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BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION IN THE MATTER OF THE APPLICATION ) OF PUBLIC SERVICE COMPANY OF NEW ) MEXICO FOR APPROVAL TO ABANDON ) SAN JUAN GENERATING STATION UNITS ) 2 AND 3, ISSUANCE OF CERTIFICATES OF PUBLIC CONVENIENCE AND NECESSITY FOR REPLACEMENT POWER ) RESOURCES, ISSUANCE OF ACCOUNTING ) ORDERS AND DETERMINATION OF RELATED RATEMAKING PRINCIPLES AND) TREATMENT, ) ) Case No. 13-00390-UT ) ) ) PUBLIC SERVICE COMPANY OF NEW MEXICO, ) ) Applicant ) CONFIDENTIAL CONFIDENTIAL POST-HEARING BRIEF OF PUBLIC SERVICE COMPANY OF NEW MEXICO Public Service Company of New Mexico ("PNM") submits this Confidential Post- Hearing Brief in furtherance of its request that the New Mexico Public Regulation Commission ("Commission") approve the Stipulation filed on October 1, 2014, in this proceeding. I. INTRODUCTION The factual and pertinent procedural backgrounds underlying this case are set forth in The matters contained in this Confidential Post-Hearing Brief PNM's Post-Hearing Brief. address the confidential portions of the pre-filed testimony, exhibits and hearing transcript in this proceeding that are subject to the Protective Order and orders of the Hearing Examiner on confidentiality. This Confidential Brief deals primarily with the issue of a post-2017 fuel supply for the San Juan Generating Station ("San Juan") as it relates to PNM's request for a certificate of public convenience and necessity ("CCN") for an additional 132 MW in San Juan Unit 4. 1

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Page 1: BEFORE THE NEW MEXICO PUBLIC REGULATION …bloximages.newyork1.vip.townnews.com/santafenew...p. 7 and GV-8 Rebuttal Stip. Moreover, even assuming that the final purchase price for

BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION

IN THE MATTER OF THE APPLICATION ) OF PUBLIC SERVICE COMPANY OF NEW ) MEXICO FOR APPROVAL TO ABANDON ) SAN JUAN GENERATING STATION UNITS ) 2 AND 3, ISSUANCE OF CERTIFICATES OF PUBLIC CONVENIENCE AND NECESSITY FOR REPLACEMENT POWER ) RESOURCES, ISSUANCE OF ACCOUNTING ) ORDERS AND DETERMINATION OF RELATED RATEMAKING PRINCIPLES AND) TREATMENT,

) )

Case No. 13-00390-UT )

) )

PUBLIC SERVICE COMPANY OF NEW MEXICO,

) )

Applicant )

CONFIDENTIAL

CONFIDENTIAL POST-HEARING BRIEF OF PUBLIC SERVICE COMPANY OF NEW MEXICO

Public Service Company of New Mexico ("PNM") submits this Confidential Post-

Hearing Brief in furtherance of its request that the New Mexico Public Regulation Commission

("Commission") approve the Stipulation filed on October 1, 2014, in this proceeding.

I. INTRODUCTION

The factual and pertinent procedural backgrounds underlying this case are set forth in

The matters contained in this Confidential Post-Hearing Brief PNM's Post-Hearing Brief.

address the confidential portions of the pre-filed testimony, exhibits and hearing transcript in this

proceeding that are subject to the Protective Order and orders of the Hearing Examiner on

confidentiality. This Confidential Brief deals primarily with the issue of a post-2017 fuel supply

for the San Juan Generating Station ("San Juan") as it relates to PNM's request for a certificate

of public convenience and necessity ("CCN") for an additional 132 MW in San Juan Unit 4.

