Northern Colorado’s Carbon Bomb: How PRPA’s Gas Overbuild Could Blow Up the Region’s Clean Energy Future and Lock In a Fossil Overcapacity Crisis

Approved under outdated assumptions, Rawhide's gas expansion now risks cementing 868 MW of redundant fossil capacity—stranding clean energy, inflating rates & triggering a financial & legal nightmare.

If you’re a resident of Longmont, Fort Collins, Loveland, or Estes Park, now is the time to speak up. Demand that your city officials halt construction of the 5 new gas turbines, reopen the Integrated Resource Plan, and call for an independent DOE or NREL review. It’s not too late now to reverse course—but soon it will be. This isn’t just about curtailing clean energy and escalating emissions—it’s about protecting our region from a massive multi-hundred-million-dollar mistake.

The Coming Overcapacity Crisis: How PRPA’s Gas Gamble Could Lock Northern Colorado into a Dirty Energy Trap

Introduction: The Illusion of Progress

On April 21, 2025, the Larimer County Commission unanimously approved Platte River Power Authority’s (PRPA) 1041 permit application to construct five new jet-engine gas turbines at the Rawhide Energy Station north of Wellington, Colorado. For many in the region, this decision was framed as a pragmatic step toward energy resilience: a temporary "bridge" to cover the intermittency of wind and solar during the twilight years of coal.

At first glance, this narrative appears reassuring. The gas turbines, capable of producing up to 200 megawatts (MW) of electricity, are said to provide flexible backup during periods of low renewable output, especially after the planned 2029 retirement of Rawhide Unit 1, PRPA’s existing 280 MW coal-fired plant. PRPA’s 2024 Integrated Resource Plan (IRP) positioned this as a seamless transition: phase out coal, bring in gas, and deepen renewable energy integration.

But that story is now a fiction—rendered obsolete by sweeping changes in federal energy policy.

In January and April of 2025, President Donald J. Trump issued a cascade of Executive Orders that overturned key assumptions underpinning the IRP. Most consequentially, Executive Order 14156, signed on January 20, declared a National Energy Emergency. This was not symbolic rhetoric. The declaration triggered sweeping authority under the Federal Power Act, particularly Section 202(c), empowering the U.S. Department of Energy (DOE) to retain critical energy infrastructure—especially coal plants.

Then, on April 8, a second wave of orders followed. These included directives titled The Reliability and Security of the United States Electric Grid, Reinvigorating America’s Beautiful Clean Coal Industry, and Protecting American Energy from State Overreach. Together, these orders codified a policy shift of historic magnitude: any retirement or fuel-switching of electric generating units over 50 MW is now prohibited if it would reduce accredited capacity or compromise grid reliability. The Executive Orders expressly require the DOE to prevent such retirements and compel continued operation of qualifying coal units—including, by every clear metric, Rawhide Unit 1.

This is the new legal and policy context. And it makes one thing brutally clear:

The Rawhide coal plant may not be shut down in 2029.

Not while a National Energy Emergency remains in effect and Executive Orders prohibit fuel-switching that reduces reliability. The Department of Energy, under Secretary Chris Wright, is now actively identifying coal assets for federal retention. Rawhide is a textbook case: dispatchable, geographically isolated, fuel-secure, and serving four key cities—Longmont, Fort Collins, Loveland, and Estes Park.

This changes everything.

If the gas turbines are built as planned, and Rawhide Unit 1 remains online as now federally required, then PRPA will not be transitioning to a cleaner, more flexible grid. It will be building a parallel fossil fleet, operating simultaneously, and creating a worst-case overcapacity scenario that could devastate the utility’s financial standing, displace renewable generation, and break faith with the public’s trust.

This is a bridge to nowhere. It is an on-ramp to a dead end.

The Cost of Clinging to a False Assumption

Permit approvals are always supposed to be forward-looking, but this permit was anchored in a backward-facing plan. PRPA’s IRP was finalized before the January 20 energy emergency declaration. Before the April 8 orders. Before the EPA’s March 2025 restructuring of the Regional Haze Program, which deprioritized coal phaseouts as a tool for visibility improvements. Before the federal government made it clear that strategic coal capacity is now considered a national security asset.

And yet Larimer County proceeded with approval as if none of this had happened.

This disjunction between federal policy and local permitting has created a legal and operational contradiction. The County approved new gas turbines on the premise that Rawhide coal was going offline. But that retirement is now barred by federal directive. The legal fiction of Rawhide’s shutdown allowed the permit to proceed—when in fact, that very shutdown is the condition that makes the gas turbines appear necessary in the first place.

If Rawhide coal remains, the gas turbines are no longer a bridge. They are an excess. A redundancy. A $350 million insurance policy on a coal-free future that no longer exists.

What Happens Next?

