BCA Letter To PUCT

January 6, 2026

Mr. Thomas J. Gleeson, Chairman
Kathleen Jackson, Commissioner
Ms. Courtney K. Hjaltman, Commissioner
Ms. Morgan Johnson, Commissioner
Public Utility Commission of Texas
P.O. Box 13326
Austin, TX 78711-3326

Dear Honorable Chairman and Commissioners-

The Bandera Canyonlands Alliance (BCA) is a local landowner organization representing members in Bandera, Real, and Uvalde Counties. For nearly 20 years, BCA has worked to protect the land, water, and economic vitality of this region. I write today on behalf of our members regarding the proposed Howard Solstice high-voltage transmission line project by CPS Energy and AEP Texas.

BCA has joined the Hill Country Preservation Coalition in urging these companies to route transmission lines within existing utility and highway corridors to protect sensitive river basins and groundwater resources. As currently proposed, several route segments would cut through some of the most rugged and ecologically fragile terrain in the Hill Country.

These routes raise serious concerns about costly legal fights over right of way acquisition and unpredictable engineering obstacles. Construction across karst landscapes—characterized by unmapped caves, fissures, and interconnected underground water systems—poses substantial risks to springs, rivers, and the Edwards Aquifer Contributing and Recharge Zones. Disruption to these systems could threaten drinking water supplies relied upon by millions of Texans. The remote nature of these areas also increases wildfire risk and complicates emergency response in the event of tower failure or line ignition.

In addition to environmental risk, the business case for these routes demands rigorous scrutiny. Engineering and construction costs for massive transmission towers in such terrain will be significantly higher, and any cost overruns or delays will be borne by CPS and AEP customers and ratepayers across Texas through increased electricity rates. Clear-cutting wide easements and anchoring tall towers into unstable geology further magnifies both financial and environmental risk.

Given that ratepayers statewide will absorb these costs, it is essential that the Public Utility Commission of Texas require a thorough and transparent review of all proposed routes. This project should not be fast-tracked without full regulatory evaluation of alternatives that minimize risk, cost, and environmental harm.

The regional economy must also be considered. Tourism and outdoor recreation are the backbone of many local communities. Visitors from around the world come to enjoy the area’s scenic landscapes, rivers, wildlife, and state parks. The introduction of large transmission towers in remote and visually intact areas threatens this economic engine and puts small businesses—lodging operators, outfitters, restaurants, and retailers—at risk.

For these reasons, we respectfully request that the PUCT require CPS Energy and AEP Texas to prioritize existing highway and utility corridors for these new transmission lines. These established routes reduce the need for extensive land clearing, offer proven geological stability, and significantly lower the risks to water resources, public safety, and costs to ratepayers. Thank you for considering the concerns of BCA and the many Texans who depend on these lands and waters.

Respectfully submitted,

(signature) H. Blake Stanford

H. Blake Stanford
President Bandera Canyonlands Alliance