1

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II. THERE IS SUFFICIENT CERTAINTY CONCERNING A FUTURE FUEL SUPPLY FOR THE COMMISSION TO APPROVE

PNM'S REQUEST FOR THE 132 MW OF SAN JUAN UNIT 4

Section V.D.3 of PNM's Post-Hearing Brief addresses the non-confidential evidence

concerning the efforts of PNM and the other remaining San Juan owners to secure a post-2017

fuel supply for San Juan. To summarize, there are nearly three years left under the current

Underground Coal Sales Agreement ("UG-CSA") so there is no immediate issue with respect to

a fuel supply for San Juan. PNM Ex. 51, Rebuttal Testimony in Support of Stipulation and

Response Testimony on Reserved Issue of Chris M. Olson ("Olson Rebuttal"), p. 17. PNM and

the other remaining owners of San Juan recognize the importance of having sufficient certainty

concerning a cost-effective and reliable post-2017 fuel supply and they are in the process of

negotiating with the San Juan Coal Company ("SJCC") and BHP Billiton ("BHP") for a post-

2017 fuel supply. Id., p. 50. Due diligence has been undertaken with respect to the SJCC

underground coal mine and a solicitation was issued to qualified miners requesting an expression

of interest and indicative pricing for a coal supply. Id. p. 13; WRA Ex.4 (Confidential).

PNM and the other remaining San Juan owners have undertaken a thorough evaluation of

PNM Ex. 41 (Confidential), Confidential Response options for a post-2027 fuel supply.

Testimony on Reserved Issue of Gary Vicinus ("Vicinus Response"), p. 5. Potential fuel supply

options include: (1) the existing San Juan underground mine; (2) a proposed new surface mine

on the Ute Mountain Ute Tribe reservation; and (3) expansion of the existing Navajo Mine. Id.

pp. 5-6. One of the goals of pursuing these three options is to create competition among mines

and suppliers to ensure the most competitive, flexible and reliable source of coal supply given

San Juan's status as a mine mouth power plant. Id. p. 5

2

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The San Juan Coal Mine has been the exclusive supplier for San Juan since operations

commenced in 1971. PNM Ex. 50, Direct Testimony and Exhibits in Support of Stipulation of

Chris M. Olson ("Olson Direct"), p. 51. The existing SJCC underground mine has recoverable

coal reserves under its existing coal lease of some 58 million tons. 14 Tr. 3250-51 (1/23/15)

(Olson). There are also an additional 99 million tons available under what is known as the Twin

Peaks Extension. 14 Tr. 3251 (1/23/15) (Olson). The majority of the capital expended at the

SJCC underground coal mine has been depreciated and future capital expenditures are

anticipated to be lower than in the past. Vicinus Response, p. 6. So long as future capital

requirements can be amortized over a sufficient period of time, forecasted coal supply prices

could drop significantly. Id.

The Ute Mountain Ute option involves the development of a new surface coal mine. Id.

Negotiations with the Ute Mountain Ute Tribe have resulted in agreement on certain preliminary

terms and conditions such as royalty rates in lieu of taxes, exploratory drilling and development

of mining plans. 13 Tr. 3005 (1/22/15) (Olson); Vicinus Response, p. 6. Based on recent

testing, it is estimated that the Ute Mountain Ute option represents approximately 60 million tons

of coal reserves. 13 Tr. 2998 (1/22/15) (Olson). The coal quality from the Ute Mountain Ute

reservation is as good, or better, than coal from the San Juan underground mine. 13 Tr. 2998-99

(1/22/15) (Olson). This testing suggests that development of the Ute Mountain Ute option may

be a low-cost alternative to the SJCC underground mine and provides leverage in the ongoing

discussion with SJCC. Vicinus Response, p. 7. An in-service date of 2020 is achievable for the

proposed Ute Mountain Ute surface mine. 13 Tr. 3004 (1/22/15) (Olson).

3

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The potential expansion of the Navajo Mine, which currently supplies the Four Comers

Power Plant, is a third option. Yicinus Response, p. 7. However, this option is the least

desirable and has not been the focus of current efforts to secure a post-2014 fuel supply. Id.

At present, PNM and the other remaining owners are concentrating on negotiations with

SJCC and BHP for the early termination of the UG-CSA and the sale of the underground mine.

PNM and Tucson Electric Power entered into Id. at 8; 13 Tr. 3012 (1/22/15) (Olson).

