CALL TO ACTION-
The Platte River Power Authority (PRPA) application with the Colorado Air Pollution Control Division (APCD), for construction of five new gas turbines seven miles northwest of Fort Collins, is open for public comment until December 10. Documents can be found here:
https://drive.google.com/drive/folders/1lSBbX_60Ashu8XQYCe6tdOAYnD9S8k9d
CforSE, The Fort Collins Sustainability Group (FCSG) and Northern Colorado Partners for Clean Energy (NCP4CE) are asking that you send a comment to the APCD.
We are asking that the APCD do one of the following:
Deny the permit or
Permit a fewer number of turbines or
Issue the permit on the condition that the turbines not run on high ozone days along the front range (this is permissible for the SPP – see below) or
Both 2 and 3
You can simply ask the above requests, or use the talking points below, or say what you like, share your story.
You can submit your comment by filling out this form:
https://docs.google.com/forms/d/e/1FAIpQLSfW6hRmDKu1QqHh2ByrJOahNwSh29BB-14JlBOd0hxJo8Apgg/viewform
In the drop down menu choose: PRPA Rawhide Energy Station #24 LR 0705
TALKING POINTS -
The portion of Larimer County along the front range is in the EPA severe non-attainment zone for ozone pollution, and the American Lung Association rates our air quality with a grade of F. Building new methane gas burning infrastructure will add to poor air quality.
“The mission of the CDPHE Air Pollution Control Division is to improve and protect outdoor air quality in Colorado by developing and implementing cost-effective, efficient air pollution control measures that comply with state and federal law. The division issues and enforces air quality permits, monitors outdoor air pollution, and more.” https://cdphe.colorado.gov/apcd Note that the mission is to protect Coloradoans by improving and protecting air quality, not to do the bidding of utilities. Thus a thorough and rigorous evaluation of this project and permit application is required, including whether less polluting alternatives are feasible.
The EPA Non-attainment zone mysteriously draws it's boundary to exclude Rawhide. The Regional Air Quality Commission has asked that this boundary be redrawn. Rawhide is currently the single biggest contributor to air pollution (due to the coal plant) along the front range. Although this will decrease when the coal unit is shut down in 2030, burning gas will continue to contribute significant amounts of pollution if the new methane turbines are allowed to be built, and if they and the existing turbines are allowed to operate without restriction.
The new gas turbines are NOT needed because PRPA already has 388 MW of gas CTs, which are more than enough “insurance” until more renewables and storage can be built.
The Effective Load Carrying Capacity (ELCCs) that the PRPA placed on its renewable resources (wind, solar, and storage) in their original Integrated Resource Plan (IRP) were lower than those used by the Southwest Power Pool Regional Transmission Organization (SPP RTO), which is the “balancing authority” (BA) that the PRPA plans to join in 2026. Using updated, more accurate ELCCs, PRPA has a planning reserve margin of 48.6% in 2030 WITHOUT building a new gas-fired power plant. That is twice the planning reserve margin that PRPA says it needs to join the SPP! For more detail, please see this letter submitted to the Larimer County Commissioners by Mike Foote, Esq. For the NCP4CE https://colivableclimate.org/wp-content/uploads/2025/03/NCP4CE-letter-to-Commissioners-24-ZONE3715.pdf
The projected cost of building the gas turbines has gone up from $350 million in 2024 to a current price of $623 million, a 78% increase. This is a huge and unreasonable increase, which negates the “financially sustainable” argument for building the gas. How much solar and batteries could be purchased with $623M?
When the price of the new methane gas turbines was projected to be $350 million, PRPA planned to increase wholesale rates to the owner cities by 6.3% each year. Now the wholesale rate increase is projected to be 7.5% per year, with the huge hike in the cost of the gas plant. The rate increase will create an even greater hardship for ratepayers, at the same time that PRPA will be imposing increased health and safety impacts caused by more fossil fuel.
The APCD has the ability to place conditions and restrictions on a permit. The APCD could place a condition that any new gas turbines permitted under the current application will not be allowed to function on days of high ozone pollution along the front range. Although PRPA claims that the SPP doesn't allow such a condition, the following is a quote from a private email to Barbara Krupnik-Goldman from a Senior Director, Markets Administration, Southwest Power Pool:
“Thermal resources generally have emission requirements they must meet for federal, regional and/or local requirements. These parameters can be applied to determine how a resource is offered and therefore how it operates in the market, but if it is available to run it must be offered for use based on those parameters..... Emissions constraints set by relevant regulatory bodies can be factored into how a resource participates in the market, and will typically be reviewed by SPP’s Market Monitoring Unit to ensure no gaming is taking place.” (bold added)