2023 IRP Q&A: PNM Public Advisory Process

For Q&A associated with the Gridworks Facilitated Stakeholder Process, please click here or go to PNM.com/FSPQA.

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General
What do you mean when you say that PNM is one of the top companies in the U.S. for diversity? (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

Response: PNM

We mean diversity in terms of the diversity of employees, including minorities and women, especially in leadership.

Hydrogen gas turbines are not the solution for electricity generation, which needs to be done only by wind, water, sun, and some geothermal. We've waited so long for climate action, that we now need to actually move into World War II style deployment of wind and solar. And yet, we are not utilizing the wind that we have in eastern New Mexico. We need to make sure we're looking in the right direction and going as fast as we need to go because the generations after us deserve a sustainable planet. (Asked at May 25, 2022 meeting)
Asked by CSolPower on May 25, 2022. View meeting information here.

Initial Response: PNM

This comment speaks for itself. That said, E3 has done a lot of work on regionally integrated resources plans looking at how other utilities incorporate transmission planning; they may be able to give a broader perspective on other resource plans E3 has worked on and how transmission is done in other regions.

We're trying to do the best we can. It's just a very, very complicated way to do generic transmission and generic resource planning. You really need to have the specifics of locations and resources within an RFP.

Initial Response: E3

We would underscore that incorporating transmission planning into a resource plan is a tall task, not to say we shouldn't try to take steps forward to do a better job with it. Definitely, it is a challenge for the reasons PNM has laid out.

PNM continued.

Information on the different mixes of existing resources and the different types of resources included in the study are based on what the individual utilities provided. These are the resources the individual utilities found were the best mix to meet their obligations to their customers at a reasonable cost while also meeting their environmental constraints. In addition to what is economical, they considered what's available within their jurisdictions and what their forecasts are.

E3 continued.

The mix ends up looking a little bit different for each utility, although almost every utility has a large portion of new solar and storage built into their future plan. Each also has opportunities to build in resources like wind, geothermal, and natural gas, and demand response. This covers the big picture.

Is there any excess generation available for use, like that sold in the market, for example? (Asked at May 25, 2022 meeting)
Asked by a member of the public on May 25, 2022. View meeting information here.

Response: E3

This slide is largely focused on the availability perspective.

This is a summer peak day, a day when the region as a whole is probably relying on the resources it needs at maximum capability in order to meet its needs.

There would be many other times throughout the rest of the year when loads are lower, when there would be an available surplus of energy or even energy that utilities want to be able to sell into the market to avoid, for example, renewable curtailment.

But that's just not the picture we see on the summer peak day.

Also, even as the region comes to rely more and more heavily on this combination of solar and storage to meet its summer peaking needs, you do still have remaining firm resource needs. Given this amount of solar, storage, wind, demand response, and hydro that is built into the utilities’ portfolios, there is still a pretty significant need for firm resources, including any flavor of nuclear, coal, or natural gas that can be dispatched on demand and for sustained periods of time.

And we see that being true through 2033. A common finding that we've seen in all of our work, even as we push the envelope even further: Some form of firm capacity will be needed to maintain reliability, even as the grid approaches 100%, or really ambitious targets for renewable or carbon free resource integration.

Looking at the different utilities’ plans for what is coming on online, there is still way too much natural gas and not enough wind. So, is this study based on what has been in previous plans, and not the reality of addressing climate change? (Asked at May 25, 2022 meeting)
Asked by a CSolPower on May 25, 2022. View meeting information here.

Response: E3

The study represents the utilities’ current or previous resource plans, including the capacity of different resources. Here, you're looking the amount of installed capacity within the portfolios, which is a different picture from the amount of energy that these resources generate over the course of a year—something more directly linked to the sort of climate impact that any one of these portfolios might have.

Regarding an earlier question about the dispatch of energy storage and its treatment in the study, an important qualification for this entire exercise is that E3 modelled the southwest as a whole, requiring us in a study like this to make certain assumptions as to how effectively each of the utilities can share its pool of resources with others, especially as the grid enters into more tight conditions.

And so, what this analysis represents is essentially, in some respects, an optimistic perspective on how the total portfolio of resources within the region could support the total needs of the region. The reality of our world today, however, is that we're not perfectly in a fully optimized market, and it is the domain of each utility to assess its own loads, resources, and exposure to the market under loss of load conditions.

So, looking at this on a utility-by-utility basis, you might end up with slightly different answers than we found in this study, but we believe our general findings are valid.

Is the availability for 2033 64,000 megawatts? (Asked at May 25, 2022 meeting)

Asked by CSolPower on May 25, 2022. View meeting information here.
Response: E3

Yes. That's a figure that's definitely in our technical report.

On the previous question around transmission, because this is a regional study, we didn't include a very detailed representation of internal transmission constraints within the system. So that's another reason that you might think of this as a slightly optimistic view as to the ability of the region as a whole to collectively share its resources to meet the region's needs.

Here (Slide 27) is what the system looks like from the different perspectives of installed capacity, effective capacity, and annual generation.

These are three different ways to think about various aspects of a system.

On the far left of this graph, you see the total installed capacity of the different types of resources across the different scenarios. There is expansion by 2033, in our IRP scenarios, up to close to 60,000 megawatts of capacity. Again, most of that new capacity coming from renewables and energy storage.

In the middle panel, we take that installed capacity, and translate it into effective capacity, or ELCC capacity. This is essentially where we've tried to take those installed capacity numbers for every resource in the system and direct them, based on LLP modeling, to account for what those resources provide to the system, when it's truly constrained, when it truly needs it most. And here you can see that the corresponding bars for the renewables in the storage have actually shrunk quite a bit. What this reflects is the implicit limits on these resources and their contributions to resource adequacy due to variability and duration limits. And in a comparative sense, the remaining firm resources like coal and natural gas get a much smaller haircut on an ELCC basis.

But the picture on the far right is the one that's perhaps the most relevant for the questions around climate and clean energy. That is the question of an annual basis over the course of the entire year: How much of energy is being supplied by these various types of resources? And so, this is a transition that we see occurring.

Given this portfolio of resources. If you look today across the region, we're probably at 35% by 2026 carbon free energy. By the time this transition to this specific portfolio occurs by 2033, you'd have approximately 70% carbon free energy in the system that is coming largely from a mix of nuclear, solar, and wind resources.

Right now, PNM is a little bit ahead of that curve on the energy mix for our portfolio. We're about 50% carbon free right now and expect to be ahead of the curve for the overall region going forward.

We're a water shortage region. How has that come into planning? (Asked at May 25, 2022 meeting)
Asked by a member of the public on May 25, 2022. View meeting information here.

Initial Response: E3

It affects the planning in a number of respects, some of which are not taken into account directly within our study, and some of which are, certainly, as water becomes more and more constrained within the region. And that may have impacts on economic growth within the region. That's something that you would expect to see show up within utilities’ load forecasts--their expectations for future economic growth.

We've taken previous load forecast from utilities at face value, so we haven't made any assessment or judgment as to how water use within the region might impact those forecasts. But we think that is something that we would expect utilities within the region to be thinking about.

On the supply side, the risk of drought is something that we did try to think about and factor directly into this work. Essentially, within a model like this loss of load probability model, we have some representation of how much energy is available from the region's hydro resources. And the amount of energy that's available, you can imagine, is a function of what the underlying hydro conditions are.

What we tried to do, and this is based on input that we've gotten directly from the Western Area Power Administration and the Bureau of Reclamation, is characterize the relative risk of severity of drought in a probabilistic way, such that there's some probability in our model that you end up in a really critical hydro situation that reduces the value of the region's hydro resources. In some cases, you may be in a more normal condition on a relative basis, and you have a little bit more capability. So, on the supply side, that’s how we would expect that to come into play.

Initial Response: PNM

From PNM’s perspective, looking at the resource plans that were in our 2020 IRP and the types of resources we're looking at now—and this is pretty true broadly across the West—the new resources that are coming on board are much lower water use resources than the resources that are being retired. So, when you think about coal plants have steam boilers being retired and replaced with solar storage, maybe aeroderivative, and natural gas turbines that run very infrequently and that don't require much water, the net water usage for electrical power generation is significantly decreasing, say, for any entity building a pumped hydro plant or something like that.

Once the record peak is final, will PNM be breaking down the generation source contributions that were used to meet the peak: For example, what came from San Juan? What came from natural gas generation? What came from solar? What came from wind? (Asked at July 27, 2022 meeting)
Asked by NM RETA on July 27, 2022. View meeting information here.

Initial Response: PNM

We can certainly take that [question] back. It's not something that we have done in the past. We can certainly take that back and see if it's something that we can go ahead and include in a presentation going forward. That does remind me there was a previous question about presenting historic peak information. We do have a filing we make every year--it's our Case 3137 filing. It shows a load and resource balance, including a forecast for peak each year. So, we will post a summary of that.