Amendment No. 6 to the UG-CSA with SJCC and BHP to facilitate these negotiations and the

associated due diligence for the sale of the SJCC underground coal mine. Olson Rebuttal, p. 50.

As noted in PNM's Notice of Status of Fuel Negotiations, on February 12, 2015, the San Juan

owners voted unanimously to extend the period for negotiations with SJCC and BHP to May 1,

2015. The proposed extension contemplates a sale of the SJCC underground coal mine to a

third-party mining company.

PNM and the other remaining owners received indicative pricing for a post-2017 coal

supply in December 2014 from two mining companies, Bowie and Westmoreland. 12 Tr. 2944-

2945 (1/21/15) (Olson); WRA Ex. 3 (Confidential). Bowie provided a cost-plus proposal for

coal and Westmoreland provided an indicative price of $53.64 per ton of coal which is less than

or close to the current price for coal from the SJCC underground mine. 12 Tr. 2957-59 (1/21/15)

Westmoreland also communicated in its bid that following due diligence and (Olson).

negotiation, the price for coal could be reduced further. 12 Tr. 2958 (1/21/15) (Olson).

Phase I of the implementation of the San Juan fuel supply strategy process involved due

diligence by PNM and the other remaining owners and obtaining indicative coal pricing for a

post-2017 fuel supply which has now been completed. 13 Tr. 3025 (1/22/15) (Olson). The next

step in the process involves continued due diligence and site visits by the mining companies and

4

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the issuance of the Phase 2 bid instructions to the prospective coal mining companies. 14 Tr.

3249 (1/23/15) (Olson). This is to be followed shortly thereafter with the issuance of proposed

form contracts for the transaction including a draft of a purchase and sale agreement for the sale

of the mine and draft fuel supply agreement. Id. These documents spell out the terms and

conditions for going forward in the bidding process. 14 Tr. 3250 (1/23/15) (Olson). Since

submitting their indicative pricing, the mining companies have been conducting due diligence in

connection with their potential purchase of the SJCC underground coal mine and development of

final coal pricing. 12 Tr. 2956 (1/21/15) (Olson). The goal is to have firm coal pricing estimates

in March 2015. 14 Tr. 3249 (1/23/15) (Olson).

Important for the Commission's consideration is that the indicative coal pricing is less

than the coal pricing used in PNM's replacement resource planning analysis. Vicinus Response,

p. 7 and GV-8 Rebuttal Stip. Moreover, even assuming that the final purchase price for the

SJCC underground mine is $180 million as advanced by SJCC, the coal price would still only be

about $2.95/MMBtu which is less than the pricing assumption of $3.25/MMBtu used in Mr.

O'Connell's portfolio analyses. 9 Tr. 1959-60 and 1968-70 (1/15/15) (Vicinus). Therefore, the

additional 138 MW capacity in San Juan Unit 4 is likely to be even more cost-effective than

shown in PNM's portfolio analysis.

As noted in Section Y.D.3 of PNM's Post-Hearing Brief, the Stipulation opponents have

attempted to raise questions about the likelihood of PNM and the other San Juan owners

concluding a fuel supply agreement with SJCC and BHP as a basis to deny the CCN for the

additional 132 MW interest in San Juan Unit 4. Although successful negotiations with SJCC and

BHP are the preferred outcome, if an agreement is not reached, this would not leave San Juan

5

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without a post-2017 fuel supply. A "Bridge Coal Supply" strategy has been developed to assure

a continued fuel supply for San Juan. Vicinus Response, p. 9; WRA Ex. 5 (Confidential).

The two very viable sources for a post-2017 fuel supply for San Juan in the worst-case

scenario of a failure to reach agreement with SJCC and BHP are the SJCC underground mine

and the proposed surface mine on the Ute Mountain Ute reservation. Vicinus Response, pp. 10-

Under the UG-CSA, SJCC must sell its assets at the greater of market price or the 11.

undepreciated net book value. Id. p. 10. It is estimated that the Ute Mountain Ute surface mine

can be developed and in production by 2020. 13 Tr. 3004 (1/22/15) (Olson). However, under

either of these scenarios there may be a need for an interim or "bridge" supply of coal until the

buyout price is determined for the SJCC underground mine or the Ute Mountain Ute surface

mine commences production. Vicinus Response, p. 9.

