Carta de la Autoridad de las APP a LUMA Energy

Eng. Josué A. Colón Ortiz I Executive Director
Roberto Sánchez Vilella Government Center (Minillas), De Diego Avenue, Stop 22, San Juan, PR 00907
PO Box 42001, San Juan PR 00940-2001
July 22, 2025
BY ELECTRONIC MAIL
juan.saca@lumapr.com
Mr. Juan Saca
President & Chief Executive Ofﬁcer
LUMA Energy, LLC
PO Box 363508
San Juan, PR 00936-3508
Dear Mr. Saca,
Re.: Notice of Disputes to LUMA Energy, LLC and LUMA Energy ServCo, LLC,
under Article 15 of the T&D OMA
Reference is made to the Puerto Rico Transmission and Distribution Operating
and Maintenance Agreement (“T&D OMA”), executed on June 22, 2020, between
the Puerto Rico Electric Power Authority (“PREPA”) as Owner; the Puerto Rico
Public-Private Partnerships Authority (“P3A”), as Administrator; and LUMA Energy,
LLC and LUMA Energy ServCo, LLC, (jointly, “LUMA”) as Operator. Capitalized terms
used but not defined herein have the meanings set forth in the T&D OMA.
Pursuant to Sections 15.1, 15.2(a) and 15.3 of the OMA, P3A hereby serves this Notice
of Disputes on LUMA.
Puerto Rico’s electric customers have endured nearly four years of rolling outages,
ballooning costs, and broken promises - even as billions in federal reconstruction
dollars sit idle. Despite repeated written notices and good faith attempts to secure
voluntary compliance, LUMA continues to ﬂout its most basic obligations under
the T&D OMA. The ten sections that follow chronicle a pattern of chronic non-
performance - from vegetation management failures that have plunged
the Island into darkness, to stone-walled audits, seconded-employee cost
overruns, and a reimbursement backlog starving the grid of the very funds meant
to rebuild it.
Docusign Envelope ID: D12C753B-AFEB-464E-A922-64A6578FBB4E

Mr. Juan Saca
July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
When the Government launched its 2020 procurement, LUMA cast itself as the
transformative operator uniquely qualified to greatly improve Puerto Rico’s
electric system. Its proposal boasted “unparalleled, hands-on experience” with
FEMA-funded megaprojects, a disaster-recovery résumé spanning 300
jurisdictions, and a front-end transition plan that would slash costs, curb theft, and
unleash a flood of federal dollars - all without raising rates. Over an eleven-month
transition, PREPA opened every door: asset tours, data rooms, and unrestricted
systems access - all bankrolled by millions in customer funds to ensure LUMA
knew exactly what it was taking on.
Fast-forward five years and close to $3 billion in operational budgets,
including $500 million in Service Fees to LUMA, those representations and
assurances were wholly unfounded. LUMA has only received $345 million in
federal reimbursements out of approximately $10 billion federally assigned funds
for T&D projects for permanent works under the Hurricane María disaster, whereas
PREPA has secured about $1.3 billion on its own. Alarmingly, LUMA has been
further unsuccessful in achieving the obligation of $385 million in projects
incurred under Hurricane Fiona’s emergency work withdrawn from its operation
account.
Reliability metrics remain flat or falling; island-wide blackouts on June 12 and
December 31 of 2024 and again on April 16 of this year, underscored how little
progress has been made to clear trees or harden lines. Meanwhile, PREPA has
been forced to pump more than $500 million of its own federal reimbursements
into LUMA’s accounts just to keep the lights on. In short, the promises of world-
class expertise and financial discipline have not merely gone unmet—they have
boomeranged into new crises of liquidity, transparency, and public confidence.
The people of Puerto Rico, and the Government that represent them, are fed up.
Most recently - while outages mount and billions in federal dollars remain
untapped - LUMA asked the Energy Bureau for a provisional base-rate hike
that would add roughly $30.04 to the average 400-kWh residential bill
every month, a 32.75 % jump even before the formal case is heard. In its own
Executive Summary, LUMA concedes the increase would bankroll five “major
investments”: $800 million for distribution hardening, $300 million for substation
upgrades, $250 million for transmission repairs, $240 million for a one-time
vegetation reset, and $220 million for a preventive-maintenance program. Four
out of these five categories are precisely the kind of permanent-work
and § 406/428 hazard-mitigation projects FEMA has already approved and funded
across Puerto Rico’s T&D system. Put simply, LUMA wants consumers to pre-pay
for capital work the federal government stands ready to reimburse, while also

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July 22, 2025
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footing the bill for everyday maintenance that FEMA will never cover. P3A rejects
that premise outright: when LUMA’s actual revenues fall short of its optimistic
forecasts, the remedy is internal cost discipline—trimming seconded-employee
expenses, attacking technical and non-technical losses—not conscripting
Puerto Rican families to subsidize managerial inefficiency through higher rates.
In light of the foregoing, P3A hereby enumerates a non-exhaustive sample of each
instance in which LUMA has exhibited a flagrant deficiency in transparency and
accountability, deliberately distorted material facts, and demonstrably failed to
comply with its contractual obligations since assuming operation of the T&D
System. Such conduct has compelled P3A, in its capacity as Administrator, to issue
the following Notice of Disputes under Sections 15.2(a) and 15.3(b) of the T&D OMA.
For each of the ten (10) disputes identified, we set forth below a detailed exposition
of its nature, together with the corresponding formal demands served upon
LUMA. Therefore, P3A, as the Administrator of the T&D OMA, demands the
immediate commencement of the Dispute Resolution Procedures concerning
each dispute. Should LUMA fail to remedy these violations within the contractually
prescribed windows, PREPA and P3A will pursue every remedy the T&D OMA
allows - including, if necessary, termination of the agreement - to protect public
funds, restore reliable electric service, and hold LUMA fully accountable.
I. Notice of Technical Dispute: Federal Funding:
P3A, in its role as Administrator of the T&D OMA, notifies this dispute due to
LUMA’s persistent failures to comply with its federal funding obligations. Despite
repeated warnings and formal letters (included herein), LUMA has continued to
exhibit systemic deficiencies in cash flow reporting, reconciliation of federal
expenditures, and timely submission of Requests for Reimbursements.
1. March 7, 2025- P3A (J. Colón Ortiz- Exec. Dir.) Letter to LUMA (J. Saca - CEO)
– Unauthorized Use of Seconded Employees Under the Operation and
Maintenance Agreement
• Non-compliance by LUMA:
o LUMA's use of seconded employees violated federal procurement
rules under 2 C.F.R. Part 200. Specifically, LUMA engaged in self-
performed work with seconded employees without adhering to
federal procurement standards applicable to state entities.

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July 22, 2025
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o FEMA classified LUMA's secondment arrangement with Quanta and
its affiliates as a contract requiring full and open competition, which
LUMA failed to conduct.
o LUMA failed to include mandatory federal contract provisions, such as
those required by 2 C.F.R. § 200.327 and Appendix to Part 200, in its
Secondment Agreements.
o LUMA created organizational conflicts of interest by employing
secondees from Quanta while Quanta was a major subcontractor in
federally funded projects.
o LUMA violated its own procurement standards as established under
the T&D OMA.
• The continued use of seconded employees directly violates P3A's
obligations under Section 5.9 of the T&D OMA, which mandates
compliance with applicable laws and maximization of project eligibility
for federal funds.
• Request for Action and Information (including due date):
o P3A directed LUMA to immediately cease the use of seconded
employees in all federally funded projects, effective upon receipt of
the letter. LUMA is unauthorized to engage seconded employees for
any work under the T&D OMA.
o Within ten (10) business days, LUMA must:
• Provide a written plan detailing measures to ensure full compliance with
FEMA's procurement requirements and specific steps to eliminate
seconded employees from all projects.
• Submit a comprehensive accounting of any ongoing or completed
projects that involved seconded employees, including contract values,
funding sources, and scope of work performed.
• Demonstrate its plan to mitigate future violations and ensure all
contracting practices align with federal and Commonwealth
regulations.

Mr. Juan Saca
July 22, 2025
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2. December 10, 2024- PREPA (J. Colón Ortiz-Exec. Dir.) Letter to LUMA (J.
Saca-CEO)– Re.: Compliance with Section 7.5 of the T&D OMA: Federally
Funded Capital Improvements
• The letter was a response to LUMA's December 6, 2024-Letter
regarding compliance with Section 7.5 of the T&D OMA concerning
Federally Funded Capital Improvements.
• PREPA noted LUMA's failure to identify its obligations under
Section 7.5(b) of the T&D OMA as referenced in a previous
December 4, 2024, letter from PREPA. This failure underscored a
persistent and troubling pattern of non-compliance and
misunderstanding of LUMA's contractual obligations under the
T&D OMA.
• PREPA stated that LUMA's arguments were "either disingenuous or
denote a surprising lack of understanding of the RFR procedures
[and WCA]". PREPA asserted that these deficiencies hindered
PREPA's ability to secure timely reimbursements and jeopardized
compliance with federal funding requirements essential to Puerto
Rico's recovery.
• Specifically, there was a lack of a detailed schedule of Federally
Funded Capital Improvements and a timeline of planned
improvements for the next 4.5 months, preventing PREPA from
ensuring adequate funding.
• LUMA's actions in neglecting its responsibilities violated the terms
of the T&D OMA and placed critical projects and funding at risk.
LUMA exhibited systemic noncompliance by failing to adhere to
guidelines under Chapter 7 of the Central Office for Recovery,
Reconstruction, and Resiliency (COR3) Payment and Cash
Management Policy.
• Submissions by LUMA for COR3 compliance contained significant
deficiencies, including insufficient descriptions, lack of supporting

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July 22, 2025
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documentation, and issues requiring Requests for Information
(RFIs). PREPA indicated that LUMA had only withdrawn $564
million from the Federally Funded Account to replenish its
operating account but secured only $235 million in
reimbursements, forcing PREPA to transfer $496 million of its funds
to cover the gap caused by LUMA's failures.
• PREPA demanded immediate corrective action from LUMA,
including:
o Submission of accurate and complete reconciliations for all
outstanding Work Cost Accounts (WCAs) with supporting
documentation as per COR3 guidelines.
o Delivery of the detailed schedule of Federally Funded
Capital Improvements required under Section 7.5(b) of the
T&D OMA.
o Submission of a detailed listing of all Federally Funded
Expenditures incurred and reported to the Puerto Rico
Energy Bureau (PREB), including reconciliation to approved
Capital Budgets and corresponding RFRs.
o Resolution of deﬁciencies in RFR submissions to ensure
future requests comply with COR3 standards.
• PREPA stated that any deﬁciencies in LUMA's performance that
threaten PREPA's compliance with federal requirements would
continue to be addressed forcefully and appropriately.
3. December 4, 2024- PREPA (J. Colón Ortiz-Exec. Dir.) Letter to LUMA (J.
Saca-CEO)– Re.: Compliance with Section 7.5 of the T&D OMA: Federally
Funded Capital Improvements Schedule and Reconciliation
Deficiencies

Mr. Juan Saca
July 22, 2025
Page 7 of 81
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• PREPA asserted that LUMA failed to comply with its obligation
under Section 7.5(b) of the T&D OMA. This obligation required
LUMA to provide PREPA with a detailed schedule of Federally
Funded Capital Improvements. This omission by LUMA included a
failure to provide a timeline of planned improvements for the next
four and a half (4.5) months, which significantly hindered PREPA's
ability to ensure sufficient funding and jeopardized critical projects
due to non-compliance with Federal Funding Requirements.
• LUMA received $839 million in funding but only reconciled $146
million, representing a mere 17% of the funds. This severe
insufficient reconciliation undermined LUMA's capacity to request
advances and jeopardized PREPA's access to federal funds, with
LUMA's delays and inefficiencies adversely impacting PREPA's
participation in the program.
• PREPA demanded immediate corrective action from LUMA. The
specific requests for documents and information were:
o Submission to PREPA of a comprehensive schedule of
Federally Funded Capital Improvements as required by
Section 7.5(b) of the T&D OMA.
o Delivery of a detailed analysis of expenses incurred for the
projects outlined in the aforementioned schedule.
o Reconciliation of the detailed analysis of expenses with the
Federally Funded Expenditures reported to the Puerto Rico
Energy Bureau (PREB) under the quarterly reporting
requirements in case No. NEPR-MI-2021-00043.
o Identification of all reimbursed expenses along with their
corresponding Request for Reimbursement ("RFR")
numbers.

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July 22, 2025
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o Linking unreimbursed expenses to the Project Worksheet
("PW") obligations under which LUMA intended to request
reimbursement.
4. December 4, 2024- PREPA (J. Colón Ortiz-Exec. Dir.) Letter to FOMB (R.
Mujica-Exec. Dir.) & COR3 (M. Laboy Rivera-Exec. Dir.)– Re.: Financial and
Operational Concerns Regarding FEMA Cost-Share Requirement and
Project Reconciliation
• PREPA expressed concern regarding the allocation of
approximately $1.5 billion for the acquisition of generators and
other equipment to reconstruct Puerto Rico's transmission and
distribution system. PREPA stated it was required to secure a 10%
cost-share ($150 million) to fulfill Federal Emergency Management
Agency (“FEMA”) requirements but currently lacked the necessary
funds to meet this obligation.
• PREPA communicated that the $1.5 billion allocation would not
immediately impact its cash flow unless LUMA and Genera
completed the necessary reconciliation processes and executed
the associated projects.
• Regarding noncompliance, LUMA (along with Genera) had
received $858 million in advanced funding through the WCA
Program but had only reconciled $146 million, representing a mere
17% of the funds. This low reconciliation rate severely limited their
ability to request additional advances.
• PREPA asserted that this situation placed it at significant risk as
FEMA evaluated the recipient, and the deficiencies and
inefficiencies by LUMA and Genera could jeopardize PREPA's
continued participation in the program.
• PREPA requested that LUMA and Genera fulfill their responsibilities
promptly and efficiently regarding COR3's continued oversight to
ensure the effective utilization of the allocated $1.5 billion. The letter

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July 22, 2025
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did not specify a precise due date for the submission of any
requested information, instead calling for prompt and efﬁcient
action.
5. September 24, 2024- PREPA (J. Colón Ortiz-Exec. Dir.) Letter to FOMB (R.
Mujica- Exec. Dir.)-Re: FOMB’s Notice of Violation on PREPA’s Proposed
2024 Fiscal Plan Updated Response
• PREPA highlighted to the FOMB that due to LUMA’s non-
compliance in receiving its required inputs after the response
deadline and integrating them into the revised proposed PREPA
Fiscal Plan.
• PREPA emphasized each instance of non-compliance by LUMA to
provide the required input:
o Delayed Submission of Required Inputs: PREPA received
the required inputs from LUMA Energy, LLC, that were
outlined in the FOMB's Notice of Violation (NOV) after the
response deadline. This directly indicates a delay on LUMA's
part in providing essential information for PREPA's updated
fiscal plan.
o Challenges in Developing a Unified CapEx Roadmap:
PREPA, LUMA, and Genera were tasked with developing a
comprehensive capital expenditures roadmap. However,
after discussions, all three parties, including LUMA, agreed
that it is "infeasible to jointly develop a unified, holistic plan".
The letter attributes this difficulty to the "discrete interests
of each party" and their specific requirements under their
respective O&M agreements, suggesting a lack of cohesive
planning despite the recognized need. While not solely
LUMA's non-compliance, it points to a collective failure to
achieve a unified plan, in which LUMA is a participant.
o Receipt of O&M Expense Projections via the FOMB: PREPA
received information on LUMA's O&M expense projections

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July 22, 2025
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from the FOMB on Thursday, September 19th, 2024. This
phrasing suggests an indirect channel for receiving LUMA's
projections, rather than directly from LUMA, potentially
indicating a prior delay or issue with direct submission.
• PREPA also noted that it received additional information from
LUMA on September 17th, 2024, regarding load and customer
forecasts, which will be incorporated into the revised fiscal plan.
6. Aug. 28, 2024-PREPA (F. Berríos Portela-Chairman of PREPA’s
Governing Board) Letter to LUMA (J. Saca-CEO)– Re.: Federally funded
works cash flow
• During meetings of the Committee on Assets Under OMA of the
PREPA Governing Board (the "Committee"), LUMA was requested
to include detailed information in its reports regarding the cash
flow of federally funded projects, specifically focusing on
expenditures and the number of reimbursements received. This
request was deemed crucial given the current fiscal constraints
and PREPA's cash flow limitations.
• LUMA did not submit the requested information on July 22, 2024,
despite a prior indication that failure to provide the data would
result in limiting delegated authorities and management access
for federally funded works. LUMA again did not provide the
requested updated cash flow information for federally funded
projects during the Committee meeting on August 26, 2024.
• A report provided on July 23, 2024, indicated expenditures of $748.8
million from May 2023 to May 2024 for federally funded projects.
RFRs submitted for FY2024 totaled $230.6 million, but only $140
million was reimbursed. This indicated that a significant amount of
funds had yet to be reimbursed by federal agencies, and LUMA had
yet to request such reimbursements.