We would note that there are differences in the way resources are accounted for as well as the contributions of different resources over time, as folks have probably gathered from previous presentations on ELCC [Effective Load Carrying Capability] that resources will change as a function of both system conditions and the penetration level of given resources on the system, as well. In the last IRP we move from installed capacity accounting for thermal resources to force capacity accounting. So, you'll see some differences in the way the numbers are represented. Take that into account.

You can also go to the [Public Regulation] Commission's website to search for the Case 3137 and pull out those filings we make each year to take a look at what the loads and resources tables are showing.

PNM Update:













As cost allocation will change, is some change in tax structure expected to make up for the government revenues that will be lost as we use less fossil fuels? (Asked at December 15, 2022 meeting)
Asked by a member of the public on December 15, 2022. View meeting information here.
Response: PNM

Setting aside things like gas taxes for vehicles and things like that, if you're talking about all electric fleet, that's a bit aside from what we would do here at PNM. The PNM customers at least pay a gross receipts tax on their electric bills, so that would be applicable to our total revenue requirements.

As long as we're recovering our overall revenues, if any individual customer reduces or changes their usage patterns to optimize their costs, that would change the gross receipts taxes to the State of New Mexico a little bit. That's something that needs to be kept in mind as to how the legislature is going to look at what their revenue needs are going to be relative to the overall gross revenues collected by all the different businesses throughout the State.

Grid Modernization
As we expand residential commercial batteries through powerwalls or charging automobiles, we need to be assured that those facilities have capabilities that maximize the utilities [available to the public], not the company. For instance, we could have greater reliability through some system that allowed PNM to utilize the capacity when it's not really needed by the resident, but there has to be some kind of relationship with manufacturers or some requirements that, if you have a powerwall, it has to have at least these kinds of capabilities. Is anything like that happening, and how do we make sure it’s not an advertising gimmick for [electric] automobile manufacturers ? (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

Response: PNM

There's a lot happening in this area: How are we thinking about how the system will interact with customer owned storage or other devices? Or are there other ways that the utility can partner with customers to ensure that they are as involved as possible with the transition towards carbon free?

So, you might have seen some commercials out there—of a truck that can plug into the house and can light the house in the event there's a distribution outage. So, there are two-way chargers that are going to be available to allow an electric vehicle to charge or discharge back.

You can also have behind the meter storage. Some of the questions to consider:

If a customer is paying for behind the meter storage, they may want to use that to optimize the benefits from that against their utility bill, and that may not be the best thing for the system.

Or does PNM then open up programs—something we are looking at—where we could either incentivize a customer to sell us the ability to utilize, say, 50% of their battery for the benefit of the system.

Or could there be utility programs where the utility does something, to start doing more distributed energy resources that may or may not be utility owned, but we can then manage and figure out the proper incentive mechanisms to ensure that we can operate those for the benefit of the system -- and not necessarily focusing on tariff optimization.

We have a completely above the board approach as we are going into this transition. We are considering AMI [Advanced Metering Infrastructure] and grid modernization (grid mod) as well as distributed energy management resource systems.

I appreciate that [one car company] is doing that. How do we make it a requirement so it's not an advertising gimmick but something real that can benefit the country? (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

Response: PNM

PNM has had discussions with big name automobile manufacturers about pilot programs in terms of dedicating a fleet of vehicles to using two-way chargers to look like a large battery from the utility’s point of view. If we go back three or four years, the biggest hesitancy from the automobile manufacturers was on the warranties of the batteries; they're starting to get over those trepidations.

What sub-populations of the PNM customer base are going to be impacted and in what order? How do we keep that in balance, both for the system and as we have more distributed generation? How does that change the role of the grid and other factors? (Asked at April 28, 2022 meeting)

Asked by a member of the public on April 28, 2022. View meeting information here.

Response: PNM

If we're thinking about this from the reliability perspective, there are probably things that we can do with distributed resources. That would mean considering micro grids or things we could do to prop up specific areas of the distribution system to be a bit more resilient and reliable. There are things going on right now like that--maybe at the edge of a feeder or something similar.

We will do our best to cover this issue in this IRP process.

Regarding the IRP, we're looking at things from a bulk transmission level. So, we're not seeing any individual distribution feeders. We have to understand what the aggregate effect of all of the distribution and distributed energy resources are and incorporate those.

If it turns out that sometime down the road that it becomes obvious that the system needs to be more bi-directional, will you be looking into the costs associated with that? (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

Response: PNM

If you mean allowing enough feeder capacity and reverse flow to come from the distribution behind the meter side back onto the PNM system, that's certainly a problem we're facing right now. There are some feeders that are getting to the point where they can't support any additional behind the meter solar.

There are ways we can deal with these issues, and PNM’s distribution planning department is working on the ability to add storage or other things to try to alleviate some of those constraints. All options [are] on the table, and the grid modernization and distribution planning groups are working on say, if they're exporting that much power, how do we then examine that from the bulk transmission level?

Update: PNM

See slides from Grid Modernization meeting held October 17, 2022.

The IRP process could benefit from a technical session discussing retail rate design. What kind of rate designs would be enabled by AMI? (Asked at April 28, 2022 meeting)
Asked by Sandia National Laboratories on April 28, 2022. View meeting information here.

Initial Response: PNM

We are allowed to talk about rate design in the IRP process, and we did in the 2020 IRP, with a load forecast scenario that looked at very aggressive time of use pricing rates and showed what the anticipated impact to our load forecast would be based off of that time of use rate shift that would make requiring AMI to implement that type of behavior likely.

Going a step further, ‘How are we going to look at the rate designs for electric vehicles?’ Considering perhaps a super off-peak rate during high solar production to influence when electric vehicles will be charged is certainly something that we should be considering.

One of PNM’s requirements, going forward, starting next year, is to show that we are serving our customers with an averaged carbon intensity of 400 pounds per megawatt hour or less over the course of the year; that goes from 2023 through 2031, and then drops to 200 pounds or less in 2032.

And so, one of the key things that we learned in this last planning cycle is when you get to 2032, when you have that step down from 400 pounds to 200 pounds, it's really about decarbonizing the off-peak hours. And if you're not incentivizing electric vehicles to be charging when the sun is shining, you’ve got additional solar. It creates a much larger problem to try to decarbonize the off peak if you're adding load in the long peak.

Update: PNM

See slides from December 15 meeting for discussion of future rate design.

As you put more and more individual storage units into a gateway system that gets smarter and smarter, could you use artificial intelligence to program a group of gateways to manage the system on a real-time basis and not worry about we'll take from person A, B, or C? Artificial intelligence will do it fast. (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

Response: PNM

We will need to see some greater advancements in the control systems for energy storage: the ability to make sense of all the simultaneous decisions that could be made. There are over a dozen different use cases for energy storage in terms of different values that they can provide. And trying to figure out which is the right one, in the moment, is something we doubt humans can do. We're going to have to make sure that we've got algorithms that can do it and in a very intelligent way.

Can the system be more robust in an extreme weather event? (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

Response: PNM

The specific concern raised about the 2020 IRP was that some thought that the load forecast by the time we got out to 2040 was wrong. We had a lot of different load forecast scenarios. Granted, the further out in time you go, the more uncertain forecasts are. We think we're using industry best standard practices for load forecasting, but we can have a conversation about it.

We are scheduling a technical session with PNM’s load forecasting group to discuss all the parameters, and, if there's a different load forecast scenario that needs to be considered, we can have them generate one and run it through the portfolio model.

Another topic that was raised in 2020 was renewable resource cost development. Perhaps folks didn’t understand exactly how we develop renewable resource cost assumptions. We can go through in detail what we did and if there are alternative methods. Something else might be more appropriate, so let's figure that out.

And the same thing would go for other candidate: resource technologies. We recently issued two requests for information (RFIs). We did one very similar to what we did at the outset of the last planning cycle, where we were asking for new and emerging technologies to look at things that would help us to decarbonize the system. There are no limits on whether it has to be a utility or supply side resource or demand, right demand side resource, or distributed energy resource. We're hoping to see the whole kit and caboodle in terms of the amount of information that we receive.

We also recognize that there are some technologies that take a long time to develop. In the last planning cycle, there were two or three long duration storage projects that typically take five to 10 years or longer to be developed. And so, we put out a second RFI to try to get more specific information about not just general technologies, but also specific projects that may have long lead times. The RFIs are due June 15 and respondents’ updates by September 15.

The deadlines for the RFIs correspond to when we want to bring the responses back to our stakeholders to discuss these different technologies and resources, and how we can incorporate them into our modeling protocols, making sure that we have the ability to run them as resources for load serving requirements in our model when we start doing the full scenario analyses in the September-October timeframe.

