Motion for Leave to Intervene

							                       Motion for Leave to Intervene
                                     in
                          Case No. 11-00123-UT

William H Payne, author of Alternate Report, Electric Integrated
Resource Plan for the Period 2008-2027 and David B. McCoy,
Executive Director, Citizen Action New Mexico in compliance with
NMAC 1.2.2.23A hereby request leave to intervene in the above
captioned case.

NMAC 1.2.2.23 provides as follows:
1.2.2.23 INTERVENORS AND COMMENTERS: A. Intervention: Any
person other than staff and the original parties to a proceeding who
desires to become a party to the proceeding may move in writing for
leave to intervene in the proceeding.

(1) The motion for leave to intervene shall indicate the nature of the
movant’s interest in the proceeding.

(2) The motion shall also comply with the provisions of this rule governing
pleadings except that the motion shall indicate the facts relied upon as
grounds for intervention.

(3) Motions for leave to intervene shall be served on all existing parties and
other proposed intervenors of record.


1 Movants' interest is to bring to attention to the proceedings, the
public and PNM rate payers possible [subsidization of large-scale solar
generation of electricity by PNM rate increases] that are not authorized
by New Mexico renewable energy mandates. which may be subsidized
by PNM rate increases. The rate increases to provide large scale solar
generation are not justifiable based on a competent scientific analysis
for efficiency and cost related to alternatives for the proposed period
of the rate increase.

2 The facts relied upon are as follow:
Fact 1 relies upon the misleading justification for the rate raise
presented in the statement in paragraph 5 of the NOTICE OF
PROCEEDING AND HEARING.
PNM states that its 2008 IRP showed that energy efficiency reduced
the need for future generation plant additions and that the costs for
capacity and energy that can be avoided through energy efficiency and
demand management programs could result in a $390 Million net
present value savings over the 20-year planning period.
PNM load forecaster Mr Steve Martin identified sources of demand for
electricity on August 21, 2007, PNM Alvarado Square, Albuquerque, New
Mexico




Mr Martin's foils [?? EXPLAIN] were not included in the about 1 7/8
pound official report.

The curtailment or reduction for the sources of electricity demand
identified by Mr Martin should be addressed as an alternative to be
taken along with implementation of energy efficiency and demand
management

Abstract [?? IDENTIFY] explains reason for Alternate Report: Electric
Integrated Resource Plan for the Period 2008-2027
Official Electric Integrated Resource Plan [IRP] for the Period 2008-
2027 appears to be a product of a verbal faction of attendees for
approximately 17 sessions. Omission of what others consider
important foils from Official report and elimination of which, we feel,
are unessential foils in about 229 page report is an obligation to others
to write an alternate report. Failure of the Official report to forecast
available source of heat [BTUs] which is to be converted to electricity
and to address the sources of increased demand, and to make
practical arguments for feasibility of natural gas and alternate energy
sources renders the Official Report about unusable.

2 Fact 2
asserts that Heat Rate does not apply to concentrated solar power
(CSP) or Photovoltaic generation of electricity. And wind too.

PNM Director for Advanced Generation Development, Mr Greg Nelson
and engineer Frank Currie both state in writing that Heat Rate only
applies to electricity generation from combustible sources.

The position of the PNM Director regarding heat rate as only applicable
to electric generation from combustible resources is incorrect. Heat
rate also encompasses the conversion efficiency of the system with
whatever is the heat input:
Mr Jake Rudisill, Vice President, Operation and Project Management of
Meridian Energy USA emailed
From: "Jake Rudisill" j.rudisill@meridianenergyusa.com To:
bpayne37@comcast.net
Sent: Tuesday, May 10, 2011 4:37:20 PM
Subject: Heat Rate misconception

Mr. Payne,

The definition of heat rate is not the heat content of just the fossil fuel
inputting the conversion system—it is the conversion efficiency of the
system with whatever is the heat input. ...

We have been in the process, so far unsuccessful, of trying to determine who
is right.

[Resolution of the heat rate issue is important from the standpoint of
justification for the rate increase that is being requested and will be used for
large scale solar generation technology. ???]

[PNM has not provided a cost analysis of the efficiency of the provision of
solar based generation of electricity in comparison with the available
alternatives on any scientifically recognizable basis. ??]

3 Fact 3 Liberal arts 'educated'
From: “Jason Marks, PRC” Jason.Marks@state.nm.us
To: bpayne37@comcast.net, “David King, PRC”
David.King@state.nm.us, “Jerome D Block, PRC”
JeromeD.Block@state.nm.us>, Becenti@state.nm.us, “Sandy Jones,
PRC” Sandy.Jones@state.nm.us
Cc: dave@radfreenm.org, nmusa@rt66.com,
mhartranft@abqjournal.com, “Staci Matlock”
smatlock@sfnewmexican.com>, amorales58@comcast.net
Sent: Monday, September 13, 2010 9:12:09 AM
Subject: Re: Large-scale solar generation of electricity fraud in New
mexico?

Mr Payne:

I don’t understand your concerns. There are two basic solar electric
technologies: photovoltaic panels (PV) and thermal concentrating solar power
(CSP). The development and deployment in NM is focused on PV. Hundreds
of homeowners with installed PV systems can tell you that their systems
produce electricity in line with specifications, as proved by meters.
You (either an individual or a utility) buy a solar system for a certain price,
you install it, and it generates electricity for 20 or 30 years or so, with
minimal operating and maintenance costs. There are no fuel requirements
(and thus no “heat rate”). When you spread the upfront costs over the
system’s lifetime electric production and adjust for tax credits and REC
incentives, you arrive at the cost per kwh. You get to decide if you think that
cost per kwh is reasonable before you make the investment. There is no
fraud.

Jason Marks

may be incorrect and possiblly involved in large-scale solar
genernation of electricty fraud?

PNM has not provided an analysis of the breakdown for private
installation, i.e., by homeowners and businesses, of solar electric
generation systems to provide a need and cost analysis for installation
of solar generation installation by PNM. The issue of the efficiency and
costs of onsite localized generation of solar electricity versus the
comparative efficiency and costs of construction of centralized
production and the transmission have not been considered relevant to
the rate increase. [??]

Additionally, the alternative for reduction of electrical usage by
geothermal development for new construction that would be available
over the time period [through 2027?] has not been addressed.

The above facts support the conclusion that the evidence for the rate
increase is incomplete, incorrect and has not considered actual
efficiencies and production costs related to existing alternatives. Peer
review has not been performed for the PNM assumptions that no
analysis for the factors of heat rate {and???] is necessary. weighed by
honest technically-competent and other thinking people whose written
decision are subject to international review and comment to reach
proper conclusion on PNM rate increases?

Submitted June 24, 2011 by certified mail.


________________________________________
William H Payne
________________________________________
David B McCoy