Mr. Juan Saca
July 22, 2025
Page 11 of 81
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• PREPA's cash flow was under significant pressure, and a
July 23, 2024-Report noted that PREPA had transferred at
least $540.8 million from available cash to replenish service
accounts. LUMA was requested to provide the information and
include an action plan to address and reconcile the existing cash
flow gap between expenditures, submitted RFRs, and
reimbursements no later than August 30, 2024. It was emphasized
that should LUMA not provide this information, the PREPA
Governing Board might need to review and potentially limit access
to manage these federally funded projects to address the cash flow
concerns.
• LUMA was urged to diligently and timely request federal
reimbursements to stop or significantly reduce the drainage of
state funds and to replenish accounts for the benefit of LUMA's
clients.
7. August 21, 2024- PREPA (J. Colón Ortiz-Exec. Dir.) Letter to LUMA (J.
Saca-CEO)– Re.: Urgent Notice Regarding Timely and Accurate Cash
Flow Data from LUMA
• Under the T&D OMA, LUMA is responsible for generating sufficient
revenues from both collections for power services and obtaining
federal reimbursements for the federally funded T&D projects it
oversees.
• Since the Commencement Date, LUMA has failed to adequately
perform these responsibilities, leading to unnecessary and
unreasonable expenses that contributed to PREPA's depleted
liquidity. LUMA's "blanket denial" in its August 16, 2024-Letter did
not address these specific concerns.
• According to information provided by Mr. Nelson Morales, PREPA's
Chief Financial Officer, LUMA had begun providing daily bank
balances and cash flow information, as recommended in PREPA's
July 29th
-Letter. This change was noted to have reduced errors and

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July 22, 2025
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improved PREPA's ability to submit timely reports to stakeholders.
PREPA remained vigilant and reserved its rights to further
comment and demand accurate and timely reporting of financial
information under Section 3.8 of the T&D OMA. Following the
recommendations in the July 29th
-Letter, LUMA had "noticeably
improved its reporting behavior," making PREPA's work more
efficient.
• PREPA expected LUMA to continue to deliver daily cash reports to
various stakeholders.
8. July 29th, 2024- PREPA (N. Morales- CFO) Letter to LUMA (K. Hasan-
CFO)– Urgent Notice Regarding Timely and Accurate Cash Flow Data
from LUMA
• This letter highlighted PREPA's ongoing challenges in collecting
timely and accurate cash flow information from LUMA, stating that
LUMA's actions regarding federal funds management and
customer collections were depleting PREPA's liquidity.
• Historically, PREPA received daily bank balance and cash flow files
from LUMA, which were essential for monitoring liquidity and
reporting. However, these files often contained errors and delays,
complicating PREPA's ability to submit timely reports to
stakeholders. PREPA had repeatedly prompted LUMA for
corrections, but the cash flow files frequently remained unrevised
by LUMA or were held up.
• This noncompliance meant PREPA was unable to publish accurate
cash flow files and lacked adequate visibility into its liquidity, a
practice deemed "wholly negligent" and "unacceptable" in a
bankruptcy context. PREPA asserted that LUMA had failed to
acknowledge and correct the problem and had not demonstrated
commitment to improving the flow and accuracy of financial
information.

Mr. Juan Saca
July 22, 2025
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• LUMA's failure to provide the required information constituted a
violation of Section VI of Annex I (Scope of Services) of the
Transmission and Distribution Operating and Maintenance
Agreement (T&D OMA), which mandates the operator (LUMA) to
provide all financial activities and assist in the preparation of
reports. PREPA stated it was imperative that LUMA immediately
begin to provide PREPA with the relevant financial information in
a timely and accurate way.
• PREPA requested immediate attention to this matter and prompt
confirmation of LUMA's corrective actions. No specific calendar due
date was given, but the urgency for immediate action was
emphasized. The letter was copied to a comprehensive list of
stakeholders, including key officials from FOMB
, PREPA, P3A,
Genera, AAFAF, PREB, and PROMESA.
9. June 27, 2024-PREPA (J. Colón Ortiz-Exec. Dir.) Letter to FOMB (R. Mujica-
Exec. Dir.)–Re: PREPA’s proposed alternatives to cover the difference
between PREPA’s FY24 certified budgets and PREPA’s FY25 proposed
budgets
• PREPA emphasized that LUMA expends "exorbitant amounts of
money" without a demonstrated need or benefit, specifically
related to its Seconded Employees Program (where
salaries/wages exceed local employee compensation and over
20% of the allocation is used for miscellaneous expenses like plane
tickets and hotel stays for employees and spouses) and
publicity/marketing. PREPA notes that these lavish expenses are
unjustified.
• LUMA has shown resistance to disclose information regarding its
Seconded Employees Program.
• LUMA's mismanagement has caused a severe liquidity shortfall for
PREPA, characterized by a backlog of over $550 million in delayed
reimbursements and working capital advances for federally
funded projects.

Mr. Juan Saca
July 22, 2025
Page 14 of 81
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• LUMA expended over $950 million in federally funded CapEx but
only obtained $451 million in FEMA reimbursements and Working
Capital Advances through Q3 2024, leading to a negative liquidity
impact of over $550 million on PREPA.
• LUMA has not been required to correct its "glaring inefficiencies"
in obtaining federal funds.
• PREPA deemed LUMA's unjustified overspending and inability to
generate sufficient revenues from collection efforts or to oversee
federally funded projects as "unjustifiable".
• Despite repeated warnings and invitations from PREPA to discuss
LUMA's modus operandi, LUMA has taken no action to address
these issues.
• PREPA described LUMA's operations as "drastically less economic
and human resources" compared to PREPA.
• PREPA emphasized that LUMA has failed to secure
reimbursements for Emergency Measures (Category B),
Permanent Work (Category F), and Management Cost (Category
Z) at a rate comparable to PREPA. PREPA highlights that LUMA's
failure to generate sufficient revenues and obtain
reimbursements has hindered its capacity to perform necessary
repairs and maintenance of the T&D systems.
• PREPA reiterated that LUMA attempted to transfer the burden of
its inefficiencies to rate-payers by demanding budget increases.
• PREPA requested the FOMB to investigate LUMA's Seconded
Employees Program to ascertain its necessity and the
reasonableness of the associated salaries, wages, and benefits.
• PREPA proposed that the $36.4 million variance between the
certified FY24 and proposed FY25 budgets for HoldCo and
HydroCo be reduced by the amounts authorized for LUMA's
Seconded Employees Program and its marketing and publicity
programs.

Mr. Juan Saca
July 22, 2025
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• PREPA moved the FOMB to revise and redistribute P3A's Budget
Allocation efficiently and fairly to fully cover PREPA's budgetary
needs for FY25 without requiring rate increases.
• PREPA asserted that $40.1 million of interest income from
PREPA's accounts, which is currently contributing to PREPA's
liquidity shortfall due to LUMA's reimbursement backlog, should
be attributed directly to PREPA's operating entity budgets.
• PREPA advised the FOMB to reject LUMA's request for a budget
increase given LUMA's demonstrated inefficiencies.
10. June 5, 2024- PREPA (J. Colón Ortiz-Exec. Dir.) Letter to LUMA (J. Saca-
CEO)– Re.: Follow up on PREPA’s March 15, 2024, Letter denouncing
LUMA’s Inability to generate sufficient revenues and obtain federal
reimbursements and inviting LUMA to discuss specific measures to
improve revenues and federal reimbursement rate
• PREPA reiterated its position from the March 15, 2024-Letter to Mr.
Cory Schneider, LUMA's Chief Financial Officer, stating that LUMA's
failure to generate sufficient revenues and secure reimbursements
from federally funded projects hindered PREPA's ability to fund its
Service Accounts.
• PREPA asserted that LUMA had displayed a lack of understanding
of its obligations and the T&D OMA business model by refusing to
acknowledge its responsibility. LUMA also appeared to incorrectly
present unvalidated working capital advances and unapproved
RFRs as revenue sources.
• LUMA failed to obtain any reimbursement dollars under applicable
disaster declarations in Categories B, F, and Z. PREPA denounced
that LUMA often failed to pursue reimbursements diligently. Many
RFRs submitted by LUMA were returned by FEMA and/or COR3 due
to significant deficiencies. For instance, even eighteen months
after Hurricane Fiona, LUMA had not secured a single obligation for

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July 22, 2025
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over $465 million in incurred eligible expenses, which PREPA
viewed as either an inability or disregard of duty by LUMA.
• LUMA failed to respond to PREPA's March 15, 2024-Letter and
refused to take any action to correct its inefficiencies regarding
revenue generation and federal reimbursements. Between LUMA's
Interim Period Service Commencement Date and May 2024, LUMA
had expended over $950 million of federally funded Capital
Expenditures (“CapEx”) but only obtained $381 million in FEMA
reimbursements and WCAs ($69 million in FEMA reimbursements
and $312 million in WCAs). This resulted in a net negative liquidity
impact on PREPA of over $550 million through Q3 2024.
• To compensate for LUMA's inefficiency, PREPA was forced to
transfer over $430 million from its restricted federal funds account
to LUMA. Due to LUMA's inaction, PREPA's liquidity had been
significantly impacted, leading to an anticipated cash shortfall for
the June 2024 Service Account Funding Cycle, which was due on
July 15, 2024.
• To resolve this problem, PREPA demanded that LUMA take
immediate action to:
o Resolve federal reimbursement delays with COR3 to address
the backlog of over $550 million in reimbursements.
o Correct any incomplete RFRs.
o Submit all accumulated and delayed RFRs and reduce
delays in incurring eligible expenses, submitting RFRs, and
securing reimbursements.
o Transfer all overfunding from its T&D Federally Funded
Capital Account.

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July 22, 2025
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• PREPA invited LUMA to urgently schedule a meeting to discuss
specific measures to achieve the obligation of funds and improve
its reimbursement rate. No specific due date for this meeting or the
requested immediate actions was provided within this letter,
beyond emphasis on urgency.
11. June 5, 2024- PREPA (J. Colón Ortiz-Exec. Dir.) Letter to P3A (F.
Fontanés Gómez)– Re.: PREPA’s Urgent Demand for LUMA to take
immediate corrective action regarding its reiterated failure to generate
sufficient revenues from collections efforts, inefficient federal
reimbursement rate, and delays in transferring overfunding from the
Capital Account
• PREPA asserted that LUMA had failed to generate sufficient
revenues and secure reimbursements from federally funded
projects, which hindered PREPA's ability to fund its Service
Accounts. Between LUMA's Interim Period Service
Commencement Date and May 2024, LUMA had expended over
$950 million of federally funded CapEx but had only obtained $381
million in FEMA reimbursements and (WCAs. This resulted in a net
negative liquidity impact on PREPA of over $550 million through
Q3 2024.
• PREPA stated that LUMA has not corrected its "glaring
inefficiencies," and PREPA was forced to transfer over $430 million
from its restricted federal funds account to compensate for LUMA's
inefficiency. PREPA highlighted that LUMA's unjustified
overspending and inability to generate sufficient revenues from
federal T&D projects were "unsustainable". Despite PREPA's
repeated warnings and invitations to discuss solutions, LUMA took
no action to address these issues.
• PREPA had previously warned P3A and LUMA about potential cash
shortfalls since August 2023. On August 16, 2023, during a meeting,
it was noted that PREPA had obtained approximately $300 million
in FEMA reimbursements, but LUMA had only obtained $46 million.

Mr. Juan Saca
July 22, 2025
Page 18 of 81
PO Box 42001, San Juan PR 00940-2001
By August 2023, PREPA had already transferred approximately $376
million to LUMA's operating accounts. PREPA further informed that
on August 17, 2023, it sent an email to Mr. Juan Saca, LUMA's
President and CEO, denouncing that over $700 million in federal
reimbursements had not been obtained.
• PREPA also noted that LUMA had failed to respond to PREPA's
March 15, 2024-Letter, which reiterated concerns and denounced
LUMA's inability to generate sufficient revenues and secure
reimbursements, and that LUMA refused to take any action to
correct its inefficiencies.
• PREPA stated that LUMA's apparent lack of understanding of its
obligations and the T&D OMA business model, its incorrect
presentation of unvalidated working capital advances and
unapproved RFRs as revenue sources.
• In many instances, LUMA failed to obtain any reimbursement
dollars under applicable disaster declarations (Categories B, F, and
Z) and often failed to pursue reimbursements diligently. Many RFRs
submitted by LUMA were returned by FEMA and/or COR3 due to
significant deficiencies. For example, eighteen months after
Hurricane Fiona, LUMA had not secured a single obligation for over
$465 million in incurred eligible expenses.
• As a direct consequence of LUMA's inabilities, PREPA confirmed it
would face an anticipated and projected cash shortfall for the June
2024 Service Account Funding Cycle, due on July 15, 2024.
• PREPA demanded LUMA take immediate action to:
o Resolve federal reimbursement delays with COR3 to address
the backlog of over $550 million in reimbursements.
o Correct any incomplete RFRs.

Mr. Juan Saca
July 22, 2025
Page 19 of 81
PO Box 42001, San Juan PR 00940-2001
o Submit all accumulated and delayed RFRs and reduce
delays in incurring eligible expenses, submitting RFRs, and
securing reimbursements.
o Transfer all overfunding from its T&D Federally Funded
Capital Account into the Operating Account.
• PREPA requested that P3A, as Administrator of the T&D OMA, take
immediate and decisive action against LUMA on or before five (5)
days from the letter's date (implying June 10, 2024) to avoid
underfunding the June 2024 Service Account.
• PREPA indicated that if LUMA did not take effective remedial
action, PREPA would have no choice but to exercise the
mechanisms in Section 15.2(a) of the T&D OMA.
12. March 15, 2024- PREPA (J. Colón Ortiz-Exec. Dir.) Letter to LUMA (C.
Schneider-CFO)–Re.: Response to LUMA Letter regarding
Misrepresentations
• This letter served as PREPA's response to LUMA's March 5, 2024-
Letter (Transmittal # LUMA-PREP-T-00703)1. PREPA's addressed
what it considered to be LUMA's misrepresentations and to set the
record straight regarding LUMA's alleged inability to generate
sufficient revenues from collection efforts or obtain
reimbursements from federally funded projects.
• PREPA highlighted significant noncompliance and inefficiencies
on LUMA's part:
o LUMA failed to generate sufficient revenues from power
service collections and to secure reimbursements from
federally funded T&D projects.
o LUMA's actions thwarted PREPA's ability to fully fund its
Service Accounts.

