The Southern Renewable Energy Association (SREA) filed written comments with the Kentucky Public Service Commission on March 7, 2025, raising critical concerns about the assumptions and recommendations included in Louisville Gas & Electric and Kentucky Utilities (LG&E/KU)’s Joint Integrated Resource Plan.
Key Concerns with the IRP
SREA’s comments feature a report by energy analysts from The Brattle Group, whose analysis highlights three primary concerns with LG&E and KU’s proposed resource strategy. First, the IRP assumes a major increase in electricity demand, largely driven by the expectation of significant data center growth in Kentucky. However, only one data center project (400 MW) is in the “imminent” phase, while the rest remain speculative. Without these assumed loads, the need for additional generation capacity significantly decreases, raising concerns about overbuilding unnecessary infrastructure.
Second, the IRP significantly undervalues the contribution of solar and wind resources while overestimating the reliability of natural gas and coal plants. The utilities assign zero capacity value to wind and solar in winter, even though neighboring regions such as PJM and MISO recognize their contributions. At the same time, the plan does not account for the increasing forced outage risks of gas and coal plants during extreme weather events, which could compromise grid reliability.
Finally, the IRP assumes minimal reliance on energy imports from neighboring states, despite available transmission capacity and the economic benefits of leveraging lower-cost market purchases. Greater regional transmission planning could reduce costs and improve reliability, yet the IRP does not sufficiently explore this opportunity.
SREA’s Recommendations for a More Balanced Energy Plan
To improve Kentucky’s energy strategy, SREA and The Brattle Group recommend adjustments in several key areas. First, the state should develop a transparent process for forecasting data center growth, ensuring that projections are realistic and account for clean energy preferences among large corporate energy consumers. Additionally, demand-side management options should be evaluated to reduce peak loads and improve grid stability.
Second, the IRP should reassess the contributions of renewable energy. Industry best practices suggest assigning non-zero winter capacity values for solar and wind, and modeling should be adjusted to reflect the growing reliability risks of thermal generation, particularly in extreme weather conditions.
Another crucial step is issuing competitive solicitations for renewable energy and storage projects. By conducting open Requests for Proposals (RFPs), utilities can gather real market data on renewable and storage costs, allowing for better-informed investment decisions. Competitive procurement would help identify the most cost-effective solutions for Kentucky’s energy needs.
LG&E and KU should incorporate regional market purchases and transmission planning into their strategy. The existing transmission network should be used more effectively to access lower-cost energy imports, and new transmission investments should be considered to improve access to regional renewable resources.
The Path Forward
Kentucky is at an energy crossroads, and the decisions made today will shape the state’s power landscape for decades. The concerns raised by SREA and The Brattle Group underscore the need for a more balanced approach—one that leverages the full potential of renewable energy, prioritizes cost-effective solutions, and ensures long-term grid reliability. By making these strategic adjustments, Kentucky can foster a more resilient, sustainable, and economically sound energy future.
