A legal opinion dated November 28, 2022, prepared by the law firm Pietrantoni Méndez & Álvarez LLC for the Public-Private Partnerships Authority (AAPP), concluded that the extension of the "Interim Period" in LUMA Energy’s contract could be approved by a majority of the AAPP Board of Directors without being treated as a new transaction. The document analyzed whether extending the interim period required a process different from the one originally contemplated in the contract.
According to the opinion, the extension did not constitute a new transaction under Act 29 on Public-Private Partnerships, so a majority vote of the board’s members was enough to approve it. The existence of the document was made public by Telemundo journalist Rafael Lenín López, who posted images of the legal opinion on social media and raised its relevance to the controversy over the extension of the agreement with LUMA.
The matter is part of the court dispute over the validity of the decisions taken to extend the contract’s interim period, a controversy that has reached the Puerto Rico Supreme Court through cases CT-2025-0006 and CT-2025-0007.