Mr. Juan Saca
July 22, 2025
Page 20 of 81
PO Box 42001, San Juan PR 00940-2001
o LUMA refused to acknowledge its responsibility
demonstrating a lack of understanding of its obligations
under the T&D OMA business model.
o LUMA misrepresented unvalidated working capital
advances and unapproved RFRs as revenue sources to fund
Service Accounts, which PREPA labeled as "deceptive in
nature".
• In many instances, LUMA failed to secure a single reimbursement
dollar under applicable disaster declarations (Categories B, F, and
Z). For instance, for Hurricane Fiona (Public Assistance 4671), PREPA
received $68,764,676.91, while LUMA received $0. For Hurricane
Fiona, PREPA received $152,283.41, with LUMA again receiving $0.
• Eighteen months after Hurricane Fiona, LUMA had not achieved a
single obligation.
• Many RFRs submitted by LUMA were returned by FEMA and/or
COR3 due to significant deficiencies.
• PREPA characterized LUMA's complaints about Service Account
replenishments as "petulant letters" and their lack of a concrete
plan to correct deficiencies as a "waste of time" and a "misuse of
ratepayers' funds".
• PREPA contended that LUMA's overall reimbursement rate was
"drastically less economic" than PREPA's.
P3A hereby demands that LUMA (i) immediately halt the use of seconded
employees on any federally funded work, (ii) produce within ten (10) days a detailed
cost-justification and head-count plan that reduces Seconded-Employee
spending by at least $36.4 million for FY 2026 deliver, (iii) produce within ten (10)
days a written compliance plan that (a) reconciles every outstanding Work-in-
Capital Advance, (b) produces an accurate schedule of Federally Funded Capital
Improvements required by § 7.5(b) of the T&D OMA and (c) cures all deficiencies in
pending Requests for Reimbursement, and (iv) reimburse PREPA for any federal-

Mr. Juan Saca
July 22, 2025
Page 21 of 81
PO Box 42001, San Juan PR 00940-2001
funds gap PREPA has back-filled since June 2024. Pursuant to §§ 15.2(a) and 15.3(b),
P3A hereby commence the Article 15 dispute-resolution procedure for this matter.
II. Notice of Technical Dispute: Service Account Funding-Compensation
& Budgets
P3A, as Administrator of the T&D OMA, issues this Notice of Technical Dispute due
to LUMA’s persistent and material breaches of its contractual obligations, which
have culminated in a liquidity crisis for PREPA and a direct threat to the continuity
of public electric service. Despite being responsible, under the T&D OMA, for
securing sufficient revenues and timely reimbursements for federally funded
projects, LUMA has failed to do so.
1. February 13, 2025: P3A Letter (J. Colón Ortiz-Exec. Dir.) to LUMA (J. Saca-
CEO)- Re: URGENT ACTION REQUIRED- Fuel Account Funding
• On February 11, 2025, P3A received an alarming communication
from Genera informing PREPA that LUMA had refused to transfer
$4.5 million in PREPA-authorized funds to Genera’s Fuel Account to
fund December 2024-fuel purchases, despite formal approval on
February 11, 2025.
• Consequently, P3A issued an urgent notice to address a critical
issue and demand LUMA, emphasizing LUMA serious non-
compliance with the T&D OMA as LUMA’s inaction is a direct
violation of the agreement.
• This inaction jeopardized continuity of power generation, risking: (i)
shutdown of generation assets; (ii) breach of fuel supply contracts;
(iii) damage to credit lines and suspension of future deliveries; and
(iv) severe impact on Puerto Rico’s electrical grid.
• This crisis was created due to LUMA’s mismanagement of federal
funds, specifically its misuse of operational funds for capital
expenditures and failure to secure timely federal reimbursements.

Mr. Juan Saca
July 22, 2025
Page 22 of 81
PO Box 42001, San Juan PR 00940-2001
• P3A warned LUMA against further aggravating the situation it has
created by withholding funds.
• P3A concluded that LUMA’s conduct has created a critical and
avoidable emergency and demanded immediate compliance.
2. December 2, 20241
-PREPA (J. Colón Ortiz-Exec. Dir.) to the Incoming
Transition Committee Re: Request for Additional Information on the
Breakdown of Transfers from the Reimbursement Account to LUMA
Energy, LLC and Genera PR, LLC
• This letter provided a table detailing the distribution of $496.1
million transferred from the Federal Reimbursement Account to
LUMA and Genera, with transfer dates ranging from December
2022 to July 2024.
• Of the total $496.1 million transferred, $433.1 million was
transferred to LUMA and $63.1 million to Genera.
The speciﬁc transfers listed in the table total $496,070,448, of
which $433,012,073 were allocated to LUMA and $63,058,375 to
Genera.
3. November 27, 2024: PREPA Letter (J. Colón Ortiz-Exec. Dir.) to LUMA (J.
Saca-President & CEO) Re: PREPA’s Response to LUMA’s November 25,
2024, Notice of PREPA Non-Compliance with Service Accounts Funding
– October 2024 (Transmittal # LUMA-PREP-T-00833)
• PREPA confirmed that it had authorized a transfer of $189,783,000
to replenish LUMA’s Service Accounts and $15,121,000 to replenish
Genera’s Service Accounts.
• PREPA emphasized that it is facing a predictable cash shortfall,
which impacts its ability to fund LUMA and Genera’s Service
Accounts. This shortfall is due to reasons outlined in PREPA’s
1
The original letter is in Spanish.

Mr. Juan Saca
July 22, 2025
Page 23 of 81
PO Box 42001, San Juan PR 00940-2001
various letters to LUMA on this matter. Specifically, it stated that
its severe liquidity shortfall is driven solely by LUMA’s backlog of
delayed reimbursements for WCAs and reconciliation for federally
funded projects.
• LUMA has received to date $858M in funding, including working
capital advance, but has only reconciled $146M, representing a
mere 17%. Consequently, limiting LUMA’s ability to request
advances, compromising the WCA Program.
• More than 24 months after Hurricane Fiona, LUMA has obtained
no obligation of PWs for RFRs or WCAs, despite potential out of
pocket expenses of over $300M.
• PREPA noted LUMA has taken no action to correct its
inefficiencies.
• PREPA has been forced to transfer over $496M from its restricted
federal funds account to compensate for LUMA’s failure to fulfill its
obligations.
• PREPA stated that due to LUMA’s overspending, along with its
inability to generate sufficient revenues either from its collection
efforts for power services or its endeavors to obtain
reimbursements from the federally funded T&D projects, is simply
unsustainable.
4. November 1, 2024- PREPA Letter (J. Colón Ortiz-Exec. Dir.) to AAFAF (O.
Marrero Díaz-Exec. Dir.) Re: Confidential Communication to the Energy
Bureau of PR regarding PREPA's Liquidity Challenges
• This letter refers to a Resolution and Order issued on October 30,
2024, by PREB, in the case NEPR-MI-2020-0001, to assign a
Hearing Examiner to address PREPA’s liquidity issues. The letter
was sent because, in this Resolution, PREB referenced confidential

Mr. Juan Saca
July 22, 2025
Page 24 of 81
PO Box 42001, San Juan PR 00940-2001
communication regarding the problem, and PREPA filed a motion
before PREB requesting access to it.
• PREPA also requested AAFAF consent to be granted access to
confidential communication.
• The letter had six (6) attached letters as follows:
o October 4, 20242
-PREPA Letter (J. Colón Ortiz-Exec. Dir.) to
the President of PREPA’s Governing Board (NAME) Re:
Letter received from AAFAF– PREPA attributed its liquidity
crisis to LUMA’s persistent failure to comply with its
obligations under the T&D OMA to secure sufficient
reimbursements for federally funded projects. Between
2021 and June 2024, LUMA incurred $1.2 billion CapEx
eligible for reimbursement; however, it secured only $588
million in reimbursements, consisting of $167,846,002.42 in
RFRs and $420,850,002.60 WCAs. This resulted in a $600
million shortfall that has significantly impacted PREPA’s
liquidity position.
o October 3, 2024: PREPA (J. Colón Ortiz-Exec. Dir.) to Genera
(B. McElmurray-CEO)-Re: CDBG-DR Cost Share Request for
Generation Assets Reconstruction Projects- PREPA
acknowledged Genera’s request to be designated as agent
for the purpose of accessing CDBG-DR funds. PREPA
agreed but emphasized the designation is for specific
legacy generation projects and reiterated that Genera
remains bound by PREPA’s oversight and applicable federal
and Puerto Rico law requirements.
o September 24, 2024: PREPA (J. Colón Ortiz-Exec. Dir.) to
FOMB (R. Mujica-Exec. Dir.)-Re: FOMB’s Notice of Violation
on PREPA’s Proposed 2024 Fiscal Plan Updated Response-
PREPA responding to FOMB’s Notice of Violation regarding
2
The original letter was in Spanish.

Mr. Juan Saca
July 22, 2025
Page 25 of 81
PO Box 42001, San Juan PR 00940-2001
the proposed 2024 PREPA Fiscal Plan. PREPA emphasized
that delays in completing the fiscal plan revisions are due to
LUMA’s failure to provide customer count data necessary for
accurate forecasts and submit consolidated budget
materials as part of the required roadmap for federal fund
planning.
o September 16, 2024: PREPA (J. Colón Ortiz-Exec. Dir.) to
FOMB (R. Mujica, Exec. Dir.) Re: FOMB’s Notice of Violation
on PREPA’s Proposed 2024 Fiscal Plan- PREPA detailed
obstacles and dependencies related to LUMA (and Genera)
that impact the fiscal planning process and PREPA’s overall
financial health. Specifically:
 FOMB found information submitted by LUMA to be
incomplete.
 As of the date of this letter LUMA had not provided
PREPA with the required information regarding
Energy Efficiency, internally. PREPA noted that there
was a lack of coordination and information
fragmentation of information regarding federal
funds.
 PREPA found it unfeasible to jointly develop a unified,
holistic plan for the capital expenditure roadmap with
LUMA and Genera under the PREB process, because
of issues in collaboration or alignment necessary for
this critical planning function.
 PREPA noted that FOMB approved the Outage Event
Reserve Account, however, LUMA “failed to act one
way or another” on including this account in its
annual budget submissions despite repeated
invitations.

Mr. Juan Saca
July 22, 2025
Page 26 of 81
PO Box 42001, San Juan PR 00940-2001
 PREPA suggested that the PREB and the FOMB
should call out LUMA when it fails to act.
 PREPA also noted that any rate increase should only
be considered after confirming that extravagant or
exaggerated expenses have not been incurred by the
private operators, including LUMA. Therefore, it
called out for full transparency regarding the true
needs of the electrical system and the cost-
effectiveness of expenses incurred by LUMA and
Genera.
o September 16, 2024: PREPA (J. Colón Ortiz-Exec. Dir) to
PREPA’s Finance Director (N. Morales)-Re: Transfers to
Service Accounts Supplemental Information- PREPA was
experiencing financial constraints due to the slow-paced
reimbursement of federally funded projects to replenish
LUMA and Genera’s service accounts. PREPA confirmed its
responsibility to cover the 10% cost share on federally
funded projects carried out by LUMA and Genera.
5. October 30, 2024- PREPA Letter (J. Colón Ortiz-Exec. Dir.) to LUMA (J.
Saca-CEO)-Re: PREPA’s Response to LUMA’s October 22nd
, 2024, Notice
of PREPA Non-Compliance with Service Account Funding- September
2024 (Transmittal # LUMA-PREP-T-00817)
• PREPA acknowledged receipt of LUMA's letter from October 8th
and October 22nd, 2024.
• PREPA confirmed authorization of a transfer of $176,956,000 to
replenish LUMA's Service Accounts and $76,884,000 to replenish
Genera's Service Accounts.
• Funding for returns to Accounts Receivable for Reserve details will
not be provided until a required report is submitted and approved
by P3A.

Mr. Juan Saca
July 22, 2025
Page 27 of 81
PO Box 42001, San Juan PR 00940-2001
• PREPA attributed its predictable cash shortfall and inability to fully
fund accounts, including reserve accounts, partly to factors
including LUMA's backlog of over $550M in delayed
reimbursements and WCAs for federally funded projects.
• PREPA emphasized a net negative liquidity impact of over $550M
through Q3 2024, stemming from LUMA expensing over $950M in
federally funded CapEx but only securing $451M in FEMA
reimbursements and WCAs, during the specified period.
• PREPA noted its limited progress on Hurricane Fiona federal
funds, with FEMA denying $267.6M in costs and only one (1)
obligation of PWs for $800,000.00 for RFPs/WCAs over two (2)
years post-landfall.
• PREPA stated that despite multiple requests, LUMA has taken no
action to correct its inefficiencies, forcing PREPA to transfer
over $445.4M from restricted federal funds to compensate.
• PREPA characterized LUMA's unbridled overspending, along with
its inability to generate sufficient revenues either from its
collection efforts for power services or its endeavors to obtain
reimbursements, is simply unsustainable.
• PREPA requested LUMA make necessary adjustments to comply
with its obligations under the T&D OMA.
6. August 21, 2024- PREPA letter (J. Colón Ortiz-Exec. Dir.) to LUMA (J. Saca-
CEO)-Re: PREPA’s Response to LUMA’s August 16th
Letters re: Service
Account Funding (LUMA-PREP-T-00788) (LUMA-PREP-T-00784)
• PREPA categorized LUMA's August 16th, 2024-Letters as
containing "misconstructions about the Parties obligations under
the T&D OMA and Applicable Law regarding PREPA’s liquidity,"
making misleading claims, and refusing to acknowledge its

Mr. Juan Saca
July 22, 2025
Page 28 of 81
PO Box 42001, San Juan PR 00940-2001
responsibility regarding a liquidity issue. Therefore, PREPA stated
it was left with no other choice but to reassert its position to set
the record straight.
• PREPA stated it “categorically rejects LUMA's statement that
'PREPA is solely responsible for its own ... liquidity position”.
• Under the T&D OMA, LUMA is responsible for generating sufficient
revenues from power service collections and obtaining federal
reimbursements for federally funded T&D projects.
• PREPA stated that since the Commencement Date, LUMA has
failed to meet both revenue generation/collection and
reimbursement obligations, leading to LUMA's poor financial
position. PREPA referred to LUMA's model as unsustainable.
• PREPA attributed its cash shortfall and inability to fully fund
Service Accounts partly to LUMA's actions.
• PREPA reiterated its severity of shortfalls driven by LUMA's
backlog of over $550M in delayed reimbursements and WCAs for
federally funded projects.
• PREPA claimed that LUMA had expensed over $950M in federally
funded CapEx from Commencement Date through June 2024 but
only obtained $451M in FEMA reimbursements and WCAs during
this period. This resulted in a net negative liquidity impact on
PREPA of over $550M through Q3 2024.
• PREPA noted its limited progress on Hurricane Fiona federal
funds, stating FEMA denied $267.6M in costs and only obligated
one $800,000.00 PWs for RFPs/WCAs over two years post-landfall.
PREPA, with drastically fewer economic and human resources,
obtained $1.2B in reimbursements, out of which it was forced to
transfer over $445.4M to compensate for LUMA’s incompetence.