The worst-case scenario isn’t hypothetical. It is, at this point, the default trajectory. If PRPA proceeds with construction, and if DOE invokes its emergency powers—as explicitly instructed in the April 8 orders—the region will be left with:

• 280 MW of coal (Rawhide Unit 1)

• 388 MW of existing gas (Rawhide peakers)

• +200 MW of new gas turbines
  = 868 MW of fossil capacity

This is not resilience. This is bloat. And it raises urgent questions:

• Who pays to operate and maintain two overlapping fossil fleets?

• What happens to ratepayer bills when capital and fuel costs double?

• How will renewables survive in a grid saturated with “must-run” fossil generation?

• What recourse will cities like Longmont and Fort Collins have if stranded assets trigger bond downgrades or lawsuits?

None of these questions were addressed before the April 21 vote—despite being raised by myself in multiple public comments. PRPA has not released a post-Executive Order capacity analysis. No financial contingency plan has been made public. No revised IRP has been submitted. And Larimer County did not require it.

The illusion of progress was too politically convenient to interrogate. But the consequences of that illusion are now poised to cascade—through every layer of utility planning, regional economics, environmental compliance, and public accountability.

Section I: How Executive Orders Changed the Game

To understand why the five new gas turbines at Rawhide are no longer a bridge—but a trap—we must confront the legal and constitutional reality that emerged in 2025 on the heels of Donald Trump’s landslide victory in the 2024 election. On January 20, President Donald J. Trump issued Executive Order 14156, declaring a National Energy Emergency under the National Emergencies Act. This was not a mere rhetorical flourish. It was the formal invocation of federal emergency powers to override, reorient, and enforce national energy security priorities—in urgent response to the perceived inter-linking problems of rising electricity demand, inflationary pressure, international supply threats, and grid instability.

Executive Order 14156 declared, in unequivocal terms, that “the United States’ insufficient energy production, transportation, refining, and generation constitutes an unusual and extraordinary threat to our Nation’s economy, national security, and foreign policy.” Citing attacks on U.S. energy infrastructure and the weaponization of energy by hostile foreign actors, the order made clear: American domestic energy generation—including coal—is not just an economic asset. It is a strategic imperative.

From that moment forward, any plan to retire reliable, accredited generating capacity required a new test: Does this retirement reduce grid reliability during a declared emergency? If the answer is yes, the federal government now has both the authority—and the mandate—to intervene.

April 8: The Orders That Locked In Coal

Then came the second wave. On April 8, 2025, President Trump signed a coordinated suite of energy executive orders that restructured the entire legal landscape for fossil fuel generation, particularly coal. Four of these orders are especially relevant:

1. The Reliability and Security of the United States Electric Grid

2. Reinvigorating America’s Beautiful Clean Coal Industry

3. Protecting American Energy from State Overreach

4. Regulatory Relief for Certain Stationary Sources

Together, these orders elevated coal from a legacy fuel to a protected national asset. They explicitly prohibit the decommissioning, retirement, or fuel-switching of any electric generating unit over 50 MW—unless doing so can be proven not to reduce “accredited generating capacity” or grid reliability. Enforcement responsibility falls to the Department of Energy (DOE) under the Federal Power Act §202(c), which grants emergency authority to compel continued operation of energy facilities deemed critical to grid function.

That authority is not theoretical. It has precedent. DOE has previously used §202(c) emergency powers during natural disasters, extreme weather conditions, and post-hurricane recovery operations. The April 8 orders now systematize this tool for proactive use. They require DOE to:

• Develop a uniform methodology for assessing regional reserve margins.

• Identify energy assets deemed essential to reliability.

• Use Section 202(c) to block the retirement of any such asset.

• Prohibit fuel-switching or shutdowns that reduce capacity, even during environmental compliance planning.

Rawhide Coal Is Now Federally Shielded

Rawhide Unit 1 fits every metric for retention under this framework:

• 280 MW of nameplate capacity.

• Baseload, dispatchable, and fuel-secure (coal stored on-site).

• Isolated from urban population centers, reducing sabotage risk.

• Integral to the power supply for over 350,000 residents across Longmont, Fort Collins, Loveland, and Estes Park—a wealthy region that may be considered vital to national security.

Under previous political circumstances, Rawhide was scheduled for retirement in 2029. But under the Trump administration’s executive orders, that shutdown cannot occur unless DOE explicitly approves it—and that is increasingly unlikely. Federal policy now treats coal as a bulwark of energy sovereignty, not an environmental liability.

Moreover, EPA Administrator Lee Zeldin has announced the agency’s intent to restructure the Regional Haze Program. The stated goal: to prevent the Clean Air Act program from being used to shut down otherwise viable and economical coal assets. This includes delaying or revising compliance with the Mercury and Air Toxics Standards (MATS) rule updates, which had previously been used to justify coal retirements under environmental mandates.

What does this mean for PRPA? It means Rawhide can’t simply be retired on paper. It means no Integrated Resource Plan (IRP) can simply presume the absence of Rawhide unless DOE certifies its dispensability. It means the coal plant remains in play, and the assumptions used to justify the five new gas turbines are fundamentally invalid.