The long duration storage RFI and also hydrogen resource modeling were some issues that raised in the 2020 IRP comments, so we'll want to discuss those. We've been doing some additional testing and modeling -- R&D -- within our own groups. We can talk about that as well as general ways these things are modeled if there are other assumptions about them. For example, one question was about how much water does it take to make hydrogen and does PNM have access that kind of water.

Distributed resource modeling is on our list for discussion as well. We want to make sure we talk about that as much as we can but, again, that one gets a little bit tricky because the IRP is at the bulk system level, not at the individual feeder level. But we do have to make sure we can figure out how we account for all of those DRs when we are designing a least cost plan.

Regarding scenario tree development, I was explicitly thinking about the Four Corners Power Plant Thinking about the different scenarios and sensitivities that we're going to need to run, how are we going to model the existing resources? What were we doing with our existing resources? Is that the best use of them or the most appropriate way to consider the existing system?

The IRP process should discuss the electrification of vehicles and how [residential battery storage might work beyond individual household use.] (Asked at May 25, 2022 meeting)
Asked by CSolPower on May 25, 2022. View meeting information here.

Initial Response: PNM

We will absolutely incorporate this idea into PNM’s grid mod plans--more customer participation, communications equipment, or real time, smart meters and smart chargers, for example—so that residents don't just return home from work or errands, plug in their cars, and start charging at the wrong time of the day.

Most people have smartphones now that charge slowly overnight but charge really quickly at other times. We can use these same types of functions for electric vehicles, where perhaps a commercial entity with a fleet of electric vehicles would have a charging infrastructure and use it as a battery, as needed, for the entire grid. We must figure out how to price that type of program and decide the kinds of incentives to put in place.

If you're trying to figure out how to decarbonize the entire economy, it might start with the electric sector. Once you get the electric sector emissions down pretty low, you've still got a lot of emissions coming from transportation and natural gas for heating homes, for example. And once you get emissions out of the electric sector, you've got to replace those other forms with electric cars and other such things.

We will discuss this issue at the upcoming Grid Modernization meeting.

Also, we will cover load assumptions regarding electric vehicle adoptions in the Load Forecast presentation.

Update: PNM

See slides covering Grid Modernization (presented at the meeting held October 17, 2022), and the Load Forecast (presented at the meeting held December 15, 2022).

How do we anticipate moving to off grid? Are people putting their own batteries onto their own solar systems and how will they interact with the grid? How does that in the long term, or even the near term, impact what we're doing here? (Asked at May 25, 2022 meeting)
Asked by a member of the public on May 25, 2022. View meeting information here.

Initial Response: E3

We definitely are seeing a trend within the industry towards customers who choose to put solar on their rooftops are also beginning to choose, in some cases, to pair or co-locate battery storage behind the meter. To some extent, when it comes to resource adequacy or reliability, that behind the meter storage might be seen as somewhat of a substitute for the grid scale storage, in the sense that its technical capabilities are aligned or more similar to what a grid scale battery would give you.

That may be technically true, but it may also be optimistic in the sense that it would rely on that customer to use their battery in such a way that's completely aligned with the utility’s needs. And what we'll often see is that customers do choose to use their batteries in ways that are more consistent with the price signals they receive through their tariff or their rates.

So, in that sense, as the portion of storage that's behind the meter continues to grow, there's maybe a need, if we want to get as much value out of those storage resources as possible for society as a whole, to ensure that tariffs and rates are well aligned with utilities’ needs and encourage the right types of behavior when it comes to how those resources are operated behind the meter.

Initial Response: PNM

The way that we would need to look at the distributed resource additions is that they can take the place of some utility scale resources, so long as the utility is able to manage those resources through a distributed energy management system, or otherwise send out completely aligned price signals with the current state of the system. If you've got real time pricing, or advanced metering infrastructure, customers know exactly what's going on with a system’s prices, as opposed to legacy block rates that don't necessarily align price at a specific moment in time with the way the system is being operated.

If you can align the way that the distributive energy resources would work in conjunction with the rest of the system, they can take the place of some of those utility scale resources that are part of our grid mod discussions.

You could see it in the form of micro grids, or in a number of different ways. But getting customers to participate and act in a way that's beneficial for the system, not just beneficial for themselves, is the key to ensuring that the distributed resources are really taking the place of some of the utility investment.

Perhaps it will be utility incentives, or utility programs that customers can take part in in order to participate that way. But there are a lot of mechanisms we could consider but we will have to align the customer incentive and customer behavior with the utility system’s perspective to ensure whatever mechanism works.

Will PNM consider scenarios for electrification of the economy beyond cars by 2040? (Asked at June 8, 2022 meeting)
Asked by a member of the public on June 8, 2022. View meeting information here.

Initial Response: PNM

Yes. Different load forecast scenarios will be part of the July 6 presentation.

In the 2020 IRP, along with looking at increased penetration of electric vehicles, we also did some load forecast work on increased adoption of building electrification. In this IRP, we've also been doing some work in terms of modeling. We did hydrogen last year, and we did it in a simplified way, where we assumed a hydrogen economy.

An alternative is modeling electrolysers [hydrogen generators] themselves, the loads that they would add, and, of course, producing hydrogen. You are going to have electric loads associated, though, so we are modeling those more explicitly.

We also want to do even more rapid transition towards building electrification, if we assume that everything has to be electrified by 2043, or 2042, which is going to be year 20 of this IRP.

We will be doing transportation electrification, at least three different scenarios or sensitivities, in terms of the load forecast, and how it would be affected by electric vehicle charging. We will also have the building electrification scenario or sensitivity. And if there are other things stakeholders want to consider, then, absolutely, we can figure out how to work them into the IRP.

Update: PNM

See July 6 presentation and December 15 presentation for load forecast topics.

As we get distributed generation coming on in small pocket areas or micro grids, what happens when you have little pockets spread throughout the system? How do we get that to feed back into the system? How do we begin to understand that? What are some of the factors we should be looking for or where we should be looking for data when we may not have much of it in the PNM service area? (Asked at June 8, 2022 meeting)
Asked by a member of the public on June 8, 2022. View meeting information here.
Initial Response: PNM

We will explore this topic under grid modernization, and PNM’s distribution planning team will also present some of their ideas on distributed resource management at an upcoming meeting.

Some of this planning will also come down to how the interconnection processes. What makes the most sense? For example, if something is behind the meter, or you have a smart inverter that is never going to be exporting back onto the grid and is just covering the load that's behind the meter there, you don't have to go through a FERC work desk interconnection process, as you would if you were actually exporting back onto the grid.

So, depending on the penetration levels of those distributed resources, as well as how you might be able to integrate everything back up into a centralized, distributed energy management resource system, you may not actually want a lot of counterflow back into the system. So that's another piece we encounter now; it's probably because of net metering rates.

So, the systems are oversized to dump power back onto the grid. But in the future, you might want to look at more as well: The resources behind the meter should be really just serving the load behind the meter.

These are important things to keep an eye on. How can we begin to formulate AMI ideas about how best to work together?

The distributed energy piece is going to be a big one, and we see distributed resources growing. There is no denying that. It makes sense to ensure that distributed resources are done in a way that maximizes the value to the system and that the system stays resilient and provides the value to the folks who are spending the money on it.

We are discussing this internally in PNM and are trying to figure out the best way forward. Some of this planning will be in a PNM grid modernization filing later this year.

Update: PNM

Also see slides covering Grid Modernization (presented at the meeting held October 17, 2022).

Please say a little bit more about distributed storage. Did you mean on the utility side of the meter? Or did you mean customer-owned and controlled storage? (Asked at July 6, 2022 meeting)

Asked by WRA on July 6, 2022. View meeting information here.

Response: PNM

This is something that we'll dive into much more detail in a future meeting--probably along the lines of grid modernization (grid mod) and distributed resources. It's both. As we move the system forward, if we want to get to the fully decarbonized system, unleash the power of our customers, and make sure we're doing everything we can to move this forward, there's going to have to be incentives for behind the meter, customer-owned storage.

Having those incentives right and having those hooked into a distributed energy resource management system, so that the utility operators are actually the ones who can control that storage to some degree is important because the more we align the operation of behind the meter resources with the system requirements--and not individual customer requirements--the more those resources can offset the larger utility scale transmission side and resources.

We're also going to need to have utility-owned distributed source storage on our side of the meter at different places, depending on the location and the customers. There may be advantages to the utility owning and having it on its side of the meter versus on the customer side. It may be both. There is also going to have to be utility scale storage; you're going to have to have it in the load pocket; and you're going to have to have it out near resources.

We envision this as using storage as the way to manage the dispatch of the system to manage reliability and to manage the efficient use of the transmission and distribution system. There's going to be so much storage on there and so many different components of it, that it's all going to have to be worked into computer algorithms--using AI and other things to make sure that we're able to manage this all--in real time.

