BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO
PROCEEDING NO. 18F-0866E
DELTA-MONTROSE ELECTRIC ASSOCIATION, COMPLAINANT, V. TRI-STATE
GENERATION AND TRANSMISSION ASSOCIATION, INC., RESPONDENT
COMMENTS OF LARRY MILOSHEVICH
RELEVANT CONTEXT AND TWO POINTED QUESTIONS

1. INTRODUCTION
Larry Miloshevich is an Independent Advocate with a technical background in

Colorado PUC E-Filings System

atmospheric science and geophysical engineering, with broad knowledge of energy and
climate science. He has submitted filings in several PUC dockets1, both independently
as here, and on behalf of Energy Freedom Colorado2. He has written a white paper
entitled "A Strategy and Six Ways to Address Community Energy Goals", which
includes a review of challenges facing Tri-State and its member co-ops [1, sec. 4].
The purpose of this filing is to complement the legal arguments presented by the
formal participants in this proceeding, by adding context and background that seems
relevant to the Commission's decision. This filing aims to illuminate "the forest" as this
proceeding will generally focus on "the trees."
It would be difficult to argue against the reasonableness of DMEA's desire to
procure wholesale energy for its customer-members that is:
• much cheaper than members currently pay Tri-State;
• much cleaner than Tri-State's coal-heavy energy mix; and

1

16I-0816E (Mountain West/SPP); 16A-0396E (Xcel ERP); 17M-0694E (Pre-rulemaking);
18M-0080E (Transmission planning); 19R-0096E (Rulemaking).

2

Energy Freedom Colorado is a nonprofit, volunteer group that researches and advocates
competition and consumer choice in the electricity sector. http://EnergyFreedomCO.org/

 • increasingly produced locally in order to foster local economic development and
jobs, and keep energy dollars circulating locally.
A growing number of member co-ops object to Tri-State's resistance to change
as the energy landscape evolves, forcing members to continue buying energy that is
both expensive (far above market prices) and dirty (dominated by uneconomic coal
plants) [2]. These conditions suppress local economic development and attractiveness
to businesses [3], and threaten a downward economic spiral across Tri-State territory.
As to the basic question at hand – should DMEA be allowed to exit its Tri-State
contract at a just, reasonable and non-discriminatory cost – the answer is clearly 'yes.'
Among other reasoning, the precedent of Kit Carson co-op's exit at a cost of $37M
[4,5,6] demonstrates Tri-State's own conclusion that: 1) an exit is contractually allowed;
and 2) a mutually-acceptable (and therefore just and reasonable) exit charge for DMEA
would be, in some appropriate way, proportional to $37M.
One possible outcome of this proceeding is a narrow decision that establishes a
reasonable exit charge for DMEA. Another possible outcome is a broader remedy that
would provide a template that other co-ops could follow if they so choose. The ongoing
clean energy transition is being driven by energy economics, state policies, and societal
imperatives, and these forces provide the underlying motivation for DMEA and other
members to seek change or seek an exit from Tri-State. These pressures will almost
certainly continue and increase, and this issue will likely return to the PUC in the near
future unless a broad decision is reached. The cost of renewable energy will continue
to decline relative to the operational costs alone of Tri-State's legacy coal fleet [7,8];
and furthermore, the economic development and jobs associated with locally-produced
renewable energy will become increasingly apparent to more of the member co-ops.
Tri-State's rigid position is not sustainable.
Section 2 of this filing provides a well-referenced review of the following topics:

2

 • Sources of dissatisfaction with Tri-State, including: contract length; cap on local
generation; high costs; and governance structure.
• Solutions that some co-ops have tried (with limited success): buy out the contract;
use PURPA to develop local energy; and work within Tri-State to effect change.
• The economics of Tri-State's generation fleet, and several approaches that would
allow Tri-State to provide all of its members with cheaper and cleaner electricity.
Section 3 of this filing explores two important questions concerning the
perplexing observation that Tri-State – a nonprofit that claims to exist for the benefit of
its member co-ops – acts in a hostile manner rather than a "cooperative" manner toward
its more forward-looking members.
QUESTION 1: Why would Tri-State block member co-ops that want to pursue cheaper
and cleaner electricity without shifting costs onto other members? What are Tri-State's
underlying motivations?
QUESTION 2: Why are any of the distribution co-ops, much less a controlling majority,
willing to charge their own customer-members high prices for dirty electricity rather than
follow the lead of Kit Carson, DMEA, LPEA, United Power etc., that are instead fighting
for the interests of their customer-members as one might expect?
Two state statutes enacted during the 2019 Legislative session concern PUC
oversight of Tri-State [9]: the PUC Sunset/Reauthorization bill (SB19-236)3, and the
Climate Action Plan to Reduce Pollution (HB19-1261)4. The former statute requires TriState to participate in the Electric Resource Planning process and to submit "a
Resource Plan that meets the energy policy goals of the state." The latter statute
strengthens state energy policy goals by requiring large utilities to reduce carbon
3