The fuel supply options available during any potential bridge period include building up

the coal inventory produced from the SJCC underground mine and obtaining coal from the

Navajo, El Segundo and/or Kayenta Mines. Id. pp. 11-12. Taking into account the cost of coal

from these alternative sources, including transportation, and the cost of building an inventory

from the SJCC mine, the average cost of the bridge supply coal would be approximately

$3.11/MMBtu. Id. p. 14; 8 Tr. 1667 (1/14/15) (Vicinus). Again, even with the higher coal costs

during the temporary bridge period until a permanent supply could be secured from either the

underground mine or the Ute Mountain Ute surface mine, the costs are in line with those used in

PNM's resource portfolio modeling. Vicinus Response, p. 25; Ex. GV-8.

III. CONCLUSION

The foregoing represents a viable and well-executed fuel supply strategy that will allow

the owners of San Juan to timely obtain the necessary certainty concerning coal supply and

6

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pricing to conclude the final ownership restructuring necessary to implement the Revised SIP.

The strategy introduces elements of market competition and considers the risks of future market

and regulatory conditions. Id. at 27. It also includes a back-up plan that will ensure a reliable

supply of coal at a reasonable cost. Id. The post-2017 fuel supply strategy provides the requisite

certainty for the Commission to issue a CCN for the 132 MW of capacity in San Juan Unit 4

pursuant to the terms of the Stipulation.

Respectfully submitted this 16th day of February 2015,

PUBLIC SERVICE COMPANY OF NEW MEXICO

Benjamin Phillips Associate General Counsel PNM Resources, Inc. Corporate Headquarters - Legal Department Albuquerque, NM 87158-0805 Phone: 505-241-4836 Ren.Philli ps@pnmresources. com

Bradford A. Borman Senior Corporate Counsel PNM Resources, Inc. Corporate Headquarters - Legal Department Albuquerque, NM 87158-0805 Phone: 505-241-4864 Bradford. B orman@pnmresources. com

Richard L. Alvidrez Miller Stratvert P.A. 500 Marquette NW, Suite 1100 P.O. Box 25687 Albuquerque, New Mexico 87125 Phone: (505) 842-1950 Fax: (505)243-4408 ral vidrez@mstlaw. com

7

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Patrick T. Ortiz Cuddy & McCarthy, LLP 1701 Old Pecos Trail P.O. Box 4160 Santa Fe, New Mexico 87502-4160 Phone: (505)954-7323 Fax: (505)954-7373 portiz@,cuddvmccarthv.com

Attorneys for Public Service Company of New Mexico

#519413

8

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BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION

IN THE MATTER OF THE APPLICATION ) OF PUBLIC SERVICE COMPANY OF NEW ) MEXICO FOR APPROVAL TO ABANDON ) SAN JUAN GENERATING STATION UNITS ) 2 AND 3, ISSUANCE OF CERTIFICATES OF PUBLIC CONVENIENCE AND NECESSITY FOR REPLACEMENT POWER ) RESOURCES, ISSUANCE OF ACCOUNTING ) ORDERS AND DETERMINATION OF RELATED RATEMAKING PRINCIPLES AND) TREATMENT,

) )

Case No. 13-00390-UT )

) ) ) PUBLIC SERVICE COMPANY OF NEW

MEXICO, ) )

Applicant )

CERTIFICATE OF SERVICE

I hereby certify that the Confidential Post-Hearing Brief of Public Service Company of New Mexico was mailed first-class, postage-paid, or hand-delivered on February 16, 2015 to the following persons whose mailing addresses are listed below and emailed to those persons at the email addresses shown below:

Bradford Borman, Esq. PNM Resources, Inc. Corporate Headquarters - Legal Department

Benjamin Phillips, Esq. PNM Resources, Inc. Corporate Headquarters - Legal Department

Albuquerque, NM 87158-0805 Albuquerque, NM 87158-0805 Bradford.Borman@,pnmresources.com Ben.Phillips@,pnmresources.com

Nann M. Winter, Esq. Stelzner, Winter, Warburton, Flores, Sanchez

Cholla Khoury, Esq. Assistant Attorney General Office of the Attorney General & Dawes, P.A.

