Power Resource Group, Inc. v. Public Utility Commisison of Texas and Texas-New Mexico Power Company
This appeal concerns Power Resource Group, Inc.'s challenge to the Public Utility Commission of Texas's interpretation of rule 23.66, which governs the obligation of electric utilities to purchase energy and capacity from qualifying facilities (QFs). Power Resource argued that utilities must contract with QFs within 90 days of notification, irrespective of the QF's ability to deliver power within that period. The Commission asserted that a legally enforceable obligation only arises if the QF can provide energy within 90 days. The Texas Court of Appeals affirmed the district court's judgment, upholding the Commission's interpretation as reasonable and not preempted by federal law, and denied Power Resource's contract and fraud claims against Texas-New Mexico Power Company.