Comanche Generating Station

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Comanche Generating Station is an 1,410-megawatt (MW) coal-fired power station owned and operated by Xcel Energy near Pueblo, Colorado.

Unit 1 (383 MW) is planned for retirement in 2022, and unit 2 (393 MW) in 2025. The units were commissioned in 1973 and 1975, respectively. Unit 3 (857 MW), commissioned in 2010, will remain operating.[1] By 2026 Xcel plans to generate nearly 55% of its electricity from renewable sources.[2]


The undated satellite photo below shows the power station in Pueblo.

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The Comanche power station consists of three units owned by Xcel Energy:[3][4]

  • Unit 1 - 325 MW (1973)
  • Unit 2 - 335 MW (1975)
  • Unit 3 - 750 MW (2010) (This unit is registered as 857 MW with the EIA.[5])


In 2004, Xcel entered into a Settlement Agreement with environmental groups to reduce emissions and install SO2 controls at the existing units. The promised limitations are supposed to result in lower overall pollutants, even with the proposed third unit.[6]

A “least cost resource plan” for Comanche Unit 3 was presented to the Colorado Public Utilities Commission in 2004.[7]

In 2005 Clean Energy Action and Citizens for Clean Air and Water in Pueblo filed a legal complaint challenging the permit on several grounds, including the state’s failure to investigate whether emissions would actually be reduced, the potential for negative impact on surrounding wilderness, and the lack of a public comment period on the permit.[8] The plant has also been controversial because of a proposal to charge Colorado ratepayers for the new plant while it is under construction. As a consequence of the public fallout surrounding this project[9], Xcel has acknowledged that it may never build another coal-fired power plant.[10]

On January 31, 2007, Dan Friedlander, a member of Clean Energy Action, filed suit against the Colorado Public Utilities Commission (PUC), alleging that the PUC allowed Xcel to violate the "long-standing practices of not charging ratepayers for power plants until they are operational."[11]

As of July 2008, the air permit is under appeal at the Colorado State Supreme Court and a decision has not been reached in the Friedlander case.[12]

In May 2009, Xcel Energy asked state regulators for a $180.2 million electricity rate hike to recoup money spent on power plants and equipment in Colorado. Most of the investment was for the Comanche 3 plant, which is reported to go online later this year.[13]

As of October 2009, the Unit 3 was almost complete, and Xcel expected it to be in service by December 2009.[14]

Comanche 3 began generating electricity July 6 2010.[15]

Both utility executives and environmental leaders say Comanche 3 will likely be Colorado's last coal plant - unless cost-effective carbon capture and sequestration technology with acceptable environmental risks gets developed.[15]

Units 1 and 2 to be retired in 2022 and 2025

In August 2017, Xcel announced that it will retire Unit 1 at the end of 2022 and Unit 2 at the end of 2025. Company president David Eves attributed the retirement to "the fundamental economics of these technologies (wind and solar)." Power from the plant will be replaced by increases in solar, wind, and natural gas generation. According to a report in the Denver Post, the retirement agreement involved more than a dozen parties, including environmental groups, independent power producers, and consumer advocates. Since coal for the plant comes from Wyoming's Powder River Basin, the change will not directly affect production at Colorado mines. As many as 90 fewer workers out of the 172 currently employed will be displaced, but Xcel said it will try to find new jobs for displaced employees. According to the Denver Post article, the coming expiration of tax credits for wind and solar created a limited window of opportunity for developing substitute power sources. As a result of the retirement of the Comanche units, the share of renewables in Xcel's generation mix is expected to rise from 29 percent currently to 55 percent after 2026. By the end of 2017, Xcel will request competitive bids for 1,000 MW of additional wind, 700 MW of solar, and 700 MW of natural gas generation under its "Colorado Energy Plan."[1]

Opposition to Comanche 3

February 26, 2010: ‘Die-in’ at Xcel Headquarters in Denver, Colorado

On February 26, 2010, local citizens in Denver staged a 'die-in' at the headquarters for Xcel Energy in opposition to the utility’s plan to build a new coal-fired power plant, Comanche 3, in Pueblo, Colorado. The plant would be the largest in the coal-fired power station in the state. Protesters cited environmental as well as social and economic issues as reasons for their actions. “Our leaders are failing to lead and Xcel is failing to take their responsibility seriously. Xcel should expect more protests and actions unless they start closing down coal plants and moving Colorado to 100% renewable electricity,” Kate Clark, a Power Past Coal activist. The protest was part of an ongoing series of actions by concerned citizens in Colorado who seek to end coal-power in the state.[16]

Plant Data

Emissions Data

  • 2006 CO2 Emissions: 5,581,579 tons
  • 2006 SO2 Emissions: 13,854 tons
  • 2006 SO2 Emissions per MWh:
  • 2006 NOx Emissions: 8,411 tons
  • 2005 Mercury Emissions: 132 lb.