A Legal Straitjacket

The binding nature of these orders cannot be overstated. While some may argue that executive orders can be challenged or delayed in court, they are presumptively enforceable and must be treated as authoritative by all federal agencies. In permitting cases, courts regularly defer to executive orders that guide agency action—especially during a national emergency. And under the Supremacy Clause of the Constitution, federal law—including executive action under valid statutory authority—preempts state and local decisions that conflict with it.

That is exactly the posture of these orders.

They override any local planning assumptions about fuel transitions. They elevate the retention of Rawhide coal from a local decision to a federal mandate. They require DOE and potentially FERC to intervene if PRPA attempts to decommission strategic capacity in defiance of national emergency policy.

In this context, Larimer County’s decision to approve the new gas turbines—based on the now-invalid assumption that Rawhide will be retired—borders on negligence. The Commission was not just approving a power plant. It was endorsing a planning model that is now structurally incompatible with federal law.

The Implications Are Immediate and Far-Reaching

With the new executive orders in place:

• PRPA cannot assume Rawhide will be retired in any credible financial or environmental model.

• Construction of the new gas turbines now guarantees simultaneous fossil operation, not substitution.

• The permit approval embeds structural overcapacity into PRPA’s portfolio for at least the next two decades.

The illusion is gone. This is not transition. It is duplication—with devastating consequences for ratepayers, renewables, utility finances, and public trust.

Section II: The Math of a Fossil Overbuild

At the heart of PRPA’s Rawhide expansion is a math problem—one that’s no longer theoretical. Now that the Rawhide coal plant cannot be legally decommissioned without federal approval, PRPA’s future fossil fuel fleet will no longer be an either-or proposition. It will be additive. What was once modeled as a substitution plan—gas replacing coal—has quietly become a doubling down.

Here’s what that looks like, numerically:

• Rawhide Unit 1 (coal): 280 MW

• Existing Rawhide gas turbines (peakers): 388 MW

• New gas turbines (approved April 21): 200 MW
  = Total fossil capacity post-construction: 868 MW

That’s 868 megawatts of firm, dispatchable fossil generation. In a region with relatively slow and not explosive demand growth, that number is not a sign of prudence. It’s a warning siren.

Peak Demand vs. Overbuild: The Capacity Mismatch

PRPA’s own load forecasts do not justify this level of capacity. According to its 2024 Integrated Resource Plan, PRPA’s system peak load in recent years has hovered around 700 to 730 MW, with only modest projected growth over the next decade—even factoring in electrification and AI trends.

That means if PRPA proceeds with both coal and gas simultaneously online, its fossil fleet alone will be nearly 120% of peak demand. And that’s before factoring in hundreds of megawatts of wind, solar, and hydroelectric resources already contracted or operating in the system.

This is not grid resilience. This is grid bloat.

Overcapacity may sound harmless—better too much than too little, right? But in utility planning, overcapacity is not just a waste of money. It creates operational inefficiencies, financial liabilities, and structural distortions that cascade throughout the system.

The Fixed Cost Trap

Every megawatt of capacity PRPA brings online carries fixed costs—capital financing, insurance, maintenance, staffing, and fuel security measures. If the utility is unable to dispatch these new units frequently (because coal is retained and renewables continue generating), then those fixed costs must be spread over fewer kilowatt-hours of output.

The result? A steep rise in per-unit costs, which gets passed directly to consumers. Even a modest underutilization of the new gas turbines could turn a $350 million infrastructure investment into a financial anchor—one that ratepayers will be forced to drag for decades.

This scenario, known in utility finance as a “stranded asset” risk, is not theoretical. It has played out across the country, from TVA’s failed Bellefonte nuclear project to PG&E’s gas buildout before the California solar boom. Stranded assets aren’t just idle—they’re actively harmful, draining ratepayer resources and crowding out smarter investment options.

Dispatch Conflicts and Market Saturation

Even if PRPA wanted to fully utilize all 868 MW of fossil capacity, it couldn’t—not without displacing renewables, violating emissions limits, or sending electricity into markets at a loss.

Dispatchable fossil generation competes internally for runtime. With so much fossil capacity online, PRPA will face a continuous scheduling conflict:

• Which units do you run when gas is cheap, but coal is federally required to stay online?

• How do you justify running new gas when old gas is already there—and debt-free?

• What happens when wind and solar generate during midday, but you’ve bonded gas turbines that must produce revenue?

This isn’t a resilience puzzle. It’s a grid management nightmare. Too many dispatchable units chasing too few peak hours, locked in by contractual obligations and stranded asset pressures.

Financial Consequences: Who Pays?

The math may be abstract inside an IRP, but it hits hard in real-world economics. When overcapacity drives down utilization rates, and fixed costs remain high, someone must absorb the losses. And that “someone” is the public.

• Ratepayers in Longmont, Fort Collins, Loveland, and Estes Park will pay through higher electric bills.

• City governments may face downgraded credit ratings if PRPA’s bond covenants are stretched or broken.

