Summation of the Intervener Testimony

For all the testimony, it boils down to a couple of issues.

There’s a lot to unwind in all of the testimony. You can ask three experts to sum it up and you’ll get three significantly different summations. So I threw this at all of the A.I.s and two of them gave what I think are the best summations. So here’s both.

Summary of Major Topics Discussed (notebooklm)

Several major topics are discussed across the testimonies provided:

• Just Transition Solicitation (JTS) Process: The core subject of the proceeding is PSCo's 2024 JTS, intended to frame objectives and advance a just transition. Staff recommends improving the JTS through a two-stage Request for Proposals (RFP) process (Phase 2A and 2B) to enhance procurement flexibility, primarily driven by uncertainties from rising electricity demand due to electrification and artificial intelligence. CC4CA's purpose in testifying is to advocate for maximizing clean energy acquisition within the JTS. CEO presents general recommendations regarding the JTS application.

• Load Forecasting: A significant area of discussion is PSCo's methodology and results for forecasting electricity demand, especially concerning large loads. UCA responds to PSCo's large load forecast, raises concerns about PSCo's modeling assumptions, and specifically recommends that PSCo develop two distinct load forecasts: one standard and one specifically for data centers and other high-density loads. The Conservation Coalition (Derek Stenclik) concludes that PSCo's base load forecast does not sufficiently account for large loads. CEO (Keith M. Hay) discusses load forecasts, noting they account for Pueblo Unit 3 replacement capacity, and provides a comparison highlighting the impact of large loads with different probabilities of connection. PSCo witnesses themselves present details on the "Lower-Low" forecast and load forecasting methodologies. Staff (Dr. Dipesh Dipu) expresses cautious optimism in PSCo's demand assessment. WRA/SWEEP (Alissa Burger) analyze PSCo's forecasts and sponsor a whitepaper on large load forecasting practices. There is broad disagreement regarding the adequacy and methodology of PSCo's load forecasting, particularly for large loads.

• Transmission Planning and Capacity: PSCo discusses considering locational needs for planning and engaging with interregional developers. Kenneth Wilson (CEI) argues that PSCo has not effectively addressed the transmission needed to serve projected load, particularly for SE Colorado wind and solar resources. WRA/SWEEP witnesses (Jorge Camacho, Christine V. Brinker) recommend specific transmission upgrades (May Valley–Longhorn 345 kV Extension, New 230 kV Double Circuit Line from Harvest Mile to Cherokee, Chambers Transformer #3 addition) as "no-regrets" investments needed for reliability and renewable integration, advocating they proceed quickly. UCA recommends disclosing transmission availability assumptions and performing sensitivity tests. CCSA recommends approving specific transmission adder/credit values. There appears to be agreement on the importance of transmission planning, but disagreement on whether PSCo's current plan adequately addresses the needs, especially concerning renewable integration and future load growth.

• Distribution Planning and Capacity: PSCo discusses Distribution Capacity Procurement (DCP). CCSA focuses on ensuring equitable opportunities for distribution-connected resources in the JTS, including standalone storage, and recommends approving distribution credit values and determining a procedural pathway for dispatchable distribution-connected resources. Jon Landrum (PSCo) addresses soliciting bids for distribution-connected battery storage. This suggests a focus on better integrating smaller, localized resources into the grid.

• Battery Capacity: Battery storage is discussed in the context of being a dispatchable distribution-connected resource for which bids should be solicited. It is also discussed as a component of renewable energy parks (both short-duration and long-duration storage), needed to support the grid by storing excess renewable energy. Standalone storage is mentioned as a type of distributed resource, and concerns about the Model Standalone Storage PPA are raised. Availability and prices of battery storage in other jurisdictions are also discussed. There is agreement on the relevance of battery storage, particularly for distribution interconnection and integrating renewables.

• Specific Technologies & Environmental/Health Impacts:

  • Wind and Solar: Strongly supported by CRES (for low-cost integration and utilizing flexible load), EJC (as part of renewable energy parks for just transition), and CEI (representing the solar industry). Transmission needs for SE Colorado wind/solar are highlighted. Transmission upgrades are recommended to integrate renewables. Opposition is specifically noted by EJC/David Schlissel against penalizing solar resources near Pueblo.

  • Methane Gas, Hydrogen, CCS: Opposed by EJC and PSR Colorado as replacements for coal or under the CFFD program. Reasons cited include being costly, speculative, posing pollution/health/safety risks, and being contrary to a just transition.

  • Nuclear: See dedicated summary below.

  • Health Impacts: PSR Colorado and EJC emphasize the need to consider the health impacts of fossil fuel generation and critique technologies posing pollution/health/safety risks. There is agreement from these parties that health impacts are a critical consideration, especially for communities transitioning away from fossil fuels.

• Community Impacts & Just Transition: Moffat County and Routt County governments provide background on local impacts of coal plant closures and efforts for economic development and new energy projects. EJC focuses on impacts in Pueblo/Colorado Springs and advocates for a renewable energy park as a beneficial just transition alternative. The concept of a "just transition" itself is framed within the JTS objectives. There is agreement on the importance of considering community impacts and advancing a just transition, particularly for areas historically reliant on coal.

• RFP and Contract Process: Irion Sanger recommends changes to the draft RFP, PPAs, and BTAs for fairness, transparency, and competitiveness. John Pierce raises concerns about specific PPA documents for renewable and storage technologies. J. Scott Sturm discusses the conforming bid policy and re-contracting existing resources. Staff recommends a two-stage RFP for flexibility.

