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Story/photos by Allen Best

Trucks roll through downtown Springfield and Lamar, in southeastern Colorado, day and night, ferrying goods on Highway 287 from the port at Houston to Denver and other interior locations.

Those same communities also want to be part of an electric highway, one that transmits power produced on the windy plains of southeastern Colorado to urban markets along the Front Range.

“The chance to fully participate in providing electricity needed and desired by the Front Range of Colorado seems like a once-in-a-generation opportunity,” say the commissioners of Baca, Prowers, and Las Animas counties in a letter submitted on Oct. 1 to the Colorado Public Utilities Commission.

The commissioners of the three counties cite long-term economic benefits “that can only be realized if transmission is available.” They say wind farms can provide a “stable generator of tax revenue coming from a source that requires almost no county services, once built and operational.” They call it a “dream come true.”

Filings submitted to the PUC suggest that the farm-based counties of southeastern Colorado will get their wish, if not immediately.

But it’s complicated—very, very complicated. And expensive.

Xcel Energy wants to spend $2.2 billion to $2.3 billion on new 345-kV transmission lines that will loop around eastern Colorado to connect to new generating sources, primarily wind but also some solar. Xcel calls it the Colorado Power Pathway. An extension would allow the wind of far-southeastern Colorado to be tapped.

Tied at the hip to this new transmission proposal is another plan by Xcel Energy to add massive amounts of new generation, primarily wind and solar in eastern Colorado, but some solar on the Western Slope (and conceivably in the San Luis Valley) and then also acquire existing natural gas plants. Xcel has not reported a cost estimate of this new generation, but a report to investors in early November assures them healthy returns.

The three PUC commissioners must decide in the next few months whether Xcel’s plans are the best for the 3.3 million Coloradans who get electricity from the company. The PUC filing system on these two inter-related dockets already exceeds 2,000 separate documents.

This likely is the biggest PUC decision since 2004, when a different set of commissioners authorized construction of $1 billion coal plant in Pueblo called Comanche 3.

The future of that plant—and past—are now being hotly debated. Comanche 3 was originally projected to operate until 2070. Xcel, the operator and majority owner, now wants to put it on the bench, a part-time performer, beginning in 2030 and close it by 2040. Others think it should be sent to the locker room by 2027. Still unclear is who will pay.

An important development in the discussion occurred on Nov. 9 when many of the major stakeholders—the Colorado Energy Office, Western Resource Advocates, Colorado Solar and Storage Association, Pueblo County and the staff of the PUC, among others—recommended approval of Xcel’s transmission plans substantially as proposed.

Xcel, they said, “has met its burden of proof of demonstrating that the Pathway Project” is needed. The settling parties recommend conditional approval for the extension to the farms and ranches of far-southeastern Colorado.

Consumer groups have also delivered a recommendation, this one an alternative to Xcel’s plan. This partial stipulation comes from consumers: the Colorado Office of the Utility Consumer Advocate, Climax Molybdenum Co., and Colorado Energy Consumers. It advises the PUC commissioners to allow Xcel to build just one segment of Xcel’s 5 proposed segments at first, and with strong incentives to save, not spend, money. It calls for phasing of construction, including the extension to far-southeastern Colorado.

The PUC commissioners are under no obligation to accept any of the proposals.

This is from Big Pivots 48 (Nov. 15, 2021). Have issues of the e-journal delivered to your e-mail box by signing up for a subscription.


Today (Nov. 15), they listened as Xcel representatives were questioned by attorneys from various groups, then quizzed the Xcel representatives themselves. Their questions indicated they had been following the arguments and had some thoughts of their own.

John Gavan, for example, wanted to know the vulnerability of Chinese-manufactured transmission hardware to cybersecurity threats. Gavan also asked a question that revealed the final costs of what Xcel proposes for transmission could cost upward of $2.2 to $2.3 billion. The hearing continues at least until Wednesday afternoon, perhaps to be continued at a later date.

One long-time observer of the PUC describes the current commissioners—Gavan, of Paonia, Megan Gilman of Edwards, and Eric Blank of Boulder—as “wickedly smart,” with both brains and backbone.

Xcel’s proposed Colorado Power Pathway transmission lines would create a semi-circle in eastern Colorado: extending from the St. Vrain power plant near Greeley east to Yuma, then south to the Lamar area. From there, it would march west along the Arkansas Valley to connect to the massive transmission lines in the Pueblo area that feed power to metropolitan Denver.

