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Technical commenters say Northwestern's modeling undercounts renewables, excludes demand response and misstates costs
Summary
Technical reviewers and advocacy groups told the PSC the IRP uses modeling choices that under-accredit wind/solar and overstate costs for renewables and batteries while excluding demand-response as a candidate resource, arguing those choices bias outcomes toward fossil plants.
Technical speakers pointed to specific tables and appendices they say show systemic modeling bias. Jennifer Swearingen said that some cost tables and capacity-accreditation inputs understate wind and storage performance and that certain gas-plant candidates exclude fuel and pipeline costs; Nick Fitzmaurice and others said Northwestern used in-house formulas that depart from regional accreditation methods and urged independent review.
Commenters asked the PSC to require Northwestern to disclose the modeling assumptions and appendices (including capacity-accreditation methods and cost inputs), to include demand-response and long-duration storage as candidate resources, and to submit the plan for independent technical review if it fails to meet administrative rules.
