Xcel Energy spent years funding the environmentalists who would eventually block its own gas plants, lobbying for the carbon mandates that would strand its coal fleet, and promising Colorado ratepayers that reliability and affordability would never suffer. The bill has arrived. Energy Bad Boys, a publication with no particular sympathy for utility executives in distress, documents the reckoning with something approaching satisfaction.
The precipitating event is a filing Xcel submitted to the Colorado Public Utilities Commission in March — a document the editors call "The Comanche Report," named for the coal plants at its center. The report contains an admission remarkable for its candor: Xcel's system does not meet its own reliability requirements, and it will not meet them for at least two years, possibly three. The only near-term solution, the company told regulators, is to keep its Colorado coal plants running. The same coal plants it had publicly celebrated retiring.
A Utility Hoisted on Its Own Petard
The editors do not let readers mistake Xcel for a passive victim of misguided state policy. They reconstruct a decade of choices that led directly to this moment. In 2018, Xcel became the first investor-owned utility in the country to declare a self-imposed goal of reaching a carbon-free electricity system by 2050. It followed that pledge by donating thousands of dollars to climate advocacy organizations — Fresh Energy in Minnesota, Western Resource Advocates in Colorado — and then worked alongside those groups to push regulators toward faster coal retirement schedules. It lobbied for the very carbon-free electricity mandates that Colorado and Minnesota eventually enacted.
The piece notes that Xcel's environmental policy manager, Nick Martin, explained at the time of the 2018 commitment: "As the economics of clean energy have improved, it became clearer that we could meet more aggressive goals without sacrificing affordability or reliability for our customers." Energy Bad Boys observes, with some economy of language, that "The Comanche Report has determined that this was incorrect."
The sequence matters. Xcel did not simply comply with state mandates handed down from Denver. It was a co-architect of those mandates. When Colorado passed House Bill 19-1261 and Senate Bill 19-236 in 2019 — legislation requiring utilities to file clean energy plans and targeting an 80 percent reduction in greenhouse gas emissions by 2030 — Xcel supported both bills. When it filed its own Clean Energy Plan in 2021, the company told the Public Utilities Commission it could achieve "an estimated 85 percent reduction in carbon dioxide emissions from 2005 levels and deliver nearly 80 percent of our customers' consumed energy from renewable resources" while "not compromising the Company's longstanding focus on reliability and affordability." That plan accelerated the retirement of Comanche Unit 3 from 2070 to 2030 — forty years ahead of schedule, two decades after the facility entered service.
The Reliability Hole
The Comanche Report, as summarized by Energy Bad Boys, lays out the consequences with unusual directness for a utility filing. Xcel analyzed multiple scenarios — keeping different combinations of coal units online, extending retirements, adding small amounts of new capacity — and found that every single one failed the industry's basic reliability standard. That standard, the Loss of Load Expectation, requires that a utility's system not experience a load-shedding event more than once every ten years. Under all of Xcel's analyzed scenarios, the piece reports, "the Company's loss of load probability exceeds the planning standard of less than 0.1. In some cases, the loss of load probability is over 10 times greater than planning best practices."
Ten times the acceptable blackout risk. Not a marginal miss — a categorical failure of the basic reliability compact between a regulated monopoly utility and the customers it serves. Energy Bad Boys notes that this outcome "isn't a surprise to many of us," though it may be to those who took Xcel at its word when the company promised the transition could be managed without sacrifice.
The near-term situation, as Xcel itself describes it, requires not just keeping Comanche Unit 2 running but restarting Comanche Unit 3 — a unit it had committed to retiring. The company found that "the incremental cost to replacing Comanche Unit 3 would be magnitudes more expensive for customers than" restarting the facility, and that "there are no reasonable alternatives to returning Comanche Unit 3 to service." Energy Bad Boys contextualizes this with its own 2023 analysis: the earlier decision to accelerate Comanche Unit 3's retirement from 2040 to 2030 alone added $8 billion to the cost of Colorado's energy transition, because retiring the asset ten years early required replacing its capacity with wind, solar, and battery storage on an accelerated timeline, all of which earns the utility a rate of return paid by ratepayers.
The Rate Base Engine
Here the analysis sharpens into something more structurally interesting than a simple "green energy failed" narrative. Energy Bad Boys walks through Xcel's investor presentation — filed contemporaneously with the somber Comanche Report — and finds an entirely different tone. Where the regulatory filing describes a company in crisis, the investor presentation describes a company preparing to spend its way to higher profits.
The mechanism is the rate base: the value of utility assets on which regulators allow the company to earn a return. Every dollar Xcel spends building wind farms, solar arrays, transmission lines, and battery storage becomes part of the rate base, and the rate base generates corporate profit. Customers pay for the assets; shareholders collect the return. Energy Bad Boys cites data from S&P Global showing that spending on generation, transmission, and distribution in Colorado tripled from $4.8 billion in 2009 to $13.6 billion in 2024. Looking ahead, Xcel projects its rate base will increase by another $17.6 billion over five years — $4.9 billion in distribution upgrades, $4.65 billion in transmission, $2.2 billion in renewables, and $1.79 billion in new natural gas generation.