SB19-236 (Sunset Public Utilities Commission). "PUC Reauthorization bill."
https://leg.colorado.gov/bills/sb19-236

4

HB19-1261 (Climate Action Plan to Reduce Pollution).
https://leg.colorado.gov/bills/hb19-1261
3

 emissions 80% by 2030 relative to 2005 levels. Tri-State will soon be required to
provide cost-effective clean energy to all of its members, and therefore Tri-State would
be well advised to modify its business model sooner rather than later in order to repair
member relations and avoid further defections and a less bright future. A broad
Commission ruling could help motivate this coming evolution.

2. CONTEXT – BACKGROUND ON TRI-STATE AND ITS MEMBER CO-OPS
Although Tri-State is governed by its member co-ops, the individual co-ops have
little ability to control their energy sources and wholesale electricity costs due to TriState's restrictive contracts and its governance structure. Reasons for dissatisfaction
with Tri-State by some of its member co-ops include [10,11,4]:
• Contract length. Tri-State contracts are 40-50 years long, tying co-ops to a single
wholesale supplier with agreements that seemed good at the time, but have
become onerous as alternatives have gotten both cheaper and cleaner. The
present dissatisfaction began in 2005 when Tri-State proposed to build a new coalfired generation plant in Kansas, and wanted member co-ops to extend their
contracts from 40 years to 50 years to pay for it (Kit Carson and DMEA refused)
[4]. Tri-State finally gave up on building the new coal plant, but it is shedding its
other coal generation far too slowly for some members' liking.
• Cap on local generation. Tri-State's "all requirements" contract restricts local
electricity generation by any member co-op to 5% of its peak load. As of late 2017,
four co-ops had reached the cap and four more were near the cap [10]. This
limitation is frustrating to some members because local renewable generation is
cheaper, cleaner, incurs no transmission charges, supports local economic
development and jobs, and keeps energy dollars circulating in the local economy.
• High costs. The price of Tri-State's wholesale power is approximately 7.5 cents
per kilowatt-hour (kWh), which is much higher than the current western wholesale
market price of about 3.1 cents/kWh, and much higher than the 4.5 cents/kWh that

4

 Granby-based Mountain Parks Electric negotiated for solar electricity [11]. TriState's high price reflects the high fuel and operational costs of its legacy coal fleet
[7,8], at a time when Xcel Energy is contracting for competitively-procured wind
energy at less than 2 cents/kWh, and dispatchable solar-plus-storage at 3.6
cents/kWh [4]. Tri-State's prices have gone from being the lowest in the state a
decade ago, to now being substantially higher than all other suppliers, including
investor-owned utilities, wholesale markets, and renewable energy Power
Purchase Agreements [12, slide 3].
• Governance structure and voting power. Tri-State is composed of a few large coops and many small co-ops, yet each co-op gets one vote on the Tri-State Board.
Three large Colorado co-ops (which have reached the 5% self-generation cap)
have 152,000 customer-members and 3 votes on the Board, while the 22 smallest
co-ops with a total of only 103,000 customer-members have 22 votes and therefore
a majority on the 43-member Board. It is difficult to change the status quo because
Tri-State is effectively ruled by the smaller co-ops, which have prevented policy
changes that would allow more local energy development by the co-ops that want it
and that serve many more customers [4]. The Tri-State voting apportionment has
been compared to the design of the U.S. Senate, but with no U.S. House to
balance decision-making with a factor that represents population. There is also an
inter-state component, where 66% of the Tri-State customer base lives in
Colorado, but the Colorado co-ops have only 43% of the votes on the Board [10,
see chart].
Tension between the Tri-State Board and some of its member co-ops arises from
an inherent conflict: Tri-State has a duty to provide its members with the lowest-cost
service, but the lowest-cost resources these days are competitively-procured local
generation and/or wholesale market purchases, not Tri-State's legacy fossil fuel
generation.
Several member co-ops have pursued their energy goals anyway, in several
ways (but with limited success):
5