We don't think you want to count out any of those options. We need them all in order to make sure that we can manage the system reliably and cost effectively and move the decarbonization path forward. We can't eliminate any of our options right now.

Does the solar implementation assume that there is adequate feeder capacity, smart meters, etc., to allow the proposed residential solar projects to be built? (Asked at July 6, 2022 meeting)
Asked by NMPRC on July 6, 2022. View meeting information here.

Response: PNM

Yes, if everything could be interconnected, efficiently, and if we can alleviate the constraints. Our PNM subject matter experts who developed the forecast will do a presentation on it.

If there are things that need to be done to the interconnection process that can be overcome, we will need smart meters--as more and more of distributed resources are added, we will have to have a view into the edge of the system right up into the customer points. With smart meters with AMI we will be able to manage renewable production and customer usage by each individual meter.

In order to make sure that our operators are able to manage the system effectively, they can't be blind to what's going on behind the customer meter. They have to be able to see that, especially, if this adoption rate is what we see materialize, it would represent approximately 1250 megawatts.

Right now, we're a 2000-megawatt system, and if we have approximately half of the resources of the system behind the meter our operators will have to have visibility in real time to make sure they can operate the system.

What is GHG? (Asked at October 17, 2022 meeting)
Asked by a Member of the Public on October 17, 2022. View meeting information here.

Response: PNM

That's greenhouse gas. So, we're talking about how we are trying to empower customers to take more control over what their greenhouse gas footprint would be. And that could be from putting more rooftop solar or storage directly on their side of the meter, or it could be enabling additional reductions in their greenhouse gas footprint by allowing for more electric vehicle infrastructure and a number of other things-- just controlling their overall energy consumption in a way that's more beneficial for the system through getting additional real time information from the advanced metering infrastructure and other such things.

A recent study shows that 97% of AMI (Automated Metering Interface) value is failing to meet its promises and there's a cite to a Utility Dive article. Is PNM proposing anything here that is different than 78% of utility customers that already have AMI meters? (Asked at October 17, 2022 meeting)
Asked by InterWest Energy Alliance on October 17, 2022. View meeting information here.

Initial Response: PNM

We will get back to you on that. We're not sure exactly how these other 78% of utility customers are doing AMI or things of that nature. We will say that AMI is going to give us more information and it’s the way we utilize that information that's going to be important.

For example, time of use rates or time of day rates are a tool in the toolkit. It's not a silver bullet that's going to magically cause customers to change their behavior and completely overhaul the entire system in a more efficient way. We know that, typically, electric usage is relatively inelastic. So, a lot of the efforts also must be done through education and other such things.

PNM Public policy/legal continued.

We're not early adopters. Obviously, nowadays, there are a lot of other states that have already done this, and we have the advantage of learning from some of what they've done. Our consultants have had years of experience, as well as experience working with DOE to develop some of their standards and their planning.

We at least have some ability to reflect on what has not been done well, and make sure that we're incorporating best practices, which we think we've done in our robust plan.

PNM continued.

We'll have a look at all of the things that are typed in the chat window [during this session] and will take a look at that article. We don't think we can compare and contrast PNM’s plan going forward to what other utilities that have already put AMI out there have done or failed to do.


The grid mod statute includes a requirement to consider whether grid mod applications are, “designed to support connection of New Mexico electrical grid into regional energy markets and increased New Mexico capability to supply regional energy needs through export of clean and renewable electricity,” [according to] MNSA 62-8-13B2. How will PNMs plan comply with this requirement? (Asked at October 17, 2022 meeting)
Asked by InterWest Energy Alliance on October 17, 2022. View meeting information here.

Initial Response: PNM Public policy/legal

Our grid modernization application focuses on the distribution side, but we do recognize that that is one of the aspects that the Commission can consider. That's in the statute.

Our testimony in particular does address that piece of it: it discusses what our current efforts are with regard to regional transmission discussions. When we were discussing the merger, which is not part of this discussion, but we as a company did make a commitment to have discussions with our regional partners to try to join or have discussions about some kind of a regional transmission organization.

So that's still something that we have been keeping informed about. We have participated in some regional meetings in Colorado related to regional efforts.

So even though this particular project or plan doesn't include transmission upgrades--it is focused on distribution--the RTO (Regional Transmission Organization) discussion is still part of what our overall efforts are as a company. We have also addressed it in our testimony in the application.

PNM continued.

We are currently actively involved in a number of different efforts exploring various regional transmission, organization, market design, things of that nature. In particular, PNM is participating in what's known as WMEG (Western Market Exploratory Group). Nick Philips, head of IRP, is chairing the subcommittee on resource adequacy and generation investment. There are other committees on market design and things of that nature.

Most of those efforts are looking at how you would implement a regional transmission organization or a more centralized market structure in the West but with a focus on sometime in the 2030 decade. These things are not going to happen overnight. They're going to take time.

PNM is one of the smaller utilities out there. In fact, we're either the smallest big utility or the biggest small utility. And these types of organizational shifts in the West are going to have to be led by some of the larger organizations. PNM can't make it happen by itself.

There are a few different things to think about. One, there's the Western resource adequacy program or WRAP that's looking at trying to do some more concentrated efforts around resource adequacy planning among Western members. The effects of that could flow into a couple of different market-based designs. One is the enhanced day ahead market or EDM, done through the California ISO. That will be available to EDM participants to do day ahead market scheduling for energy - that's not capacity. There's also an SPP (Southwestern Power Pool) West being designed.

And again, all of these are pretty well in their infancy stages and they're going to take time to develop. And it's going to have to be a look at where each and every one of these potential entities in the West would want to go.

There are over 30 different members exploring the potential market structures through WMEG. But again, the timeline really is focused on what could be done to deliver a market potentially sometime in the 2030 decade.


Will the current grid need to be enlarged--or will distributed energy resources be reduced--or at least keep it at its current size? (Asked at October 17, 2022 meeting)
Asked by a Member of the Public on October 17, 2022. View meeting information here.

Initial Response: PNM

So, the overall size of the system that we would need in order to serve our customers reliably, just thinking about the amount of, let's call it, nameplate capacity that we'll have on our system to meet our renewable energy requirements, decarbonize the system, and keep the system operational from a reliability point of view, we're going to need to see somewhere in the neighborhood of maybe four to six times the amount of nameplate capacity of resources relative to our peak load.

Right now, we're a 2,000-ish megawatt system. We actually hit a new all-time retail peak back on July 19 of this year: 2,071 megawatts. We have just a little over 4,000 megawatts of total resources right now to serve our system reliably. That includes a reserve margin, of course. But as we go further down the decarbonization path, with renewable resources, you can't always expect 100% of their output, especially not when you need it.

A solar facility, as an example, might give you across the course of the year 32% of its nameplate rating in terms of annual energy production, or what's known as capacity factor-- wind resources are maybe a little bit higher than that, depending on where they're sited. But compare that to, say, historically a nuclear plant or a coal plant or something that you can just turn on and run at full output, virtually for all hours of the year, you're going to get a lot less energy out of some of these renewable resources. You're going to have to have a lot more of them in order to meet the renewable energy requirements. Then we're going to have to have a lot more other resources in order to balance the system in terms of storage or other flexible generation to make sure that we can dispatch the system in a reliable way.

Going forward, we're going to need to have something in the neighborhood of four to six times the amount of total nameplate megawatts on the system to meet our capacity and energy requirements.

Now, it's not to say it is all going to be utility scale or utility sited. The more that's done on the distributed level--reduce requirements or utility scale operations, so long as they're able to be dispatched by the utility or they can be integrated in the system in an efficient way.

And that gets down to what we discussed earlier in the presentation on the distributed energy resource management system.

We're also going to think about increasing the amount of transmission that's available potentially, in order to deliver those resources or siting storage in a way to make use of the existing transmission system more efficient and start thinking about potentially energy only deliveries. We do have enough transmission capacity to deliver resources to load under N-1contingency conditions right now and serve our system reliably. But that means you may have to think about the way you deliver resources a little bit differently. We don't need to deliver every single megawatt of renewables as they're produced if we can store them and deliver them at different points in time when we need them.

Now, that's just talking about kind of planning 101.

When we start getting more into the resiliency aspect of things, as we have talked a little bit at a previous presentation about a supply side resiliency study that PNM does, one of the big takeaways there was if we want to take for example, the 200 megawatts of Four Corners out of the portfolio, and we wanted to replace that with an all renewable storage portfolio, we could do that under traditional reliability planning, by using a combination of 100 megawatts of four-hour storage, 50 megawatts of two-hour storage, and about 100 megawatts of solar resources.

But when we looked at that under some extreme weather scenarios and looked at how the system would perform under outage analysis, if outages were to occur, what we saw was that short duration storage plus renewable portfolio performed much different than a firm dispatchable type portfolio.