• Local budgets could be redirected away from schools, roads, or public safety to backstop utility losses.

• Investors in renewable and distributed energy will hesitate, seeing the market as saturated and structurally biased toward fossil generation.

These are not side effects. They are the direct, calculable results of a capacity expansion that violates every principle of modern grid planning.

The False Security of Redundancy

Defenders of the new gas turbines argue that they are “insurance”—a flexible, fast-start resource to fill gaps left by coal and renewables. But insurance only makes sense when there is a clear risk being offset. If coal is staying online and renewables are growing, then the risk of insufficient dispatchable capacity is not real. The real risk is overcapacity, and it is not just financially harmful—it is operationally paralyzing.

PRPA is heading toward a future in which its system is so overloaded with firm capacity that it cannot prioritize clean energy, is unable to respond flexibly to demand-side innovation, and can’t justify the economics of its own infrastructure decisions. Worse, it may find itself forced to run uneconomic units simply to recoup capital, a dynamic known in regulatory circles as the “must-run trap.”

The gas turbines may be fast-start. But the trap they create is slow and inescapable.

Section III: Financial Fallout — Ratepayer Pain and Bond Market Shock

When Larimer County approved PRPA’s permit for five new gas turbines on April 21, 2025, it did more than greenlight a construction project. It triggered a financial time bomb.

PRPA now faces a capital commitment of $350 million or more for infrastructure that may be rendered underutilized the moment it is built. The turbines were modeled as replacements for Rawhide Unit 1, the coal-fired plant slated for retirement in 2029. But under federal executive orders issued in January and April 2025, that retirement can no longer legally proceed without Department of Energy approval—approval that is increasingly unlikely to be granted.

The result is a utility locked into running both fossil fleets—the old and the new—simultaneously. And when infrastructure is redundant, debt-financed, and locked into long-term fixed costs, the question is no longer if someone will pay. It’s who will pay—and how bad the fallout will be.

$350 Million in Capital Exposure, with No Exit

Industry benchmarks for aeroderivative gas turbines—like the LM6000 units PRPA is likely to procure—place per-megawatt costs around $1.5–$2 million, inclusive of site work, interconnection, and permitting. Multiply that by 200 MW and PRPA’s project falls squarely in the $300–$400 million range.

That’s before financing costs. That’s before inflation. That’s before any cost overruns, which are increasingly common in today’s constrained construction and equipment supply chain environment.

And it’s not optional capital. Once bonds are issued and construction begins, PRPA must pay those debts back—regardless of whether the turbines ever operate at modeled capacity. The economics of these turbines do not scale down. If they run at half their projected capacity because coal is retained under federal mandate, the per-kWh cost of those units doubles.

This isn’t a planning error. It’s a stranded asset scenario in the making—built into the system by a permit that approved 200 MW of new gas under the false assumption that 280 MW of coal would disappear.

Underutilization: The Death Spiral Begins

The core financial problem isn’t just capital outlay. It’s capacity factor collapse.

Gas turbines like these are typically modeled for 10–30% annual utilization. But if Rawhide coal remains online—providing base load power due to federal retention orders—then the actual utilization of the new gas turbines could fall well below that range. They may sit idle for long stretches and be dispatched last—or displace clean energy. They will become financial liabilities rather than operational assets.

This triggers what utility finance experts call a debt-service mismatch: where the fixed costs of infrastructure cannot be justified by the revenue it generates. PRPA will be forced to raise rates to maintain solvency. That rate pressure, in turn, will reduce energy affordability and incentivize DER migration, potentially causing further load defection and worsening revenue shortfalls.

This is the debt spiral—self-reinforcing and hard to reverse once initiated.

Bond Downgrades and Municipal Risk

PRPA is a public power agency. Its obligations are backed—either directly or indirectly—by the fiscal health of its owner communities: Longmont, Fort Collins, Loveland, and Estes Park.

If the agency takes on $350+ million in debt for infrastructure that cannot deliver its projected revenue, ratings agencies will notice. Standard & Poor’s, Moody’s, and Fitch monitor public utilities for signs of fiscal imprudence. Building redundant fossil infrastructure during a federal energy emergency—while maintaining a second fleet under legal compulsion—is the very definition of imprudence.

A downgrade in PRPA’s bond rating would have ripple effects:

• Higher borrowing costs for all future capital projects.

• Reduced investor confidence, particularly in clean energy or modernization initiatives.

• Credit pressure on member cities, which may be called upon to backstop financial shortfalls or assume risk exposure through contractual obligations.

What begins as a stranded infrastructure problem rapidly becomes a municipal finance crisis. City councils would be forced to make impossible tradeoffs—between backstopping their public utility’s debt and protecting local budgets for transit and public safety.

The four cities that own and control PRPA may find themselves dragged into bondholder negotiations and ratepayer lawsuits—none of which were on the table when PRPA first sold this project as “resilience infrastructure.”

Layered Liability: Who Pays for Redundancy?

