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WDEP Shared Governance Committee Final Report

In 2024, the Getches-Wilkinson Center and the Boulder Faculty Assembly Climate Science and Education Committee (CSEC) co-chaired a shared governance committee regarding campus energy and climate policy. The Committee was nominated by the Թ’s Chief Operating Officer to review and, if appropriate, recommend alternatives to the Թ’s plans to upgrade the Western District Energy Plant (WDEP). The Committee's nomination was followed by an expressing concerns with the climate impacts of the WDEP upgrade and signed by over 460 CU community members.

On March 21, 2024, the WDEP Shared Governance Committee submitted its Preliminary Recommendation Report to the Chief Operating Officer. In its Preliminary Report, the Committee recommended that the Թ not go forward with its original upgrade plan for WDEP, citing the increase in greenhouse gas emissions that would result from that plan, and the availability of alternative optionsto meet campus resilience needs in a cost-feasible way. In July 2024, the Թ rejected the Committee's recommendation and approved the original WDEP upgrade plan. In October 2024, the Committee released its Final Report, addressing the Թ's claims and documenting concerns with the Թ's decision-making process around WDEP. The key findings from that Final Report are reproduced below.

The Committee's reports can be accessed here:

Download the Final Report

Download the Preliminary Recommendation Report

Download Additional Questions from the Committee

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Summary Findings from the WDEP Committee Finding Report