And if we want to align the characteristics, not just on a frequency of outage bases, but also on a magnitude of outage basis, the durations of those storage devices would have to be increased from two- and four-hour to 14- and 16-hour storage. So, significant increases on the overall dispatch.

And you can think about that in terms of the overall megawatt hours of storage that we would need on the system to make sure that we're able to respond to outages in a certain way.

So, it's not to say that you have to just add duration, you can also add power electronics and increase the capacity, both the charging and discharging rate, so long as you're adding that amount of volume of stored energy. But we're going to have to add more and more resources to make sure that we can provide the same characteristics of our traditional system and just take the carbon out of it.

To get back my initial point, four to six times the amount of nameplate is probably the minimum. You might see it has to be more than that. And it's going to have to be done in concert with distributed energy resources, taking those into account, looking at how we deliver resources, both the distribution and the transmission level, and how we're going to intelligently site storage to maximize the efficiency of the system, both of the transmission and the distribution level integrated from customers through distributed energy resource management systems. And looking at the supply resiliency side of it as well.

PNM Distribution continued.

What we like to think about in our distribution team is the deployment of these technologies that's in grid mod, and really where we're going with the integration of more renewables into the system, it's all about data, and then it's managing energy flow in two directions.

And so, if we have the data, we're able to optimize the design. And when we can optimize the design, then that is really taking the resource to its optimum level, and then at that point, we will have to add additional, maybe it's transmission, maybe its distribution substation, just depends on how the growth is occurring. And really, what's driving a lot of the transformation is growth.

And the other piece of this--the name of the game--is location is critical. So, where those energy resources are located, where the customer is located for the new load - that drives the resources or the additions to the system that may be required or not required, depending on what we can, if we can site energy storage or site resources near load.

PNM continued.

And then how efficiently that load utilizes the system is important as well. So, we think about the additional transportation electrification load or additional building electrification load, all those things that go towards decarbonizing the full economy.

We want to incentivize those loads to appear on the system at times where they're not going to add to the stress of the system.

So, if we can have charging loads, for example, occur during the middle of the day when solar output is at maximum, and we might be either in a position where we're having to curtail, sell off system, or store that energy, and it can be utilized by electrification loads, that's not necessarily going to add additional resources to the system. It's using the existing resources more efficiently.

But if people are coming home and charging their electric vehicles at times where we're already trying to manage a net peak load that could require us to add additional resources in order to make sure we can serve that load reliably.

So, there's, how efficiently the loads are utilizing the system, how are we incentivizing customers to participate in the right ways? We want to make sure that we're allowing all of this to happen. This brings to mind the adage that the utility industry is 5% of GDP but it's the first 5%.

In order to do all those things going forward that we want to do to decarbonize the entire economy--transportation, electrification, more building electrification--taking carbon everywhere else out, we have to have a strong and reliable utility in order to deliver the carbon free energy that we're going to be producing going forward to our customers and allowing them to utilize that throughout the rest of the economy to further decarbonize other sectors.


How will the proposed system ensure operations in situations when the grid or advanced system goes down, as in a storm situation? (Asked at October 17, 2022 meeting)
Asked by a Member of the Public on October 17, 2022. View meeting information here.

Initial Response: PNM Distribution

Let's remember that today, if we have an outage, the way that our operations center knows of the outage is when customers call in; we don't have visibility to an individual customer. So maybe the first advancement with AMI (Advance Metering Interface) is that we will have real time energy information and we'll know if we have outages at a customer level.

So then, if we look at the blue chevrons right in the middle of the screen (Slide 11), there's a long bar there that runs from year two to year six; it's a distribution automation. So, we have the automation, sectionalizing, and bulk control. And then right below that we have the ADMS Fault Location Isolation & Service Restoration, the FLISR.

Those two systems will actually work in concert.

What you'll see in our plan is now, on a distribution level, if there's a fault that occurs, we're going to sectionalize our feeder into smaller subsections so there are fewer customers that are out. That's the sectionalization.

And then the FLISR piece of it is, if the fault occurs, we sectionalize and isolate the fault, and we can restore from another feeder, from another source. That's the FLISR.

So, the outage rates will be much smaller; the fault, wherever it may occur, will be isolated and sectionalized. Our crews and our operations center will know exactly where that fault is so they're able to dispatch the crews to address it in a much shorter timeline. And they're able to go right to the fault rather than having to patrol the entire feeder looking for the fault or the event.

And then all the other customers will be restored until we fix and resolve the smaller section that's out. Then, once that's resolved, we're able to return those customers back to service.

Member of the Public continued.

I guess where my concern comes, is when there's an outage--we have so many--we become so dependent upon these communication systems operating. If the communication systems fail, then many things in the past that have been available on a manual basis then become unavailable to most any level.

So, I need to think about that a little more, but maybe all of you need to think about it, too.

PNM continued.

That's a really good point. So, as our systems become much more intelligent, we're much more dependent upon data. We always design backups into our system as well. So, we have backup control centers. We have backups if we lose communication. So, there should always be a backup and a contingency.

But very good point. Thank you for that.


Is PNM proposing to roll out dynamic pricing and load management programs as the AMI (Advanced Metering Interface) meters are deployed to start collecting information? (Asked at October 17, 2022 meeting)
Asked by Southwest Energy Efficiency Project on October 17, 2022. View meeting information here.

Initial Response: PNM

We certainly are going to start collecting information. Our pricing team has already been meeting with a number of stakeholders in advance of our upcoming rate application filing later this year.

Speaking of a time-of-day pilot program--not to be confused with time of use rates--it is a more succinct rate structure that will try to better align the costs incurred by the utility with the rates that people pay during different points throughout the day. And it is also differentiated by season. We'll be able to talk about that a bit more specifically at a future meeting, but we are going to be rolling out a pilot program for that. This upcoming rate filing and continuing to try to advance that throughout the rest of the rate structure is going forward as more and more AMI gets deployed throughout the system.

But AMI, of course, can't be deployed overnight.

On the load management programs, we currently do offer demand response programs through our energy efficiency plan. That's the peak saver program and the power saver program. And we'll be talking about those and potential other options that may be available in the future at a future meeting.

There are a number of pluses and minuses associated with the programs that are done through energy efficiency. In particular, we want to try to make them available to as many customers as possible and minimize the number of customers opting out of the programs after they've joined.

These are 100% voluntary programs. That tries to keep more customers engaged but, on the other hand, it also makes it so that customers can opt out. And we can't always count on all that capacity for reliability purposes. But we do try to make sure that we make those burdens as flexible as possible to keep more customers engaged.

The power saver program is for residential customers, it's typically for HVAC loads, and it's dispatched cycling through HVAC loads across the system so that not everybody has all their air conditioning turned off simultaneously for an extended period of time, but typically rotating through turning air conditioners off--maybe 30 minutes at a time--for a subset of the overall program population and cycling through those a for a four-hour window. Now those programs are currently set to be operable June through September from 8 a.m. to 8 p.m.

The same applies for the peak saver program, which is a large commercial and industrial program that allows those types of customers to participate. Again, it's a voluntary program.

Combined, we count on about 30 megawatts of peak reduction for those programs towards meeting our reliability requirements. We do have more than that enrolled in the program. Because of the voluntary nature and looking at actual program operations compared to just what the nominal contractual obligations were, there's a bit of a difference there. So, we only count about 30 megawatts towards our reliability requirements.

As far as whether there will be new programs being offered going forward, once AMI is installed, we're always mindful that we want to make new customer programs for as many different portions of the population as we can. As we look at that we know our energy efficiency team--there's an active RFP out right now-- is trying to look at different types of demand response programs, something that might be it would be a bit firmer.

We always take a look at what other alternatives are out there. But we do have to be careful that we're not going to harvest or cannibalize, say, from one program to feed another. We want to make sure that we're not double counting megawatts or double counting things and are trying to make sure that we're serving our customers reliably.

So, you'll need to take a look at what makes sense for these programs going forward--as we've looked at some of the time-of-day pricing rates--and try to align costs in those with where the costs are incurred in our system, looking at where the loss of load probability is on our system, and trying to think about where we want to focus: potentially alterations to the existing demand response program to potentially make new programs to fill in gaps.

The risks and our shift in our system are moving later in the day--in the summer towards the net peak periods, that 5 p.m. to 10 p.m. timeframe, especially in the summer. And in the winter, we see kind of a dual peaking, where we'll start to see a little bit of risk in the morning hours as well as in the net peak hours in the afternoon.

So, as we get more and more information from AMI programs, as we start to see better into what our customers are doing, we will try to offer additional programs. But right now, we do have the two programs we are offering through the energy efficiency programs as well as an active RFP looking at potential new programs or increasing loads on the existing programs, depending on what those prices kind of look like and where we think we could get customers to enroll.

PNM Public policy/legal continued.