Joined at the hip, or at least the substation, to this transmission freeway are Xcel’s plans for new generation to replace closing coal plants and to meet burgeoning demand expected in the next decade and perhaps beyond.

That’s the big picture for consideration of the 90-mile extension of a transmission line from the substation north of Lamar called May Valley to a substation close to Springfield called Longhorn.

“Landowners in southeast Colorado would love to have the ‘mailbox money’ that comes with renewable energy development on their farms and ranches,” the letter from the county commissioners says. “Those who currently have development will happily tell anyone that drought, hail, and commodity prices have no effect on the royalty payments they get from wind towers. A steady source of income is welcome to almost any operation.”

As was noted in a June 2020 story by Big Pivots, maps from the National Renewable Energy Laboratory show Colorado’s southeastern corner as a blob of red for annual average wind speeds at 30 meters. At 80 meters above ground, the blob broadens and turns purple.

Nate Blair, manager of the distribution system and storage analysis group at NREL, said the theoretical potential of the wind generation from Baca County alone was nearly as great as the total summertime generating capacity from all the coal, gas, and other generating sources across Colorado as of 2017.

Colorado’s first major wind farm, Colorado Green, located about 15 miles south of Lamar, began production in 2003. It was at the time the nation’s fifth largest wind farm.

But even better wind resources lie to the south in Baca County. It was at the very heart of the Dust Bowl of the 1930s.

Timothy Egan, who wrote “The Worst Hard Time,” stopped by Denver’s Tattered Cover for a reading in 2006. He said Baca County gave him his very best material. The book went on to win the National Book Award for Non-Fiction.

Following the success of Colorado Green, two wind developers Iberdola and Baca Green Energy, jointly leased 42,000 acres of farms and pastures.  Towers were erected to test the steadiness and velocity of the wind. There was plenty of wind, but it was stranded. Existing transmission lines were inadequate to ferry any more electricity to markets. For Xcel Energy, Tri-State Generation and Transmission, and other utilities, the lowest-hanging fruit and hence the most easily plucked lie along existing transmission lines. The wind developers let the leases lapse.

It’s useful to compare Colorado today with the Colorado of 2003, when Colorado Green came on line. No renewable portfolio mandate had been adopted then. Indeed, Xcel Energy was assembling plans for Comanche 3. The coal-fired power plant at Pueblo was formally approved by the Colorado PUC in early 2005. That was just two months after Colorado voters approved the first tepid renewable energy mandate of 10% by 2015.

Xcel famously opposed the amendment then blew past it and several more that were adopted by legislators. Wind prices tumbled and Xcel, and other utilities, became more comfortable integrating it into the power generating mix without sacrificing reliability or cost.

By 2016, the company was willing to step more boldly into renewable energy on its own. Even the most ardent renewable energy advocates were shocked in late 2017 when the company revealed the low, low bids it had received for wind, solar and battery storage. Wind routinely undercut the cost of coal, and even solar was competitive.

The next year, U.S. Rep. Jared Polis ran for governor of Colorado on a platform of 100% renewable generation by 2040. He won convincingly.

A month after his election he showed up at an event at the Denver Museum of Nature and Science sponsored by Xcel Energy. David Eves, then the Xcel CEO, announced that the company believed the technology existed to achieve 80% reduction in carbon emission from its generating sources by 2030 as compared to 2004 levels. Further, he said, Xcel was willing to set a goal of zero emissions by 2050, making a leap of faith that technology would be devised in the intervening 30 years to achieve that.

During his time at the lectern, the governor-elect Polis said elections have consequences, and he pointed to his election as a catalyst for Xcel’s action.

That 2018 election has had enormous consequences in the Legislature. Before, the Republican-dominated Senate had effective veto power over the more ambitious climate and energy legislation. Democrats gained a majority in both chambers in that election. Together with an occasional Republican ally (See: “How Kevin Priola became a reliable vote for energy & climate legislation in Colorado.”) legislators passed SB 19-261, setting a goal for decarbonizing the economy 50% by 2030 (and 90% by 2050). Another, almost equally important bill required Xcel to achieve an 80% reduction in carbon emissions by 2030. Dozens more energy- and climate-related bills have been passed since then.

The general plan is to decarbonize electricity to replace the use of fossil fuels in other sectors, transportation, buildings and more.