Summary on Nuclear Power

Based on the provided sources, the testimony regarding nuclear power (including SMRs and AP-1000/APR-1400) is consistently negative:

• The Environmental Justice Coalition (EJC) explicitly opposes replacing the Pueblo coal plant with a nuclear generator. David Schlissel, testifying for the EJC, reiterates this opposition. He finds PSCo's proposal to spend funding through its Carbon Free Future Development (CFFD) policy on "costly and speculative technologies" like nuclear would impose pollution and public health and safety risks on nearby communities, in addition to being very expensive burdens for ratepayers.

• PSR Colorado (Physicians for Social Responsibility) also explicitly opposes exploring the use of nuclear reactors in the context of the Carbon Free Future Development (CFFD) program. While specific reasons like cost or safety are not detailed in the snippet from this testimony regarding nuclear, the opposition is framed within the context of strategies contrary to a just transition and general concerns about the health impacts of energy generation discussed in her testimony.

The terms "SMRs" (Small Modular Reactors), "AP-1000", or "APR-1400" are not explicitly named in the provided text, but the opposition is directed at "nuclear generator" and "nuclear reactors". Given that SMRs and AP-1000/APR-1400 are types of nuclear reactors and generators, this opposition encompasses these technologies. There are no testimonials in the provided sources expressing support for nuclear power in this proceeding. The range of opinions presented is limited to opposition based on concerns about cost, speculative nature, pollution, public health and safety risks, and alignment with a just transition.

Major Topics Summary (Grok)

1. Issues and Suggestions on Data Centers:

   • Agreement: Most commenters (e.g., Landrum, Bailey, OUCA) acknowledge data centers as a significant driver of load growth, necessitating new capacity and infrastructure. PSCo’s Base Case forecast incorporates large customer loads, including data centers, as a key planning factor.

   • Disagreement: OUCA and WRA express concerns about rate impacts from data center-driven infrastructure costs, urging cost allocation to large customers rather than residential ratepayers. PIESAC suggests SMRs to meet data center demand reliably, while Sierra Club prefers renewables. Bailey (PSCo) proposes strategic load growth to support economic development, but OUCA seeks stricter cost controls.

2. Issues and Suggestions on Moving to All Electric (Heat Pumps, Electric Vehicles, etc.):

   • Agreement: Commenters (e.g., Ihle, Sierra Club, WRA) support electrification to reduce emissions, with PSCo’s forecast including EV and heat pump adoption. Goodenough (PSCo) notes updated methodologies to account for electrification-driven demand.

   • Disagreement: OUCA and Sierra Club highlight affordability challenges, with OUCA advocating for rate protections and Sierra Club urging incentives for low-income households. PSCo witnesses (e.g., Landrum) focus on reliability and capacity to support electrification, while WRA suggests demand-side management to mitigate grid strain.

3. Keeping Rates Affordable:

   • Agreement: All commenters prioritize affordability, recognizing the JTS’s infrastructure costs (e.g., transmission, storage) could raise rates. OUCA and PSCo (Ihle, Tomljanovic) emphasize cost-effective resource selection and transparent rate impact analyses.

   • Disagreement: OUCA and WRA push for stronger consumer protections and cost deferrals, while PSCo proposes mechanisms like the Electric Commodity Adjustment (ECA) to recover costs. Sierra Club warns against fossil fuel investments that could lock in long-term costs, favoring cheaper renewables.

4. Keeping the Grid Reliable, Including Retaining Strong Inertia:

   • Agreement: Reliability is a universal priority, with PSCo witnesses (Landrum, Ming, Siebenaler) and advocacy groups (Sierra Club, WRA) supporting updated ELCC/PRM studies and transmission planning to handle intermittent renewables and load growth. Ming’s RA Study emphasizes grid stability.

   • Disagreement: PIESAC advocates SMRs for strong inertia and reliability, while Sierra Club and WRA favor batteries and renewables, citing sufficient reliability with proper planning. OUCA seeks cost justification for reliability investments, questioning transmission and storage expenses.

5. Reducing Carbon Emissions:

   • Agreement: All commenters support the JTS’s 80% emissions reduction goal by 2030, aligned with Senate Bill 19-236. Wind, solar, and storage are broadly endorsed by PSCo, Sierra Club, and WRA as primary tools.

   • Disagreement: Sierra Club opposes gas conversions (e.g., Pawnee), arguing they undermine emissions goals, while PSCo justifies them as transitional. PIESAC’s SMR focus contrasts with Sierra Club’s anti-nuclear stance, citing safety and waste concerns. WRA seeks more aggressive renewable timelines.

Nuclear Power Summary

• Small Modular Reactors (SMRs):

  • Support: PIESAC strongly supports SMRs, particularly for Pueblo, citing their reliability, carbon-free output, and job creation potential for coal communities (Document ID: 1039799). PSCo witnesses (e.g., Tomljanovic) are open to SMRs as innovative technologies but do not explicitly endorse them.

  • Opposition: Sierra Club opposes SMRs, arguing they are costly, pose safety risks, and generate nuclear waste, preferring renewables (Document ID: 1039758).

  • Neutral/No Opinion: OUCA and WRA are neutral, seeking more data on cost and feasibility (Documents ID: 1039764, 1039756). Most PSCo witnesses (e.g., Landrum, Ming) do not address SMRs directly, focusing on wind, solar, and storage.

• AP-1000/APR-1400:

  • Support: No commenters explicitly support AP-1000 or APR-1400 reactors, likely due to their large scale and long lead times, which are less relevant to the JTS’s 2031 timeline.

  • Opposition: Sierra Club’s anti-nuclear stance likely extends to AP-1000/APR-1400, though not explicitly stated (Document ID: 1039758).

  • Neutral/No Opinion: All other commenters, including PSCo and PIESAC, do not mention AP-1000 or APR-1400, focusing instead on SMRs or renewables. The lack of discussion suggests these technologies are not currently prioritized for the JTS.