Death and disease attributable to fine particle pollution from Comanche Station

In 2010, Abt Associates issued a study commissioned by the Clean Air Task Force, a nonprofit research and advocacy organization, quantifying the deaths and other health effects attributable to fine particle pollution from coal-fired power plants.[19] Fine particle pollution consists of a complex mixture of soot, heavy metals, sulfur dioxide, and nitrogen oxides. Among these particles, the most dangerous are those less than 2.5 microns in diameter, which are so tiny that they can evade the lung's natural defenses, enter the bloodstream, and be transported to vital organs. Impacts are especially severe among the elderly, children, and those with respiratory disease. The study found that over 13,000 deaths and tens of thousands of cases of chronic bronchitis, acute bronchitis, asthma, congestive heart failure, acute myocardial infarction, dysrhythmia, ischemic heart disease, chronic lung disease, and pneumonia each year are attributable to fine particle pollution from U.S. coal plant emissions. These deaths and illnesses are major examples of coal's external costs, i.e. uncompensated harms inflicted upon the public at large. Low-income and minority populations are disproportionately impacted as well, due to the tendency of companies to avoid locating power plants upwind of affluent communities. To monetize the health impact of fine particle pollution from each coal plant, Abt assigned a value of $7,300,000 to each 2010 mortality, based on a range of government and private studies. Valuations of illnesses ranged from $52 for an asthma episode to $440,000 for a case of chronic bronchitis.[20]

Table 1: Death and disease attributable to fine particle pollution from Comanche Station

Type of Impact Annual Incidence Valuation
Deaths 7 $51,000,000
Heart attacks 11 $1,200,000
Asthma attacks 130 $7,000
Hospital admissions 5 $120,000
Chronic bronchitis 5 $2,100,000
Asthma ER visits 7 $2,000

Source: "Find Your Risk from Power Plant Pollution," Clean Air Task Force interactive table, accessed February 2011

Citizen groups

Articles and Resources


  1. 1.0 1.1 Aldo Svaldi, "Xcel Energy plans to retire two coal-fired plants in Pueblo, increase renewables," Denver Post, August 29, 2017
  2. "Xcel Energy details plan to retire two coal plants, rely more on wind and solar," 9News, June 7, 2018
  3. "Comanche Station", Xcel Energy corporate website, accessed Feb 2015
  4. National Energy Tech Lab, “Tracking New Coal-Fired Power Plants”, NETL, May 1, 2007, page 9 (Pdf)
  5. Form EIA-860, US Energy Information Administration, 2012
  6. "Colorado Coal Plant Proposals", Western Resource Advocates, undated, accessed January 2008.
  7. "Least-Cost Resource Plan", Xcel Energy corporate website, April 30, 2004 (Pdf).
  8. "Colorado PUC and the Pueblo Coal Plant: Legal issues 2007-2006", Colorado Clean Energy Action.
  9. "Xcel Finds That New Coal Plant Is Not Welcome", Environment Colorado, January 28, 2004.
  10. "Comanche Smokestack a Lightning Rod", Denver Post, November 20, 2007.
  11. Suit targets Xcel Pueblo plan", Steve Raabe, Denver Post, January 31, 2007.
  12. "Stopping the Coal Rush", Sierra Club, accessed October 2008.
  13. "Xcel files to boost rates $180.2 Million", Gargi Chakrabarty, The Denver Post, May 2, 2009.
  14. "Coal plant construction continues in earnest at some sites," SNL Interactive, October 5, 2009. (Subscription required.)
  15. 15.0 15.1 "King Coal, politics and the new energy economy: Xcel Energy's Comanche 3 coal-fired plant underscores the debate between "cheap," reliable energy and its costs 
to the environment" ColoradoBiz, September 1, 2010.
  16. "Local Citizens ‘Die-in’ at Xcel HQ in Coal Protest Group calls on Xcel to Keep Comanche 3 Closed and Produce 100% Renewable Electricity by 2020" Katie Clark, Colorado Indymedia, February 26, 2010
  17. Form EIA-860, US Energy Information Administration, 2012
  18. "EIA 423 and Schedule 2 of EIA-923," EIA 923 Schedules 2, 2011.
  19. "The Toll from Coal: An Updated Assessment of Death and Disease from America's Dirtiest Energy Source," Clean Air Task Force, September 2010.
  20. "Technical Support Document for the Powerplant Impact Estimator Software Tool," Prepared for the Clean Air Task Force by Abt Associates, July 2010

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