That, in turn, makes development of wind in southeastern Colorado more likely.

I-25 at dusk, Nov. 12, 2021

Transportation has become Colorado’s second largest source of greenhouse gas emissions, but the state hopes to have nearly a million electric cars on the roads by 2030 and has been taking steps to electrify medium- and heavy-duty vehicles.

In early May, I drove to Walsh, a town 518 people in southeastern Colorado. Like nearly all small towns on the Great Plains, it’s shrinking. It has been for the better part of a century. Mechanized agriculture has required fewer workers and caused farms to be consolidated. Since 2000, the town has lost a quarter of its population.

Gone are the two cafes that people can remember, and the 11-man football team has dwindled to 6-man, with just 7 turning out the year before last, when I checked. A grocery store remains in operation, but only because of creation of a cooperative. The private sector wasn’t interested. There just aren’t enough shoppers any more.

In their October letter to the PUC, the commissioners in the three-county area cited job creation of wind generation, a strategy to stanch this population erosion.

“For our communities, the full-time jobs with benefits that come with development means that there will be careers at home for our kids so that they can stay here. Most people think that agricultural products are our most valuable export from rural communities, but those of us who live here know that the most valuable export is our children who move away for greater opportunities,” the letter says.

“Every 35 wind towers, give or take, is a full-time job that can be filled by someone from our community.”

Those who remain are Fred and Kay Lynn Hefley. They own 6,000 acres and lease 1,000 acres in Baca County. They grow corn irrigated with water from the underlying Ogallala Aquifer as well as dryland wheat and grain sorghum.

They had written a letter to the PUC in 2018 that I happened to notice. They were unhappy that Tri-State Generation and Transmission, the wholesale provider for their local electrical provider, had not stepped away from coal to develop their wind.

Others had also recognized the potential of renewables in southeastern Colorado. In 2009, the Colorado Energy Office had commissioned a study called REDI (Renewable Energy Development Infrastructure) that noted the wind potential of southeastern Colorado. Utilities had met for several years to talk about a transmission line that could have carried wind from Wyoming down far-eastern Colorado and eventually to the Southwest. Nothing much came of all this.

With Fred driving his pickup, we went to the site of one of the four 80-foot wind turbines erected over a decade ago as the result of grants awarded by the Colorado Department of Agriculture and the Natural Resources Conservation Council, a federal agency. Kansas, he said, was maybe 12 miles to the east and Oklahoma a similar distance south.

Returning to Walsh, we drove along a fence with dust piled two wires high. On farm and ranches of southeastern Colorado altogether, the margins between prosperity and peril seem always to be thin, a constant dialogue between hope and discouragement.

In early November, I talked with the Hefleys again, this time by phone. They seemed heartened. Xcel Energy had held a meeting in Springfield, the county seat of Baca County 21 miles to the east. “We are hopeful,” they said, “but we are not hoping for it tomorrow. (Xcel representatives) said it would be 5 or 6 years before they would ever get this far, to Walsh. I believe they are truly working on it.”

Fred and Kay Lynn Hefley

Fred and Kay Lynn Hefley at their farm south of Walsh, about 12 miles from Kansas and Oklahoma.


But the PUC commissioners will have the final say on that. Since March, thousands and thousands of pages of testimony have been filed, of which I have read just a few hundred.

Alice Jackson, the chief executive of Xcel’s Colorado division, in her Oct. 22 rebuttal testimony, nicely laid out the scope of what is underway in Colorado.

“The clean energy transition is occurring in stages, with changes to the bulk electric system and the way it behaves at each stage, from the type of power injected to where it is injected,” she said.

“Colorado can show the rest of the country how to take the next step in the clean energy transition in a reliable and affordable manner. Transmission infrastructure is a key part of that next step, enabling the collection and utilization of all forms of clean energy to advance decarbonization across various sectors of the economy.”

In the past, transmission and generation were treated somewhat separately by the PUC. This presented what was commonly described as the “chicken or egg” dilemma. Build the transmission and then figure out the generation, or vice versa? This time, the PUC is looking at the plans by Xcel for massive new amounts of wind and other renewable generation at the same time it looks at the transmission necessary to get it to where it is needed. They are, as Jackson notes in her testimony, joined at the hip.