  1. The Թ’s original program plan for the WDEP project was written without adequate alternatives analysis, which is essential to adequate environmental decision making.
  2. The Թ’s original WDEP plan (Option 2E) was developed with a lack of understanding of the regulatory flexibility offered by the explicit language of Reg 7. The Թ’s perception that Option 2E was required to ensure campus resilience likely resulted from that misunderstanding.
  3. In its Preliminary Report, the Committee found that Option A1 provides similar resilience benefits to the Թ’s Option 2E. The Թ continued to claim that compelling resilience needs required the adoption of Option 2E despite detailed analysis by the Committee to the contrary when considering the regulatory flexibility in Reg 7. The Թ did not provide the Committee with any data or analysis supporting its claim.
  4. The Թ claims Option 2E is required to protect continuity of mission critical research. Under the Թ’s own Energy Master Plan, that goal is supposed to be achieved by other means, which the Թ has not yet implemented.
  5. In the program plan it submitted to the CU Board of Regents (Fall 2023, see here), the Թ did not take into consideration the additional greenhouse gas emissions that would result from Option 2E relative to the business-as-usual assumptions in its 2024 climate action planning. In this program plan, the Թ also highlighted carbon reduction benefits of the plan that are “...likely [to] hold true until at least 2030.”2 According to the Committee’s review of the Թ’s models, those emissions reductions are small and short-lived. Meanwhile, the Թ did not alert the Board of Regents to more substantial increases in carbon emissions that the plan would represent relative to the business-as-usual scenario in the long-term.
  6. The Թ’s program plan included several additional claims that were incorrect and/or incomplete based on available data. It is possible that if the Regents had received more accurate and complete information, they would have invested greater resources in finding an alternative to the Թ’s plan. For example:
    • The Թ claimed that Option 2E will replace “existing 30-year-old combustion turbines” (p. 3), without mentioning the turbines have been rebuilt in 2013, and had very little depreciation on them given minimal use since 2013;
    • The Թ claimed (p.4) that Option 2E aligns with the Թ’s 2021 Energy Master Plan (EMP), despite the fact that the EMP explicitly planned to avoid base loaded cogeneration starting 2027, given GHG considerations (see here, p. 52; note that at the time the EMP was finalized, Reg 7 which the Թ claims precipitated the need for Option 2E was already in force);
    • Under the heading “Sustainable Design”, the Թ highlighted the possibility of reconfiguring the new turbines “to operate on alternative fuels like hydrogen or other cleaner burning fuel sources” (p. 4), even though it is widely accepted that hydrogen does not provide a feasible source of energy for heating for environmental, economic, and other reasons.
  7. Concerns regarding the Թ’s recent planning to upgrade WDEP should also be understood in the context of WDEP’s role in the Թ’s failure to achieve its 2020 climate targets. As the Committee noted in its preliminary report (p. 9): “The minimal use of cogen throughout the 2010s substantially contributed to the Թ’s miss of its 2020 climate target. With the grid expected to become cleaner than cogen by 2029, there is a risk that once again the Թ will find itself using the less climate friendly option for energy generation. In other words, the Թ that did not baseload cogeneration when it was climate friendly to do so will shift to baseloaded cogeneration just when it is no longer climate friendly to do so.” The Թ did not provide the community with adequate transparency regarding the minimal use of cogeneration during the 2010s. That minimal use ran counter to the Թ’s planning under the 2009 Conceptual Plan for Carbon Neutrality (see Preliminary Report, pp. 4-5).
  8. The desire to obtain federal tax credits under the Inflation Reduction Act (IRA) was, according to the Թ, an important factor in its decision to pursue Option 2E, as well as the timing for its decision. Nevertheless, the Թ did not carry out the necessary analysis regarding eligibility requirement for the credit. To the Committee’s understanding, the Թ lacked such analysis as late as June 2024, even though concerns were flagged by the Committee in March 2024.
  9. The Թ used contradictory assumptions in its financial analysis and its climate analysis. The contradictory assumptions created a biased impression regarding the financial benefits of the Թ’s Option 2E. On the one hand, the Թ claimed its intention to reduce the excess emissions of Option 2E over Option A1 through an early phase-out of baseloaded cogeneration. On the other hand, for its lifecycle cost analysis, the Թ assumed that baseloaded cogeneration would continue in the long run, resulting in financial benefits to the Թ over Option A1. The Թ should not use two contradictory sets of assumptions, one to claim financial advantages (assuming long-term base-loading), then another to try to limit the increase in emissions (assuming a shift away from baseload generation, presumably as early as 2029).
  10. The Թ did not share with the Committee a campus load-curve, which is essential for energy planning. Despite repeated Committee requests, the Թ did not corroborate its claim regarding peak-load of 200 kpph steam needs.
  11. While the Թ’s Climate Action Plan assumes a 30% decline in campus energy consumption, the Թ planning for WDEP assumed peak demand would remain constant long into the future. The Թ was not willing to engage with the Committee regarding options to reduce peak-load through demand-side management.
  12. The Թ’s claims that Option 2E will reduce campus NOx emissions by 50% relative to current emissions has not been supported by data. While the turbines the Թ plans to install under Option 2E have lower NOx emissions intensity than the existing turbines, the existing turbines are only operated by the Թ on rare occasions. In distinction, under the Թ plan, the new turbines will be used continuously for base-loaded cogeneration. The Թ did not present an analysis of the absolute levels of NO x emissions that would result from its plan to support the claim of 50% reduction.
  13. While claiming to be committed to shared-governance principles, the Թ essentially ignored the Committee’s Preliminary Report, instead repeating claims (including publicly) that were found and documented by the Committee to be incorrect based on available data. The Թ refused to share relevant planning documents, or to engage the Committee in a meaningful review of the materials that the Թ developed in April-May 2024.
  14. The Թ’s lack of cooperation with the Committee during April-May 2024, hindered the work of the Committee, and, among other things, hindered the development of additional alternatives to the Թ’s Option 2E, which may have been even more favorable than Option A1.
  15. There was no urgency for the Թ to finalize its decision by the original April 1 deadline, or by July 2024, as later claimed by the Թ. Given the regulatory flexibility identified by the Committee, the Թ’s resiliency needs were met at all times and there was no threat that they would be unmet in the coming years. Further, as discussed in the Preliminary Report, eligibility for tax credits did not present a consideration justifying expediting the decision without appropriate analysis and consideration of alternatives. At the end, the Թ delayed its decision beyond its original April 1 deadline, but also failed to cooperate with the Committee to develop additional alternatives after April 1.