Mr. Juan Saca
July 22, 2025
Page 29 of 81
PO Box 42001, San Juan PR 00940-2001
• PREPA characterized LUMA's unbridled overspending, along with
its inability to generate sufficient revenues either from its
collection efforts for power services or its endeavors to obtain
reimbursements, is simply unsustainable.
• PREPA requested LUMA to make necessary adjustments to
comply with its T&D OMA obligations and emphasized that LUMA
must improve its reimbursement rate.
7. August 16, 2024-PREPA Letter (J. Colón Ortiz-Exec. Dir.) to FOMB (R.
Mujica-Exec. Dir.) & AAFFAF (O. Marrero-Exec. Dir.)-Re: PREPA’s
Anticipated Inability to Replenish LUMA’s Service Account for the August
2024 Service Account Funding Cycle
• Referencing the T&D OMA, PREPA acknowledged receiving
LUMA's request from August 8th, 2024, for a transfer of $824.920M
to its Service Accounts.
• PREPA stated it had authorized a transfer of only $262.486M to
replenish LUMA's Service Accounts.
• PREPA stated that, according to its numerous letters, for over a
year, it had consistently warned LUMA about an expected liquidity
shortfall driven solely by LUMA's backlog of over $550M in delayed
reimbursements and WCAs related to federally funded projects.
• The letter claimed that from the T&D OMA Commencement Date
through June 2024, LUMA had expended over $950M in federally
funded CapEx but only secured $451M in FEMA reimbursements
and WCAs during that specific period.
• PREPA asserted that this led to a net negative liquidity impact on
PREPA exceeding $550M through Q3 2024. PREPA also
mentioned it had obtained a total of $1.2B in reimbursements
during that time.

Mr. Juan Saca
July 22, 2025
Page 30 of 81
PO Box 42001, San Juan PR 00940-2001
• The letter further noted that despite potential out-of-pocket
expenses surpassing $300M in the two years following Hurricane
Fiona's landfall, LUMA had secured no obligation of PWs for RFPs
or WCAs related to that event. PREPA highlighted that FEMA had
denied $267.6 million in costs submitted by FEMA to date.
• LUMA's "unjustified overspending, along with its inability to
generate sufficient revenues either from its collection efforts for
power services or its endeavors to obtain reimbursements from
the federally funded T&D projects it oversees, has reached its
tipping point; PREPA no longer has sufficient funds to replenish
LUMA's Service Accounts".
• PREPA proposed an urgent meeting involving representatives
from the FOMB, AAFAF, P3A, and LUMA to discuss these matters
and identify ways to maintain sufficient liquidity.
8. August 9, 2024- PREPA (J. Colón Ortiz-Exec. Dir) Letter to LUMA (J. Saca-
CEO- and J. Laird-VP, Customer Exp.)-Re: LUMA CC&B Write-Off Process
Initiative Notiﬁcation
• This letter was in response to LUMA’s August 5th
, 2024-Letter.
• LUMA requested PREPA’s confirmation for a write-off of over $300
million in public assets.
• PREPA did not accept LUMA’s proposed five-day timelines to
evaluate and confirm the write-off, especially one exceeding $300
million.
• PREPA explicitly stated that it did not confirm or authorize the
requested write-off of $366,013,251.73 as of the letter date, stating
that LUMA has not shared its write-off policy.

Mr. Juan Saca
July 22, 2025
Page 31 of 81
PO Box 42001, San Juan PR 00940-2001
• Under the T&D OMA, LUMA is responsible for all billing and
collection services for the T&D System, including accumulated
debt.
• PREPA noted that LUMA's letter does not clearly outline its
responsibility for debt recovery.
• PREPA stated it was not aware of LUMA's efforts to collect
on 148,900 service agreements with balances that are deemed to
be non-collectible.
• PREPA stated that the lack of information in LUMA's letter hinders
an informed analysis of the proposed write-off and policy.
• PREPA required LUMA to provide detailed proof of its efforts to
collect before any write-off is considered.
• PREPA viewed writing off over $300 million in public assets with
no collection efforts or transparency as "profoundly detrimental to
the public interest" and would not allow it.
• Appendix A to the letter details the non-electric and electric
service agreements proposed for a write-off, totaling over $366
million.
9. July 15, 2024- PREPA Letter (J. Colón Ortiz-Exec. Dir.) to LUMA (C.
Schneider-CFO)-Re: PREPA’s Response to LUMA’s July 9th
, 2024 Letter
requesting Service Account Funding for the June 2024 Service Account
Funding Cycle (Transmittal # LUMA-PREP-T-00771)
• Pursuant to the T&D OMA, PREPA confirmed it had authorized a
transfer of $205.697M to replenish LUMA's Service Accounts and
$169.271M to replenish Genera’s Service Accounts. A certification
attached as Annex A confirmed these specific transfer amounts
made on July 15th, 2024.

Mr. Juan Saca
July 22, 2025
Page 32 of 81
PO Box 42001, San Juan PR 00940-2001
• Details for funding LUMA Purchase Power Account and Genera
Reserve Accounts would not be provided until a required report
was submitted and approved by P3A. Other LUMA Service
Accounts were scheduled to receive two-thirds funding, in
compliance with Section 14.3(f) of the T&D OMA.
• PREPA referenced a previous letter of June 3, 2024, where it had
warned LUMA it would be unable to fund the LUMA Service
Accounts for the June 2024 cycle.
• Despite that warning and a significant effort, PREPA reported it
had been able to cover the June 2024 Service Account funding.
However, PREPA cautioned that, following the June transfer and
as previously warned, it would face a predictable cash shortfall and
would be unable to fund LUMA and Genera Service Accounts for
the July 2024 Service Account Funding cycle, which was due in
August 2024.
• PREPA attributed the anticipated July 2024 liquidity shortfall to
reasons outlined in previous letters, specifically reiterating the
severe shortfall driven solely by LUMA's backlog of over $550M in
delayed reimbursements and WCAs related to federally funded
projects.
• The letter claimed that from the Interim Period Service
Commencement Date through June 2024, LUMA had expensed
more than $950M in federally funded CapEx but only secured
$451M in FEMA reimbursements and WCAs during that specific
period.
• PREPA asserted that this resulted in a net negative impact on
PREPA’s liquidity, exceeding $550M through Q3 2024. PREPA also
noted it had obtained a total of $1.2B in reimbursements during
that same time.

Mr. Juan Saca
July 22, 2025
Page 33 of 81
PO Box 42001, San Juan PR 00940-2001
• Regarding Hurricane Fiona, PREPA pointed out that despite 18
months after landfall, LUMA had obtained no obligation of PWs for
RFRs or WCAs related to that event.
• PREPA also highlighted that FEMA had issued Ineligibility
Determination Memos denying Fiona's costs totaling $267.6M as
submitted by FEMA to date.
• PREPA contended that despite its multiple requests, LUMA had
taken no action to correct its inefficiencies.
• Instead, PREPA reported it had been forced to transfer over $484.4
million from its restricted federal funds account to compensate for
LUMA's failure.
• LUMA's unjustified overspending and inability to generate
sufficient revenues either from its collection efforts for power
services or its endeavors to obtain reimbursements from federally
funded projects it oversees as "simply unsustainable".
• To address the situation, PREPA urged LUMA again to make the
necessary adjustments to comply with its obligations under the
T&D OMA.
10. June 27, 2024-PREPA Letter (J. Colón Ortiz-Exec. Dir) to FOMB (R. Mujica-
Exec. Dir.)-Re: PREPA’s proposed alternatives to cover the difference
between PREPA’s FY24 certified budgets and PREPA’s FY25 proposed
budgets
• PREPA submitted proposed budgets for fiscal year 2025 (FY2025)
for HoldCo ($62.634M) and HydroCo ($26.175M). Also, it stated no
rate increase would be necessary to fund these proposed budgets,
as all necessary expenses can be covered through an efficient and
fair redistribution of the budget allocation made by P3A.

Mr. Juan Saca
July 22, 2025
Page 34 of 81
PO Box 42001, San Juan PR 00940-2001
• PREPA highlighted a $36.4M variance between the FY24 certified
budgets and the FY25 proposed budgets for HoldCo and HydroCo.
• PREPA identified areas of exorbitant spending by LUMA,
particularly criticizing its "Seconded Employees Program",
seconded from the companies that comprise LUMA: the Canada
firm ATCO and the U.S. based companies Quanta Services, Inc. and
IEM, which cost over $200M and involved unnecessary expenses
funded by rate-payers.
• PREPA suggested the $36.4M variance could be covered by
reducing authorized amounts for LUMA's Seconded Employees
Program and its marketing/publicity programs.
• PREPA requested the FOMB to investigate LUMA's Seconded
Employees Program.
• PREPA argued the budget allocation should be redistributed due
to LUMA's mismanagement and a significant backlog of over
$550M in delayed reimbursements and WCAs.
• PREPA stated LUMA's failure to generate sufficient revenues and
obtain reimbursements for federally funded T&D projects had a
significant negative impact on PREPA’s liquidity, resulting in
PREPA being forced to transfer over $445.4M from its restricted
federal funds account to compensate for LUMA's inefficiencies.
• PREPA requested the FOMB to revise and redistribute the P3A's
Budget Allocation to fully cover PREPA's FY25 budgetary needs
without rate increases.
• PREPA emphasized its critical role and the importance of budget
allocations reflecting true operational needs to ensure the stability
of Puerto Rico's electric infrastructure.

Mr. Juan Saca
July 22, 2025
Page 35 of 81
PO Box 42001, San Juan PR 00940-2001
11. June 3, 2024- PREPA (N. Morales- CFO) Letter to LUMA (C. Schneider-
CFO)-Re: Projected Shortfalls for Service Account Funding for June 2024,
due on July 15, 2024, under T&D OMA
• This letter was a follow-up to PREPA's May 13, 2024-Letter, which
expressed urgent concerns regarding the deterioration of
PREPA's liquidity and related service account funding risk. PREPA
had not received a response to the May 13 Letter.
• This letter confirmed and expanded upon the anticipated and
projected cash shortfall for the June 2024 Service Account
Funding cycle, which was primarily driven by LUMA-controlled
events.
• Based on available information, PREPA projected that it would be
unable to complete two-thirds of funding for LUMA, in compliance
with the T&D OMA. This inability was based on recent funding
requests from LUMA and Genera for their respective Service
Accounts. PREPA anticipated a predictable cash shortfall and
stated it would be unable to fully fund LUMA and Genera Service
Accounts due on July 15, 2024.
• The anticipated and previously informed liquidity shortfall was
due to various reasons outlined in PREPA's letters, including
upcoming financial obligations in June and July, such as insurance
premiums and PREB fees. PREPA anticipated an insurance
premium payment of approximately $65 million due at the end of
July 2024 and stated it was disbursing $10 million related to PREB
fees at the end of June 2024.
• PREPA urged LUMA to immediately resolve its federal
reimbursement delays, including addressing a backlog of over
$550 million in reimbursements financed through PREPA's cash,
correcting any incomplete or insufficient RFRs, submitting all
accumulated and delayed RFRs, and reducing delays between

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July 22, 2025
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incurring eligible expenses and submitting compliant RFRs and
securing federal funds.
• PREPA referenced its May 13-Letter, which highlighted LUMA's
T&D Federally Funded Capital Account. PREPA was reportedly
pleased to see that on May 29, LUMA had returned $33.9 million in
overstated amounts from its Federally Funded Capital Account to
the T&D Operations Account, as had been requested by PREPA
and P3A. Therefore, it stated LUMA must continue this practice on
a timely and recurrent basis, consistent with prudent and
responsible management of public funds.
• PREPA asserted that LUMA's failure to urgently implement the
necessary measures and secure sufficient federal funds
reimbursements would jeopardize PREPA's ability to fund LUMA
and Genera's Service Accounts for June 2024 and July 2024.
• LUMA is contractually responsible for customer billing and
revenues, collections, and management of federal funds for T&D
reconstruction efforts, all of which have a direct and material
impact on PREPA's liquidity and ability to fund the Service
Accounts.
• PREPA proposed an urgent meeting with P3A, LUMA, and PREPA
to discuss these matters and other suggestions to regain and
maintain sufficient liquidity for the benefit of all stakeholders.
12. May 13, 2024-PREPA (J. Colón Ortiz-Exec. Dir.) Letter to LUMA (C.
Schneider-CFO) Re: Response to LUMA Letters Regarding Service
Account Funding dated March 19, 2024, and April 16, 2024
• PREPA stated it had funded the pertinent Service Accounts in an
amount that was two-thirds (2/3) of the requisite funding LUMA
had notiﬁed us, explaining this was due to PREPA's insufﬁcient
liquidity to fund the full amount and that this funding level was
compliant with the T&D OMA.

Mr. Juan Saca
July 22, 2025
Page 37 of 81
PO Box 42001, San Juan PR 00940-2001
• PREPA noted that neither of LUMA's letters mentioned the
overfunding of the Capital Account (Federally Funded), (Section
7.5(b) of the T&D OMA) from which PREPA believed funds should
be transferred to the Operating Account.
• PREPA stated the Outage Event Reserve Account was not funded
because there was no revenue source to replenish it or an
approved budgetary income source, a fact LUMA had
acknowledged in writing.
• PREPA stated the GenCo Reserve Account was not budgeted or
contemplated for funding from PREPA's existing rate structure,
and funding it from PREPA cash would reduce liquidity, pending
P3A conﬁrmation of Genera's submission.
• PREPA expressed serious concerns about LUMA's management of
federal funds, citing issues with understanding rules for
reimbursement, recordkeeping, validation, and timeliness.
• Based on data LUMA released, PREPA's analysis indicated a net
negative liquidity impact exceeding $500 million on PREPA cash,
primarily due to delays in federal capital reimbursement funding
by COR3, which PREPA linked to LUMA's management issues and
states it as the main reason it had been unable to fund LUMA and
Genera Service Accounts fully.
• PREPA stated LUMA had provided no indication or commitment
that it would promptly stabilize or reverse this worsening negative
liquidity trend.
• PREPA urged LUMA's Finance Department to demonstrate the
required expertise and immediately take steps with COR3 to
correct incomplete/delayed federal fund reimbursement requests.
PREPA noted it had invited LUMA to discuss urgently
recommended remedial measures, but LUMA had unfortunately
never agreed to meet.
• PREPA reiterated that LUMA was responsible for billing, collecting,
and effectively managing federal funds for T&D reconstruction

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July 22, 2025
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efforts, highlighting the direct and material impact this had on
PREPA's cash.
13. April 18, 2024- P3A (F. Fermín Fontanés Gómez-Exec. Dir.) Letter to LUMA
(CFO-C. Scheider)-Re: Federally Funded Projects and Management of
Operating Account
• PREPA repeatedly communicated with LUMA regarding concerns
about PREPA's liquidity, LUMA's management of service account
funding, and federal funding reimbursements from COR3 and
FEMA. LUMA did not respond to some of PREPA's letters and
never confirmed its availability to meet with PREPA to discuss the
issues.
• PREPA stated it had funded two-thirds of the required Service
Account funding for LUMA, consistent with the T&D OMA.
However, PREPA warned LUMA that it would face a shortfall and
be unable to fully fund the Service Accounts for the June 2024 and
July 2024 cycles due to LUMA's failures.
• The Capital Account, managed by LUMA, had been overfunded,
and PREPA/P3A requested that these funds be transferred to the
Operating Account. This transfer did not appear to be done
promptly or consistently.
• PREPA and P3A raised significant concerns about LUMA's
handling of the federal reimbursement process, identifying it as a
primary driver of PREPA's liquidity issues.
• LUMA had not submitted RFRs below a $1M threshold, contrary to
COR3/FEMA guidelines. Specific RFRs submitted by LUMA have
remained uncertified by COR3 since July 2022. Many RFRs were
returned by FEMA and/or COR3 due to significant deficiencies,
including issues with the format and detail of submitted task
details, missing required information (i.e., mileage maps and travel
reports), and generic replies to Requests for Information (RFIs).
• LUMA failed to obtain any reimbursement for specific disaster
declarations or categories of work, including Category B
(Emergency Measures), Hazard Mitigation Grant Program, and

