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Home My WebLink AboutResponse to Constituent Letter - Mail Packet - 10/28/2025 - Letter from Mayor Jeni Arndt to the Energy Board re Determining performance toward City goal: 100% renewable electricity Mayor City Hall Fort Collins, CO 80522 970.416.2154 970.224.6107 - fax fcgov.com October 23, 2025 Energy Board c/o Christie Fredrickson, Staff Liaison PO Box 580 Fort Collins, CO 80522 Dear Chair Smith and Board Members: On behalf of City Council, thank you for providing us with the October 17, 2025 memorandum regarding determining performance toward the City goal of 1000% renewable electricity. We understand that the Board recommends City Council ensure a well-documented and transparent process for renewable electricity consumption, recognize that RECs are essential and continue to pursue responsible environmental actions while also documenting goal performance. City Council is scheduled to hear a staff report regarding renewable electricity progress and accounting overview during the Tuesday, October 28 Work Session. The Board is invited to view the Work Session via FCTV cable channels 14 or 881 or watch online at fcgov.com/fctv. Thank you for the expertise and perspectives that you bring to the Board and share with City Council. Best Regards, Jeni Arndt Mayor /sek cc: City Council Members Kelly DiMartino, City Manager Utilities – Energy Board 700 Wood St. Fort Collins, CO 80522 970.221.6702 970.416.2208 - fax fcgov.com M E M O R A N D U M DATE: October 17, 2025 TO: Mayor Arndt and City Councilmembers FROM: Brian Smith, Energy Board Chairperson RE: Determining performance toward City goal: 100% renewable electricity BACKGROUND The City’s use of renewable electricity and performance against its 100% renewable electricity use goal have been frequent topics of discussion at Energy Board meetings. The topic has been included as a specific part of our agendas, an element of other discussions, and addressed in public comments. ENERGY BOARD DUTIES AND FUNCTIONS Given the broad interest and applicability of the renewable electricity use goal, the Energy Board has considered the best methodology the City can use to demonstrate performance. We offer Board input here in accordance with our chartered duties and functions, specifically: (2) To advise the City Council and staff in developing City policies that encourage the incorporation of energy conservation and efficiency, carbon emissions reduction and renewable energy into the development and provision of City utility services, the design and construction of City transportation projects, and the way in which the City impacts the overall built environment within the community; (3) To advise the City Council and staff regarding the alignment of energy programs and policies with City, ratepayer and community values and service delivery expectations. OBSERVATIONS • The City’s renewable electricity goal, adopted in October 2018 is …100% renewable electricity supply to the City from Platte River supported by the Fort Col- lins Utilities distribution system by 2030, without compromising the three principles of af- fordability, reliability and environmental stewardship for Fort Collins Utilities, Platte River and our community. (Resolution 2018-094) • This goal was later refined with the 2021 adoption of the Our Climate Future Plan where re- newable electricity is addressed in Big Move 12. Here the goal is described as, “Everyone in the community receives affordable and reliable 100% renewable electricity, including from local sources.” Docusign Envelope ID: F57DB232-A538-4BDB-8148-B9E788D3FC7B o The 2018 Resolution defines renewable electricity as “non-fossil fuel sources,” ex- plicitly including “hydroelectricity and geothermal sources and other means that may become available and do not add greenhouse gases to the atmosphere.” o The nature of the renewable electricity goal and its applicability to the community imply that it is a consumption-based goal. In particular, the 2021 goal refinement addresses end users and electricity they consume: “Everyone in the community re- ceives…100% renewable electricity.”  A consumption-based goal must consider both local generation and elec- tricity delivered to or from the grid. • There is genuine interest in the community about the renewable electricity goal and whether the City will achieve it. As 2030 draws closer, the City will need to communicate its performance with respect to renewable electricity use, and how that performance level was determined. • For the City’s consumption-based goal, grid connections and Platte River’s Southwest Power Pool membership make the use of renewable energy certificates (RECs) essential for demonstration of performance. This is because, once added to the grid, electrons are indis- tinguishable. RECs are the instrument to identify that a given quantity of electricity was gen- erated from renewable sources —specifically, 1 REC = 1 MWh of renewably generated elec- tricity. o RECs financially support renewable energy producers and play an essential role in measuring renewable energy consumption on the interconnected grids in the US o Quality of RECs can vary. They can be sold separately from electricity, although in that case the associated electricity would no longer be considered renewable. When mismanaged, RECs may also be subject to double counting. Characteristics indicative of higher quality RECs are third-party certification, transparent attributes and chain of custody, and minimal negative environmental impact. RECs that are not separated from their energy are preferred, meaning they stay “bundled” to- gether. o FC Utilities is committed to utilizing only high-quality RECs that are directly associ- ated with Platte River and local renewable electricity generation, avoiding so-called “unbundled certificates.” • Given the potential variation in interpretations, measurement approaches and accounting instruments, it is important that the City confirm a methodology for determining perfor- mance against the renewable electricity goal. o Published City documents do not contain specific methodology. o Established standards of practice provide guidance for an adopted methodology  Among others, US EPA publishes guidance for “solar ‘use’ claims” (https://www.epa.gov/green-power-markets/guidance-making-claims)  On its guidance page, EPA cites an NREL document, “Renewable Electricity: How do you know you are using it?” (https://docs.nrel.gov/docs/fy15osti/64558.pdf). It states: “Voluntary purchasers need to substantiate their self-imposed renewable targets and their marketing claims (e.g., “This product was made with 100% wind power”). In both compliance and voluntary markets, RECs are the way to show you are using renewable energy.” Docusign Envelope ID: F57DB232-A538-4BDB-8148-B9E788D3FC7B RECOMMENDATIONS • Ensure the City has a well-documented and transparent process for establishing perfor- mance levels and claims related to renewable electricity consumption. This process should conform to current standards of practice. • Recognize that RECs are essential elements of tracking and achieving renewable electricity goals for a grid-connected city, like Fort Collins. • Continue to pursue responsible environmental actions while also documenting goal perfor- mance. o Use only high-quality (bundled) RECs that are reliably sourced and managed. o Maintain and enhance programs that support distributed renewable generation, en- ergy efficiency and promote clean technologies. o Hold Platte River accountable for achieving its environmental goals and responsible generation management. As always, the Energy Board is grateful for the opportunity to provide comment and appreciates City Council’s consideration. Respectfully submitted on behalf of the Energy Board, __________________________ Brian Preston Smith, Energy Board Chairperson Energy Board cc: Brian Tholl, Energy Services Director Travis Walker, Light & Power Director Christie Fredrickson, Energy Board Support Docusign Envelope ID: F57DB232-A538-4BDB-8148-B9E788D3FC7B