 • Buy out the contract. Kit Carson co-op set the precedent of buying out their TriState contract and choosing a different wholesale electricity supplier. Kit Carson
terminated its contract with Tri-State by negotiated agreement in 2016, in pursuit of
stable low-cost clean energy after experiencing 10 rate increases over the previous
13 years. The buyout involved paying Tri-State a $37 million exit fee that prevented
cost-shifts onto the remaining co-ops. Kit Carson then entered into a 10-year
Power Purchase Agreement with Guzman Energy. Guzman is building solar
arrays across Kit Carson territory, and the co-op is buying that power at a fixed
price. The new contract also gives Kit Carson the freedom to develop local
renewable energy. Guzman paid the exit fee, and Kit Carson is paying Guzman
back over six years, off their books, using savings from lower energy costs. Kit
Carson is now insulated from the risk of rate increases associated with Tri-State's
coal-heavy generation, and will save $50-70 million over the 10-year contract with
Guzman. Kit Carson is aiming to self-produce 100 percent of its daytime electricity
needs by 2022. [4,5,6]
• Use PURPA to develop local energy. DMEA challenged Tri-State's 5% cap on
locally-produced electricity with the argument that the federal PURPA law
supersedes Tri-State's "all requirements" contract. The Public Utility Regulatory
Policies Act of 1978 (PURPA) [13] was an early step toward breaking monopoly
utility control over electricity generation, by requiring utilities to purchase electricity
from any small power producer that can provide power at a price equal to or slightly
above the utility's "avoided cost" for electricity. The Federal Energy Regulatory
Commission (FERC) upheld the challenge, allowing DMEA to procure power from
Independent Power Producers through PURPA [14,15]. This ruling allows all 905
electric co-ops and 830 municipal electric utilities in the nation to procure costcompetitive local power through PURPA. However, the viability of this approach is
still waiting on another Tri-State appeal and a rehearing at FERC. Frustrated once
again, DMEA went a different direction, and in October 2018 DMEA's customermembers passed a measure allowing the co-op to issue stock to finance a TriState exit, similar to the Kit Carson approach but using a different financing
mechanism [16,17].
6

 • Petition Tri-State to raise the 5% cap. La Plata Electric Association (LPEA), in
southwestern Colorado, had competitive races for open Board seats in a 2017
election, and the campaign largely centered on increasing renewable energy. The
LPEA Board voted to approach Tri-State about increasing the cap on local
renewable energy production to 10% [18]. The resolution to raise the cap was
voted down by the Tri-State Board [11]. Pressure to lift the 5% cap will likely
increase as more member co-ops reach the cap, and as the cost of local
renewable energy continues to decline. In January 2018, the LPEA Board voted
to study alternatives to Tri-State after receiving a petition signed by 1000 people
and 100 businesses calling for 100% renewable electricity and more local
generation [4].
• Petition Tri-State for a "partial-requirements contract". United Power has contacted
the other Tri-State member co-ops to express "grave concerns" about its power
supply, and to propose a potential solution. United Power borders Xcel Energy
territory and therefore competes for new businesses with a territory that has
wholesale electricity prices that are 28% lower than Tri-State's [2]. This challenge
to attracting (or keeping) businesses that want low cost and/or cleaner electricity
will increasingly affect economic development in all communities served by TriState. United Power has proposed an amendment to Tri-State's bylaws that allows
for a "partial-requirements contract" that permits greater than 5% local generation
and some amount of access to lower cost power, while keeping all members
financially whole [19]. The current situation has already cost the economy of
United Power's territory a new data center, because the customer insisted on
access to low-cost renewable energy which United Power cannot provide under its
Tri-State contract [3]. The City of Montrose, the largest city in DMEA's service
territory, has also expressed to the Commission the importance of lower and more
stable rates for local economic development and jobs in their community5.