The end game is closing coal plants: Hayden by the end of 2027, the unit at Craig of which it is part owner by 2028, and converting Pawnee, the plant at Brush, to natural gas.

Questions abound. For example, why haven’t Tri-State, Colorado Springs, or any other utilities chosen to join Xcel in its transmission? Jackson says just because the other utilities have not chosen to join Xcel in this new transmission highway—for reasons not publicly identified—does not mean they can’t get on the on-ramp once its built.

Could Xcel use existing transmission to add more renewables? That’s one criticism. Another criticism is that the system has not been configured in a way that will most advantageously add the best renewables in the next several decades.

And there are questions whether Xcel, being in a hurry to get this new transmission built by 2027, in order to get the new renewable generation on line by 2030, is looking past some potentially game-changing technology.

Lafayettte resident Larry Miloshevich argues in a 97-page filing that Xcel’s existing transmission system can deliver more renewables than Xcel gives it credit for. A Lafayette resident, Miloshevich spent 20 years at the National Center for Atmospheric Research, where he researched cloud physics and atmospheric water vapor. Since 2016, though, he has been following proceedings at the PUC where, he says in his Sept. 22 filing, he advocates in favor of “forward-looking measures that accelerate the transition to renewable energy in cost-effective ways.” Unlike nearly all those who intervene in PUC proceedings, he has no legal training.

In essence, Miloshevich makes the case that Xcel proposes to use 20th century technology when better is now available.

Both Xcel and the Colorado Energy Office suggest new technology may be appropriate to discuss in coming years, but not now. In fact, the major thrust of Jackson’s testimony is that this is not time for what-if dawdling.

“We cannot—and should not—study potential options in perpetuity,” she wrote.

“The State of Colorado’s emission reduction goals both for the power sector and statewide demand action, and the Pathway Project is a considered and well-supported approach to facilitating that action.”

What-iffing is an inherent part of the process, though.  What effect will time-of-use rates have on electrical demand in coming years? (Too soon to say, says the PUC chief economist, Erin O’Neill).

And how much electricity do the models say will be needed if a heat dome occurs in Colorado during the summer of 2030 such as caused elderly people in Portland last June to literally bake to death in their apartments.

Another what-if comes from MIloshevich but is echoed by others.

“Optimizing the existing transmission system could enable the integration of new renewable energy quickly and cost-effectively, and reduce the scope and cost of needed new transmission,” he says. “New transmission, including Power Pathway, would also benefit from deploying those technologies, especially the advanced carbon-core conductor, which would increase the capacity and performance of the Project while substantially reducing its total cost.”


Comanche Generating Station

Xcel Energy plans to retire Comanche units 1 and 2 in 2022 and 2025 but wants to keep operating Comanche 3 on a part-time basis until 2040.  

Chris Neil, rate analyst for the Colorado Office of the Utility Consumer Advocates, makes that same argument. Instead of waiting until new transmission is completed, Xcel can add new generation in the next few years, he said in his Oct. 22 testimony.

Front-loading renewable generation—installing it sooner than the transmission—has a net-present value that is $318 million less than the alternative that would add new wind and other generation beginning in 2025.

Developers have proposed thousands of new renewable generation for 2022-2024, he says, and the existing transmission system can accommodate those additional renewables.

The indirect background for this argument is the testimony of James F. Hill, the director of resource planning and bidding for Xcel. His Sept. 3 testimony warns against front-loading renewables because of how much the wind turbine and solar panels must then be curtailed because of transmission congestion. But his chart indirectly made the case for front-loading as less expensive, despite the increased curtailment.

The Office of the Utility Consumer Advocates also hired Chris Clack to review Xcel’s plans. Clack has become a nationally and internationally known figure in the realm of climate and energy. He has a Ph.D. in applied mathematics and plasma physics from the University of Sheffield, England, where he focused on nonlinear magnetohydrodynamic waves. In Colorado since 2012, he was the lead scientist at the University of Colorado-Boulder on mathematical optimization study of wind and solar energy within the United States. In 2016, he founded Vibrant Clean Energy.

Xcel’s transmission plan “is not appropriate for its intended purpose and a reconfiguration is warranted given the widely available wind and solar resources across Eastern Colorado and current policies” in Colorado, he says.

Clack argues that Xcel emphasizes northeastern Colorado when it would better give priority to southeastern Colorado. In this, he focuses on Baca County—where the Hefleys farm—but also adjoining Las Animas County. The county seat of Las Animas is Trinidad, but there is a lot of (underappreciated) landscape between there and Springfield.