On Slide 11, you can see that second chevron under the green one that's basically under Customer Empowerment, which is advanced metering infrastructure. That's really the meters portion that we're talking about. It's going to be about a three-to-three-and-a-half-year deployment. And it's on a rolling basis. So, the meters themselves will have to be physically switched out from the old analog meters, or even in some cases, digital meters to the advanced meters, the smart meters.

And that will occur over time with 530,000 customers in an area--the size of our service territory is pretty big. So, it will take some time to deploy that to all customers.

But in addition to that, at the same time, we have the other areas in blue {on this Slide} which are the distribution upgrades, and then the supporting services in gray that are occurring at the same time.

So, the time everybody is fully transitioned to the new meters would be roughly around the end of year four of this plan, beginning after the Commission makes that decision.


Where in the futures and sensitivities models do you factor the possibility of decentralization impacting demand for PNM services? (Asked at November 2, 2022 meeting)
Asked by a Member of the Public on November 2, 2022. View meeting information here.

Initial Response: PNM

Do you mean decentralization of resources or decentralization of load? Could you clarify?

Member of the Public continued.

It just seems that looking far into the future, where the possibility is of people to kind of fork off, requiring PNM or backing up at home with their own batteries, all that kind of thing.

It may be too early, but I just keep wanting to see that somewhere rattling around in our thinking because customers could peel off in different ways. And that could impact the company in many ways. So, it's probably demand.

PNM continued.

Thanks for clarifying.

The way that this is being considered is through our demand forecasts. The IRP, again, looks at just PNM's retail customers. If a customer were to become completely self-sufficient, and no longer be a part of the PNM’s retail system, they would not be included in the load forecast. That's not an obligation we would have to serve.

If the customers are incorporating their own resources behind the meter through additional adoption of behind the meter photovoltaic (PV) rooftop solar, essentially adding their own batteries behind the meter, those are things that we are incorporating through the load forecast.

So, we have a specific component in the load forecast that assesses a forecast of behind the meters: PV adoption. And there's going to be four or maybe five different behind the meter PV forecasts. One of them will be trying to back out all existing PV on the behind the meter PV on the system. One will be assuming there's no new incremental behind the meter PV, Then, there's going to be three different incremental behind the meter PV forecasts.

And so, each of these forecasts can be used as modifications to the overall retail load forecast and would reduce the amount of system requirements that would have to be added and, in turn, reduce the amount of retail sales to support those customers. That would be accounted for--with additional behind the meter storage additions.

Again, that would end up depending on how [those modifications] are operated. If they are operated just on behalf of any individual customer for their own benefit, that would manifest through a change in the load shape in one way.

On the other hand, if we were to look at the establishment, once we have AMI (Advanced Metering Infrastructure), of perhaps a distributed energy resource management system, we can start to model the behind the meter resources as something that has full visibility--not just a load modifier, but a dispatchable combination of resources that PNM could operate or dispatch, through an aggregated system for the benefit of the entire system. Thus, that would reduce the need for additional resources on the system.

Those are the ways we're thinking about it for this integrated resource planning cycle, and we'll have to continue to think about it going forward. Additionally, there's going to be independent forecasts for different building electrification as well as transportation electrification forecasts. And then a time of use, or time of day rate pricing sensitivity that will say, "Well, if enough customers joined this time of day pricing program and modify their behavior, how might that change the overall requirements of the system?"

So, that's the way we're looking at, at least from the supply planning point of view. And we would always keep in mind as well, when we're establishing what the needs of the system are, and we determine that so much solar might be needed, or so much storage might be needed, even if it's coming in at the utility scale, that it doesn't mean it's something that has to be done by the utility. It could always have a part for the customer to enable them to be part of the transition, so long as the resources are dispatched for the benefit of the system, and not dispatched for the benefit of any specific customer.

We know that this has been an ongoing question for years. And we hope that [this response] helps to think about the way we're looking at it this go around, from the integrated resources planning point. The key has to be about just what are we doing for our retail customers? And then how can we take lots of small, distributed resources, and think about how they could be aggregated up to the system level. Because when we're looking at the IRP, we’re always looking at the bulk transmission system; we're not modeling down to the distribution levels.

Member of the Public continued.

Thank you.

I keep raising this because I do see things as being pretty far, some of it's pretty far, out in the future. I'm not expecting immediate answers of any sort. I just want to understand how to think about it. And you're helping me a lot.


Are you expecting any resistance to PNM’s interest in getting information from behind the meter? (Asked at November 2, 2022 meeting)
Asked by a Member of the Public on November 2, 2022. View meeting information here.

Initial Response: PNM

In 2016, we filed a case for the adoption of Advanced Metering Infrastructure (AMI), and there was a lot of resistance. That case was denied by the Commission, and there were a number of groups and individuals that filed protests. That seems to have changed a little bit.

The Commission, as a part of our grid modernization filing, required us to file our AMI component. If they approve it and they require AMI to be the de facto standard meters of the system, that will be deployed, and it's met with some resistance, we're not sure necessarily what the company would do for individuals who may not want that type of meter.

But we certainly see that going forward. AMI--advanced communications--will be a significant component and part of the infrastructure of the system. We can't decarbonize completely; we can't do all the things on the distributed level--things that we need to do in order to decarbonize--without having that visibility into the edge of the system.

PNM update:

Our Grid Mod filing identifies the opt-out options and fees proposed by PNM – a customer will pay a one-time fee at opt-out, and then a recurring monthly fee for meter maintenance and manual reading. If a customer opts out prior to deployment, they will keep their existing meter; if a customer opts out after deployment, the new meter will be replaced with the same type they had before AMI deployment.

Grid Mod FAQs are posted on PNM’s website here.

PNM is also voluntarily adopting the U.S. Department of Energy’s Data Guard Energy Data Privacy Program Voluntary Code of Conduct. (https://www.smartgrid.gov/data_guard.html).


IRP Report
Please distinguish between load served and connected load and be consistent in the IRP. (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

Response: PNM

We will ensure that a scenario that removes BTM-DG [Behind the Meter Distributed Generation] is included in the IRP.

Customers are free to do what they want and what they do behind their meters makes it hard to know what those loads are. We don’t have intelligent meters, and we can’t know exactly what the fully connected load is.

The load the utilities serves is what is seen at the meters by the utility. For those individuals or commercial entities that have BTM rooftop sources, serve part of their load.

It's entirely possible that you could add up the best practices and they would not meet the adequacy that we might see as we try to electrify so many things. How did the study deal with that? (Asked at May 25, 2022 meeting)
Asked by a member of the public on May 25, 2022. View meeting information here.

Initial Response: E3

We built this study around a specific load forecast that was developed based on the utilities’ own assumptions as to the future of transportation, electrification, and such. Our work here represents an evaluation of, given a certain load forecast, the resources that the utilities have planned and have in the ground today that are sufficient to meet that load forecast to a sufficient standard.

That means there is a lot of pressure on the utilities in their load forecasting to make sure that they're keeping up with the trends that we're seeing within the industry with respect to electrification, both transportation and buildings, and that the load forecasts reflect the best future information we have as to the size of those growing segments. As the question alludes, if those dynamics aren't captured in a forward-looking evaluation of how large loads could grow, there may not be sufficient resources developed in the plant to keep pace with those changes.

Initial Response: PNM

We would want to ensure that E3 agrees that part of resource adequacy planning is to ensure that this resource adequacy standard has sufficient room to cover uncertainty around that load forecast and that always carries enough reserves to cover that uncertainty with the load forecast and a number of other variables.

E3 continued.

Agreed.


We're a water shortage region. How has that come into planning? (Asked at May 25, 2022 meeting)
Asked by a member of the public on May 25, 2022. View meeting information here.

Initial Response: E3

It affects the planning in a number of respects, some of which are not taken into account directly within our study, and some of which are, certainly, as water becomes more and more constrained within the region. And that may have impacts on economic growth within the region. That's something that you would expect to see show up within utilities’ load forecasts--their expectations for future economic growth.

We've taken previous load forecast from utilities at face value, so we haven't made any assessment or judgment as to how water use within the region might impact those forecasts. But we think that is something that we would expect utilities within the region to be thinking about.

On the supply side, the risk of drought is something that we did try to think about and factor directly into this work. Essentially, within a model like this loss of load probability model, we have some representation of how much energy is available from the region's hydro resources. And the amount of energy that's available, you can imagine, is a function of what the underlying hydro conditions are.

What we tried to do, and this is based on input that we've gotten directly from the Western Area Power Administration and the Bureau of Reclamation, is characterize the relative risk of severity of drought in a probabilistic way, such that there's some probability in our model that you end up in a really critical hydro situation that reduces the value of the region's hydro resources. In some cases, you may be in a more normal condition on a relative basis, and you have a little bit more capability. So, on the supply side, that’s how we would expect that to come into play. 