The most devastating financial reality is this: everyone pays, but no one benefits.

Ratepayers will face higher bills. This isn’t a forecast—it’s a certainty. Even if the turbines are barely used, they must be financed. And PRPA has no shareholders to absorb the blow.

Local governments may face legal exposure. If courts determine that the permit was granted based on materially outdated assumptions, and if ratepayers suffer quantifiable harm as a result, class action litigation is not out of the question.

Bondholders will demand answers. Environmental watchdogs will demand audits. And the Department of Energy—empowered by Executive Order 14156 and Section 202(c) of the Federal Power Act—may yet step in to halt or unwind the expansion if it deems the overbuild to compromise national grid flexibility or fuel neutrality.

This is not a prudent hedge. It is a system-wide fiscal hazard, locked in by the approval of a permit based on an IRP model that no longer reflects federal law.

A Utility Model Built on Legal Fiction

PRPA’s current plan—coal out, gas in—was never re-evaluated after the January and April executive orders changed the legal landscape. There was no revised IRP. No updated demand forecast. No DOE consultation.

Instead, Larimer County approved the permit on April 21 as if it were still 2024.

That temporal lag has consequences. By failing to account for the new federal mandates, PRPA is now preparing to finance a gas buildout based on obsolete modeling. And when that model fails, the public will be left holding the bag.

Section IV: Renewable Reversal — How Overcapacity Kills Clean Energy

When PRPA’s gas turbine permit was approved, the public was told the project would “support renewable integration” by firming intermittent supply. In theory, that’s true: flexible gas can help balance variable generation.

But that’s not what this project is actually doing.

In reality, by combining five new gas turbines with a federally retained coal plant, PRPA is flooding its system with firm fossil capacity that will crowd out renewables at every level—from utility-scale solar to behind-the-meter batteries. The result is a renewable reversal: a structural shift in dispatch priority, investment signals, and grid architecture that locks in fossil favoritism and blocks clean energy from scaling.

This is not a side effect. It’s baked into the math.

The Curtailment Trap: When Fossil Crowds Out Clean

Every electric grid has a dispatch stack—a merit order that determines which resources are turned on, and when. When firm fossil resources are available and already financed, they are prioritized. They’re “must-run” assets with sunk capital and high fixed costs.

This is especially true in PRPA’s case. If the Rawhide coal plant is kept online under federal Executive Orders, and the new gas turbines are built as planned, the system will be saturated with dispatchable fossil power. During sunny or windy days—when solar and wind output peaks—there will simply be no room on the grid to absorb it.

PRPA’s operators won’t turn off the new gas turbines. They can’t—they need the runtime to justify the debt. They won’t shut down Rawhide either—it’s federally retained and still cost-effective under baseline load. So what gets curtailed?

Renewables.

Wind and solar assets will be told to ramp down. Community solar arrays will be clipped. Battery discharges will be deprioritized. This is the curtailment trap—a system where clean energy is available but unwanted, because fossil generation has been structurally overbuilt.

Similar dynamics are playing out in California, where transmission congestion has delayed solar projects and wasted tens of millions of dollars in curtailed renewable output, and in Germany, where overcapacity has paradoxically caused CO2 emissions to increase despite massive investment in renewable energy. PRPA is now on the same trajectory—but without the same market size or regulatory sophistication to absorb the damage.

Lost Market Signals: DERs, Storage, and Customer Innovation

Beyond the dispatch stack, overcapacity sends a chilling message to the broader energy ecosystem: don’t bother.

If you’re a homeowner in Longmont or Fort Collins thinking about rooftop solar, why invest when you know your system will be curtailed? If you’re a business weighing battery backup or load-shifting software, why sign up when the grid doesn’t value flexibility? If you’re a startup building smart thermostats, VPP tools, or microgrid controllers—why engage with a utility that just spent $350 million doubling down on centralized fossil power?

PRPA is signaling that customer-centered innovation is not part of its future. By oversaturating its system with dispatchable fossil capacity, the utility is telling the market: “We’ve got this handled. We don’t need your help.”

That’s not just bad strategy—it’s bad economics. The clean energy transition isn’t a luxury add-on. It’s a cost-reduction strategy for an increasingly digital and electrified economy. When PRPA disables the signals that make clean energy viable, it delays investment, suppresses adoption, and deprives communities of the job growth, grid flexibility, and resilience benefits that decentralized resources provide.

Worse, it strands customer assets. Households and businesses who have invested in solar or storage may find their systems curtailed or devalued, even as they continue paying higher rates to backstop the utility’s stranded fossil fleet.

The Must-Run Trap: When Sunk Costs Dictate Dispatch

Once a utility builds expensive infrastructure, a perverse incentive takes hold: keep it running, no matter what.

This is the must-run trap. It happens when a utility is so financially overexposed to a specific asset that it becomes cheaper (on paper) to keep dispatching that asset—even if better, cheaper, cleaner options are available.