“The technical potential for wind and solar PV in the Southeastern portion of Colorado could power the entire state,” he writes. The two counties contain 11% of the total maximum technical potential or wind development in the entire state and 10% of the total maximum technical potential for solar PV development, he says.

In addition to diversifying more from wind, geographic diversity would help Xcel’s portfolio, he says, and minimize need for additional backup generation.

Clack also finds Xcel’s plan failing to look forward past 2030, when by a new Colorado law, Xcel and other utilities must figure out how to integrate into a broader electrical market to allow greater sharing of electricity. The premise is that costs can be lowered and vulnerabilities reduced. The wind seems to always be blowing somewhere.


Pawnee power plant

The Pawnee coal-burning plant near Brush would be switched out to burn natural gas beginning in 2028, according to Xcel’s plan, although testimony has been presented to PUC commissioners that the plant could be shut down altogether with no adverse consequences to costs and reliability.

One final and very important piece of testimony was delivered by the Sierra Club and Natural Resources Defense Coalition, banded together in one of these dockets as the Conservation Coalition. they hired Derek Stenclik, who has a consulting business called Telos Energy in New York state that specializes in grid planning and technologies that enable renewable integration.

Stenclik, in his 68 pages of testimony, talks in depth about models, especially as they relate to the reserves that utilities want in order to ensure reliability and how effectively an individual resource can serve that purpose. In Xcel’s filings, he testified, he found a “clear bias toward new natural gas resources in the upcoming procurement process.”

The upshot? Increased capacity and higher cost to Xcel’s ratepayers., he says.He similarly found that the Xcel studies “discounted the capacity contributions of renewable resources and energy storage.”

Wonky enough for you? Hey, read these studies yourself. But it matters immensely. No utility wants to see the lights go off, and especially for extended periods. The most recent horror show was in Texas during February 2021—although it must be noted that it was natural gas, not wind, that was the primary failure in that case.

That takes us to Comanche 3. In theory, this coal-fired power plant can deliver reliable power because—well, it doesn’t rely upon the sun shining or the wind blowing. In practice, it has been down often, including nearly all of 2020 and also during the summer of 2019 when demand on Xcel’s system peaked.

Xcel wants to keep it operating from 2030 to 2040 as a backup, about 33% of the time. Stenclik disputes this value, as it’s slow to crank up.

“Comanche 3 may not be able to start in time when needed for reliability purposes,” he says.

While he does not dwell on the future of Pawnee, the coal plant Xcel wants to convert to natural gas, Stenclik suggests it could be closed down by 2024 with no real loss of reliability.

Xcel’s past and projected resource mix to 2030. The company wants to purchase gas-burning infrastructure but use it selectively.


Often, PUC commissioners have closely hewed to advice from the Colorado Energy Office. Keith Hay, who shepherds public policy for the Colorado Energy Office, generally supported Xcel in a Sept. 24 filing. He also warned that Xcel, even with the May Valley-Longhorn extension, which he recommends get a conditional approval, will need more generating resources to meet demand looming beyond 2030 as Colorado electrifies transportation and other sectors.

“The commitment to electrification will propel load growth for” Xcel and other utilities “for years to come,” he said.

Seen very broadly, one issue here is whether Xcel will create transmission that will enable Colorado to meet its decarbonization goals, not just of electricity but also in other sectors. But a secondary issue is whether Xcel is doing so in the most expeditious way.

On the latter question, the expertise of a long-time Xcel observer from Minneapolis, home base for the company, may deserve attention.

John Farrell, of the Institute for Local Self Reliance, pointed out why investor-owned utilities were needed—but also need to be watched. The formula used to determine the revenues the company can earn are based on capital expenditures.

“Utilities even now still generally make their money when they build stuff, so they are always going to be biased to spend capital and get a return on investment,” he said last week in a forum sponsored by Empower Our Future, a Boulder-based group.

Xcel has the lobbyists to prevent changing this incentive, said Farrell. The company’s position is “we will give you the energy you want, and we are happy to own it.”

A report to investors in early November more or less makes the same point. The PowerPoint reports Xcel plans $9.93 billion in capital expenditures in Colorado from 2022 through 2026 on transmission, electrical generation and other assets.

Allen Best
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