Dear New Mexico Public Regulation Commissioners,

Please consider this letter for public comment in support of 100% renewable replacement power for the retirement of San Juan Generating Station, Case No. 19 00195-UT.

As a voter in New Mexico I am pleased that PNM will close the San Juan coal plant. The issue of replacement power for the San Juan coal plant is perhaps the most important energy decision that must be currently addressed. It will have enormous consequences for at least the next 20 years.

PNM’s plan for replacement power includes the 280MW Piñon gas plant, with El Paso Natural Gas company providing the gas pipeline and supplying the take-or-pay gas contract.

An overwhelming consensus of scientific data warns that we must transition from fossil fuel dependency to renewables as quickly as possible to avoid catastrophic climate disruption. Investing in gas violates the letter and spirit of the Energy Transition Act. In addition to adverse warming impacts, including fires and drought, the combustion of gas will cause spills, leaks, and methane emissions which will cause public health consequences; the fracking of the gas will consume billions of gallons of clean water; and cause continuously rising electric rates.

El Paso Natural Gas company has an alarming history of accidents and violations:

• August 19, 2000  pipeline rupture and fire near  Carlsbad, New Mexico  killed 12 family members, incinerated them while they were camping. (https://www.bizjournals.com/albuquerque/stories/2002/09/16/story3.html In addition to tens of millions paid to the families of people who burned to death, El Paso Natural Gas paid $15.5 million fine as part of a settlement with the Department of Justice and pipeline safety regulators. (https://www.chron.com/business/energy/article/El-Paso-agrees-to-fine-settling-explosion-case-1820725.php;
  https://violationtracker.goodjobsfirst.org/violation-tracker/-el-paso-natural-gas-company
• March 23, 2003 pipeline explosion. The explosion sent flames 160 meters in the air, forcing evacuations. The heat from the flames melted the siding of two nearby homes and started many smaller grass fires. ("Re: CPF No, 5-20031002H" (PDF). Archived (PDF) from the original on October 28, 2013.)
• June 28, 2006 El Paso Natural Gas paid $225,000 to settle state and federal air quality regulations. (https://web.archive.org/web/20070418182524/http://www.azag.gov/press_releases/june/2006/ElPasoAgreement.pdf
• November 5, 2009 pipeline explosion left a hole about 30 yards by 20 yards and close to 15 feet (4.6 m) deep. The blast shook homes, melted window blinds and shot flames hundreds of feet into the air. The home nearest the blast — about 100 yards away- was destroyed, and 3 residents from those homes were injured. About 200 residents in the area were evacuated. ( https://www.nytimes.com/2009/11/06/us/06brfs-PIPELINEEXPL_BRF.html
• August 1, 2018 explosion occurred along lines that supplied gas to plants. The El Paso Natural Gas pipeline failed causing explosions. (https://www.reuters.com/article/us-texas-pipeline-fire/texas-investigators-probe-pipeline-blaze-that-injured-seven-idUSKBN1KN21R One person died, (https://www.cbs7.com/content/news/Officials-responding-to-major-fire-east-of-Midland-489779741.html five people were sent to hospital with critical burn injuries. (https://www.reuters.com/article/us-texas-pipeline-fire/natural-gas-pipeline-explosion-in-texas-critically-injures-five-idUSKBN1KM64N

By the end of the decade, battery storage will be the cheapest option for balancing the grid, overtaking gas peakers. Before the end of the “useful” life of the Piñon gas plant, energy storage will beat gas peakers on cost across all our energy markets, resulting in stranded assets for ratepayers.

What Is Wrong With PNM’s Continued Dependence on Gas:
� It is not the most cost-effective solution;
� It is not the best environmental outcome;
� It is not the best jobs outcome;
� It locks in fossil fuel when an avalanche of scientific data demonstrates that we must decarbonize all of power markets.

Costs for renewables plus storage have dramatically declined in cost! Renewables plus storage are available and feasible. We can no longer invest in gas. The good news is that it is not necessary. I urge you to deny PNM’s request for the Piñon gas plant and require PNM to replace the energy with aggressive energy efficiency and renewable energy plus storage.

Respectfully,