Client: Sierra Club
Authors: Bryndis Woods, PhD
February 2026
On behalf of Sierra Club, Principal Analyst Dr. Bryndis Woods filed testimony before the Texas Public Utility Commission regarding SPS's Application to amend its Certificate of Convenience and Necessity (CCN) to construct eight new generation facilities totaling over 4,100 megawatts in Texas and New Mexico.
Dr. Woods' direct testimony evaluates three issues in SPS’s Application: 1) the claim that additional generating capacity is needed to serve large-load interconnection requests; 2) the Company's approach to pursuing solar and wind resources; and 3) the potential impacts of the forthcoming expansion of SPS’s regional grid operator, Southwest Power Pool (SPP). Dr. Woods' recommendations included that the Commission require SPS: include only contractually committed new loads in its base load forecast; establish consumer protections for new large loads; utilize available surplus interconnection capacity to develop additional wind and solar projects; and assess the potential impacts of SPP's expansion.
Dr. Woods' cross-rebuttal testimony focused on additional issues in the proceeding, including that: SPS's Island Case modeling should not be used to make determinations regarding resource reliability; battery storage projects contribute significantly to grid reliability during extreme winter weather events; new gas pipeline capacity in the Permian Basin favors retirement of coal-fired units at the Tolk plant; and any extension of Tolk's coal-fired units would entail significant costs.