That’s where PRPA is heading. With over $350 million in sunk costs for the new gas turbines, and with Rawhide Unit 1 likely retained under federal orders, the utility will feel immense pressure to maximize utilization of its fossil fleet. Every hour a gas turbine sits idle is a loss. Every day that coal isn’t dispatched increases the relative cost of running the system.

So what happens? The utility rationalizes continuous fossil dispatch—even during off-peak hours. It avoids DER participation programs. It downplays curtailment complaints. It marginalizes solar and storage in future IRPs. All in the name of “recovering investments” and “protecting ratepayers.”

In practice, it creates a self-reinforcing fossil bias. Once fossil overcapacity is built, it becomes institutionally impossible to retire it—because the financial liability is too high, the dispatch inertia is too deep, and the political resistance too entrenched.

The system becomes a stranded asset factory, churning out expensive, inflexible, and redundant capacity while freezing out the modular, scalable tools that actually support resilience and decarbonization.

Structural Incompatibility with a Clean Energy Future

PRPA’s gas-plus-coal scenario is not neutral to the clean energy transition. It is structurally incompatible with it.

Overcapacity is not a staging area for renewables—it’s a ceiling. It fills the grid with inflexible generation that must be dispatched first, leaving no room for solar ramping, battery discharges, or demand-side responses. It kills the price signals that DERs need to thrive. It stalls the growth of storage, innovation, and customer choice. And it builds the institutional narrative that renewables “don’t perform,” when in fact they were simply crowded out.

This is the final irony of the April 21 permit approval. It was pitched as a move to stabilize the grid. In truth, it is a move to sterilize the grid—to render it impervious to innovation, flexibility, and decarbonization.

And once that structural reality sets in, it’s not just today’s clean energy projects that suffer. It’s tomorrow’s.

Section V: Structural Lock-In and Political Fallout

In infrastructure planning, there is a point of no return—a moment when a theoretical model becomes a permanent feature of reality. With the approval of Platte River Power Authority’s (PRPA) gas turbines, Larimer County crossed that threshold.

What may have seemed like a rational hedge—building flexible gas to firm a renewable transition—has now become a binding, self-reinforcing system of overcapacity that will distort the region’s energy landscape for decades. This isn’t just a temporary detour. It is structural lock-in. And the political, regulatory, and legal fallout is only beginning.

Infrastructure Is Inertia

Once physical infrastructure is built, it rarely gets dismantled early—especially when it’s publicly financed. These five gas turbines, once constructed, will not simply be mothballed in five or ten years when renewable economics improve or climate policy shifts.

Why?

Because they will be bonded. Staffed. Maintained. Permitted. Integrated into long-term dispatch schedules. And backed by financial instruments that depend on continuous operation to justify their cost.

This is the essence of structural lock-in: the way in which past investment decisions constrain future policy options. PRPA will not be able to accelerate battery storage, virtual power plants, or flexible load programs if it has already filled its capacity margin with 868 MW of fossil generation. Every new megawatt of clean energy added to the system will erode the economics of its existing fossil fleet.

That dynamic creates a vicious cycle:

• Fossil dispatch is prioritized to protect sunk costs.

• Renewables are curtailed or delayed.

• Public confidence in the energy transition erodes.

• Political support for further clean energy investment weakens.

This is how progress stalls—not because of overt opposition, but because of subtle, bureaucratic self-interest in protecting infrastructure that never should have been built in the first place.

The Sidelining of Future Clean Energy Projects

The most tragic consequence of this overbuild is not what it costs—it’s what it displaces.

PRPA’s own IRP already showed modest growth in distributed energy resources (DERs), battery storage, and virtual power plants. But that growth will now be deprioritized—not by policy, but by physics. There is only so much headroom in a regional grid. And if fossil capacity is locked in at 868 MW, the system simply won’t be able to absorb large-scale new solar, community battery arrays, or aggressive demand response programs.

This means:

• Local solar companies may go out of business.

• Emerging grid services like demand flexibility may be shelved.

• Clean energy developers may bypass PRPA’s territory altogether.

• Regional innovation hubs may wither.

Instead of accelerating the clean energy transition, PRPA’s approval locks in a fossil-first future—one that is inflexible, centralized, and top-down. That’s not just a missed opportunity. It’s a generational failure in public infrastructure strategy.

Political Blowback Is Coming

The citizens of Longmont, Fort Collins, Loveland, and Estes Park were told a fairy tale: that this was a smart, cautious move to stabilize the grid. That the gas turbines were temporary. That coal was going away. That renewables would flourish.

Now, with Rawhide Unit 1 legally protected under federal executive orders, and with $350 million in new gas capacity coming online, that story has unraveled.

The result? Public betrayal.

When ratepayers see higher bills—not lower. When rooftop solar gets curtailed. When PRPA falls behind regional utilities that are actually modernizing their grids. When bond ratings are downgraded. When clean energy developers walk away.

Voters will ask what happened.

