Abilene, TX · May 2026 · Cliff case study
360.5 MW BTM turbines · Title V · PSD expansion
What the record shows
Longhorn's first turbine block fit inside TCEQ Standard Permit 177263, but the same public record shows the site moving into Title V and the next two buildings into NSR / PSD / GHG PSD review.
Outcome
No denial. A permit-class cliff: standard permit at the first BTM block, Title V obligations at the site, and public-notice PSD exposure at expansion.
Lesson
BTM power does not scale linearly. RICE runtime math applies to emergency diesel fleets; turbine plants need a separate Title V / PSD threshold model.
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