765 kV Documents
AI generated image of potential 765 kV line across West Texas.
George Noelke is actively participating, pro se, as an intervenor in two (59182, which passes through Irion County and 59475) of the proposed 765 kV line projects sought by Oncor and LCRA at the Texas Public Utility Commission. This page provides links to many of his self authored legal documents he filed, as well as other important documents. It is a work in process. The purported purpose of the lines was to provide additional electricity to the Permian Basin, which includes Irion County. As the cases unfolded, however, it became readily transparent that the lines would also be used as transmission lines for AI data centers. Landowners attacked whether the projects were needed; the lines were transmission lines and did not simultaneously provide for generation of additional electricity. And, as the cases neared final decision at the PUC, public outrage at data centers and the economics of mass energy generation have caused Governor Abbott to propose that data centers need to be responsible for their own energy generation.
See additional commentary at the bottom of this page.
A. 59182 (Involving Irion and other Texas Counties)
September 10, 2026: Noelke’s Replies to Exceptions in 59475, with ongoing special appearance in 59182. This is undoubtedly tedious reading, but pay attention to: 1 the opening concerning the late breaking remand to SOAH, and 2, my summary on page 2 and 3. Here are Oncor/LCRA's Replies. Here is Commissioner Gleeson's proposed remand memo. (I provide a very brief response on the last page of my Replies at the Addendum.)
September 2, 2026: Noelke's Exceptions in 59475 and Special Appearance in 59182. Filed in both 59182 and 59475, this document explains how the ALJ's in 59475 got it right. Here is what Oncor and LCRA filed to explain how the ALJ's got it wrong. The parties have 1 week to reply to one another. (This is being cross posted in 59182 and 59475 because the cases were consolidated on whether the 765 kV lines were "needed".)
August 20, 2026: Proposal for Decision issued in 59475 against Oncor and LCRA. Since the decision on “need” was consolidated in 59182 and 59475, this means the “need” in 59182 likewise was not proven so 59182 now also falls. Caveat: the exceptions process has not been completed yet, and then the PUC has to issue its final agency order.
August 19, 2026: Noelke’s Notice of Legislative Testimony in the Texas House State Affairs Committee. https://interchange.puc.texas.gov/search/documents/?controlNumber=59182&itemNumber=583
August 14, 2026: ALJ Exceptions Letter responding to Noelke’s jurisdiction issue filed, wholly rejecting his arguments. Noelkes exceptions not considered. (See Commentary below.)
August 14, 2026: Go here to view the PUC board meeting addressing the 765 kV cases. PUCT Chairman Gleeson filed this memorandum about this meeting. Query whether the public comment by intervenors was ex parte. The same day Senator West files this letter on behalf of the Rocker B; note that he is not calling for dismissal of the cases. And, see the Exceptions Letter also filed the same day, mentioned above.
August 2, 2026: Noelke's Notice of Legislative Testimony filed in 59182 and 59475. The PUC isn't as eager as Senator Schwertner is to get these cases dismissed, so this document serves as a prompt. July 31, 2026: Noelke’s jurisdiction objection to the PUC setting late deadlines (after the 180 days) for exceptions and replies to the PFD.
July 29, 2026: Noelke’s testimony before the Texas Senate Business & Commerce Committee.
July 15, 2026: Noelke’s Notice of Denial of CCN by Operation of Law. Note: about 1 day after filing this the PUC filed a response to the SOAH memorandum and set a deadline for exceptions and replies; See Item 555. Without briefing this here, this filing still does not adequately addressed the missed deadline; the PUC can't correct for the missed deadline simply by late filing their response.
July 14, 2026: Applicants’ Reply to Motion to Dismiss
July 7, 2026: Noelke’s Motion to Dismiss 59182 . (The pending deadline for the CCN to approved by the PUC is July 14, and it is legally impossible for them to meet that deadline. )
June 17, 2026: Noelke’s Exceptions to the PFD.
June 9, 2026: Proposal For Decision (PFD) favoring Oncor/LCRA’s Route 228.
April 10, 2026: Noelke’s Post Hearing Reply Brief with recommended Findings of Fact, Conclusions of Law and Ordering provisions.
April 3, 2026: Noelke’s Initial Post Hearing Brief.
February 18, 2026: Noelke's Statement of Position and Route Adequacy Challenge and Direct Testimony.
B. 59475 case
September 10, 2026: Noelke’s Replies to Exceptions in 59475, with ongoing special appearance in 59182. This is undoubtedly tedious reading, but pay attention to: 1 the opening concerning the late breaking remand to SOAH, and 2, my summary on page 2 and 3. Here are Oncor/LCRA's Replies. Here is Commissioner Gleeson's proposed remand memo. (I provide a very brief response on the last page of my Replies at the Addendum.)
