Five amendments to a three-year plan is a lot, but that’s what Nevada energy utility NV Energy has proposed to its 2021 Integrated Resource Plan. An IRP is the process through which the Public Utilities Commission of Nevada (PUCN) ensures the utility has the resources it needs to reliably and affordably serve Nevada electric customers. NV Energy’s 5th amendment to its current IRP would allow the utility to get major projects approved under a shortened, simplified process that doesn’t get the scrutiny an IRP should otherwise have.

In this case, NV Energy is pushing through some major new investments to build new and add to existing fossil fuel generators that will impact reliability, affordability, and environmental goals. Most notably, this 5th amendment proposes converting the existing North Valmy Generating Station into a natural gas plant, in addition to adding a 400-megawatt solar farm and a 400-megawatt battery storage facility. NV Energy submitted this proposal in order to meet anticipated energy needs, however, it is informed by outdated modeling and procurement practices and would lead to NV Energy failing to fulfill a decades-long promise to retire the Valmy coal plant, and instead expand its natural gas operations.  

Historically, when energy utilities file amendments to integrated resource plans, the process oftentimes results in the exclusion of stakeholder and consumer input, in addition to lacking meaningful efforts to find the most cost-effective, reliable, and clean resources.  

This is why we have intervened alongside numerous other companies and organizations including Western Resources Advocates, Sierra Club, Interwest, Google, and MGM Resorts International, to urge PUCN to hold NV Energy accountable and avoid allowing a flawed amendment to result in unnecessary ratepayer burdens.  

Our engagement and intervention efforts have revolved around the following key arguments: 

• It is NV Energy’s responsibility to ratepayers to find the most cost-effective energy sources through competitive procurement. Competitive procurement occurs through a request for proposals that asks developers, energy technologies, and service providers to offer project bids that the utility can then choose from and select the best and most cost-effective projects and contracts that meet energy and reliability needs. However, in the 5th amendment filing, NV Energy has neglected to demonstrate how its procurement process has resulted in the most cost-effective options for ratepayers.
  
  
• NV Energy must honor its promise to retire the Valmy coal plant. The proposal to convert the Valmy coal plant to a natural gas plant lacks an adequate needs analysis that will result in an unnecessary ratepayer burden. NV Energy’s analysis only identified a potential need for resources in the Valmy area for up to two years. To meet this limited, short-term need, the 5th amendment proposed a $83 million dollar investment while neglecting to provide transparent information on long-term gas and pipeline costs, environmental risks, and operation timelines.
  
  
• The 5th Amendment proposal is premature. The filing of this amendment is rushed and unnecessary as the 2024 Integrated Resource Plan will be filed in six months. It would benefit stakeholders, ratepayers, and NV Energy to wait until the 2024 Integrated Resource Plan to thoroughly address how to meet energy demands through a more robust stakeholder engagement process, competitive procurement practices, and more transparency.

Through these arguments, United, along with our fellow intervenors, is seeking to bring attention to the ways in which NV Energy’s 5th amendment attempts circumvent best practices to the detriment of ratepayers and the state’s environmental goals. As additional steps, United provided a brief regarding concerns about NV Energy’s ability to withhold information within the 5th amendment from intervenors citing confidentiality concerns on December 18 and filed further testimony on December 19. This element, while still ongoing, has been an obstacle in allowing intervenors to fully grasp NV Energy’s plans and effectively hold them accountable.