Regulatory Commission of Alaska

Public Comment for TA493-1 & TA494-1 by Margo Waring of Renewable Juneau

January 19, 2021

Regulatory Commission of Alaska
701 W. 8th Avenue, Suite 300
Anchorage, AK 99501

RE: AELP_Hecla Greens Creek Power Contract

Dear Commissioners,

I appreciate the opportunity to provide helpful public interest comments and positions on the Avista-AELP-Hecla Greens Creek contract in TA 494-1 http://rca.alaska.gov/RCAWeb/ViewFile.aspx?id=656170f2-d8eb-4346-bc3a-aabbdeb67705 and docket TA 493-1 http://rca.alaska.gov/RCAWeb/ViewFile.aspx?id=4895c41b-9b91-41f8-b10e-fcc5bea6984c regarding the Princess Dock contract for your consideration. 

Renewable Juneau is a non-profit 501c3 organization that educates, advocates and works to support the City and Borough of Juneau’s adopted Juneau Renewable Energy Strategy for powering all sectors of the economy with renewable energy to meet the goal of 80% carbon free energy by 2045. One of our current efforts is to assure that all Juneau’s downtown docks that serve cruise ships are electrified so that ships can use shore power while in port. We are also concerned and have expressed this concern to the USFS, that Juneau’s mines produce about 16% of greenhouse gas emissions in the Borough. Hecla, when burning diesel for electrical generation, represents roughly 6% of the GHG of Juneau. The Hecla Greens Creek Mine is entirely in the service territory of Avista/AEL&P and uses a federally funded electrical transmission line. 

Regarding Hecla Mining’s (Greens Creek) contract with Avista/AEL&P, we believe it is in the local public interest for the mine operation to be on firm renewable power all the time and not curtailed. It is our understanding that the more electricity sold from a utility provides revenues, profits and pays down operations and debt, while Hecla could achieve full 100% renewable power to run their operations and become zero carbon with no diesel generation emissions. This  outcome would make considerable progress toward the goals and community values set forward in the City and Borough of Juneau (CBJ)’s Climate Action and Implementation Plan (JCAIP)1 and the Juneau Renewable Strategy (JRES)2. We understand that Avista/AELP curtailed Hecla in 9 of the last 12 years. Curtailments are significant and have caused an increase in fossil fuel usage and GHG emissions in the City and Borough of Juneau.  

While we appreciate that Hecla has been allowed to reduce its carbon footprint through this past contractual arrangement, more can and should be done. Climate change and GHG emissions are important issues currently under consideration with the US Forest Service in its scoping that will either allow or, with conditions allow, the continuation of Hecla mining operations on the Admiralty Island National Monument.3 We believe that Avista/AEL&P and Hecla Mining could revise its contract to enable Hecla to be a firm customer or have options to seek and procure renewable energy from other sources outside AEL&P if AEL&P cannot meet Hecla’s energy requirements. Such provisions may help Hecla in its current and future permitting to eliminate its diesel generation carbon footprint and reduce its fuel oil spill potential in the Admiralty Island National Monument. 

Regarding the Princess dock situation, CBJ is currently studying the possibility of electrifying its other docks and Norwegian Cruise Lines has publicly committed to electrifying its planned new dock. These very large additional electrical loads would be firm. Given these likely increases in firm demand, and the limitations of energy supply, it would be unwise for Avista/AEL&P customers to seek interruptible service.  Therefore, unless Hecla becomes a firm customer or finds another source of renewable power, Hecla may be in a position where the mine could lose power to these and other future firm customers unless new power sources like Sweetheart Lake Hydropower are supported and permitted to come online.  

Renewable Juneau supports Juneau Renewable Energy Strategy’s goal of 80% renewable energy to power, heat, and drive the City and Borough of Juneau by 2045. The RCA has a role to ensure that these local community public interest objectives from duly elected local government are enabled and fostered through the RCA approval process of power contracts and tariffs. 

Thank you in advance for your consideration,

Margo Waring





Renewable Juneau, Board President

Type

Comments

Date Filed

1/19/2021

Tracking Number

TR2100354

Filed By

Danielle Redmond

Entities

Certificate(s)

Means Received

Internet

Related Matters

TA494-1	Alaska Electric Light and Power Company - Contract - Special (Amendment No. 4 to Contract with Princess Cruise)
TA493-1	Alaska Electric Light and Power Company - Contract - Special (Amendment No. 2 to Contract with Hecla Greens Creek Mining)

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