MOTION FOR LEAVE TO INTERVENE AND REQUEST FOR DISCOVERY

[billp37]

BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION

IN THE MATTER OF THE APPLICATION OF PUBLIC SERVICE COMPANY OF NEW MEXICO FOR APPROVAL OF RENEWABLE ENERGY RIDER NO. 36 PURSUANT TO ADVICE NOTICE NO. 439 AND FOR VARIANCES FROM CERTAIN FILING REQUIREMENTS PUBLIC SERVICE COMPANY OF NEW MEXICO, Applicant

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Case No. 12-00007-UT

MOTION FOR LEAVE TO INTERVENE
AND REQUEST FOR DISCOVERY

http://www.prosefights.org/pnmrider/pnmrider.htm#motion

William H Payne, author of the PNM Alternate Report: Electric Integrated Resource Plan for the Period ..., and intervenor in CASE NO. 11-00369-UT in compliance with NMAC 1.2.2.23A hereby requests to intervene.

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.

states:

1 Nature of interests in the proceeding are:

A Ensure that decision for rate increase is based on facts provided by engineers and scientists as opposed to liberal arts verbal and essay analysis.

B Determine if the New Mexico Renewable Energy Act NMSA 1978, §§ 62-16-1 et seq. ("REA") is merely an alternergy business ploy.

C Determine if large-scale solar and wind generation of electricity equipment purchase, installation and maintence costs are greater than electruc sales revenue derived from them.

D Determine if Energy Returned on Energy Invested is greater than one for Schott solar panels.

E Determine if proper disposal of toxic solar panels is considered.

F Compel PNM and Schott Solar to respond through Discovery to requests for information for which responses to past requests were promised but never fulfilled.

G Expose unintelligence and incompetence at the PRC and New Mexico state government.

2 Facts relied upon include:

A Post alerts prospective intervenor

fast neutron
Santa Fe, NM
January 12, 2009

From actual experience, wind farms produce 1.2 watts per square meter. Solar Thermal and Photovoltaic methods capture 5 to 6 watts per square meter. There is no economy of size in either technology. Dividing the watts you need by those values gives the land area in square meters needed to produce the juice. The numbers are astronomical

http://www.topix.net/forum/source/santa-fe-new-mexican/T0QVJ5UD3R25...

of possible science/engineering problems with wind and solar generation of electricity,

B MorganStanley VP informs prospective intervenor that large-scale solar generation of electricity is a fraud.

MorganStanley is reported to have lost about $24.1 million in the bankruptcy of Eclipse Aviation.

C Renewables, like solar and wind, may not be the best way to go?

Efficiency winning the day

The second big trend—which is driven in part by the first—is that VCs are focusing on less-capital-intensive, “demand side” investments of modest size in the smart grid, energy efficiency and energy storage markets. For instance, there’s a slew of software companies offering applications that let utilities manage energy distribution more effectively and that enable the utilities’ customers to reduce energy consumption and costs.

“Renewable energy has been a big theme for many years,” said Lux’s Holman. “I think energy efficiency is going to take center stage.”

Money, cleantech and what comes next
Bruce Rayner
3/5/2012 12:15 PM EST
Electronic Engineering Times Maarch 6, 2012 pages 22-28.

D Repeated requests to PNM spokesperson Don Brown to get performance ... have gone unanswered despite promises from Mr Brown that this information would be made available.

E Recently install solar generation of electricity array have been installed at

1 PNM Reves natural gas peaking plant solar array
2 PUBLIC SERVICE COMPANY OF NEW MEXICO PHOTOVOLTAIC PLUS BATTERY FOR ...
3 PNM Los Lunas solar array.

can provide data as to costs of solar arrays, installation, and maintence and revenue from sale of electricity to determine whether large-scale solar generation makes sense from a financial standpoint. PNM must be forced furnish this information under Discovery.

F PNM load forecaster Mr Steve Martin identified sources of demand for electricity on August 21, 2007, PNM Alvarado Square, Albuquerque, New Mexico.

Growing number of customers, increased construction surely contributes to increase of natural gas consumption.

Hearing examination should include analysis of whether limiting new construction is more effective than energy efficiency if there is a problem with future natural gas supply?

G PRC procedure in Case No. 11-00369-UT of relying of testimony inste... and should not be used 12-00007-UT. But if it is, then this should be reported to the public and formal complaints of misconduct filed.

3 WHEREFORE,

Grant motion to intervene with Discovery as allowed under TITLE 1 GENERAL GOVERNMENT ADMINISTRATION CHAPTER 2 ADMINISTRATIVE ....

Respectfully submitted this March 28, 2012.


____________________             ___________
William H Payne                        date