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Montana PSC asks for more review of MDU's 2024 IRP; commissioners request amendments before Dec. 16
Summary
Commission staff identified modeling and documentation gaps in Montana Dakota Utilities' 2024 integrated resource plan, including limited modeling of the Badger Wind project and omitted long-duration storage; commissioners voted unanimously to continue review to Dec. 16 and asked for commissioner amendments by Dec. 10.
The Montana Public Service Commission on Dec. 2 deferred action on Montana Dakota Utilities' (MDU) 2024 integrated resource plan so commissioners could suggest revisions to staff's draft comments. Commissioners voted unanimously to revisit the matter at the Dec. 16 business meeting and set a deadline for proposed commissioner amendments.
Mike Dalton, a regulatory analyst, told the commission the 2024 IRP was filed Sept. 27, 2024, and that MDU later filed a supplement on March 28, 2025 that provided more modeling for a project called Badger Wind. Dalton said the IRP and supplement model a 150-megawatt Badger Wind purchase and noted that MDU examined resource adequacy under both the legacy accreditation approach and MISO's proposed direct loss-of-load (DLOL) method, which would move the expected date that MDU needs additional capacity earlier.
Staff's draft comments pointed to several purported deficiencies in the IRP: incomplete documentation of MDU's engagement with advisory groups and the public, inconsistent assumptions about demand response, omission of certain resources (for example, long-duration battery storage labeled as an emerging technology), insufficient disclosure of EGEAS model inputs, and a lack of description of the process the utility would use to acquire additional resources (including whether competitive solicitations/RFPs were used).
Vice President Fielder emphasized concerns about the effect of the DLOL accreditation method on the timing of capacity needs and urged a careful review of consultant assumptions and procurement practices. He asked that commissioners provide suggested amendments to staff by close of business on Wednesday, Dec. 10, so staff can distribute revised materials before deliberations on Dec. 16. "I'd like to have us take some more time and have commissioners take a look at it and offer amendments or thoughts to staff within the week," he said.
Commissioners expressed support for staff's generally constructive tone in the draft comments but said they wanted more attention to modeling choices, comparables, and whether adequate RFPs had been used for major contracts such as Badger Wind. Commissioner Molnar seconded the motion to continue; the motion carried unanimously.
What happens next: Commissioners who want to suggest changes must submit them to staff by Dec. 10. Staff will incorporate commissioner points and return a revised draft for deliberation at the Dec. 16 business meeting. Any questions about cost recovery for resources discussed in the IRP will be handled in an open rate case rather than in the IRP comment process.