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July 22, 2025
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Category Z (Management Cost) for Hurricane Maria, and Category
B and Z for Hurricane Fiona. PREPA highlighted that it had
obtained reimbursements in these categories while LUMA did not.
• PREPA was forced to transfer significant amounts (over $430-$445
million) from its federal funds account to compensate for LUMA's
inefficiencies and fund Service Accounts. Despite repeated
warnings and invitations to discuss solutions and implement
improvements in areas like billing, collections, meter operations,
project management, and the reimbursement process, LUMA
took no action whatsoever to correct its inefficiencies.
• As a direct consequence of LUMA's failure to urgently implement
necessary measures, PREPA faced projected cash shortfalls and
noted its inability to fund the Service Accounts in upcoming cycles
fully.
14. January 26, 2024-PREPA (J. Colón Ortiz-Exec. Dir.) Letter to LUMA (C.
Schneider-CFO)-Re: Response to LUMA’s January 17th, 2024, Letter
Regarding Service Accounts Funding (Transmittal # LUMA-PREP-T-
00683)
• PREPA rejected all explicit and implicit allegations of purported
non-compliance or breach of the T&D OMA made by LUMA
concerning Service Accounts funding. It reiterated that it funded
the Service Accounts in an amount that was two-thirds (2/3) of the
sums LUMA notified, which PREPA stated was compliant with
Section 14.3(f) of the T&D OMA, indicating no default event had
occurred. Therefore, PREPA had consistently funded two-thirds
(2/3) of the sums for T&D Service Accounts in the past months as a
necessary measure to maintain sufficient liquidity under HoldCo.
• PREPA stated that LUMA's ability to fund the Service Accounts
depended primarily on LUMA's proper execution of its contractual
obligations, which include timely and accurate billing, collection
from customers, ensuring proper meter operation, suspending
service to delinquents, and managing federally funded T&D

Mr. Juan Saca
July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
projects. PREPA asserted that LUMA's failure or inefficient
execution of its contractual duties thwarted PREPA's ability to
adequately fund the Service Accounts.
• As of September 2021, PREPA obtained over $664,620,311 in federal
reimbursements from federally funded projects, while LUMA had
only obtained approximately $43M during the same period.
• Additionally, PREPA had been required to allocate over
$411,474,000 from its federal reimbursements to fund LUMA's
Service Accounts and other fiscal deficiencies, instead of the
reconstruction projects it intended to develop.
• PREPA viewed LUMA's claims as disconnected, incomplete, and
believed a fair discussion required LUMA to acknowledge its
shortcomings in raising sufficient revenues, deeming LUMA's
attempt to blame PREPA as misleading and counterproductive.
15. October 5, 2024-PREPA (J. Colón Ortiz-Exec. Dir.) Letter to LUMA (J. Saca-
President & CEO)-Re: LUMA Response to Josué Colón’s Email August
17th, 2023
• PREPA emphasized that in the past few months both it and LUMA
had exchanged multiple letters regarding Service Account
funding.
• Nonetheless, PREPA again rejected all explicit and implicit
allegations of purported non-compliance or breach of the T&D
OMA made by LUMA concerning Service Account funding. It
reiterated it had funded the T&D Service Accounts at two-thirds
(2/3) of the sums LUMA notified, which PREPA asserted was
compliant with Section 14.3(f) of the T&D OMA. PREPA indicated
this funding level was necessary to preserve its minimum liquidity,
given growing funding obligations.

Mr. Juan Saca
July 22, 2025
Page 41 of 81
PO Box 42001, San Juan PR 00940-2001
• PREPA specifically highlighted LUMA's "double counting" of
certain funding requested for Purchased Power, noting that this
funding was now directly funded to Genera under the LGA OMA.
This indicated a financial mismanagement issue on LUMA's part
in their funding requests.
• PREPA also raised the issue of the outstanding Outage Events
Reserve Account funding request from LUMA that remained
unfunded, indicating a lack of a proper revenue source for its
replenishment.
• PREPA stressed that LUMA's ability to fund its Service Accounts
depended primarily on LUMA's proper execution of its contractual
obligations, which included timely and accurate billing, collection
from customers, ensuring proper meter operation, suspending
service to delinquents, and managing federally funded T&D
projects. PREPA implied that LUMA's inefficient execution of these
duties impacted on PREPA's ability to fulfill its funding obligations.
16. August 30, 2023-PREPA (N. Morales-CFO) Letter to LUMA (C. Schneider-
CFO)-Re: Service Account Funding – July 2023
• PREPA yet again asserted that it had funded two-thirds (2/3) of the
sums LUMA requested for the Operating Account + Capital
Account – Non-Federally Funded, which PREPA stated was
compliant with Section 14.3(f) of the T&D OMA. PREPA highlighted
that LUMA's request for $98,645,000 for the Purchased Power
Account double-counts over $52M of funds already provided to
GenCo Operating Account (Genera), under the LGA OMA. PREPA
only funded two-thirds of the amount LUMA estimated was
needed ($31,014,000).
• PREPA also noted it had not funded LUMA's Outage Event Reserve
Account because there was no recurrent revenue source to
replenish this account.

Mr. Juan Saca
July 22, 2025
Page 42 of 81
PO Box 42001, San Juan PR 00940-2001
• PREPA urged LUMA to optimize the use of available funding and
its collections, and federal funds reimbursements to enhance
collective liquidity.
non-compliance or breach of the T&D OMA made by LUMA
concerning Service Account funding.
17. October 15, 2021-PREPA (J. Colón Ortiz-Exec. Dir.) Letter to P3A (F.
Fontanés Gómez-Exec. Dir.)-Re: LUMA Financial Reports Accounting
Information Reporting Obligations under T&D OMA
non-compliance or breach of the T&D OMA made by LUMA against
it concerning Service Account funding.
• PREPA noted that LUMA's letter contained "irrelevant and
incorrect data" and that LUMA misrepresented valid revenue
sources in its funding requests.
• PREPA presented data indicating that LUMA largely failed to
obtain federal reimbursements for disaster declarations, showing
zero reimbursement in many categories where PREPA secured
millions.
• PREPA highlighted LUMA's inability to secure disaster relief funds
and its inefﬁcient execution of duties such as timely and accurate
billing, collection from customers, proper meter operation, and
managing federally funded T&D projects. PREPA stated that
LUMA's expenditure signiﬁcantly exceeded its budget, spending
over $730 million.
• PREPA concluded that LUMA's "underperformance" was not cause
for celebration and that the people of Puerto Rico were suffering

Mr. Juan Saca
July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
the consequences of LUMA's mistakes, deeming LUMA's "petulant
letters" a "misuse of taxpayers' funds".
P3A hereby demands that LUMA (i) submit within seven (7) days a remediation
schedule that eliminates the reimbursement backlog and restores statutory
reserve levels, and (ii) refund PREPA the $500 million advanced to cover LUMA’s
federal-funding failures. PREPA/P3A submit this dispute to Article 15 for
adjudication.
III. Notice of Technical Dispute: Outages- Performance of O&M Services
P3A, as Administrator of the T&D OMA, issues this Notice of Dispute against LUMA,
due to its failure to comply with its contractual obligations following the island-
wide blackout of April 16, 2025.
1. April 19, 2025- P3A (J. Colón Ortiz-Exec. Dir.) to LUMA (J. Saca- CEO)- Re:
Request for Information in Connection with the April 16, 2025 Power
Outage (April 16 Outage)
• P3A issued this request for information following a power outage
on April 16, 2025, which initial reports attributed to vegetation on
Line 50,100 of 230kV between the Cambalache Power Plant and
Manatí, leading to a cascade effect and the exit of all generation
units.
• P3A characterized the April 16-outage as the "most recent
manifestation of a prolonged and deeply troubling trend" of
recurring service interruptions.
• Between June 5, 2024, and April 16, 2025, Puerto Rico experienced
at least six outages affecting over 70,000 customers, with three
resulting in total system collapse. Notable incidents included:
o A failure on Line 39,000 on June 5, 2024, affecting over
123,000 customers.

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July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
o A total blackout on June 12, 2024, caused by "unaddressed
vegetation problem".
o An outage on July 2, 2024, affecting over 71,000 customers.
o An extended outage on August 24, 2024, affecting over
728,000 customers due to system-wide instability.
o Another total blackout on December 31, 2024, leaving most
of the Island without power.
o The April 16, 2025, event resulted in all 1,468,223 customers
losing power in an island-wide outage.
• P3A stated that these "recurring service interruptions – many
preventable – are embarrassing and unacceptable" and are
incompatible with the promised service quality, resilience, and
reliability as obligated by the T&D OMA.
• As Administrator under the T&D OMA, P3A is compelled to ensure
LUMA takes appropriate and timely steps to diagnose and
respond to incidents and assess system reliability risks.
• Under the reporting obligations in Articles 5 and 6 of the T&D OMA,
P3A requested LUMA to provide specific information no later than
Friday, April 25, 2025.
• The requested information included:
o Root Cause Analysis and Incident Reporting:
 Copies of all incident reports, root cause analyses,
operational logs, and internal memoranda from the past
twelve months related to the April 16-Outage.
 This includes inspection, maintenance, and
thermography records for Line 50,100 of 230kV, patrol

Mr. Juan Saca
July 22, 2025
Page 45 of 81
PO Box 42001, San Juan PR 00940-2001
and inspection records for the same line, and
information on the maintenance and calibration of
related switches and protection devices (Relays and
Breakers).
 Also requested were assessments of the failure’s origin,
sequence of events, system impacts, and
immediate/planned remedial measures, along with any
reports provided or to be provided to PREB, FEMA, or
other government agencies.
 P3A also requested prompt notification of any ongoing
developments, filings, or updates related to the April 16
Outage.
o Current Organizational Chart and Key Personnel:
 A detailed and up-to-date organizational chart for both
LUMA Energy ServCo and ManageCo, showing
departmental structure, employee counts per
department, job titles for all critical or leadership roles
(e.g., System Operations, Grid Control, Maintenance,
Customer Service, IT/Cybersecurity, and Regulatory
Compliance), and a list of current vacant positions.
o System Status Summary:
 A report detailing the operational status of the
transmission and distribution infrastructure as of April 19,
2025, identifying any major components (lines,
substations, transformers, control systems) currently out
of service, under repair, operating under constraints, or
affected by recent contingency events.
• P3A expressed confidence that LUMA shares its interest in
ensuring transparency, stability, and public accountability, and

Mr. Juan Saca
July 22, 2025
Page 46 of 81
PO Box 42001, San Juan PR 00940-2001
that prompt cooperation would assist in identifying
improvements to mitigate future service disruptions.
P3A hereby requires that LUMA (i) submit a comprehensive root-cause analysis for
each island-wide or major outage since June 2024, together with a corrective-
action program that restores SAIFI/SAIDI to pre-2021 benchmarks, (ii) publicly
report progress to P3A each quarter, and (iii) reimburse PREPA for outage-related
emergency costs attributable to LUMA’s negligence. PREPA/P3A invoke Article 15
and demand immediate initiation of the dispute-resolution process.
IV. Notice of Technical Dispute: Vegetation, Transmission Lines and
Public Lighting- Performance of O&M Services
P3A, as Administrator of the T&D OMA, issues this Notice of Dispute to LUMA for
its repeated and ongoing noncompliance with its contractual obligations,
particularly in vegetation management. Despite multiple letters from as early as
August 2022 through as recent as April 2025-LUMA has failed to address critical
deﬁciencies, such as unsafe vegetation proximity to high-voltage lines, inadequate
inspection protocols, ahead of the 2025 hurricane season, and persistent delays in
submitting compliant work plans a documentation, as required by the T&D OMA.
1. January 26, 2025- P3A (J. Colón Ortiz-Exec. Dir.) Letter to LUMA (J. Saca-
CEO)- Re: Maintenance and Inspection of Transmission Lines during
2025 Hurricane Season
• P3A expressed concerns regarding the "proximity of vegetation
within the easement to the lines" and "vegetation is within unsafe
clearance distances, creating potential risks to the safe operation
of the T&D System”.
• The "massive power outage of June 12, 2024, was directly
attributed to inadequate vegetation oversight".
• LUMA itself has identified vegetation as the primary cause of
approximately fifty percent (50%) of power outages.

Mr. Juan Saca
July 22, 2025
Page 47 of 81
PO Box 42001, San Juan PR 00940-2001
• P3A emphasized that it is "imperative that any deficiencies,
particularly related to vegetation clearance, are promptly
identified and addressed" through daily inspections. The recurring
issue indicated a potential lack of readiness for the upcoming
hurricane season by not maintaining safe vegetation clearances
and implementing required measures as outlined in the
Emergency Response Plan.
• P3A requested LUMA to provide relevant documentation and/or
information demonstrating compliance with Section 4.2 of the
T&D OMA.
o Specifically, including details regarding measures currently
being implemented in preparation for the 2025 hurricane
season.
o P3A required LUMA to provide the pertinent
documentation and information no later than noon on
Friday, January 31st
, 2025.
2. January 22, 2025- P3A (J. Colón Ortiz-Exec. Dir.) to LUMA (J. Saca-CEO)-
Re: LUMA’s Work Plan for the Maintenance of the Public Lighting System
• P3A referenced LUMA's obligation under Annex I (Scope of
Services) of the T&D OMA to "operate and maintain the public
lighting system" and to "prepare, develop, and maintain a work
plan to establish priorities and a major maintenance plan for
public lighting". This includes the installation of highly efficient
Light-Emitting Diode (LED) technology.
• The P3A highlighted that "Public lighting is an essential service
that directly impacts public safety across all island municipalities".
• A key concern was that "Adequate lighting has extraordinarily
vexed, hereby residents of Puerto Rico for years", indicating that
the failure to adequately maintain public lighting has been a

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July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
"long-standing issue". This suggested a perceived ongoing failure
by LUMA to meet its operational and maintenance obligations
regarding public lighting.
• P3A requested that LUMA "submit within five (5) calendar days,
due on January 27, 2025, a detailed work plan outlining its
approach to fulfilling this obligation". This plan must be
"organized by municipality and specify the sectors within each
municipality to be addressed".
3. January 4, 2023- PREPA (J. Colón Ortiz-Exec. Dir.) Letter to FEMA (J.
Baquero Tirado-Federal Disaster Recovery Coordinator), COR3 (M. Laboy
Rivera- Exec. Dir.), P3A (F. Fontanés Gómez-Exec. Dir.), and LUMA (W.
Stensby-President and CEO)-Re: Regulations and Permitting Process for
New Projects
• PREPA identified several areas where LUMA's previously
submitted documentation for FEMA-funded projects require
clarification, correction, or additional detail to comply with
regulations and ensure proper project execution and FEMA
reimbursements. PREPA acts as the recipient of FEMA funds and
owner of assets, making it responsible for the development of
projects in compliance with federal laws, regulations, and
engineering best practices.
• PREPA requested LUMA to clarify or correct the following matters:
o Vegetation Management: While agreeing with vegetation
management in project scopes, PREPA indicated that
LUMA must consider specific factors regarding when and
where to cut/prune vegetation (i.e., avoiding unnecessary
pruning for underground/submarine lines, high-altitude
transmission lines, and agricultural land easements).
o Cost and Documentation for Distribution Projects: For
distribution feeders, pole, and conductor repair projects,

Mr. Juan Saca
July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
LUMA's documentation needed to clearly explain repair
estimates. This includes justifying unit costs of poles (with
LUMA Standard Material Price), detailing labor costs
(including field workers, transportation), separating
hardware and installation costs for fittings, specifying cable
type and installation cost, justifying A&E and Project
Management/Administration costs, marking pole routes in
the FAAS document, providing design guides for pole
replacement, and justifying pole material choices (e.g., why
steel is cheaper than concrete).
o Infrastructure Project Design and Justification: For electrical
infrastructure projects connected to the transmission or
sub transmission system, LUMA was required to submit
detailed planning studies and design criteria if projects
increase transformation capacity or add circuits/bundles
and are not included in PREPA's 10-Year Infrastructure Plan
or the IRP 2019. PREPA also clarifies that changes in bus
configurations in substations do not necessarily improve
resilience after atmospheric events5. Specific criteria and
justifications are required for FEMA 406 mitigation projects
(i.e., conversion to gas-insulated substations, SCADA
redundancy).
o Financial and Administrative Documentation: LUMA
needed to ensure consistency between tasks/activities in
FEMA documents and its own Scope of Work (SOW), submit
engineering documents to verify A&E costs, clarify
state/municipal taxes (as they don't apply to PREPA), detail
unit costs for equipment (not aggregated), justify
contingency calculations (by LUMA Risk Analyst), and
explain escalation, overhead, and profit expenses which
may inflate costs for government utility projects.

