City of Las Cruces v. N.M. Pub. Regul. Comm'n

CourtNew Mexico Supreme Court
DecidedMay 11, 2026
StatusPublished

This text of City of Las Cruces v. N.M. Pub. Regul. Comm'n (City of Las Cruces v. N.M. Pub. Regul. Comm'n) is published on Counsel Stack Legal Research, covering New Mexico Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Las Cruces v. N.M. Pub. Regul. Comm'n, (N.M. 2026).

Opinion

The slip opinion is the first version of an opinion released by the Chief Clerk of the Supreme Court. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Chief Clerk for compliance with Rule 23- 112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion.

1 IN THE SUPREME COURT OF THE STATE OF NEW MEXICO

2 Opinion Number:

3 Filing Date: May 11, 2026

4 NO. S-1-SC-40636

5 CITY OF LAS CRUCES,

6 Appellant,

7 v.

8 NEW MEXICO PUBLIC 9 REGULATION COMMISSION,

10 Appellee,

11 and

12 EL PASO ELECTRIC COMPANY,

13 Intervenor-Appellee.

14 In the Matter of the Application 15 of El Paso Electric Company for 16 a Variance from the Fuel and 17 Purchased Power Cost Adjustment 18 Clause Methodology, New Mexico 19 Public Regulation Commission 20 Case No. 21-00064-UT

21 APPEAL FROM THE NEW MEXICO PUBLIC REGULATION 22 COMMISSION 1 City of Las Cruces 2 Bradley Douglas, City Attorney 3 Las Cruces, NM

4 Stevens Law, LLC 5 Anastasia S. Stevens 6 Santa Fe, NM

7 for Appellant

8 Erin E. Lecocq, Appellate Specialist 9 Santa Fe, NM

10 for Appellee

11 El Paso Electric Co. 12 Nancy B. Burns 13 Santa Fe, NM

14 Spencer Fane, LLP 15 Jeffrey J. Wechsler 16 Kari E. Olson 17 Joseph M. Dworak 18 Santa Fe, NM

19 for Intervenor-Appellee El Paso Electric Co. 1 OPINION

2 THOMSON, Justice.

3 {1} The public utility rate dispute at issue stems from the snow, ice, and severely

4 cold temperatures brought by Winter Storm Uri, whose Arctic air gripped New

5 Mexico for seven consecutive days in February 2021. Intervenor-Appellee El Paso

6 Electric Company (EPE) relied, in in part, upon Palo Verde Nuclear Generating

7 Station Unit 3 (PV3, PVGS Unit 3, or PVNGS Unit 3) to successfully provide

8 electric energy and capacity to its New Mexico customers without interruption

9 throughout the storm period. The rate dispute in this case centers on the propriety of

10 EPE’s use of a so-called proxy price formula to calculate the increase in consumer

11 energy costs attributable to EPE’s use of PV3. As a result of the storm, “natural gas

12 prices skyrocket[ed] due to supply constraints” in New Mexico and other states

13 impacted by the storm. See, e.g., Holcim U.S. Inc. v. Colo. Pub. Utils. Comm’n, 2025

14 CO 1, ¶ 6, 562 P.3d 55 (“The interplay of the extreme cold, freeze-offs of natural

15 gas production, and high customer demand for natural gas greatly impacted natural

16 gas prices during th[e reign of Winter Storm Uri],” causing gas prices to “spik[e].”);

17 Evergy Mo. W. Inc. v. Off. of Pub. Couns., 676 S.W.3d 438, 442 (Mo. Ct. App. 2023)

18 (“The spike in natural gas prices [caused by Winter Storm Uri] resulted in record

19 high real-time electricity prices [in Missouri].”). 1 {2} The outcome of this appeal hinges on the proper interpretation and application

2 of a number of prior rate-related orders issued by the New Mexico Public Regulation

3 Commission (the Commission or NMPRC) in separate administrative proceedings

4 involving EPE and addressing similar PV3 proxy price issues. As a threshold matter,

5 however, this Court has not previously established the level of deference, if any, we

6 extend to the Commission’s interpretation of its own prior orders. This opinion

7 resolves this issue of first impression in favor of the Commission by adopting the

8 “high level of deference” generally accorded an “agency’s interpretation of its own

9 orders.” 73A C.J.S. Public Administrative Law & Procedure § 343 (2014). Applying

10 the standard, we uphold the results of the full and fair administrative proceedings

11 held by the Commission and affirm the Commission’s final orders.

