My mom thinks I battle uber-sophisticated lawyers who got lucrative gigs in the fossil fuel industry b/c they're the smartest guys in the room. Reality of fighting El Paso Electric's proposed new gas plant is they got sloppy from going too long w/o opposition.

A...

Example 1: The NM renewable portfolio standard requires 100% of energy for NM customers to come from carbon-free resources by 2045. In its analysis to justify a new gas plant, EPE assumes they can keep charging NM customers for this boondoggle at least 40 years.

Is it sloppy for a utility to ignore a state's clean energy laws when it proposes to a massive new investment in fossil fuels? Yes. But from the utility's perspective, they think they can gamble with the ratepayers' money, so why not?

Example 2: they kneecapped solar from competing against their gas plant by pretending solar's capacity value is 25%. According to their own experts, solar's capacity value will hit 25% *after* they install 3.5x more solar than they have now.

Example 3: they prevented wind resources from competing against their gas plant by pretending wind has 0 capacity value. But EPE's own experts at E3 calculated a 17% capacity value from wind alone + more if they combine wind with solar.

Example 4: EPE could not have proposed this plant w/o shameless self-dealing. EPE's affiliate had originally bid a 327 MW CCGT at Newman Station. After the bid deadline EPE asked itself for the price of a CT at that site. The Newman CT "bid" won a supposedly competitive process.

Example 5: EPE's own experts at E3 identified a portfolio that would have allowed EPE to operate its system reliably AND save customers $$, while building less than a 1/4 of the proposed new gas capacity. EPE provided ZERO explanation for rejecting this portfolio.

The good news is that the New Mexico Public Regulatory Commission will have the opportunity to reject this dirty and wasteful investment. Stay tuned. Decision expected in November.