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July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
o Project Design Drawings: Project design drawings must be
included in the SOW and signed by a licensed and collegiate
engineer in Puerto Rico.
o PREPA requested LUMA address the identified deficiencies
and provide the necessary clarifications, corrections, and
supporting documentation for the FEMA-funded projects.
PREPA implied these corrections are necessary for the
ongoing development and evaluation of the projects and
for FEMA reimbursement.
4. August 1, 2022-PREPA (J. Colón Ortiz-Exec. Dir.) Letter to LUMA (W.
Stensby-President and CEO)-Re: Easements Conditions on Transmission
Lines 230kV, 115 kV, and 38 kV
• PREPA expressed significant concerns regarding the "condition of
the vegetation in the easements and their proximity to the lines"
within the electrical system.
• PREPA highlighted that "in some areas the distance between the
vegetation and the lines' conductors and structures, appears to be
less than the required clearance for safe operation".
• PREPA emphasized that "daily inspection of the transmission lines
by helicopter and other means is of utmost importance to detect
and attend in time the most critical areas that put at risk the
continuity of the electric service".
• LUMA was not performing these essential inspections or
addressing the identified vegetation issues effectively.
P3A hereby directs LUMA to (i) present, within five (5) calendar days, a hurricane-
season vegetation-clearance plan that satisfies Annex I, § II(B); (ii) clear all unsafe
easement intrusions on 230 kV, 115 kV and 38 kV lines; and (iii) certify monthly
compliance through third-party inspections. Failure to do so will expose LUMA to

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July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
indemnity for any vegetation-caused outage. This dispute is submitted to Article
15 for formal resolution.
V. Notice of Technical Dispute: Financial Statements/Audit/Comptroller
P3A, as Administrator to the T&D OMA, issues this Notice of Dispute due to LUMA’s
persistent and material noncompliance with its audit and financial reporting
obligations. Despite multiple directives and extensive time afforded, LUMA has
failed to provide accurate and timely financial data.
1. February 4, 2025-PREPA (M. Zapata Acosta-Exec. Dir.) Letter to LUMA (J.
Saca-CEO)-Re: Urgent Request for Data and Analysis for PREPA’s
External Audit
• PREPA stated that for its Fiscal Year 2023 financial statement audit,
it was concerned are underscored regarding LUMA's continued
delays in providing essential data and analyses. Under Annex I,
Section V(F)(2) of the T&D OMA, LUMA is obligated to aid, including
necessary information and data, to support PREPA’s annual
reporting requirements.
• Additionally, PREPA emphasized that Section 3.5 of the T&D OMA,
titled Right of Access, grants PREPA the right to access PREPA’s
System Information to oversee LUMA’s performance under the
T&D OMA.
• PREPA has repeatedly raised concerns to P3A about LUMA's failure
to supply critical audit information promptly.
• P3A's January 17, 2025-letter reiterated the urgency for LUMA to
comply with its obligations, as LUMA's continued failure to provide
requested data and analyses and its ongoing refusal to provide
access impedes PREPA's ability to meet audit and financial
statement issuance deadlines.

Mr. Juan Saca
July 22, 2025
Page 52 of 81
PO Box 42001, San Juan PR 00940-2001
• PREPA requested speciﬁc items for auditor analyses, detailed in
Attachment I (Prepared by Client-PBC items, which PREPA relies
on LUMA to provide for auditor analyses).
• To facilitate the audit process, PREPA requested LUMA to provide
Oracle IT personnel, support for depreciation issues, payroll details,
cash receipt details, access to journal entries, accounts payable
ﬁles, and system access to Project Accounting Modules.
• PREPA emphasized that this information had to be provided by
LUMA on Friday, February 7, 2025.
2. January 30, 2025-PREPA (M. Zapata Acosta-Exec. Dir) Letter to LUMA (J.
Saca-CEO) RE: Response to LUMA’s January 21, 2025, Letter Regarding
Audit Obligations
• PREPA emphasized that finally with its January 21, 2025-Letter
LUMA responded to PREPA’s November 27, 2024-Letter.
• PREPA stated LUMA has repeatedly demonstrated non-
compliance, evasion, and delay in addressing the audit, leading to
an overall lack of diligence.
• PREPA stated that LUMA agreed to assume its responsibility
under the T&D OMA and the SSA with full knowledge of the
challenges involved, including the volume and complexity of
financial reporting. LUMA has certified its ability to perform these
obligations and is being compensated accordingly.
• PREPA claimed that LUMA’s deficiencies in financial accounting
responsibilities led to over 381 correcting journal entries identified
in PREPA’s October 31, 2024-Letter.
• PREPA asserted that LUMA’s claim of having addressed 180 out
of 188 shared service audit-related requests is misleading, as many
remain unresolved, and LUMA had unilaterally marked detailed

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information requests on pass-through expenses as “closed”
without providing the necessary documentation.
• External auditors were forced to step away from the audit in
December 2024 due to LUMA’s “backlog of pending information
requests”.
• PREPA listed several critical audit requests that remain overdue,
including:
o T&D Federal Revenues: Overdue 6 months (since July 7,
2024).
o Fringe Beneﬁts LUMA employees: Overdue 7 months (since
June 9, 2024).
o Pass-Through Expenses incurred by LUMA: Overdue 3
months (since September 27, 2024).
o Seconded Payroll incurred by LUMA: Overdue 3 months
(since October 16, 2024).
o Depreciation Analysis (errors that originated during FY23): 7
months overdue (since June 23, 2024).
o AP samples: Overdue 2 months (since November 11, 2024).
• PREPA attributed the outstanding audit issues to LUMA's lack of
cooperation and failure to meet its contractual obligations,
impacting PREPA’s and the Government of Puerto Rico's ﬁnancial
statements.
• PREPA stated that it expected LUMA to take immediate corrective
action by Thursday, February 6, 2025. PREPA demanded LUMA to:
o Fully comply with all outstanding audit-related requests.

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o Cease unilateral closure of requests without resolving
underlying issues.
o Provide PREPA with full system access to streamline the
audit process.
o Adhere to established deadlines for document submissions.
o Cease bypassing PREPA in the audit process and respect
PREPA's role as the owner of the financial statements.
o Reopen PREPA FY2023 accounting periods to post pending
accounting entries as requested by the P3A.
• PREPA maintained that LUMA's continued failure to meet its
contractual obligations is obstructing progress and will not accept
further delays.
3. January 26, 2025-P3A (J. Colón Ortiz-Exec. Dir.) Letter to LUMA (J. Saca-
CEO) Re: LUMA’s Continued Noncompliance with Audit and Financial
Obligations
• This letter highlighted LUMA's persistent non-compliance with
audit and financial obligations is severely hindering PREPA's
financial restructuring and Puerto Rico's fiscal stability.
• LUMA had failed to respond to previous P3A letters from
December 15, 2024, January 15 and 17, 2025.
• PREPA emphasized LUMA's failure to grant access to System
Information, lack of cooperation in providing accurate financial
data for audits, and unresolved 24 outstanding audit items (some
overdue by over 200 days), causing significant delays in PREPA's
FY23 financial statements.

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July 22, 2025
Page 55 of 81
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• PREPA emphasized that the T&D OMA imposes extensive
obligations on LUMA to provide timely and accurate financial and
operational information necessary for the proper functioning and
reporting of PREPA’s financial operations. Hence, LUMA’s actions
are in violation of multiple provisions of the T&D OMA:
o Section 3.5: requires LUMA to provide access to all System
Information to enable PREPA’s compliance with its
oversight and reporting responsibilities.
o Section 5.15(c)(i): mandates LUMA’s full cooperation in
providing complete and accurate financial data required for
audits and financial statements.
o Annex I, Section VI: further obligates LUMA to deliver all
financial and operational data necessary for audits in
compliance with Generally Accepted Accounting Principles
(“GAAP”).
• These actions were a violation of the T&D OMA and compromise
the credibility of Puerto Rico's financial reporting. P3A demanded
immediate compliance with the November 13, 2024-directive to
reopen PREPA's FY23 accounting periods, resuming participation
in weekly financial audit meetings to resolve all outstanding audit
items within five calendar days, and submission of a detailed
corrective action plan by January 30, 2025.
4. January 30, 2025 - PREPA (M. Zapata-Exec. Dir.) Letter to LUMA (J. Saca -
CEO) – Response to LUMA’s January 21, 2025, Letter Regarding Audit
Obligations
• LUMA's Noncompliance and Deficiencies:
o LUMA's response to PREPA's audit obligations is
characterized as an instance of evasion and delay,
contributing to overall audit delays.

Mr. Juan Saca
July 22, 2025
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o LUMA is criticized for not fully assuming its responsibilities
under the Transmission and Distribution (T&D) and Shared
Services Agreements (SSA) concerning financial reporting,
which PREPA states has become an unfulfilled and
burdensome obligation.
o On October 31, 2024, a letter from PREPA detailed
deficiencies in LUMA's financial reporting, including over 381
uncorrected journal entries, errors in audit corrections, and
unclosed information requests.
o LUMA's T&D and Operations and Maintenance Agreement
(OMA) Division failed to ensure the accurate and timely
closing of financial information, impacting the T&D general
ledger's completion.
o LUMA's refusal to provide PREPA with information is cited
as non-compliance with federal revenue accounting and
potentially discriminatory.
o LUMA has consistently slowed the audit process by delaying
access to information and documentation.
o As of December 2024, and January 15, 2025, 120 and 15
pending information requests respectively remained
overdue.
o LUMA committed to delivering 15 PBCs (Prepared by Client)
by January 17, 2025, but only one was provided.
o LUMA's claim that 188 of 190 shared service audit-related
requests were "closed" was refuted, as 180 were either not
addressed or improperly marked closed.
o Several specific items remain overdue, including
T&D/Federal Revenues (over 6 months since July 7, 2024),

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July 22, 2025
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Fringe Benefits LUMA (over 6 months since September 27,
2024), Pass-Through Expenses (over 3 months since
September 27, 2024), Seconded Payroll (over 3 months since
October 16, 2024), Depreciation Analysis (over 7 months
since November 11, 2024), and AP samples (over 2 months
since November 11, 2024).
o LUMA's lack of cooperation and failure to meet its
obligations prevents external auditors from issuing financial
statements, with 100% of the PBCs still outstanding.
o LUMA has failed to participate in critical audit meetings and
provide overdue financial data, directly impacting the
issuance of PREPA's financial statements.
• Requests for Action and Information (Due Date: February 6, 2025):
o PREPA demands immediate corrective action from LUMA
on or before Thursday, February 6, 2025.
o LUMA must fully comply with all outstanding audit-related
requests without further delay.
o LUMA must cease the unilateral closure of requests without
resolving the underlying issues.
o LUMA must provide PREPA with full system access to
streamline the audit process.
o LUMA must adhere to established deadlines and
commitments for document submissions.
o LUMA must cease attempts to bypass PREPA in the audit
process and respect PREPA's role as the owner of the
financial statements.

Mr. Juan Saca
July 22, 2025
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o LUMA is requested to reopen PREPA FY23 accounting
periods to post pending accounting entries, as previously
requested verbally, in writing, and ordered by the PJA.
o PREPA expects LUMA's full cooperation to resolve these
outstanding issues immediately.
5. January 17, 2025 - P3A (J. Colón-Executive Director) Letter to LUMA (J.
Saca-CEO)-Re: LUMA’s Continued Noncompliance with Audit
Obligations
• LUMA has repeatedly failed to provide critical information necessary
for the completion of PREPA's consolidated financial statements and
audits, which is deemed a clear breach of LUMA's obligations under
the T&D OMA.
• This noncompliance includes LUMA's refusal to participate in weekly
audit meetings with the Puerto Rico Treasury Department.
• Outstanding items such as federal revenue details (193 days overdue)
and Governmental Accounting Standards Board ("GASB 68") items
(249 days overdue) directly impeding PREPA's ability to produce
accurate financial statements and comply with reporting obligations.
• LUMA's actions have already caused PREPA to miss the December
2024 and January 2025 deadlines for establishing GAAP, and the
March 31st, 2025, deadline for the final financial statements is at risk.
• LUMA's conduct is a breach of Sections 3.5 and 6.15(O) of the T&D
OMA, which require timely access to System Information and support
for PREPA's oversight and financial reporting responsibilities.
• Request for Action:
o P3A expects LUMA to take immediate action within the next
seven (7) days to address these deficiencies.

Mr. Juan Saca
July 22, 2025
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o This includes participation in upcoming meetings on Tuesday,
January 21st, and Wednesday, January 22nd.
o LUMA is requested to demonstrate a renewed commitment to
the attestation of trust, which has been undermined by its
recent actions.
6. January 15, 2025- P3A (J. Colón-Executive Director) Letter to LUMA (J.
Saca-CEO)-Re: Authorization to Reopen FY2023 Accounting Periods
• LUMA has failed to comply with P3A's directive, issued on November
13, 2024, which mandated the reopening of PREPA's FY2023
accounting periods.
• LUMA had previously requested reconsideration of this directive but
has not complied with the P3A's reaffirmation of the original directive.
• This noncompliance is an urgent and important obligation for PREPA
and the Commonwealth, exacerbating risks related to Puerto Rico's
audited financial reporting, compliance, and the issuance of
government financial statements. It also undermines ongoing Title III
proceedings.
• Requested Action:
o The P3A is giving LUMA a final opportunity to comply with the
directive to reopen and report PREPA's FY2023 accounting
periods.
o LUMA is requested to take immediate action to comply as
directed.
o The P3A will engage PREPA, the Puerto Rico Treasury
Department, and respective auditors to work with LUMA on

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July 22, 2025
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these effects immediately, and this subject will be incorporated
into weekly financial statement audit meetings.
7. December 26, 2024- PREPA (J. Colón-Executive Director) Letter to LUMA
(J. Saca-CEO) & P3A (Gerardo Loran, Esq., Interim Executive Director)-Re:
Response to LUMA’s December 10, 2024, Letter Regarding Reopening
FY23 Accounting Periods
• Delayed Response and Defiance: LUMA's month-long delay in
contesting P3A's directive to reopen PREPA's FY23 accounting
periods is deemed unjustifiable and part of a pattern of defiance that
has directly contributed to delays in issuing PREPA's financial
statements.
• Contradictory Arguments: LUMA's reliance on the Committee of
Sponsoring Organizations (COSO) framework, US Generally Accepted
Accounting Principles (GAAP), and Generally Accepted Government
Auditing Standards (GAGAS) as arguments against reopening
accounting periods is considered unsubstantiated and contradictory,
especially given the scale of required adjustments.
• Distortion of Financial Reporting: LUMA's proposal to delay material
adjustments into future periods would distort PREPA's financial
reporting, mislead stakeholders, and create significant cut-off issues,
compromising audit accuracy. This approach also disregards KPMG's
observation that it would increase audit complexity and delay
timelines.
• Compromised Internal Controls: LUMA's suggestion to move journal
entries to top-level Excel files would result in a significant deficiency
in PREPA's internal controls over financial reporting and material
noncompliance with US GAAP. Managing PREPA's financial reporting
through spreadsheets, instead of Oracle, is considered untenable and
prone to errors and manipulation.