P. O. Box 528 PO Drawer 1508 Albuquerque, NM 87103-0528 Santa Fe, NM 87504-1508 nwmter@ste1 /,nerlaw.com ckhourv@,nmag. gov

[email protected]

Peter J. Gould, Esq. PO Box 34127

Patrick T. Ortiz, Esq. Cuddy & McCarthy, LLP PO Box 4160 Santa Fe,NM 87594-4127

p gouldlaw@. gm ail. com Santa Fe,NM 87502-4160 [email protected]

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Lisa Tormoen Hickey Alpern Myers Stuart LLC 14 N. Sierra Madre, Suite A

Steven S. Michel, Esq. Western Resource Advocates 409 E. Palace Ave., Unit 2 Santa Fe,NM 87501 Colorado Springs, CO 80903

[email protected] smichel@westemresources .org

Charles F. Noble, Esq. CCAE

Donald E. Gruenemeyer, P.E. Sawvel & Associates, Inc. 100 East Main Cross Street, Suite 300 409 E. Palace Ave., Unit #2

Santa Fe,NM 87501 Findlay, Ohio 45840-4889 Noble@,energvenvironnientlaw. com [email protected]

Nicholas Schiavo Acting Public Utilities Director City of Santa Fe 801 W. San Mateo

Marcos D. Martinez City Attorney Office City of Santa Fe P. O. Box 909

Santa Fe,NM 87505 Santa Fe,NM 87501 naschiavo@,santafenm. gov mdmartinez@,santafemn. gov

James R. Dittmer Utilitech, Inc. 623 NE Saint Andrews Circle

Rachel Brown Santa Fe County Attorney's Office 102 Grant Avenue

Lee's Summit, MO 64064 Santa Fe,NM 87501 i [email protected] rabrown@santafecountvnm. gov

Daniel R. Dolan Dolan & Associates

Bruce C. Throne, Esq. 1440-B South St. Francis Drive

3321 Candelaria NE #126 Santa Fe,NM 87505 Albuquerque, NM 87107 bthroneattv@,newmexico. com [email protected]

Jeffrey H. Albright, Esq. Michael I. Garcia Lewis Roca Rothgerber LLP Assistant County Attorney, Sr.

Bernalillo County Legal Department 201 Third Street NW, Suite 1950 Albuquerque, NM 87102 i albright@,lrlaw. com

520 Lomas Blvd. NW, 4th Floor Albuquerque, NM 87102 mikgarcia@bemco. gov

Hand Deliver To: Elisha Leyba-Tercero New Mexico Public Regulation Commission 1120 Paseo De Peralta

Hand Deliver To: Dwight Lamberson New Mexico Public Regulation Commission 1120 Paseo De Peralta

Santa Fe,NM 87501 Santa Fe,NM 87501 Elisha.levba-tercero@,state.nm.us Dwight.Lamberson@,state.nm.us

2 GCG# 519407

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Hand Deliver To: Charles Gunter New Mexico Public Regulation Commission 1120 Paseo De Peralta

Hand Deliver To: Patrick L. Lopez New Mexico Public Regulation Commission 1120 Paseo De Peralta

Santa Fe,NM 87501 Santa Fe,NM 87501 Charles. Gunter @.state .nm.us Patrick.lopez@,state.mn.us

Hand Deliver To: Ashley Schannauer New Mexico Public Regulation Commission 1120 Paseo De Peralta

Hand Deliver To: Cydney Beadles New Mexico Public Regulation Commission 1120 Paseo De Peralta

Santa Fe,NM 87501 Santa Fe,NM 87501 Ashley. [email protected] [email protected]

