Thanks Spence. This is from the Office of the Consumer Advocate (OCA), not the PUC staff itself (which would still only be advisory - the staff does not make decisions for the COmmissioners).
For those unfamiliar with PUC structure, OCA is an independent office charged with advocating for residential ratepayer interests (maybe commerial as well, but I think just the small folks). It would be very suprising for OCA to back a 1.5(ish) billion dollar PPA.
I would say that this position by OCA could have been guessed - with great accuracy - months ago. It is just now available for all to read. This doesn't mean it isn't (or is) legit - just means that it is one position (of many) that the PUC will need to consider as they make their decision.