Mr. Juan Saca
July 22, 2025
Page 61 of 81
PO Box 42001, San Juan PR 00940-2001
• Violation of Agreement: LUMA's refusal to comply with P3A's directive
is a significant obstacle to completing PREPA's financial statements
and directly contradicts LUMA's obligations under the Transmission
and Distribution Operating and Maintenance Agreement (T&D OMA),
which requires supporting PREPA's audits, maintaining GAAP-
compliant records, and ensuring timely financial reporting.
o PREPA emphasizes that the directive to reopen FY23
accounting periods is necessary and appropriate and must be
implemented immediately to safeguard the integrity of
PREPA's and the Government of Puerto Rico's financial
reporting.
o The letter implicitly requests that P3A, as the sole entity
empowered to enforce compliance, act swiftly and decisively to
compel LUMA’s compliance and ensure it fulfills its
responsibilities without further obstruction. No specific due
date is provided beyond "immediately" and "swiftly".
8. November 27, 2024 - PREPA (J. Colón-Executive Director) Letter to P3A
(Fermín Fontanés, Esq., Executive Director)-Re: Response to LUMA’s
November 25, 2024, Letter on FY23 Financial Statements Audit Meetings
• PREPA stated that LUMA's letter contained "unfounded" and
"inaccurate" statements, including a false claim that a meeting
occurred on November 24, 2024 (a Sunday); the meeting took place
on November 15, 2024. PREPA asserts LUMA's claims misrepresent
facts and are an attempt to deflect from its own failures.
• LUMA was "conspicuously absent" from the weekly Financial
Statements Audit Meeting held on November 27, 2024,
demonstrating a lack of commitment.

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July 22, 2025
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• LUMA has failed to meet its obligations under T&D OMA, causing
significant delays in the audit process and jeopardizing PREPA's
ability to meet critical deadlines for financial statements.
• LUMA has not provided timely and accurate information, leading to
extensive delays and errors, including unresolved critical audit items,
missed deadlines, and an inability to reconcile key financial data.
• Despite authorization from P3A on November 13, 2024, to reopen
necessary closed accounting periods for accurate financial reporting
(a critical GAAP compliance step), LUMA has failed to act, obstructing
PREPA’s ability to meet its obligations.
• LUMA is responsible for 29 open audit items, comprising 36% of all
unresolved issues, including critical areas like payroll details, federal
revenue reconciliation, and depreciation analysis. Some of these
items have been overdue for up to 145 days. This violates Annex I,
Section VI of the T&D OMA.
o Violation of T&D OMA Provisions: LUMA's actions contravene
Sections 3.5 and 5.15(c)(i) of the T&D OMA, which mandate
timely access to System Information, including financial data
and records, for PREPA's oversight and compliance
responsibilities. Annex I, Section VI further delineates LUMA's
duty to provide accurate, complete, and GAAP-compliant
information for PREPA's audits and reports.
o LUMA's decision to bypass PREPA and engage directly with
auditors is a "clear violation of its contractual obligations",
undermines PREPA's oversight of the audit process.
• PREPA emphasized the urgency, stating that "LUMA's time is up".
• PREPA urged LUMA to act on P3A's authorization to reopen accounts.

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July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
• PREPA reiterated to LUMA that it must comply with the T&D OMA,
which includes full participation in audit meetings, compliance with
authorized protocols, and the timely provision of accurate financial
data. LUMA's cooperation is "not optional" and is an "essential
requirement".
o Deadlines for Financial Statements:
 Second draft of financial statements: December 20,
2024.
 Final issuance of financial statements: January 18, 2025.
9. November 26, 2024- PREPA (J. Colón-Exec. Dir.) Letter to LUMA (J. Saca -
CEO)-Re: Response to Notification Regarding the Decommissioning or
Disabling of Servers
• LUMA's proposed decommissioning of servers on November 27, 2024,
is inconsistent with the timeline and constitutes a breach of the
express terms of the Extended Amended and Restated Shared
Services Agreement (A&R SSA). The A&R SSA, which was extended to
an effective September 30, 2024, explicitly stipulates that services
under the agreement are to remain operational until February 28,
2025, to allow for the proper completion of migration, validation, and
commissioning activities.
• The servers LUMA intended to decommission (specifically STREBS-
SRV1, SRETLNS-SRV1, SRETLXEB$, SRETWEB-WS1, SRETEBS-SRV2,
and PREPA-SRET-IVR) are critical to PREPA's essential operations.
Their premature decommissioning would paralyze functions like the
administration of accounting for loans, retiree payroll, and the
printing of checks and reports. This action would result in severe
operational disruptions, significant legal and financial risks, and a
failure to comply with the A&R SSA terms. It would also disrupt vital
interfaces with Oracle-ERP, halt financial accounting processes, and

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impact the Retirement System's functions. These servers also contain
highly sensitive and legal data, risking damages and violations of
federal and local laws.
• PREPA asserted that LUMA has not provided the requested work plan
for the migration of the aeeppr.com and prepa.com domains, thereby
impeding progress on a critical component of the migration process.
This failure undermines LUMA's ability to justify decommissioning
these servers, especially with the February 28, 2025, deadline still
three months away.
• PREPA demanded the immediate postponement of the proposed
server decommissioning scheduled for November 27, 2024.
• PREPA stated that if LUMA insists on proceeding with the
decommissioning, PREPA will file for injunctive relief as well as other
appropriate legal remedies.
• PREPA invited LUMA to engage in constructive discussions to
establish a timeline consistent with the February 28, 2025, extension
of the A&R SSA, while ensuring compliance and safeguarding critical
systems and services.
10. November 6, 2024- PREPA (J. Colón-Exec. Dir. Letter to LUMA (J. Saca -
CEO)-Re: Response to LUMA’s October 24, 2024, Internal Controls Memo
• Noncompliance made by LUMA:
o LUMA failed to adequately apply Generally Accepted
Accounting Principles (GAAP).
o LUMA did not maintain permanent documentation to support
revenues and expenses.
o These deficiencies are considered a significant internal control
deficiency.

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July 22, 2025
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o The noncompliance creates a risk of presenting outdated or
incomplete financial data, as material financial events were not
properly accounted for.
• Request for information or action:
o This letter is a response to LUMA's prior internal controls memo.
o It notes that the P3 authority authorized LUMA to proceed with
reopening necessary closed accounting periods to make
material adjustments and correct accounting.
o PREPA's Remediation Plan continues to actively collaborate
with LUMA and Genera to implement improvements and
address internal control findings.
o The letter itself does not issue a new direct request for
information or action from PREPA to LUMA with a specific due
date.
11. October 31, 2024 - PREPA (J. Colón-Executive Director) Letter to P3A
(Fermin Fontanez- Exec. Dir.)-Re: Response to LUMA’s October 24, 2024,
Internal Controls Memo
• LUMA's Noncompliance and Failures Identified by PREPA in this
letter:
o Diverting Attention and Shifting Responsibility: LUMA’s
assertions were characterized as an attempt to divert P3A’s
attention and shift responsibility for potential delays in financial
statement issuance onto PREPA.
o Mismanagement and Failure to Fulfill OMA Obligations: Any
delays in the issuance of financial statements are directly
attributed to LUMA’s mismanagement and its failure to fulfill
obligations under the T&D OMA.

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July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
o Refusal to Align Accounting Policy: LUMA’s refusal to align with
PREPA’s policy of reopening closed accounting periods for
material adjustments, which is consistent with GAAP and
essential for transparency in the Title III process, is delaying the
audit process.
o Failure to Support Audit Processes: LUMA failed to meet its
contractual obligation under Annex I, Section VI.D of the T&D
OMA by questioning PREPA’s policy on material adjustments,
which requires LUMA to support PREPA’s audit processes,
provide access to financial records, and ensure information
accuracy.
o Poor Quality of Accounting Services: Issues have been
identified within LUMA’s accounting shared services, leading
PREPA to request approximately 155 correcting journal entries
after the FY2023 audit began in April 2024, impacting critical
areas like cash, receivables, accruals, and intercompany
transactions. This called into question the quality of LUMA’s
financial data and the effectiveness of its internal controls.
o Disregard for Prudent Utility Practices: LUMA’s objections to
PREPA’s accounting practices disregard the "Prudent Utility
Practices" standard outlined in Annex I, Section I.A part of the
T&D OMA, which mandates adherence to recognized industry
practices for reliability, transparency, and accuracy.
o Delayed Financial Reporting and Non-Compliance: LUMA's
actions resulted in significant financial reporting delays. LUMA
is obligated under Annex I, Section VI.F of the OMA to provide
timely financial information for PREPA’s reporting, including
federal filings, and under Annex I, Section VI.B, to maintain
GAAP-compliant records.

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July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
o 15-Month Delay in Federal Revenue Recognition: As of October
2024, LUMA has a 15-month delay in recording approximately
$65 million in federal revenues for FY2023, a clear failure to
meet its obligations under Annex I, Section VI.F of the OMA, and
compromising PREPA’s compliance with federal reporting
standards.
o Incorrect Capitalization of Expenses: LUMA capitalized
approximately $60 million in Category Z Administrative
Expenses without adhering to GAAP, violating Annex I, Section
VI.B of the T&D OMA. This misclassification led to audit
adjustments and compounded audit delays.
o Consistent Missed Audit Deadlines: Throughout the FY23 audit,
LUMA has consistently missed deadlines, with 30 of 66
outstanding audit items unresolved as of October 18, violating
its obligations under Annex I, Section VI.D of the OMA.
• PREPA highlighted that LUMA’s actions are delaying the audit
process for PREPA’s FY2023 audited financial statements, which the
Puerto Rico Treasury Department mandated to be completed by
December 2024.
• PREPA expressed confidence that LUMA can fulfill its obligations and
align with OMA standards by following the guidance provided in the
letter, implicitly requesting LUMA to correct its deficiencies and
comply with the contractual requirements.
12. October 30, 2024-PREPA (N. Morales-CFO) Letter to P3A (-G. Lorán-Dir.-
Project Monitoring) Re: LUMA’s Letter of September 27, 2024, to P3A
Regarding Accounting Documentation
• PREPA reaffirmed its full compliance with documentation
requests, stating it had provided the requisite accounting records.
It contended that LUMA's request for P3A intervention

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July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
disregarded PREPA's prior communications and efforts in sharing
information pertinent to audit work.
• PREPA detailed that, as of August 2023, it had provided the
requested accounting documentation, and that in bi-weekly
meetings, specifically on May 22, 2024, the agenda indicated
LUMA was reviewing this information.
• PREPA clarified that information requests related to FY2020 and
FY2021 financial statement audits were irrelevant or outdated,
given that those audited statements had been issued on
September 30, 2022, and March 3, 2023, respectively.
• PREPA, as the System’s Owner, had not received any
communication from external auditors regarding open items
pertinent to the FY2020 and FY2021 financial statement audits.
• Despite PREPA's extensive efforts, LUMA had reportedly declined
to acknowledge the provided documentation, opting instead to
escalate the matter without a justifiable basis.
• PREPA stated that its prior references to liquidity challenges were
not to detract from the documentation issue, but to highlight
critical operational challenges, primarily stemming from over $550
million in delayed federal reimbursements for LUMA-managed
CapEx, for which LUMA had yet to present a structured resolution
plan.
13. September 9, 2024-PREPA (N. Morales-CFO) Letter to LUMA (Corey
Schneider-CFO) Re: LUMA Letter of July 24, 2024-Accounting
Documentation
• PREPA asserted that LUMA's allegations regarding accounting
documentation were secondary issues that distracted the critical
liquidity crisis.

Mr. Juan Saca
July 22, 2025
Page 69 of 81
PO Box 42001, San Juan PR 00940-2001
• PREPA contended that the liquidity crisis was caused by LUMA's
deficient federal funds management process, citing over $550
million in LUMA Federally Funded Capital Expenses that remained
unreimbursed due to LUMA's mismanagement of federal funds
and has to correct, improve, disclose, secure material
reimbursements, or present a credible plan to accelerate and
improve the go-forward FEMA reimbursement process or to
address the substantial Hurricane Fiona-related claims.
• This liquidity depletion significantly strained PREPA's operational
account and impacted its ability to meet various contractual
obligations.
• PREPA, P3A, and FOMB had previously requested information and
demanded action from LUMA to immediately address these
federal funds matters, noting LUMA's responsibility under the T&D
OMA for collecting System Revenues and securing federal
reimbursements.
• Regarding LUMA's accounting allegations, PREPA characterized
them as incorrect and misleading.
• PREPA stated that LUMA's letter was a "feeble and belated
attempt to distract" from LUMA's unilateral obstruction and delay
of data and information necessary for PREPA to complete its
FY2023 financial statement audit process.
• PREPA asserted that it had provided the accounting
documentation requested by LUMA since at least August 2023,
and that LUMA was reviewing this information as of a May 22,
2024-meeting.
• PREPA deemed any requests related to FY2020 and FY2021
financial statement audits irrelevant or outdated, as the audited
financial statements for those fiscal years had already been issued.

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July 22, 2025
Page 70 of 81
PO Box 42001, San Juan PR 00940-2001
• PREPA, as System Owner, confirmed it had not received any
communication from external auditors about open items related
to the FY2020 and FY2021 financial statement audits.
• PREPA further noted that “Attachment A" referenced in LUMA's
letter was never received.
• PREPA concluded by expressing its anticipation of LUMA's prompt
response concerning the federal funds reimbursement and Fiona
claim matters, and LUMA's normalization of PREPA's access to
System Information in compliance with the T&D OMA.
14. July 29, 2024- PREPA (Nelson Morales, Chief Financial Officer) Letter to
LUMA (Kazi Hasan – Chief Financial Officer)-Re: Urgent Notice Regarding
Timely and Accurate Cash Flow Data from LUMA
• Noncompliance by LUMA that PREPA identified:
o LUMA has failed to provide daily bank balance and cash flow
files to PREPA, instead providing them only twice per week
over the past two months. These files are crucial for PREPA to
monitor liquidity and comply with the FOMB Certified Fiscal
Plan.
o The cash flow data supplied by LUMA frequently contains
errors, which complicates and delays PREPA's ability to submit
timely reports to stakeholders.
o LUMA has not acted to correct these issues despite PREPA's
repeated relaying of the importance of this information, both
in-person and in writing.
o This failure by LUMA has resulted in PREPA being unable to
publish accurate cash flow files and lacking adequate visibility
into its liquidity, a practice deemed "wholly negligent" and

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July 22, 2025
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"unacceptable". This is particularly critical as a significant
deterioration in PREPA's liquidity is projected to lead to a cash
flow shortfall within 30 calendar days.
o LUMA's failure to provide the required information constitutes
a violation of the T&D OMA, Section 3.8.
• PREPA requested immediate attention to this matter and prompt
confirmation of LUMA's corrective actions. PREPA specifically asked
that LUMA immediately begin to provide the relevant financial
information in a way that is timely and accurate.
o While no specific future due date is given for the confirmation
of corrective actions, the request stresses the need for
"immediate" action regarding the provision of accurate and
timely data.
15. April 11, 2024-PREPA (J. Colón Ortiz-Exec. Dic.) Letter to P3A (R. Lugo Mas-
Contract Compliance Manager)– Re: OIG Report OIG-E-24-004
• Under Section 5.3 and Annex 1 Section 1(A)(4) of the Transmission
and Distribution Operating and Maintenance Agreement (T&D
OMA), LUMA (collectively referring to LUMA Energy, LLC and LUMA
Energy ServCo, LLC) is responsible for performing all billing and
collection services for the T&D System. Furthermore, LUMA is
responsible for managing the information systems that contained
historical data, balances, and payments for all PREPA clients,
including central government agencies and corporations, and for
providing said information. While the letter did not explicitly use
the term "noncompliance," it indicated that PREPA was providing
information that was explicitly LUMA's responsibility, specifically
"LUMA's pre-commencement (June 1, 2021) historical accounts
receivable" and data related to the Global Settlement Agreement,
implying a failure by LUMA to provide this information as per their
contractual obligations. PREPA reminded P3A that LUMA was
responsible for these data management and provision tasks.

