corporation Commission. And due to changes in technology, the marketplace and other factors, an IRP “will be wrong as soon as it is finished. This is why there is an annual review for two years and a completely new IRP modeling process every third year.”
‘Finite resources’ to scrutinize utilities
The difference between Evergy’s resource plan, filed on May 28, and the requests made in the “predetermination” docket, opened on Sept. 20, provoked an outcry among clean energy proponents.
Ty Gorman, Sierra Club’s Beyond Coal representative in Kansas, pointed to an absence of new evidence or analysis proving that maintaining one unit of the Lawrence plant to burn natural gas would be instrumental in the event of another storm like the one in February.
The resource plan envisions closing both units of the 487-megawatt coal-fired Lawrence Energy Center by 2023. The revised plan filed in September backs off from that and proposes closing only one unit, and operating the second unit occasionally using natural gas.
The renewables vision also was overhauled. While the integrated resource plan proposed adding 350 MW of solar in 2023 and again in 2024, the predetermination docket — which gives a utility a sense of whether it can charge ratepayers for a given expenditure — shrank the 2023 vision to 190 MW and postponed the second 350 MW piece until 2026.
Gorman said the predetermination docket’s revamped vision upended stakeholders’ role in the resource planning process, which Berry called “the primary value of an IRP. … It allows stakeholders a voice in what capital resource investments should be considered prior to the actual investments.”
Daniel said a predetermination docket “doesn’t have the type of stakeholder engagement that an IRP typically does.” Compared to an integrated resource plan, he said, it is likely to be every bit as — if not more — “opaque to the public.”
Before stakeholder feedback was incorporated into the IRP process, Gorman said, Evergy crafted its revised vision “and changed what they had shared with intervenors. They went around the IRP process to make their energy plan.”
The integrated resource plan is a complex document that stakeholders invest in heavily, often paying consultants to scrutinize models and the assumptions that underlie them, for example. Critics of the plan typically represent entities that depend on donations, like the Sierra Club and the Kansas Climate & Energy Project.
While advocates can also intervene in the predetermination docket, the Sierra Club, the Union of Concerned Scientists and the Kansas Climate & Energy Project have not asked permission to do so. Daniel said the Union of Concerned Scientists is still considering whether to invest time and money to try to shape the revised proposal in the predetermination docket. All three filed extensive comments about the integrated resource plan.
“We all spent money on lawyers, technical expertise and analysis,” Daniel said. “People have finite resources. The utility essentially uses ratepayer funds for all of their analysis. They can do all the analysis they want and ratepayers pay for it.”
Analysis is off the table for now. On Oct. 26, Evergy asked regulators to temporarily suspend the predetermination docket “to allow more time to develop some additional information necessary for the evaluation of its predetermination filing.”
On Nov. 2, commissioners granted the request.