Hand Deliver To: Commissioner Patrick H. Lyons New Mexico Public Regulation Commission 1120 Paseo De Peralta

Hand Deliver To: Commissioner Karen L. Montoya New Mexico Public Regulation Commission 1120 Paseo De Peralta

Santa Fe,NM 87501 Santa Fe,NM 87501 Patrick.Lvons@,state.nm.us Karen.Montova@,state.mn.us

Hand Deliver To: Commissioner Linda Lovejoy New Mexico Public Regulation Commission 1120 Paseo De Peralta

Hand Deliver To: Commissioner Valerie Espinoza New Mexico Public Regulation Commission 1120 Paseo De Peralta

Santa Fe,NM 87501 Santa Fe,NM 87501 Lmda.Loveiov@,state.nm.us Valerie.Espinoza@,state.nm.us

Hand Deliver To: Commissioner Sandy Jones New Mexico Public Regulation Commission 1120 Paseo De Peralta Santa Fe,NM 87501 Sandy. Jones@,state.nm.us

Email Only:

Robb Hirsch Susan C. Kery sck@,sheehansheehan. com [email protected]

Mark Fenton Mar 1c. F ento n @ n mn .com

Anthony Sisneros Anthony. [email protected]

David Van Winkle david@,vw7 7. com

Thomas Wander Thomas. W ander@pnmresources. com

3 GCG# 519407

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Mariel Nanasi, Esq. Mariel@,seedsbeneaththesnow.com

Noah Long [email protected]

Josh Ewing, Esq. John W. Boyd, Esq. [email protected] [email protected]

Joseph A. Herz i aherz@,sawvel. com

Bruno Carrara Bruno.carrara@,state.nm.us

James Cotton Andrea Crane ctcolumbia@aol. com

Glenda Murphy gmurphy@,westemresources. org

Vincent DeCesare Vincent.decesare@,state.nm.us

Michael Dirmeier mdirmeie@gmail. com

John M. Stomp III Dahl Harris dah 1 h arri s @hotmail .com i stomp@,abcwua.org

Maurice Brubaker [email protected]

Jack Sidler Jack.sidler@,state.nm.us

Adam Baker [email protected]

James Dauphinais jdauphinais@,consultbai.com

David Rode drode@daimc. com

Jay Kumar ikumar@,etcinc.biz

Antonio Paez apaez@,daimc. com

Pete Lewis [email protected]

Douglas Gegax [email protected]

Alex Dreisbach adreisbach@,daimc.com

Erin Overturf, Esq. Erin. overturf@,westernresources. org

Dated this 16th day of February, 2015.

By: Mark Fenton, Director Regulatory Policy & Case Management Public Service Company of New Mexico

4 GCG# 519407

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Mariel Nanasi, Esq. Mariel@,seedsbeneaththesnow.com

Noah Long [email protected]

Josh Ewing, Esq. ie@, fbdlaw.com

John W. Boyd, Esq. iwb@,fbdlaw.com

Joseph A. Herz i aherz@sawvel. com

Bruno Carrara Bruno. carrara@,state .nm.us

James Cotton Andrea Crane ctcolumbia@,aol.com

Glenda Murphy [email protected]

Vincent DeCesare Y incent.decesare@,state.nm.us

Michael Dirmeier mdirmeie@gmail. com

John M. Stomp III Dahl Harris dah 1 h arris @hotmail .com i [email protected]

Maurice Brubaker mbrubaker@,consultbai.com

Jack Sidler Jack.sidler@,state.nm.us

Adam Baker [email protected]

James Dauphinais i dauphinais@,consultbai. com

David Rode [email protected]

Jay Kumar [email protected]

Antonio Paez [email protected]

Pete Lewis plewis@,daimc. com

Douglas Gegax [email protected]

Alex Dreisbach adreisbach@daimc. com

Erin Overturf, Esq. Erin. overturf@westernresources. org

Dated this 16th day of February, 2015.

J 7 By: Mark Fenton, Director Regulatory Policy & Case Management Public Service Company of New Mexico

4 GCG# 519407