5

City of Montrose filing in this docket in support of DMEA's position.
https://www.dora.state.co.us/pls/efi/efi.show_document?p_dms_document_id=906313&
p_session_id=

7

 • Deploy battery storage to use purchased electricity more effectively [20]. United
Power has installed a battery storage system to store electricity purchased from
Tri-State for later use, with the aim of shaving peak demand and thereby reducing
costs. This was not storage paired with a solar array, because United Power had
already reached the 5% cap; instead, United was time-shifting electricity purchased
from Tri-State. Tri-State reacted by changing its bylaws to discourage the future
use of batteries by all of its members, and to prevent the use of batteries by
members who have already reached or are near the 5% cap. The new bylaw
counts stored energy as generated energy and therefore includes it under the 5%
cap, even though stored energy is not generated energy, and the stored energy
was even purchased from Tri-State.
Tri-State's rigid enforcement of contracts that require members to continue
paying high prices for dirty energy for the next 20-30 years risks ever-increasing
dissatisfaction and defection of member co-ops as:
1. the price of Tri-State's coal-heavy power continues to increase relative to new
renewable energy and energy storage, and/or market purchases; and
2. Tri-State alienates more members with punitive measures like the battery storage
change to its bylaws, and the unjust and unreasonable treatment of DMEA; and
3. more and more member co-ops realize that they are acting against the interests of
their own customer-members by supporting Tri-State's position and tactics; and
4. state laws evolve to further support the renewable energy transition, and increase
PUC oversight of Tri-State, as occurred during the 2019 legislative session.
A recent Rocky Mountain Institute (RMI) report analyzed the economics of
replacing Tri-State's coal-fired generation with renewable energy and energy storage,
and found that Tri-State could provide cleaner electricity to all of its members at a lower
cost than the status quo [7,8,21]. Therefore, Tri-State has at least one viable path to
stem the irreversible defection of member co-ops, if it chooses to act soon enough and
aggressively enough.

8

 Specifically, the RMI report found that:
• Tri-State’s coal assets are expensive to operate. Tri-State members could save
$600 million through 2030 by replacing its fleet of coal generators with renewable
energy and energy storage.
• A supply mix based on renewable generation and market purchases, rather than
legacy coal assets, would reduce the risk of rate increases by 30-60 percent while
maintaining system reliability. The risk factors include: increased self-generation
by members; more members exiting Tri-State; and future greenhouse gas pricing
(which was implemented for resource planning purposes in the 2019 legislative
session).
• Examples are given of IOUs, co-ops, and municipal utilities that are acting now to
transition away from legacy generation assets cost-effectively by taking advantage
of low renewable energy costs, currently available tax incentives, and low interest
rates to finance new projects.
• Tri-State could facilitate a least-cost system solution that benefits all members by
adopting a strategy of collective action, regionally-appropriate solutions, and group
buying power, as opposed to individual co-ops pursuing solutions on their own.
The RMI report is consistent with other findings that many western coal plants
are uneconomic to operate, and that ratepayers would save money if these plants were
retired and replaced with renewable energy plus energy storage [22,23]. Xcel Energy
received astonishingly low bids for wind, solar and energy storage to replace two
Colorado coal plants [24,25].
Guzman Energy recently made an innovative proposal to Tri-State that would
address the calls by some members for cheaper and more stable rates, and cleaner,
more locally-produced electricity [26]. Guzman would purchase 3 Tri-State coal plants
and a coal mine, and then shut them down and replace that capacity with a mix of wind

9

 and solar energy firmed with natural gas. The transaction would lead to lower electricity
prices for Tri-State members because the operating cost of the coal plants is higher
than the all-in cost of new replacement renewable resources. The economics of this
proposal are more favorable the sooner Tri-State acts on it, due to impending
reductions in federal tax credits that are available for the replacement resources.
On a larger scale, Community Energy Inc. commissioned Vibrant Clean Energy
to conduct a detailed power system and economic modeling study that assessed 3
scenarios for all of Colorado's coal plants: 1) continue operating them as now through
2040; 2) gradually close them by 2030 and replace the capacity with 70+% solar and
wind energy firmed by natural gas; and 3) complete the transition from coal by 2025.
The study finds that replacing all coal generation in Colorado by 2025 could save
ratepayers $2.5 billion in net present value through 2040, while reducing today's carbon
emissions by more than half, and substantially increasing net employment in the
electricity sector [27,28].
The Vibrant Clean Energy study, the RMI study, and the Guzman proposal all
show that transitioning off of coal as soon as possible would reduce rates while
advancing state energy goals, as is already clear to DMEA and other member co-ops.

