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Miguel integrates energy law, public policy, and regulatory compliance to solve complex legal and business challenges for sophisticated energy and natural resources clients. Miguel’s experience has placed him at the nexus of business and energy, land-use, and natural resources law. He represents a variety of clients involved in the development of renewable energy projects, providing regulatory counsel, and big picture thinking that helps get projects across the finish line. Parallel to his renewable energy practice, Miguel has counseled public officials and private companies in connection with cryptocurrency and energy use, including how mining operations can utilize flared natural gas produced by shale fracking to power bitcoin mining facilities.

On June 8, 2022, the Public Utility Commission of Texas (“Commission”) filed a memo from its Infrastructure Division requesting that electric utilities, power generation companies, municipally owned utilities, and electric cooperatives (“Entities”) operating outside of the Electric Reliability Council of Texas (“ERCOT”) provide to Commission Staff unredacted copies of their Emergency Operations Plans (“EOP”). Entities that operate both outside of the ERCOT power region and in the ERCOT power region, and entities that operate solely in the ERCOT power region and have already provided an unredacted EOP to ERCOT (as required by the Emergency Operations Plan rule (16 TAC §25.53), are not required to provide the Staff an unredacted EOP.
Continue Reading Public Utility Commission Requests Unredacted Emergency Operations Plans From All Applicable Entities by June 24, 2022

The Texas Supreme Court (“TXSC”) recently confirmed what many already know: the Texas Commission on Environmental Quality (“TCEQ”) has only administrative authority related to water rights in Texas. This means that water rights ownership disputes must utilize Texas courts to adjudicate water rights ownership.
Continue Reading Texas Supreme Court Water Law Verdict Highlights Lack of TCEQ Authority Over Water Rights

The second meeting of the Electric Reliability Council of Texas’s (ERCOT) Large Flexible Load Task Force (LFLTF) facilitated an opportunity for ERCOT, ERCOT market participants (MPs), and bitcoin miners to get to know one another through educational presentations and dialogue. Over 250 participated in-person and virtually.

ERCOT began the event by providing a detailed overview of its interim interconnection process that it hopes to turn into a long-term and permanent process in the future. This interim process enables large loads like bitcoin mining operations to quickly (within 150 days) interconnect with the ERCOT grid while also maintaining grid reliability and meeting existing interconnection requirements. ERCOT anticipates that as much as 17GW of large flexible loads may seek to interconnect with the ERCOT grid by 2026. The bulk of these interconnection requests are expected to be made in north and west Texas.

Continue Reading ERCOT, Market Participants, and Bitcoin Miners Become Acquainted at Second Task Force Meeting

Effective March 25, 2022, the Electric Reliability Council of Texas (“ERCOT”) began requiring documentation from large electrical loads like cryptocurrency miners before allowing them to connect to the Texas power grid. Through a Market Notice, ERCOT established an interim process requiring transmission service providers (“TSPs”) to submit interconnection studies that meet the requirements of the National Electric Reliability Council’s Reliability Standard FAC-00202 for interconnection of certain large loads. Specifically, TSPs will be required to submit the studies for interconnection of the following types of loads:

  • New loads not co-located with a Resource with total demand within the next two years of 75 MW or greater;
  • Existing loads not co-located with a Resource increasing total demand by 75 MW or greater within the next two years;
  • New loads co-located with a Resource with total demand within the next two years of 20 MW or greater; or
  • Existing loads co-located with a Resource increasing total demand by 20 MW or greater within the next two years.


Continue Reading ERCOT Now Requires Cryptocurrency Miners to Provide Information on Their Impact to the Texas Power Grid

In case you missed it while preparing for your turkey dinner, on November 22, 2021, the United States Supreme Court issued a significant decision bearing on states’ rights to water in Mississippi v. Tennessee, et al.[1]  In that decision, the Court decided 9-0 that the Equitable Apportionment Doctrine, which had prior to this decision been held to apply only to surface waters, now also applies to interstate aquifers i.e., underground waters.
Continue Reading Water Law Update: The Equitable Apportionment Doctrine Is Not Just for Rivers and Streams Any More

What if you could substitute a renewable battery powered motor for the internal combustion engine just twelve years after its invention? At minimum, we would not be faced with the challenge of limiting greenhouse gas emissions. For all of the benefits the internal combustion engine has brought humanity, its environmental consequences are not among them.
Continue Reading The Argument for Mining Bitcoin from Clean Energy and Waste Energy Streams