Yellowstone park proposes utility upgrades

The U.S. National Park Service manages over 84 million acres of land for both conservation and visitor use.  For wilderness parks, these joint objectives lead to the challenge of providing park facilities with electricity despite their remote location.  The Park Service has launched energy efficiency and sustainability programs, but many visitor and administrative facilities still need electricity for safety and comfort.  How should the Park Service balance conservation and development?

Old Faithful geyser erupts in Yellowstone National Park.

Yellowstone National Park, the nation's first park, highlights the difficulty.  Most facilities in the park receive electricity from transmission and distribution lines owned by utility NorthWestern Energy, but the park's rugged environment, challenging climate, and relatively old electrical infrastrucutre lead to frequent power outages - over 250 in 2012.  Unlike much of the electric grid outside the park, facilities in Yellowstone lack modern communication infrastructure - a Supervisory Control and Data Acquisition or SCADA system - that would let the utility diagnose and correct the cause of power outages from the utility's central offices in Montana.

As a result, Yellowstone and NorthWestern Energy have proposed to update the park's electrical distribution system.  Proposed upgrades include an automated, remote monitoring and control system, the installation of equipment buildings, back-up power generators and propane fuel tanks.  The proposed communication system would require the construction of seven towers for radio equipment within the park, generally located at existing electrical substation sites.

Under the National Environmental Policy Act, the Park Service cannot approve the plan without conducting an environmental assessment of the impacts of the proposed development.  The Park Service has released its Environmental Assessment (10.5 megabyte PDF), which is open for public comment until December 6.

The use of national park lands for energy infrastructure can be controversial due to differing philosophies on the level of development desirable in parks.  At the same time, the Park Service notes that the Yellowstone outages have had negative effects on park operations and visitor experience, creating health and safety concerns and lost revenue for concessioners.  How will this balance play out in Yellowstone?

Incremental hydropower tax incentives

Upgrading existing hydroelectric facilities to improve their efficiency or capacity can be cost-effective.  Not only will the plant produce more electricity more efficiently, but the upgrades may qualify the facility for a tax incentive designed to spur the development of new renewable electricity generation.  For example, installing inflatable flashboards or high-efficiency turbine runners could qualify a project for an energy production tax credit of 1.1¢/kWh. 

As part of the sweeping Energy Policy Act of 2005, Congress amended section 45 of the Internal Revenue Code to expand the renewable electricity production tax credit (or PTC) to incremental production gains from efficiency improvements or capacity additions to existing hydroelectric facilities.  Eligible improvements must be placed in service after August 8, 2005, and before January 1, 2014. 

To qualify incremental hydroelectric generation for the tax credit, the project owner applies to the Federal Energy Regulatory Commission under section 1301(c).  The Commission is required to certify the “historic average annual hydropower production” and the “percentage of average annual hydropower production at the facility attributable to the efficiency improvements or additions of capacity” placed in service during that time period.  The applicant is then able to take the production tax credit for the incremental amount of electric energy produced as a result of the upgrades.

While a credit of 1.1¢/kWh may seem small, hydroelectric projects typically produce relatively large amounts of electric energy at a relatively low operating cost.  Depending on the energy market, at times the tax credit may be worth half as much as the value of the underlying energy.  Also, in this context, the tax credit is only available for the incremental generation produced above the historic baseline; thus allowing incremental hydropower production to qualify for the PTC arguably rewards investment in upgrades.

At the same time, the continued availability of the tax credit for any kind of renewable electricity is in doubt.  Under current law, most renewable resources must be placed in service by the end of 2013 to qualify for the production tax credit.  Wind energy projects must be placed in service by the end of 2012.  Congress is considering whether to renew the tax credit, as it has done a number of times since it was first enacted in 1992.   According to a Congressional Budget Office report released this month, tax credits for renewable energy sources cost the government $1.4 billion in fiscal year 2011.