Testimony on Xcel Colorado's Energy Resource Plan

Clients: Natural Resources Defense Council and Sierra Club

Author: Tyler Comings

October 2021

Senior Researcher Tyler Comings filed testimony on Xcel's Colorado's Energy Resource Plan (ERP), focusing on the utility's decisions for two of its coal units--Comanche unit 3 and Pawnee. Mr. Comings' testimony found that earlier retirement of Comanche unit 3 and earlier conversion of Pawnee were lower cost. He provided inputs to modeling performed by Dr. Maria Roumpani at Strategen Consulting which quantified more than $1 billion in savings (including carbon costs) from their alternative plan compared to Xcel's ERP.

Link to Answer Testimony

Link to Cross Answer Testimony

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Testimony on Stranded Costs of Public Service Company of Colorado's Comanche 1&2 Coal Units

Client: Sierra Club

Tyler Comings

March and July 2018

On behalf of Sierra Club, Senior Researcher Tyler Comings provided an Applied Economics Clinic testimony on March 2018 in Docket No. 17A-0797E. Mr. Comings provides an expert opinion on the Public Service Company of Colorado's application to accelerate the depreciation of Comanche Units 1 and 2 and the associated rate plan to offset this expense. He concludes that the accelerated depreciation of Comanche Units 1 and 2 and offsetting mechanism is in the public interest; the success of the Renewable Energy Standard Adjustment has afforded the Company the opportunity to offset the accelerated depreciation; and the Company's proposal is reasonable but should consider other options for future stranded assets. In his July 2018 surrebuttal testimony, Mr. Comings responds to criticisms raised in cross-answer testimony, concluding that the retirement of Comanche coal-fired Units 1 and 2 saves money and reduces risks to ratepayers.

Link to Tyler Comings' July 2018 Surrebuttal Testimony

Link to Tyler Comings' March 2018 Answer Testimony

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The Future of the Martin Drake Power Plant

Client: Green Cities Coalition and Southeastern Colorado Renewable Energy Society

Tyler Comings and Bryndis Woods

November 2017

On behalf of Green Cities Coalition and Southeastern Colorado Renewable Energy Society, Senior Researcher Tyler Comings and Researcher Bryndis Woods prepared an Applied Economics Clinic report regarding the Martin Drake Power Plant. The Colorado Springs City Council has ordered that Martin Drake units 6 and 7 should be decommissioned no later than December 31, 2035, and that it would consider earlier dates. In response, Colorado Springs Utilities (CSU) is evaluating 2025 or 2030 decommissioning for units 6 and 7. Based on the information available to us, we conclude that the CSU Board should consider Martin Drake for decommissioning earlier than 2035—and certainly prior to making large capital investments in the plant—due to: the plant's inefficiencies, more efficient competition both now and in the future, failure to adequately consider alternatives, the ability to rely on regional supply, and the health impacts associated with the plant's location in a city center.

Link to Report News Coverage

Link to Report

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