To: Cynthia Hall, PRC Commissioner, Patrick Lyons, PRC Commissioner, Valerie Espinoza, PRC Commissioner, Lynda Lovejoy, PRC Commissioner, and Sandy Jones, PRC Commissioner

Cost benefit analysis needed before any further investment in and life extension of the San Juan ...

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On March 17, 2018, a coal silo collapsed at PNM’s San Juan Generating Station (“San Juan”) Unit 1 and caused an explosion and fire. Coal is highly flammable. Thankfully no one was injured. San Juan County fire
& rescue crews responded to the incident. The Unit 1 explosion has caused that unit to be inoperable.

Only one of PNM units – Unit 4 – is currently operational. PNM shut down Units 2 and 3 in December 2017 as a result of regional haze violations. On July 3, 2017, PNM filed an Integrated Resource Plan with the PRC,
concluding that its “Most Cost Effective Portfolio” for the future operations of PNM includes the full retirement of San Juan in 2022.

As a voter in New Mexico I urge the New Mexico Public Regulation Commission (PRC) to reject any further financial investment in and life extension of the San Juan coal plant given that:

1) Electricity produced at San Juan is currently more expensive than electricity purchased on the wholesale market by about double (according to PNM’s own testimony);
2) The cost of solar and wind power have continued to decline. New Mexico has some of the most productive solar and wind resource potential in the United States, which significantly improves the amount of energy generated for every dollar of capital investment;
3) Coal is the single greatest driver of climate chaos and in 2017 climate-related disasters caused a staggering $306 billion in total damages in the US, making last year by far the most expensive one on record for disasters in the country. Reducing carbon emissions from existing power plants is fundamental to mitigating against the worst impacts of climate disruption;
4) New Mexico is experiencing extended drought and coal-powered production is water intensive, and the San Juan coal plant consumes billions of gallons annually. Solar and wind use little to no water;
5) Coal-fire power production generates coal ash waste, which is a highly toxic material known to cause cancer and health defects. San Juan produces more than half a million tons of coal ash annually;
6) San Juan Unit 1 began operating in 1973, making the plant 45 years old. It requires constant capital improvements and pollution controls just to continue operating and to do so “safely”;
7) Investments in solar and wind (rather than extractive resources) will help our economy, will create jobs, are better for our environment, climate, and health;
8) Investments in solar and wind will help meet anticipated accelerated state renewable energy requirements;
9) More cost competitive solar and wind provide operational flexibility and energy security; and
10) Environmental and economic justice principles require that no further investments be made at San Juan which will exacerbate environmental and health hazards that disproportionately impact Native communities.

I urge you to reject any further investment in PNM’s San Juan coal plant and demand corporate accountability.

Why is this important?

According to PNM's own analysis, the San Juan Generating Station is not the most cost-effective resource option for New Mexicans. The fire and explosion in March have left Unit 1 inoperable. Before ANY money is spent on repairing the Unit, alternatives should be explored and a cost/benefit analysis should be provided to the New Mexico Public Regulation Commission and the public.