Southwestern Public Service Company Application to Convert Harrington from Coal to Gas

Sierra Club
Project Completed March 2022

Synapse provided expert testimony to support Sierra Club before the New Mexico Public Regulation Commission and the Public Utility Commission of Texas in the Southwestern Public Service Company’s (SPS) application to convert the Harrington Generation Station (Harrington) from coal to gas. Our testimony and analysis focused on reviewing the modeling and analysis presented by the company to support its application and evaluating the prudence of the company’s decision to convert Harrington to operate on gas, relative to retirement and replacement with alternatives. We found that the company made its decision to convert Harrington without properly testing the market for alternative resource options. Further, we found that the company locked ratepayers into continued reliance on Harrington by failing to begin procurement of replacement resources in a timely manner. Finally, we found that the company’s own modeling shows savings from converting only two of the three units to operate on gas and retiring the third, yet the company was still requesting to convert all three units.

We recommended that the Commission require the retirement of at least Unit 1, update and correct flaws in its modeling, and issue an RFP to determine if any replacement resources can be brought online in time to obviate the need to keep Harrington online. Testimony was filed in January 2022 in New Mexico and March 2022 in Texas.