They will not accept that Larimer County’s vote was “just permitting.” They will not accept that the IRP was based on outdated assumptions. They will point to the April 8 executive orders and ask: why weren’t they considered?

Legal and Regulatory Scrutiny

What starts as political backlash may soon become legal exposure.

If ratepayers suffer financial harm from redundant infrastructure built on invalid assumptions, class action lawsuits are likely. If bondholders see material misstatements in PRPA’s financial planning, securities litigation may follow. If PRPA attempts to curtail renewable generators while favoring gas dispatch, federal agencies may investigate discrimination against clean energy.

Meanwhile, Larimer County—by approving a permit that may now violate the federal Supremacy Clause—could find itself in court facing a preemption challenge or administrative appeal. The Department of Energy may issue a 202(c) order that invalidates the coal shutdown. The Environmental Protection Agency, now under Administrator Lee Zeldin’s deregulatory directive, may revise regional haze enforcement in ways that make continued coal operation legally protected—exposing PRPA’s new gas build as a redundant and unauthorized emissions source.

In short, the legal landscape is shifting fast. And the April 21 permit may become the centerpiece of multiple overlapping legal, regulatory, and political fights—all of which trace back to a single failure: building for a future that no longer exists.

Section VIII: Air Pollution Fallout — From Climate Goals to Public Health Backslide

Until now, most of the public debate surrounding PRPA’s Rawhide expansion has centered on carbon: emissions targets, net-zero commitments, and the utility’s role in regional climate action plans. But there’s another, more immediate danger that’s received far less attention—and it’s the one most likely to impact the health and safety of Northern Colorado residents in the near term.

That danger is air pollution.

By building five new gas turbines while keeping Rawhide Unit 1 coal plant online, PRPA is creating a dual-polluter scenario—a fossil fleet that will emit elevated levels of ozone precursors, fine particulate matter, heavy metals, and hazardous air pollutants for years to come. This isn’t just a carbon overbuild. It’s an air toxics time bomb, and it couldn’t be happening at a worse time.

Ground-Level Ozone: Colorado’s Ongoing Crisis

The Northern Front Range is already in violation of federal health-based air quality standards. Classified by the EPA as a Severe Nonattainment Area under the 2015 8-hour ozone standard, the region regularly exceeds safe levels of ground-level ozone—a pollutant strongly linked to asthma, heart disease, and premature death.

Ozone isn’t emitted directly. It forms when nitrogen oxides (NOₓ) and volatile organic compounds (VOCs) react under sunlight—exactly the type of emissions produced by jet-engine gas turbines like the ones PRPA plans to install. Combined with vehicle exhaust, industrial activity, and oil and gas operations, the new turbines will worsen a regional health crisis that is already chronic and deadly.

And it’s not just theoretical. PRPA’s own project documents show that the turbines are designed for frequent starts and ramping, which emit disproportionately high amounts of NOₓ and CO during startup cycles. This isn’t clean or efficient. It’s volatile combustion in a region already under federal scrutiny.

Meanwhile, Rawhide Unit 1 emits sulfur dioxide (SO₂), mercury, PM₂.₅, and other air toxics regulated under the Clean Air Act. If it continues operating under federal retention orders—as the Trump administration’s executive directives all but guarantee—then the Rawhide site becomes a cumulative pollution zone, with two overlapping fleets producing parallel plumes of harm.

The Return of Air Toxics

Gas turbines may burn cleaner than coal on a per-kWh basis, but they are not clean. In addition to NOₓ and CO, they emit:

• Formaldehyde

• Acetaldehyde

• Benzene

• 1,3-butadiene

• Carbonyls and ultrafine particles

These pollutants are known or suspected carcinogens, neurotoxins, and cardiovascular stressors. They are especially dangerous for children, pregnant women, and the elderly. And because gas turbines ramp quickly and run intermittently, their emissions are harder to predict, model, or control, especially during startup and shut-down cycles.

Add in the two 30,000-gallon ammonia storage tanks proposed for turbine NOₓ control, and the Rawhide site now introduces new industrial hazards—just miles from rural homes, farms, and schools.

From Climate Leadership to Public Health Liability

For years, PRPA has promoted itself as a climate leader, touting its commitment to 100% non-carbon electricity by 2030. But the simultaneous operation of coal and gas under this permit makes that goal effectively unreachable—not just because of carbon, but because of conventional air pollutants that violate the spirit, if not yet the letter, of Colorado’s clean air laws.

It’s not just the emissions. It’s the betrayal of community trust. The people of Longmont, Fort Collins, Loveland, and Estes Park did not support PRPA’s energy transition because they wanted jet engines and coal stacks running side-by-side. They supported it to protect their air, their children, and their future.

Now, instead of winding down air pollution at the Rawhide site, the permit guarantees decades more of it. And if ozone levels spike, if EPA enforcers crack down, if health departments start seeing clustered respiratory events—local officials and utility managers will not be able to claim ignorance. This was predictable. It was avoidable. And approved anyway.