Initial Response: PNM

From PNM’s perspective, looking at the resource plans that were in our 2020 IRP and the types of resources we're looking at now—and this is pretty true broadly across the West—the new resources that are coming on board are much lower water use resources than the resources that are being retired. So, when you think about coal plants have steam boilers being retired and replaced with solar storage, maybe aeroderivative, and natural gas turbines that run very infrequently and that don't require much water, the net water usage for electrical power generation is significantly decreasing, say, for any entity building a pumped hydro plant or something like that.


[Regarding] the expected availability of existing legacy resources--the existing coal and gas plants--there's a lot of attention around the declining ELCC's for renewables and how they fall off as penetration increases. Was there consideration about how the availability of existing resources decreases as they age or was that outside the scope [of the study]? (Asked at May 25, 2022 meeting)
Asked by the Office of the New Mexico Attorney General on May 25, 2022. View meeting information here.

Initial Response: E3

On the risks associated with existing or legacy resources, a model like this relies on assumptions around the risks of outages for all types of resources, existing resources included. And those outage risks are usually based on historical experience. In this study, we've used assumptions that are consistent with utilities’ plans for the outage risks of various resources. In general, what we see with those outage rates is that for a lot of the oldest plants on the system, and in particular, some of the coal plants, those outage rates are higher than you might see with a new facility. And so that is factored into this type of analysis.

And we do, in fact, in this study, apply the same ELCC [Effective Load Carrying Capacity] construct that we use for wind, solar, and storage to those existing resources when accounting for their capacity contributions. So, every one of those resources--whether nuclear, coal, or natural gas--gets its own haircut on its effective capacity based on assumptions around its outage rate.

PNM will discuss outage rate assumptions for its modelling in a future session.

Update: PNM

Outage rate assumptions for modelling were discussed at the January 17, 2023 meeting.

What kind of changes could be made in the storage of water? There are many cultures that store water underground, pipe water underground, or have open systems where evaporation is a major issue. Is that something that tangentially we need to address or get put into the conversation? (Asked at May 25, 2022 meeting)
Asked by a member of the public on May 25, 2022. View meeting information here.

Response: PNM

I think there are two different pieces to that, if we're thinking about being able to add water-based resources or about the hydrological resources included in the studies that have reservoirs. Is there a way to take those two closed systems as opposed to open systems to reduce the evaporation?

So, those are things that are being looked at in terms of a few pumped hydro projects that we are aware of. And there are different ways they think about either reducing or eliminating evaporative offtake from the system as a whole: Are you trying to say now that every single water reservoir should be for the entire economy or for water usage for homes or for anything other than power generation? That's a much broader discussion.

If we're going to try to get the entire economy to go a certain way, we've got to stop thinking about individual sectors and start thinking about the cross play between sectors. But that's probably a broader discussion than we have time for in these integrated resource planning forums.

Granted, if we're going to make the best use of our water resources, especially as things are becoming more constrained with more population growth in the West, existing or new hydrological resources in the form of pumped storage is one of the most well-known types of long duration storage you can add to a system; it could really play a role. But if you don't have the water for it, then what's the use? So, we've got to figure out a way to make everything work for us in an efficient and environmentally friendly way.

I just wanted to make sure that you're going to go over the storage requirements that you were looking for. [I’m seeing] 5-hour with 500 megawatts, and I would like to know how often that’s expected. [Perhaps it was related to an RFI.] (Asked at May 25, 2022 meeting)
Asked by CSol Power on June 8, 2022. View meeting information here.

Response: PNM

We do have two RFIs out right now, neither of them is specific to a duration aspect. One of the RFIs is seeking longer duration storage. And that can be anything from maybe five hours—some consider that long; it is longer than four (4) hours, but it could be eight (8) hours, 12 hours, 24 hours, a week, or even longer. We're very open ended in that RFI, and there's no prescribed capacity amount, either.

We're trying to get an idea of what is out there, especially those types of projects like pumped hydro or other things that have very long lead times for the development of those types of resources. Or maybe they're getting to the stage of being commercially viable, but they're still in pilots; we want to understand them and then get a better idea of how the commercialization of those types of resources would go.

The other RFI is more about emerging technologies, and very similar to the RFI that we issued prior to the 2020 IRP to look at those new and emerging technologies that are less project specific, but more technology specific, that we can start to consider over the planning horizon.

The IRP, of course, is about resources and storage capacity durations. Do we need to stop thinking about storage in the duration, but more about the total amount of stored energy that it could offer up? Then, you've also got the capacity side of the equation. Say, we've got 100 megawatts for a battery. Well, that 100 megawatts can be discharged at 50 megawatts, over eight (8) hours.

So, there are different ways you can utilize these storage technologies and make them look a little bit different. But there are going to be times when you might want to have that greater rate of discharge or charging. In winter, there's a shorter window for solar production, so, if we need to charge our storage devices, we might need to have a higher rate of charging capacity, even though the total volume of stored energy may or may not change.

The IRP is going to address how we start thinking about the resources we need to reliably serve our customers in a cost-effective way. I don't think there's a prescribed volume of duration of storage or capacity of storage that we've identified yet. We will be identifying that through this IRP process.

It would be helpful to repeat this discussion in writing somewhere--the amount of increase per decade and the fact there are fewer cold days, more than hot days. Will there be a detailed report written? (Asked at July 6, 2022 meeting)
Asked by InterWest Energy Alliance on July 6, 2022. View meeting information here.

Response: PNM

We can certainly take that feedback and try to organize it into a write up in the IRP itself. It shouldn't be too tough to do.

Typically, the more detailed discussion of the weather data and the load forecast development is in the Buildings Appendix C of the 2020 IRP.

Load & Energy Efficiency Forecasting
What sub-populations of the PNM customer base are going to be impacted and in what order? How do we keep that in balance, both for the system and as we have more distributed generation? How does that change the role of the grid and other factors? (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

See PNM's response to this question in Grid Modernization, April 28, 2022.



As partner systems in southwestern states move to renewable or battery storage sources of energy, how may that affect the sales of energy to PNM … or as regional utilities or regional load serving entities transition their systems towards more renewables and energy limited resources, will that impact PNM’s ability to purchase energy on the wholesale market? (Asked at April 28, 2022 meeting)
Asked by CCAE on April 28, 2022. View meeting information here.

Response: PNM

We believe this will impact PNM, and we are going to be taking a look at that much more closely.

We've been seeing a decrease in liquidity of the markets over the last few years and expect to see that continued decrease going forward. If all of the utilities in the desert southwest start having systems that are mainly solar and storage-based with a little bit of dispatchable natural gas for reliability, depending on the timeframes, the systems will become much more correlated in terms of when their risks are going to manifest.

If energy storage is the primary resource used for reliability, especially if it's shorter duration, there could get into situations where other utilities may not want to sell energy out of their stored resources because they would be unable to replenish that energy and use it for themselves later.

So, we do see a pretty big risk that we need to examine going forward related to what the energy markets are going to look like and how those dynamics will evolve as more and more systems go to your heavy deep decarbonization requirements.

Will the electrification of vehicles be included in this IRP process? (Asked at May 25, 2022 meeting)
Asked by CSolPower on May 25, 2022. View meeting information here.

Update: PNM

We discussed topics related to this question in the October 17, 2022 Grid Mod presentation.

See also the discussion around electric vehicle load in the load forecast presentation from December 15, 2022.


The study took the load forecasts at face value rather than evaluating them, and then mentioned 2% load growth. How much of the future need is driven by this expectation around high load growth? I certainly understand electrification and EV load. But some of the load growth, generally, was for population growth and industrial load. And there have been patterns of historically over projecting load growth that doesn't materialize. (Asked at May 25, 2022 meeting)
Asked by Office of the New Mexico Attorney General on May 25, 2022. View meeting information here.

Initial Response: E3

On your first question, we didn't go through an exercise of trying to disentangle exactly how much the various factors of load growth versus resource retirements drive the need for capacity within the region. But it's hard to say it's not a combination of both and that both are really significant contributors.

We found that in 2021, the system is already right on the cusp of being at the acceptable level of reliability if you were to use a one day and 10-year standard. At that point, any resource retirements or any load growth beyond that point drive a need for new resources.

Now, in terms of scale, the study points out that by the time we're out in 2033, we're looking at somewhere on the order of 5 to 6000 megawatts of conventional capacity that's expected to retire. So, at the very least, you can imagine that that would be some sort of a bookend or approximation of a portion of the need that might be set by, determined by, or associated with resource retirements.

Is demand response, for lack of better words, curtailment of the load at the demand level? Are those distributed resources or those that are actually generating? The curtailment of load is not considered in the one in 10 or two in 10, right? (Asked at May 25, 2022 meeting)
Asked by a member of the public on May 25, 2022. View meeting information here.