This is the core of the critique, and it is more damning than a simple reliability failure. Xcel's "Steel for Fuel" strategy — its phrase for replacing fossil generation with wind and solar — was, the editors suggest, always partly a mechanism for growing the asset base and, with it, shareholder returns. When Xcel CEO Ben Fowke described the strategy in 2017, he said consumers and Xcel alike would benefit: consumers from lower-cost energy, Xcel from earning a return on new construction. Energy Bad Boys is blunt about what actually happened: "Unfortunately, only Xcel seems to have benefited, as consumers have been stuck with incredibly high-cost energy while Xcel's profits have exploded in recent years."
"Xcel not only supported legislative efforts to close down coal power plants and build unreliable generators, but its own company goal of 100 percent carbon-free preceded them. And now, because of these efforts spearheaded by Xcel itself, reliability has been undermined in Colorado to the point that the same company is noting how critical these coal assets are for reliability."
The rate projections at the end of the piece provide a concrete endpoint to this trajectory. A Colorado Public Utilities Commission webinar, the editors note, showed a range of outcomes from Xcel's buildout plans. If load growth comes in below forecast, Xcel's own numbers suggest residential electricity prices could rise 55 percent by 2029 compared to 2024 levels. The beatings, as Energy Bad Boys puts it, will continue until policies improve.
The Green Groups That Bit the Hand
One of the more structurally interesting arguments in the piece concerns what happened when Xcel tried to maintain system reliability by adding natural gas capacity. The company recognized it would need dispatchable backup generation as it retired coal. But the advocacy groups it had spent years funding and empowering opposed every gas plant proposal, insisting on more wind, solar, and storage instead. Xcel had cultivated those groups, given them credibility and resources, and now found itself unable to override them even when the reliability math demanded it.
Energy Bad Boys frames this as a kind of strategic miscalculation — perhaps Xcel believed it could "feed the crocodiles by funding green advocacy groups and lobbying for carbon-free mandates, shut down their coal plants, and then cash in on new natural gas plants as the company's reserve margins dwindled downward." Instead, the gas plants were blocked by the very interest groups Xcel helped cultivate. The company discovered that the coalition it built was more committed to its stated principles than Xcel itself was.
Critics might note that this framing elides a genuine good-faith dimension to Xcel's energy transition commitments. Utility executives in 2017 and 2018 were operating in a different economic environment for renewables, and the expectation that solar and storage costs would continue falling — reducing the reliability gap — was not unreasonable at the time. The Comanche Report reflects, at least in part, supply chain disruptions and permitting delays that compressed timelines in ways that were difficult to predict. The piece does not engage seriously with this defense.
Critics might also observe that Energy Bad Boys has a consistent editorial perspective — skeptical of renewable mandates, sympathetic to fossil fuel reliability arguments — and that perspective shapes which facts get foregrounded and which get downplayed. The piece does not, for instance, address the long-term cost trajectory of the coal fleet it defends, or the external costs — health impacts, climate exposure — that do not appear in utility rate bases. These are not trivial omissions.
And one might ask whether the reliability failures documented here are unique to Colorado, or whether they reflect a broader grid management challenge that also includes transmission bottlenecks, extreme weather events, and demand growth from data centers and electrification that no one in 2018 was accurately forecasting. Xcel's self-inflicted wounds are real; they are also not the complete story of why the grid is stressed.
Who Pays for This
Throughout the piece, the editors return to a figure who is mostly absent from Xcel's investor presentation: the Colorado ratepayer. The utility's financial health and shareholder returns are functions of how much capital it deploys and what return regulators allow it to earn. In a regulated monopoly structure, the company's incentive is to build things, not to build things cheaply or to operate things that are already paid for. Coal plants that have been depreciated generate operating cash flow but not the rate-base growth that drives shareholder value. New wind farms and transmission lines generate rate-base growth. The regulatory structure, in other words, can align with decarbonization goals in ways that also serve utility shareholders — and can misalign with ratepayer interests in the process.
Energy Bad Boys closes with H.L. Mencken: "Democracy is the theory that the common people know what they want, and deserve to get it good and hard." The editors apply this to Colorado voters who elected officials who enacted, with Xcel's assistance, the policies now generating their electricity bills. It is a pointed verdict, though it perhaps understates the degree to which most voters did not know — and could not reasonably have known — that the clean energy plans their officials championed would produce a reliability crisis by 2026.
Bottom Line
Energy Bad Boys makes a compelling case that Xcel Energy's reliability crisis is not a story of a utility victimized by overzealous regulators, but a story of corporate strategy running ahead of physical reality — with the rate-base incentive structure ensuring that shareholders profited from the journey even as the destination proved unreachable. The piece is sharper as a diagnosis of regulatory capture and utility self-interest than as a comprehensive energy policy argument, and its counterarguments deserve more engagement than they receive. But on its core claim — that Xcel built the trap it now finds itself in — the evidence it marshals is substantial.