12 {3} We begin by summarizing the procedural backdrop of the Commission’s

13 rulings and explaining the nature of the PV3 facility and the proxy price

14 methodology EPE employed in calculating its storm-related, temporary rate

15 increase.

16 I. BACKGROUND

17 A. Procedural Backdrop

18 {4} The underlying administrative proceeding (El Paso Elec. Co., No. 21-00064-

19 UT) commenced when EPE moved for a variance relating to its approved Fuel and 1 Purchased Power Cost Adjustment Clause (FPPCAC) as it applied to the cost of

2 PV3-generated energy. Specifically, EPE sought authorization to employ an

3 amortized rate to collect over a twelve-month period the extraordinary, incremental

4 electricity cost increases from Winter Storm Uri. The rate was designed to lessen

5 what the Colorado Supreme Court described in parallel circumstances as “the ‘rate

6 shock’ that customers would have experienced had [the utility] sought to recover the

7 extraordinary costs over [a] shorter period of time.” Holcim U.S. Inc., 2025 CO 1, ¶

8 12. The propriety of the amortization relief EPE sought on behalf of its customers

9 has never been challenged. Instead, several intervenors—spearheaded by Appellant

10 City of Las Cruces (City)—focused that administrative proceeding on various legal

11 challenges to EPE’s claimed entitlement to collect any increased costs for PV3-

12 generated energy attributable to Winter Storm Uri.

13 B. The Nature and Status of the PV3 Facility and the Proxy Price 14 Methodology and Its Workings

15 {5} PV3 is part of a sprawling, Arizona-based nuclear electric generating station.

16 Explaining PV3’s history and status, EPE’s Vice President of Regulatory Affairs

17 testified in the proceedings that:

18 PVGS Unit 3 became operational in 1988 but was never included in 19 non-fuel base rates in New Mexico. In 1998, as part of a comprehensive 20 stipulation adopted by the Commission in Case No. 2722, the 21 Commission decertified and deregulated PVGS Unit 3 but approved the 22 voluntary use of PVGS Unit 3 capacity and energy for EPE’s New 1 Mexico customers at the lowest equivalent market price for capacity 2 and energy available to EPE. Notwithstanding that PVGS Unit 3 is a 3 decertified and deregulated plant in the New Mexico jurisdiction, EPE 4 has historically relied on the NMPRC’s approval to voluntarily use 5 PVGS Unit 3 capacity and energy to serve its New Mexico load when 6 available, and has agreed to sell power from PVGS Unit 3 to its 7 customers in New Mexico using the market proxy price established by 8 the Commission.

9 When asked to describe the benefits provided by EPE’s use of electricity generated

10 at PVGS Unit 3, EPE’s Vice President emphasized the utility’s view that “PVGS

11 Unit 3 is highly reliable” because, among other attributes, the facility “has very low

12 and stable fuel costs that have helped insulate EPE’s customers from volatile

13 purchased power and natural gas prices.” EPE’s Vice President also stated that “as

14 a carbon-free resource, PVGS Unit 3 is consistent with New Mexico’s carbon-free

15 objectives.”

16 {6} As the use of the word proxy suggests, the term proxy price denotes a default

17 pricing mechanism not dependent on the actual cost of generating power, in this case

18 electrical power produced in a nuclear power plant. See generally Final Order

19 Conditionally Approving and Clarifying Unopposed Stipulation (Final Order), El

20 Paso Elec. Co., No. 09-00171-UT, at 19-20 (N.M. Pub. Regul. Comm’n Dec. 10, 1 2009) (Doc. 1076824). 1 The Commission-approved proxy price rate for PV3-

2 generated energy was calculated on the basis of natural gas market index prices, as

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City of Las Cruces v. N.M. Pub. Regul. Comm'n, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-las-cruces-v-nm-pub-regul-commn-nm-2026.