Renewable Juneau would like to offer our initial impressions of the draft dock electrification study which will come before the Juneau Assembly at Monday’s Committee of the Whole.
The draft report provides a lot of information. It’s going to take a while to digest. But, we strongly support the draft’s recommendation that construction proceed to provide shore power for the CBJ’s two newest docks.
We appreciate the report’s acknowledgement of the fact that dock electrification can contribute significantly to reducing Juneau’s carbon footprint and to meeting the goals of the Juneau Climate Action and Implementation Plan (JCAIP) and the Juneau Renewable Energy Strategy (JRES), as well as improving air quality in downtown Juneau and reducing the impacts of tourism growth.
We’re disappointed that the report focuses so much on questions of electricity supplies and so little on design and construction details. We question whether it really accomplished the intent of developing the preliminary design and actions steps envisioned when the Assembly appropriated funding in FY20. It really doesn’t get us much farther along than the study done in 2016.
Take a look at our Dock Electrification FILE Archive here.
It is surprising that the study spent so much effort on issues of electricity supply. As a public utility, AEL&P has a legal obligation to provide electricity – the question of supply seems like an issue best left to them. It seems like a poor precedent for the CBJ to take on issues of electricity supplies. Will all new projects or consumers of electricity be expected to pay to study the effects of their proposed uses of electricity?
The report says that a primary objective of the project is to reduce GHG emissions (p.8). This is important but seems incomplete. Other important objectives are to improve air quality in the downtown area, to reduce the impacts of growth in cruise ship tourism, and to make Juneau a competitive cruise ship destination over the long-term.
It is often difficult to tell where the report just repeats what AEL&P has said, and where the report authors are drawing independent conclusions. The draft does provide some useful, though incomplete, background data on electricity demand. It correctly points out that dock electrification is only one of the proposed new needs for hydroelectricity, and that it needs to be considered in the context of meeting the goals of the JRES (p.18). However it fails to go the next step to consider how dock electrification fits into, and can facilitate, meeting the goals of the JRES.
We are not convinced by the report’s assertion that the project is only financially feasible with federal funding. This is a project with strong community support and need, and if the CBJ is unsuccessful in getting the RAISE grant we believe that alternative funding approaches need to be considered. We also have to question Docks and Harbors commitment to funding the project, since we understand that they deliberately chose a set of assumptions that dramatically limited the benefit/cost ratio in their RAISE grant application, and ignored alternatives to the energy and funding assumptions offered by JCOS that could have doubled or tripled the grant scoring.
We believe that the long life of the facility improvements, and the relatively predictable income from marine passenger fees (at least in the absence of world-wide pandemics) paid by all visiting cruisers, provide a good starting point for paying for the improvements.
Finally, we question the report’s conclusion that electricity should be provided to the CBJ docks on an interruptible rather than a firm basis. The report correctly points out that this ‘customer arrangement’ would significantly undercut the benefits, and that this is “a complex issue that is beyond the scope of this study” (p.38). It is therefore very surprising and inconsistent that the study recommends that “the purchase of electrical power should be made initially as an interruptible customer” (p.2). We believe that this discrepancy requires reconsideration.
We expect to have more questions, and we look forward to contributing to public review and discussion of the report and to helping make dock electrification a reality.
For more information on this vital community issue, Renewable Juneau has organized a small collection of documents, reports, letters of public and corporate support, and more. Take a look at our Dock Electrification Archive here.
And, if you are just looking for the just-released draft dock study you can find it here.