Mr. Juan Saca
July 22, 2025
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16. December 8th, 2023- PREPA (J. Colón Ortiz-Exec. Dir.) letter to LUMA (C.
Schneider) – Re: FY22 Audit – Construction Work in Progress (CWIP)
Project Status
• Historically, PREPA had Construction Work in Progress (CWIP)
projects that were not reclassified to depreciable assets due to
pending paperwork. While PREPA acknowledged ownership of
this responsibility, the current operating structure left PREPA
without the necessary resources to continue these
capitalization efforts.
• Under the new structure, the custody, maintenance, and
accounting of these assets were transferred to operators,
including LUMA Energy, LLC.
• Auditors from KPMG, LLC, required the ability to assert the
existence and status of these CWIP projects for the FY22 audit.
The urgency stemmed from the Governor's requirement for
PREPA's audited financial statements for FY22 to be finalized
by December 31st, 2023. The letter implied that LUMA's lack of
action or status reporting on these transferred assets
prevented PREPA from completing its audit obligations.
• PREPA requested LUMA to examine a provided list of open
CWIP projects (including those with no movement in the last
two years).
• LUMA was specifically asked to verify the existence of these
projects and report on their current status (completed, in
progress, abandoned/impaired).
• The response for each CWIP estimate should have indicated
whether the asset existed, whether construction was
completed, or whether it was impaired and should have no
longer been reported as construction in progress.

Mr. Juan Saca
July 22, 2025
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PO Box 42001, San Juan PR 00940-2001
• PREPA also noted the need to coordinate the capitalization of
these projects.
• The due date for LUMA to advise on the current status of the
CWIP projects was December 11th, 2023, by the end of business.
17. January 11. 2023-Email from OCPR to LUMA (Reporting and Regulatory
H. Leyendecker & L. Jiménez Torres) - Re: Requests for Information from
the Office of the Comptroller of Puerto Rico – Data from Information
Systems of Files in LUMA Custody.3
• The Office of the Comptroller stated that the information previously
provided was incomplete, noting that "the request for information is
not yet complete". This indicates a lack of full compliance with the
Comptroller's data request.
• Specifically, the pending and missing information for the period from
January 1, 2000, to June 30, 2020 (prior to LUMA's Commencement in
June 2021), included:
o Rate revenue, detailed by residential, commercial, and
government customers, by fiscal year.
o Accounts receivable, detailed by residential, commercial, and
government customers, by fiscal year.
o Loss from energy theft, detailed by residential, commercial,
and government customers, by fiscal year.
• An internal PREPA email further explained that PREPA does not have
access to the systems required to coordinate the missing information
with LUMA. It also noted that the Authority (PREPA) had not directly
requested LUMA to send the information and only became aware of
LUMA's January 10, 2023, letter because they were copied on an email.
3
This email was originally in Spanish.

Mr. Juan Saca
July 22, 2025
Page 74 of 81
PO Box 42001, San Juan PR 00940-2001
This suggests a gap in direct information exchange between PREPA
and LUMA regarding the Comptroller's requests.
• The Office of the Comptroller requested the outstanding detailed
information listed above.
• It also requested to be informed of a contact person for follow-up on
the information request.
• While the Comptroller's email itself did not state a new due date for
the remaining information, an internal PREPA email confirmed that
an "expiration date" was in January (partially visible as "Janu" in
source), and that PREPA is preparing a letter to request an extension
for the delivery of the remaining information. This indicates that the
original deadline for providing the complete information was either
missed or imminent.
18. August 1st, 2022- PREPA (J. Colón Ortiz) Letter to LUMA (W. Stensby
President & CEO) – Re: Letter from the Office of Comptroller of PR – Audit
15592 Term
• The letter indicated a procedural difficulty where PREPA was unable
to respond promptly to the Comptroller's Office regarding Audit 15592
because the necessary information was under the control and
custody of LUMA. While not explicitly stated as "noncompliance," this
situation highlighted that LUMA's control over information impeded
PREPA's ability to fulfill its obligations to the Comptroller's Office in a
timely manner.
• PREPA requested LUMA's intervention to establish a more agile
mechanism to respond promptly to the Comptroller's Office in cases
where LUMA holds the required information. Additionally, PREPA
asked LUMA to identify a point of contact within LUMA to discuss
viable alternatives for this process.

Mr. Juan Saca
July 22, 2025
Page 75 of 81
PO Box 42001, San Juan PR 00940-2001
19. June 21, 2022 - PREPA (J. Colón Ortiz-Exec. Dir.) Letter to P3A (Fermin
Fontanes, Executive Director) & FOMB (Alejandro Figueroa, Director) -
FY23 Budget
• Noncompliance by LUMA:
o LUMA failed to properly consolidate PREPA's Generation
Budget, instead submitting it as an exhibit without
consolidation, which PREPA views as a deceptive and
misleading representation.
o LUMA's proposed FY23 budget, including the HoldCo and
Generation budgets, does not comply with the
Transmission and Distribution (T&D) Operating and
Maintenance Agreement (OMA) requirement that expenses
must be adjusted to avoid a base rate increase.
o The consolidated budget proposed by LUMA exceeds the
2017 Rate Order revenue cap, making it noncompliant with
the applicable Rate Order.
o LUMA did not agree to additional scheduled budget
meetings following a courtesy meeting on March 3, 2022,
regarding the FY23 Generation Budget.
o By March 11, 2022, LUMA had not contacted PREPA to
request information necessary for PREPA to prepare the
FY23 Generation budget, despite the April 1, 2022, deadline
for consolidated budget submission.
o LUMA's initial revenue allocation proposal to PREPA on
March 17, 2022, suggested an approximate $54 million
reduction to PREPA's generation budget, which PREPA
contends ignored historical trends and the availability of
federal funds for generation purposes.

Mr. Juan Saca
July 22, 2025
Page 76 of 81
PO Box 42001, San Juan PR 00940-2001
o On March 31, 2022, LUMA submitted a counterproposal that
deviated from the 2017 Rate Order.
o The P3A's certification of LUMA's proposed FY23 Budget as
compliant with the Rate Order was impaired due to LUMA's
non-compliance with the T&D OMA, specifically the
requirement that LUMA submit a budget prepared and
delivered by PREPA to LUMA for consolidation.
o PREPA requests that the P3A reverse its certification of
LUMA's proposed FY23 budget.
o PREPA requests that the P3A coordinate a meeting to
review LUMA's proposed budget to ensure it responsibly
serves the needs of the electric system.
o No specific due dates for these requested actions are
mentioned in the source.
20.November 8, 2021 - PREPA (J. Colón Ortiz-Exec. Dir.) Letter to FOMB
(Alejandro Figueroa, Director) – PREPA Audited Financial Statements FY
2019
• Noncompliance: The source details noncompliance by PREPA, not
LUMA. PREPA was in a "pattern of noncompliance" regarding the
timely issuance of its financial statements. Specifically, PREPA
acknowledged that the proposed issuance date for the 2019
Financial Statement "does not comply with the timeline
established in Circular Letter No. 1300-33-21". PREPA received the
audited financial statements for FY 2018 on November 4, 2021.
Delays in completing the FY 2019 audit were attributed to PREPA
Management's efforts to prepare financial statements for previous
fiscal years (2015, 2016, 2017, and 2018) and for the PREPA
Employee Retirement System (2015, 2016, 2017, and 2018). Further
delays for the 2018 audit were attributed to internal quality control

Mr. Juan Saca
July 22, 2025
Page 77 of 81
PO Box 42001, San Juan PR 00940-2001
process issues and "external delays" from other financial
stakeholders, including the Treasury Department.
• Request for Information or Action: The sender (PREPA) did not
request specific information or action from the receiver (Financial
Oversight and Management Board) with a due date for the
receiver. Instead, the letter provides updates on PREPA's efforts
and projected timelines for its own deliverables, while also stating
a need for "constructive support":
o PREPA anticipated KPMG would issue the 2018 Audited
Financial Statement by the end of the week of October 7,
2021.
o An initial draft of the 2019 financial statements was
established to be submitted by October 31, 2021.
o The second draft of the 2019 Financial Statements was
scheduled for submission to the Treasury Department on
December 10, 2021.
o The projected issuance date for the 2019 financial
statements is January 31, 2022.
o PREPA committed to doing "everything possible to
accelerate the schedule" with "constructive support" from
the representatives of the Financial Oversight and
Management Board and KPMG to achieve the requested
milestones.
P3A require LUMA to (i) clear the open items required to complete the ﬁnancial
statements for FY 2023 audit items—including federal-revenue detail,
depreciation analysis, and GASB 68 schedules—within seven (7) calendar days, (iii)
deliver the outstanding historical revenue, accounts-receivable, and energy-loss
data demanded by the Comptroller for FY 2000-FY 2020 within ten (10) business
days, (ii) establish a permanent one-stop audit liaison, and (iii) bear any ﬁnes or

Mr. Juan Saca
July 22, 2025
Page 78 of 81
PO Box 42001, San Juan PR 00940-2001
penalties resulting from delayed production. PREPA/P3A escalate this issue under
Article 15.
VI. Notice of Technical Dispute: Pole Attachment
P3A, as Administrator of the T&D OMA, issues this Notice of Technical Dispute due
to LUMA’s ongoing failure to comply with its core billing and collection obligations
under the T&D OMA. Speciﬁcally, LUMA has refused to collect pole attachment
fees owed by third-party telecommunications and cable entities.
1. February 2, 2024-PREPA Letter to LUMA (President & CEO- J. Saca) –
Billing & Collection of Pole Attachment Fees
• PREPA stated that it received LUMA’s January 12, 2024, proposal to
split all pole (third-party) attachment fees, but states it is unable to
proceed as requested by LUMA.
• PREPA emphasized that based on the T&D OMA is that the
responsibility for collecting pole attachment fees owed to PREPA
by telecommunications and cable companies is exclusively
LUMA’s.
• PREPA stated that under the OMA, LUMA is solely responsible for
“all electric transmission, distribution, load serving, and related
activities for the safe and reliable operation and maintenance of
the T&D system.
• Section 5.3 of the OMA explicitly states LUMA’s responsibility to
“perform all billing and collection services for the T&D System by
the Contract Standards, including the requirements outlined in
Annex I (Scope of Services).
• Annex I, Section II(A) of the OMA further indicates LUMA (the
operator) is responsible for managing and maintaining all T&D
System assets, including billing and collection for pole attachment
fees.

Mr. Juan Saca
July 22, 2025
Page 79 of 81
PO Box 42001, San Juan PR 00940-2001
• PREPA further emphasized that it lacks the personnel,
infrastructure, or budget to assist LUMA in collecting delinquent
attachment fees.
2. May 21, 2024- PREPA Letter (J. Colón-Executive Director) to LUMA (-J.
Saca, President & CEO) Re: Assignment of Pole Attachment Billing to
HUB Advanced Networks, LLC
• PREPA notified LUMA that the billing and collection of PREPA’s
Pole Attachment fees for specific past due periods will be assigned
to HUB Advanced Networks, LLC.
• The past due periods assigned to HUB were July 2018-June 2019,
July 2019-June 2020, and July 2020-June 2021.
• PREPA emphasized to LUMA that it owns the electrical
infrastructure and poles and has designated HUB as its
representative to invoice all past due payments related to joint
pole attachment fees for PREPA’s infrastructure used by private
companies.
3. August 28, 2024-Resolution and Order-Case No. NEPR-MI-2019-0007;
Subject: Request for Extension of Time to Submit Updated Data
Template for Quarterly Reporting in Response to April 2024 Quarterly
Report
• The Resolution and Order took notice and granted LUMA the
extension of time it requested to submit its responses to ROIs,
until August 30, 2024.
• It includes as an attachment PREPA’s Motion in Compliance with
Resolution and Order of October 16, 2024, which:
o PREPA asserted that its financial liquidity is severely
impacted by LUMA’s inefficiencies in critical operational
areas, despite LUMA being compensated for these services.

Mr. Juan Saca
July 22, 2025
Page 80 of 81
PO Box 42001, San Juan PR 00940-2001
o PREPA argued that LUMA’s responsibility for collecting pole
attachment fees and other revenue streams is integral to
PREPA’s financial health, and LUMA’s refusal to
acknowledge this responsibility is a misinterpretation of the
T&D OMA, making LUMA’s business model “unsustainable”
and contributing to PREPA’s liquidity shortfall.
o PREPA highlighted LUMA's "deficient collection for power
services, collection and suspension of power service to
delinquent customers, collection of pole attachments fees,
among others," as well as issues with the administration of
federally funded T&D system capital projects.
o PREPA stated it has repeatedly alerted LUMA about its
inefficiencies and underperformance that negatively
impact its liquidity.
o PREPA explicitly noted a net negative liquidity impact of
over $550 million due to receiving less than expected in
FEMA reimbursements and WCA.
P3A insists that LUMA (i) assume immediate responsibility for billing and
collecting all pole-attachment charges, including delinquent balances for FY 2018-
FY 2021, and (ii) file within thirty (30) days a revised revenue-collection plan that
aligns with § 5.3 and Annex I of the OMA. PREPA/P3A commence Article 15
proceedings on this rate-related dispute.
Conclusion
The litany of failures cataloged above - federal-funding lapses, grid-crippling
outages, vegetation hazards, budget overruns, and stone-walled audits - has
pushed Puerto Rico’s patience to the breaking point. The P3A therefore invokes
Article 15’s dispute-resolution mechanism forthwith and puts LUMA on formal
notice: the Government of Puerto Rico will no longer subsidize incompetence or
excuse defiance. Puerto Ricans deserve a power-grid operator that keeps the

Mr. Juan Saca
July 22, 2025
Page 81 of 81
PO Box 42001, San Juan PR 00940-2001
lights on, respects public money, and obeys the terms and conditions of the
contract it signed.
Should LUMA fail to cure each breach during the Article 15 process, the P3A stands
ready to exercise the OMA’s ultimate remedy - early termination of the contract.
Upon an Operator Event of Default, including chronic non-performance and other
material violations as detailed herein, the P3 Authority is empowered under
Section 14.2 to declare LUMA in default, terminate the OMA, and recover all
damages while orchestrating an orderly, LUMA-funded transition to a qualified
successor operator. The P3A will not hesitate to pursue that remedy, together with
all attendant transition and recovery measures, to protect the public interest and
restore accountability to Puerto Rico’s energy system.
Cordially,
Josué A. Colón Ortiz
Executive Director
Annexes
c Francisco J. Domenech, Executive Director, AAFAF, fjdomenech@aaaf.pr.gov
Robert F. Mujica, Executive Director, FOMB, robert.mujica@promesa.gov
Mary C. Zapata Acosta, Executive Director, PREPA, mary.zapata@prepa.pr.gov
Ángel Rotger Sabat, Chief Legal Officer, LUMA, angel.rotger@lumapr.com
Francisco Prego, OMA Contract Management, LUMA, francisco.prego@lumapr.com
Alejandro J. Figueroa Ramírez, CRO, LUMA, alejandro.figueroara@lumapr.com
Lionel Santa, General Counsel, P3A; lionel.santa@p3..pr.gov

Carta de la Autoridad de las APP a LUMA Energy

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Carta de la Autoridad de las APP a LUMA Energy