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TEP鈥檚 leaders have been clear in their recent op-eds: They say community concerns about Project Blue are 鈥渇alsehoods,鈥� that critics are pushing 鈥渃laims without evidence,鈥� and that the data center will not hurt reliability or raise rates. They say the project will 鈥減ay its own way.鈥�

I took them at their word and was willing to change my stance as someone who values facts and businesses committed to being true community partners. I wrote a letter to TEP VP Bakken and asked for two simple things: I requested the documents proving (1) all Project Blue costs are truly self-contained in the Energy Supply Agreement; and (2) reliability contingencies have been modeled for the full data-center buildout.

They did not provide those documents. Instead, I was redirected to PR web pages repeating promises and leaning on the unenforceable commitments by Beale Infrastructure, as if they substitute for filed proof.

Before getting to reliability or rates, there鈥檚 a basic threshold issue. Beale is not the named counterparty to the filed Energy Supply Agreement (鈥淓SA鈥�). The ESA is with Humphrey鈥檚 Peak Power, LLC. To date, I have not received any filed documentation showing that Beale has legal authority to negotiate on behalf of or bind Humphrey鈥檚 Peak Power. That means public promises attributed to Beale are just that, promises.

They will remain as promises unless and until enforceable authority and obligations appear on the record.

Additionally, Humphrey鈥檚 Peak Power is the named counterparty to the ESA but does not appear to be registered to conduct business in Arizona. As I understand it, Arizona Statutes 搂29-3902 may not automatically invalidate the contract, but it still requires a foreign LLC to register with the Arizona Corporation Commission (鈥淎CC鈥�) before conducting business in Arizona.

Here鈥檚 why this isn鈥檛 a minor dispute about tone or rhetoric:

First, Project Blue is not a normal new customer.

TEP has argued that 286 megawatts (MW) is manageable and won鈥檛 strain the grid.

According to the City of Tucson鈥檚 April 22, 2025 Energy Sourcing Study, the entire city only had nine Large Power Service accounts in 2023. This shows how rare loads of this size are in our system. Project Blue would be the largest single load TEP has ever served. For something that is unprecedented, 鈥渢rust us鈥� isn鈥檛 enough.

Second, TEP鈥檚 own planning documents prove it knows how to show real modeling when it wants to.

In its 2023 Integrated Resource Plan (IRP), TEP publicly compares reliability options and publishes hard numbers comparing costs. The IRP shows that meeting large-capacity needs with solar-plus-storage would require roughly $314 million more in capital and about 32% higher annual revenue requirements than gas turbines in a similar scenario. That鈥檚 the kind of concrete analysis missing from the Project Blue conversation.

The IRP also models loss-of-load risk under peak-summer conditions to evaluate future reliability needs. Those models show that reliability can tighten quickly if resource additions slip or loads grow faster than expected. That鈥檚 exactly why full-load modeling specific to Project Blue should be public before approval.

Third, the public is being asked to accept big claims right before a vote.

On Wednesday, Dec. 3, the ACC is scheduled to vote on this ESA. Yet we still have no publicly released full-load reliability study, no filed cost-containment modeling demonstrating 鈥渘o cost shift,鈥� and no transparent assumptions showing how TEP covers timing risks if planned resources slip. The decision is moving forward without the foundational evidence that should precede it.

Finally, TEP is asking for belief when the stakes demand proof.

Utilities don鈥檛 hide a thriving grid. They display positive numbers as much as possible, and TEP already does this in the many ads they are running, touting 99% reliability, which sounds great, but a hyperscale data center raises the bar for power quality and makes reliability planning more complex, even with their backup systems.

If the studies showed clear surplus capacity and zero risk to households at full buildout, publishing them would strengthen public trust and make this vote easier. The refusal to release that modeling speaks louder than any talking point from TEP, the ACC, or Beale.