Kansas

2021 Evergy Triennial IRP & Subsequent Updates

NEE-Contracted Consultants, Chelsea Hotaling and Anna Sommer of Energy Futures Group, Kenneth Sercy of Sercy Consulting; Ivan Urlaub assisted with 2023 Update

Filed Comments:

2021 Triennial 

2022 Update

2023 Update

Key Conclusions and Recommendations

∙ Evergy’s model inputs generally biased the utility’s planning away from renewables

∙ Evergy’s modeling does not include the full impact of investment tax credits for batteries and renewables

∙ An alternative portfolio could achieve significantly lower costs by deploying more renewable energy and energy storage while limiting fossil fuel additions

∙ Securitization would allow coal plants to be retired sooner while saving ratepayers $500 M

Outcome

∙ In a joint resolution, Evergy committed to revisit and revise several modeling assumptions

∙ In subsequent updates on the IRP, Evergy incorporated some NEE recommendations such as including the impact of investment tax credits on up-front capital costs of battery energy storage

2024 Evergy Triennial IRP & Subsequent Updates

NEE Staff Members, Ivan Urlaub and Nick Jones

NEE-Contracted Consultants, Chelsea Hotaling, Anna Sommer, Carlos Peña Becerra, and Nina Peluso of Energy Futures Group

Filed Comments:

2024 Triennial 

2025 Update

Key Conclusions and Recommendations

∙ Evergy’s model inputs and methods generally biased the utility’s planning away from renewables

∙ Evergy’s models assume unrealistically low capital costs for natural gas power plants. NEE recommended an upward revision to reflect real project costs.

∙ Evergy’s natural gas forecasts understate risks and costs. NEE recommended revising forecasts upward or reweighting the ‘high-case’ scenario to be considered more probable.

∙ Evergy’s models do not consider the full range of potential ownership structures for new natural gas plants, which potentially forces the selection of more natural gas capacity than necessary. NEE recommended considering a wider range of ownership structures.

Outcome

∙ Evergy agreed to relax artificial model constraints for renewable capacity expansion

∙ Evergy updated model inputs to reflect the real cost of natural gas plants in development

∙ Evergy agreed to reopen consideration of converting coal plants to natural gas

∙ In Kansas, no agreement was reached regarding natural gas forecasting, but NEE requested that the Commission there consider the issue in future dockets where relevant. The Commission granted this request, allowing NEE to make fuel price forecasting a central argument in the docket for Evergy’s 2024 CCN Predetermination application to build two new natural gas plants

2024 Evergy Predetermination/CCN Proceedings

NEE Staff Member, Nick Jones & Ivan Urlaub

Direct Testimony

Case Details:

∙ Evergy applied in both Missouri and Kansas for the right to construction and recover costs from several new gas plants with combined capacity totalling 1860 MW. Under the applications, Evergy’s Kansas and Missouri affiliates would jointly own two new 710 MW CCGT plants in Kansas. Additionally, Evergy Missouri West would construct and own 100% of a 440 MW CT plant in Missouri. Notably, Evergy’s Missouri affiliates had only included the first CCGT plant in their 2024 IRPs, making Evergy Missouri West’s proposed half-ownership of the second plant a variance from the 2024 IRP.

∙ NEE acted as an intervenor in Kansas and as an expert witness in Missouri, supporting Renew Missouri’s intervention

Conclusions and Recommendations

∙ NEE recommended that fuel costs be included in analysis brought before each state’s commission. Additionally, NEE questioned the reasonableness of Evergy’s fuel price forecasts and requested that commissioners consider plant costs under high-price scenarios

∙ NEE recommended that Evergy affiliates could reduce their net-ownership in the proposed plants while still meeting their needs

∙ NEE produced comparative analysis that showed that, with reduced ownership, Evergy could invest instead in alternatives such as BESS with significant benefits for ratepayers

∙ In Missouri, Evergy had argued that the new plants would help insulate ratepayers from the SPP power market. NEE rebutted this claim by showing that BESS would outperform gas power as a market hedge.

Outcome

∙ Pending

Media 

Kansas Reflector, “Experts challenge Evergy plans to add natural gas plants in Kansas”

 2023 Ameren MO Triennial IRP & Subsequent Updates

NEE Staff Member, Ivan Urlaub prepared 2023 comments and resolution process and Ivan Urlaub and Nick Jones prepared 2024 comments and resolution process

Filed Comments

2023 Triennial

2024 Update

Conclusions and Recommendations

∙ Ameren does not adequately capture risk in its natural gas forecast

∙ Ameren should begin using capacity expansion modeling to best generate and evaluate resource plans

∙ Ameren should reinstate its consideration of Grain Belt Express transmission project as a potential vector for enhancing power supply

∙ Ameren should increase its planned implementation of demand-side management strategies

∙ Ameren should expand the customer renewable subscription programs on offer to better meet demand for those programs and to lower the net cost of building new capacity

∙ Ameren should update resource cost assumptions to capture changes in resources such as batteries

  Outcome

∙ Ameren committed to increased evaluation of demand-side management strategies

2024 Ameren MO Natural Gas CCN

NEE Staff Member, Ivan Urlaub and Nick Jones

Link to testimony

Case Details:

∙ Ameren applied to build 800 MW Castle Bluff CT plant

∙ NEE did not intervene but did collaborate and provide analysis to support Renew Missouri’s intervention 

Conclusions and Recommendations

∙ NEE contributed arguments to emphasize uncertainty in the natural gas market and the high cost of fuel likely to be incurred by Castle Bluff

Outcome

∙ In settlement, Ameren agreed to bring forward a CCN for a 200 MW BESS facility to be built by 2027. This represented an acceleration of the 400 MW by 2030 that was included in its IRP

Additionally, Ameren agreed to include in its future IRP updates the potential for lower cost wind and solar to be built in Kansas and connected via Grain Belt Express