10

 3. TWO POINTED QUESTIONS FOR TRI-STATE AND ITS MEMBERS
The preceding section provided evidence that:
1. member co-ops could have cheaper, cleaner electricity, and more local economic
development and jobs, if they weren't rigidly bound by their Tri-State contracts; and
2. Tri-State could choose to evolve with the changing times and provide its members
with cheaper and cleaner electricity by replacing its legacy coal fleet with primarily
renewable energy, energy storage, and market purchases.
So, why don't they? Isn't Tri-State supposed to be concerned about the welfare
of its member co-ops? Aren't the member co-ops, who have the authority to vote for
change at Tri-State, concerned with the interests of their own customer-members?
Digging into these perplexing questions seems relevant to this proceeding, not
only because illogical behavior begs greater understanding, but also because insight
into underlying motivations may assist the Commission in crafting a remedy for DMEA
that also speaks to the future and sends appropriate messages to Tri-State, and
possibly establishes a template for other member co-ops that seek to exit on fair terms.
These perplexing questions are elaborated below.

QUESTION 1: Why would Tri-State block member co-ops that want to pursue
cheaper and cleaner electricity without shifting costs onto other members? What
are Tri-State's underlying motivations?
Tri-State is a nonprofit, which theoretically exists for the benefit of its members,
where "benefit" means whatever its members want. In the case of DMEA (and Kit
Carson, LPEA, United Power, etc.), "benefit" means lower costs and/or cleaner energy
sources and/or more local generation and innovation. As the RMI report and the
Vibrant Clean Energy study show, and as Guzman Energy has demonstrated with Kit
Carson, Tri-State could provide all of its members with cheaper and cleaner electricity if
it so chose. Opposition might be more understandable if it came from Xcel Energy,
11

 which has shareholder interests to serve and a monopoly to protect, but Tri-State is a
nonprofit that exists to serve its members. So why don't they serve their members
better by proactively developing cheaper and cleaner energy sources?
The Boards of the member co-ops would be well advised to seriously question
why Tri-State would act against their interests, when it has viable options to pursue a
path that could provide them with cheaper, cleaner, more locally-produced electricity.

QUESTION 2: Why are any of the distribution co-ops, much less a controlling
majority, willing to charge their own customer-members high prices for dirty
electricity rather than follow the lead of Kit Carson, DMEA, LPEA, United Power
etc., that are instead fighting to protect the interests of their customer-members
as one might expect?
Why aren't all of the member co-ops clamoring for cheaper, cleaner, local
energy development, when evidence indicates that this is both possible and would be
beneficial to their interests? Isn't that contrary to their mandate? Why don't the
customer-members of those co-ops vote for more forward-looking Board members?
Two possibilities come to mind:
• Lack of facts. It is mostly the larger co-ops that are seeking solutions and change,
with representatives of the smaller co-ops on Tri-State's Board that are standing in
their way. The larger co-ops presumably have more resources at their disposal,
especially personnel and expertise, which they have used to study and understand
that alternatives to high-cost dirty energy exist. Small co-ops do not have the
resources and expertise to stay on top of the rapidly changing energy landscape.
Many of the smaller co-ops may not be aware that over the last decade, Tri-State's
prices have gone from being the lowest in the state to now being substantially
higher than all other wholesale suppliers [12, slide 3]. Hopefully, the Boards of the
member co-ops will find the information in this filing enlightening, and will dig into
some of the references, and perhaps direct their representative on Tri-State's
Board to shift to DMEA's side, because it is in their own self-interest to do so.
12

 • Misinformation from Tri-State. One consequence of the smaller co-ops lacking the
resources to do their own research and become experts on energy markets, is that
they may rely heavily on information and perspectives provided to them by TriState Management and Staff. Those Staff may have presented scenarios aimed at
manipulating the smaller co-ops into adopting a view that a DMEA exit would harm
them. If misinformation is a factor, then the situation on Tri-State's Board could
shift quite rapidly when more members learn that they've been misled by those
they trusted.
Boards of the member co-ops would be well advised to seriously question why
they would continue to support Tri-State's position when there is much evidence that it
is detrimental to their own customer-members, who presumably would prefer cheaper,
cleaner, more locally-produced electricity and the associated economic development
and jobs, if they understood that this was a viable option. Perhaps the most powerful
evidence that member co-ops are not getting the best deal from Tri-State (in addition to
the fact that Kit Carson is doing quite well with Guzman), is simply that the larger co-ops
that have the resources to fully investigate current energy markets have done so, and
they have concluded that they want change or they want out.