A Legal Reckoning May Follow

Because the region is in ozone nonattainment, any project that increases NOₓ emissions—especially one that overlaps with retained coal—must be tightly scrutinized under Clean Air Act provisions. That scrutiny is coming.

• Environmental groups may sue under citizen suit provisions for failure to model cumulative emissions.

• The EPA may issue State Implementation Plan disapprovals or SIP Calls for failing to incorporate the new gas plant emissions.

• Local governments may face new burdens under Title V permitting and air quality monitoring if emissions spike during turbine operation.

This isn’t just public health negligence. It may soon be regulatory noncompliance—with fines, lawsuits, and mandatory mitigation plans to follow.

Let’s Be Honest About What Just Happened

The Rawhide gas plant permit wasn’t a clean energy bridge. It was a multi-pollutant backslide, locking in a future of fossil combustion at a moment when cleaner, cheaper, and healthier options were fully within reach.

And while greenhouse gases like carbon dioxide and methane have dominated the conversation—and they will increase in the overcapacity scenario—the stakes here are more intimate. Ozone attacks your lungs. Mercury affects your brain. Ammonia can ignite or explode. PM₂.₅ enters your bloodstream. These are not abstractions. These are the real costs of locking two fossil fleets into the same footprint.

Conclusion: From Permit to Overcapacity Predicament

This isn’t just bad planning. It’s a slow-motion policy failure, unfolding in real time—and unless course-corrected, it will become the defining energy mistake of the century for Northern Colorado.

When Larimer County approved PRPA’s permit to build five new gas turbines, it did so under a collapsing scaffolding of outdated assumptions. It presumed a 2029 coal plant retirement that is now legally blocked. It relied on an Integrated Resource Plan that never accounted for the Trump administration’s Executive Orders. It committed hundreds of millions of dollars in public infrastructure to a buildout premised on a future that no longer exists.

This wasn’t resilience. It was redundancy. It wasn’t transition. It was entrenchment. And it wasn’t a bridge. It was the start of a bottleneck—one that will throttle renewables, inflate bills, destabilize PRPA’s finances, and fracture public trust in utility governance.

Let’s be clear about what we’re looking at:

• 868 MW of fossil capacity, locked into a grid with no corresponding demand growth.

• A system structurally incapable of absorbing new renewables without curtailment.

• A financial model predicated on the double-dispatch of coal and gas.

• A legally fragile permit granted in direct contradiction of national emergency energy policy.

It didn’t have to be this way. And it still doesn’t.

But the window is closing.

The Path Forward: Three Urgent Actions

PRPA’s gas turbines aren’t operational yet. Shovels are not yet in the ground. Contracts can still be paused. Reviews can still be reopened. Federal alignment can still be sought.

Here’s how:

1. Reopen the IRP

   PRPA’s 2024 Integrated Resource Plan is now invalidated by legal reality. Its assumptions about coal retirement, demand projections, and dispatch strategy no longer match current federal directives. It must be reopened. A supplemental IRP addendum should be commissioned immediately, specifically analyzing the implications of Executive Order 14156, the April 8 orders, and DOE’s likely 202(c) designations. No further infrastructure development should proceed until the IRP is re-grounded in legal and policy reality.

2. Suspend Construction of the Gas Turbines

   PRPA must voluntarily pause all procurement, engineering, and site work related to the new turbines until the status of Rawhide Unit 1 is resolved through formal DOE guidance. Proceeding without this clarity guarantees financial and operational conflict. Larimer County, meanwhile, should issue a temporary suspension of the 1041 permit under its own authority, citing newly emerged federal policy and the need for an updated modeling basis. This is not obstruction. It’s responsible governance.

3. Demand an Independent Review by DOE or NREL

   The Department of Energy—and specifically the National Renewable Energy Laboratory (NREL), located just 50 miles south in Golden—has both the capacity and the mandate to assess grid reliability scenarios under emergency policy conditions. Local officials, city councils, and public stakeholders must formally request an independent, federally aligned review of PRPA’s resource plan. That review should assess least-regret scenarios for capacity buildout under the new Executive Orders, and offer federally informed guidance on which assets should be retained, retired, or avoided altogether.

This is how we avoid catastrophe. Not by litigating the past, but by realigning the present to the reality of 2025.

The Stakes Could Not Be Higher

This isn’t just about megawatts and permits. It’s about public trust in regional energy planning. It’s about financial stewardship of billions in public infrastructure. It’s about whether Northern Colorado modernizes its grid intelligently—or locks itself into an expensive, fossil-first future that no one actually wanted.

If the overcapacity crisis unfolds as predicted, the pain will be real. The rate hikes will be real. The bond downgrades will be real. The missed renewable investments will be real. The legal backlash will be real.

But so too can be the correction—if we act now.

The IRP must be reopened. Construction must be suspended. And federal eyes must be brought to bear.

Only then can we step back from the brink—and build the flexible, resilient, clean, truly modern energy system Northern Colorado deserves.