September 2, 2026: Noelke's Exceptions in 59475 and Special Appearance in 59182. Filed in both 59182 and 59475, this document explains how the ALJ's in 59475 got it right. Here is what Oncor and LCRA filed to explain how the ALJ's got it wrong. The parties have 1 week to reply to one another. (This is being cross posted in 59182 and 59475 because the cases were consolidated on whether the 765 kV lines were "needed".) August 20, 2026: Proposal for Decision issued in 59475 against Oncor and LCRA. Since the decision on “need” was consolidated in 59182 and 59475, this means the “need” in 59182 likewise was not proven so 59182 now also falls. Caveat: the exceptions process has not been completed yet, and then the PUC has to issue its final agency order.
August 19, 2026: Noelke’s Notice of Legislative Testimony in the Texas House State Affairs Committee. https://interchange.puc.texas.gov/search/documents/?controlNumber=59475&itemNumber=6440
May 17 - July 29, 2026, en masse dismissal of Intervenor issue: Noelke's Objection to Applicants' List of Intervenors who did not file Statement of Position or Direct Testimony and Motion to Provide Notice and Opportunity for Hearing.
And, yet another Noelke Motion for Clarification of Order Dismissing 839 Intervenors en masse. Note: this list is incomplete. For a plain English summary of these arguments, see the third point here: testimony to the Senate Business and Commerce Committee on July 29. May 9, 2026 Noelke's Statement of Position.
C. Commentary
September 3, 2026: The law is such that it is extremely difficult for an agency to change certain Findings of Fact and Conclusions of Law in a PFD, Proposal for Decision. Applicants' Exceptions, though, just as well have the kitchen sink in it, so this may well be a situation where the Commission makes substantive changes to the PFD.
August 22, 2026: Here is the entire PFD in 59475 favoring the landowners. Here are some key things to know: a. The dates for exceptions and replies to exceptions can be found here. The ALJ's have until September 15 to finalize the PFD. As of the date of this posting, no date has been set for the oral argument for this pfd or for the 59182 PFD. b. Here is the law on what the PUC can do if they seek to change the PFD and the ALJ's final corrections in any way: 1. 16 TAC 22.262 & 2. Texas Gov't Code 2001.058(e). My take away: It is going to be extremely difficult for the PUC to change the lynchpin, Conclusion of Law # 13, which reads, ERCOT’s PBRP recommendation is not entitled to great weight in the determination of need for this reliability project." The Applicants relied solely on the Permian Basin Reliability Project to justify the 765 kV lines, and if it isn't given great weight, then the PFD will stand.
August 16, 2026: This Exceptions Letter says I am headed to Oral Argument at the PUC. Note: losses down below in the administrative process creates more grounds for appeal at the district court and above process. Will update site once the PUC announces when oral argument is scheduled.
July 31, 2026: A couple things come to mind after attending the full day (14 hour) Senate Business and Commerce Committee in Austin on July 29: HB 5066 was initially understood to be a "study" bill, not the justification for using the Permian Basin Reliability Plan to build 765 kV lines. The 180 day deadline is already understood to be be too aggressive by both the PUC and this Committee. The en masse dismissal of the 839 Intervenors in 59475 is weighing heavy on the minds of the Committee members. Here is my written testimony to the Committee. My spoken testimony was much more brief because speakers were only allowed two minutes. The day after this hearing I filed this notice about the PUC's and SOAH's ongoing lack of jurisdiction.
July 4, 2026: Bruce Springsteen recently said in this interview, "Well, I believe in critical patriotism. I believe that's the definition of a patriot, that you love your country so much that you are willing to look at it clearly, recognize its faults, encourage it to be a better place, and believe that you carry in your heart the country that is waiting." There's no better example of critical patriotism than the massive numbers of landowners who have come out to fight these 765 kV projects. These are the folks who understand how unjust this process has been, not the elected legislators and the Governor who have come late to the process to register their misgivings. Elsewhere in these pages I have quoted James Baldwin, "I love America more than any other country in the world and, exactly for this reason, I insist on the right to criticize her perpetually.” These are the things I am thinking about on this 250th celebration.
June 20, 2026: Listen to this February 2026 interview of Elon Musk for why he thinks in 30-36 months AI data centers will be located in space. It comes down to 1) it is very difficult to build large scale energy generation plants on the ground, and 2) solar energy in space. Keep in mind that these 765 kV projects are transmission not generation projects.
Copyright 2026 G. Noelke