CONCLUSION
This filing is intended to present context and background on the relationship
between Tri-State and its members, for consideration by the Commission as well as by
the Board of Tri-State and the Boards of the members co-ops. Greater understanding
of the underlying dissatisfaction of some members may help identify a remedy for
DMEA that is broad enough to be useful by other member co-ops, and possibly send a
message to Tri-State that there are viable paths forward at this time when the changing
energy landscape seems to require an evolution of their position and business model.
In the absence of a broad ruling, this matter is likely to end up before the PUC again in
the near future.

13

 REFERENCES
1. A Strategy and Six Ways to Address Community Energy Goals. Larry Miloshevich.
Nov. 2018. [PDF]
http://energyfreedomco.org/community-options.php
2. Tri-State members increasingly unsatisfied as the rise of distributed resources
upends the G&T model. Herman Trabish. Utility Dive. Jan. 15, 2019.
https://www.utilitydive.com/news/tri-state-members-increasingly-unsatisfied-as-therise-of-distributed-resou/545356/
3. United Power says Tri-State policies are turning away large customers. Joe Smyth.
Clean Cooperative. Jan. 17, 2019.
https://www.cleancooperative.com/news/united-power-says-tri-state-policies-areturning-away-large-customers
4. Colorado co-ops consider dropping their energy provider. Allen Best. Energy News
Network. April 6, 2018.
https://energynews.us/2018/04/06/west/colorado-co-ops-consider-dropping-theirenergy-provider/
5. Kit Carson CEO Reyes says Tri-State break has two big advantages. J.R. Logan.
The Taos News. June 30, 2016.
https://www.taosnews.com/stories/kit-carson-ceo-reyes-says-tri-state-break-has-twobig-advantages,23584
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Durango Herald. April 14, 2018.
https://durangoherald.com/articles/218565
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9. Colorado Public Utilities Commission will oversee Tri-State resource planning. Joe
Smyth. Clean Cooperative. May 7, 2019.
https://www.cleancooperative.com/news/colorado-public-utilities-commission-willoversee-tri-state-resource-planning
10. Uncooperative: Tri-State policies are limiting Colorado communities from developing
local renewable energy projects. Clean Cooperative. Joe Smyth. January 2018.
http://www.cleancooperative.com/uncooperative.html
11. Colorado rural electric cooperatives look at cutting the cord. Mark Jaffe. The
Gazette. August 12, 2018.

14

 https://gazette.com/news/colorado-rural-electric-cooperatives-look-at-cutting-thecord/article_53bb480c-9a86-11e8-925e-4b6fc9d553c4.html
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https://engagedeltacounty.org/wp-content/uploads/2018/09/Chris-Riley-GuzmanEnergy.pdf
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https://durangoherald.com/articles/152399
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https://www.greentechmedia.com/articles/read/wind-could-replace-6000-gigawatthours-of-coal-in-colorado

15

 23. Will lower cost renewables and natural gas accelerate PacifiCorp's generation
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24. Xcel Attracts ‘Unprecedented’ Low Prices for Solar and Wind Paired With Storage.
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https://www.greentechmedia.com/articles/read/record-low-solar-plus-storage-pricein-xcel-solicitation
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Catherine Morehouse. Utility Dive. Aug. 28, 2018.
https://www.utilitydive.com/news/colorado-approves-xcel-plan-to-retire-coal-shift-torenewables-and-storage/531098/
26. A small company sees opportunity in revolutionizing Colorado’s energy supply.
Allen Best. Energy News Network. May 28, 2019.
https://energynews.us/2019/05/28/west/a-small-company-sees-opportunity-inrevolutionizing-colorados-energy-supply/
27. Colorado could save $2.5 billion by rapidly shutting down its coal power plants.
David Roberts. Vox. Jan. 8, 2019.
https://www.vox.com/energy-and-environment/2019/1/8/18170454/colorado-coalpower-plants-shut-down-close-renewables
28. Summary of Study, Results and Key Assumptions. Community Energy. [PDF]
https://www.communityenergyinc.com/press

Larry Miloshevich, Lafayette
Larry@EnergyFreedomCO.org
Dated: June 17, 2019

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