Initial Response: E3

That's demand response programs contemplated by utilities; essentially load that can be curtailed under specific conditions, typically when the system is tight on capacity. Demand response calls are not counted as loss of load events.

Is the Miscellaneous category just everything that doesn't fit into the other categories? (Asked at June 22, 2022 meeting)
Asked by Brubaker & Associates on June 22, 2022. View meeting information here.

Initial Response: AEG

Yes, it is a kind of the catch-all for all the things that don't have a place in the other end uses.

Do you assume in your baseline load forecast this conversion rate? Over time, is what actually happens that difference could be due to energy efficiency incentives or incentives to not convert to AAC? Can part of it be forecast error? Does all of that get counted as energy efficiency? (Asked at June 22, 2022 meeting)
Asked by Sandia National Laboratories on June 22, 2022. View meeting information here.

Initial Response: AEG

Every forecast has error. This is a projection, so it could be over or underestimating the conversion rate. The actual energy efficiencies that occur could be in error, either be too much or too little energy efficiency once we actually get there.

That transformation happens as people are really moving away from evaporative cooling. It could go in either direction. It just depends on which way the actual adoption happens, because we could overshoot it, or we could undershoot it in our forecast.

And with all the codes and standards, there are so many things that are going to come into play in the future that change those adoption rates. There’s electrification and things like heat pumps happening in the in the HVAC space. Lots of little wrinkles.

Update: PNM

Please see presentations on energy efficiency (January 17 2022) and rate design (December 15 2022).


Is there a trend happening around the conversion of evaporative cooling to air conditioning? Do you assume in your baseline load projections about what that conversion rate might be? (Asked at June 22, 2022 meeting)
Asked by Sandia National Laboratories on June 22, 2022. View meeting information here.

Initial response: AEG

The short answer is yes. We are collecting information on that kind of conversion from the past. We've done primary research, and we are looking at the saturation of different types of cooling within the residential sector. So, we do have some history to help us make that assumption.

We are looking at a lot of different sources to understand how saturations change over time, and then we will build that into the model. The potential for energy efficiency is changing, as you're seeing more and more HVAC, regular air conditioning coming into PNM territory.

We are also going to rely on national sources and integrate with Itron. They are also making assumptions, using a statistically adjusted end use modeling approach that actually uses indices of cooling and heating.

Update: PNM

Please see presentations on energy efficiency (January 17 2022) and rate design (December 15 2022).


Demand side management [or, customer response based on some sort of price signal or program] is not being considered as part of energy efficiency, correct? (Asked at June 22, 2022 meeting)
Asked by Sandia National Laboratories on June 22, 2022. View meeting information here.

Initial Response: AEG

That's correct. Demand response in the traditional sense, pricing or smart thermostats that are being controlled through signals during peak periods that are targeting only demand, is not part of what we're doing in the energy efficiency potential study.

We did that kind of study in 2019 for PNM. There is a lot of overlap because things like smart appliances, or smart thermostats, or things that can be energy efficient can also be used for demand response.

We actually do estimate peak impacts for the equipment that's installed but we are not talking about the programmatic context in which those pieces of equipment can be controlled in this study.

Initial Response: PNM

Consider this scenario: A smart appliance could have a thermostat control, with an energy efficiency component allowing it to be part of a demand response program where you could turn off power to it given a signal coming from our demand response. What if there are new rate designs with real time pricing, with time of use rates or other things that could also influence customer behavior and shift the way customers are utilizing energy creating differences in the load patterns?

That's actually a sensitivity that we've done throughout the load forecasting work we are doing. There are lots of different things going into this and trying to figure out where they fit in is as important as what the impacts are going to be.

Update: PNM

Please see presentations on energy efficiency (January 17 2022) and rate design (December 15 2022).


Will the hourly estimates of how much energy savings is going to happen based on each of the bundles include, for example, smart thermostats and other demand response programs? (Asked at June 22, 2022 meeting)
Asked by Sandia National Laboratories on June 22, 2022. View meeting information here.

Initial Response: AEG

Yes and no.

It will include a smart thermostat. For example, it is done by measure, and then by end use. We take a measure and map it to the end use. For a smart thermostat, we would be mapping that to a cooling end use. We take the total energy savings assumed to occur over a year and then map that to an end use load shape.

We have calibrated load shapes that are unitized, and they match PNM’s system load shapes based on the sector. So, they all add up so that when we get a peak, it matches their peak.

We take the total annual consumption and multiply it by unitized load shape, and then get an estimate of the consumption that's being reduced or the savings in every hour. It matches the cooling load shape.

We don't make any assumptions about changing that cooling load shape based on a program.

So, yes, we would use smart thermostats but no, we're not making any assumptions about how those maps or smart thermostats would change the actual load shape or the timing of the load based on signals that are being sent.

Initial Response: PNM

We would model demand response separately. Say, a smart thermostat program is a demand response program that we would model. Absent the calling of that program, there's still some energy efficiency savings from that appliance, but clients could also allow them to participate.

If the model selects a demand response program, when it goes through the production cost dispatch, and gets to a point where the demand response program is called, you then see within the model that demand reduction in the production cost, and that would be on top of the already reduced low chamber associated with the energy efficiency measures.

AEG continued.

It's a little tricky because they're two separate pieces. And even though some programs aren't really integrated, we're still in a world where we're modeling them separately.

PNM continued.

Everything is changing and changing rapidly. The models are trying to catch up.

Update: PNM

Please see presentations on energy efficiency (January 17 2022) and rate design (December 15 2022).


How do electric vehicles fit into the modeling? (Asked at June 22, 2022 meeting)
Asked by NV5 on June 22, 2022. View meeting information here.

Initial Response: AEG

We are not modeling electric vehicles in the energy efficiency potential study. That is something we are doing more and more often as part of an electrification layering in an electrification forecast. It could be the beneficial electrification of appliances, or it could be EVs, but it does require a forecast of EVs to be to be layered in.

It's not really energy efficiency. It's more load building or electrification. It's not part of the scope here, but definitely something that we're thinking a lot about and seeing and doing in other places in in the country.

Initial Response: PNM

PNM has a transportation electrification pilot program, approved by our commission, that's going to be implemented over the coming years.

In the 2020 IRP, we had three separate transportation electrification scenarios that we modeled in our load forecast: a low, a mid, and a high that corresponded to different electric vehicle adoption rates. We had building electrification sensitivities as well. We had something over 80 different scenarios that we had run in sensitivities. We were testing, inter alia, the effects of changes in building electrification, transportation electrification, adoption rates, changes to behind the meter, and solar adoption rates. These scenarios will get worked into this IRP’s load forecast, which Itron will be discussing.

On the August 25, 2020, meeting slides, as well as in Appendix C of the 2020 IRP, we showed the breakdown of the load forecast that shows all of the different scenarios. For the load forecasts that we did, it'll show the transportation application. The building electrification will show the time of use sensitivity where we implemented more dynamic pricing signals and behind the meter solar PV adoption rates.

The August 25, 2020, presentation has a complete breakdown of the energy efficiency bundling. It shows not just the single year AEG used in its example but also a number of other pieces if you want to get an idea of what we are looking at for those and how they were working with the modeling. There are detailed write ups in that presentation about which bundles were selected, which ones were not selected, and virtually all scenarios; anything under $50 per megawatt hour was always selected. And then, depending on which scenario we're talking about, sometimes more expensive bundles were selected.

We are starting with the 2020 framework and trying to figure out where we can make incremental updates improvements and incorporate more information to make sure we're tailoring the IRP to what's important to our stakeholders.

Does rooftop solar count toward energy efficiency? (Asked at June 22, 2022 meeting)
Asked by CSolPower on June 22, 2022. View meeting information here.

Response: PNM

No. Per the Efficient Use of Energy Act, energy efficiency is defined as "measures, including energy conservation measures, or program that target conservation behavior, equipment, or devices to result in a decrease in consumption of electricity and natural gas without reducing the amount or quality of energy services." Since rooftop PV does not result in a decrease in consumption of electricity, it does not qualify as energy efficiency.

Do you plan to do a comparison of the impact on the night and early morning hours? I would assume that demands at that time are much lower. (Asked at July 6, 2022 meeting)
Asked by InterWest Energy Alliance on July 6, 2022. View meeting information here.

Response: PNM

The demands are much lower, but it doesn't alleviate the demand that's needed right after sunset. You can't just consider a very short window; you need to think about the overall system dynamics: The utility has to have enough resources under its control to meet its net peak, including reserves. But then, at some point, it's not just about that net peak and the capacity associated with that. It also becomes the amount of stored energy and the amount of energy that you need to be able to carry forward overnight into the hours of the morning to be able to sustain meeting your loads.

We are going to present another reliability analysis, looking at what the risk hours are and showing what that is as it changes over the time frame of the study--2023 through 2042.

When we presented the (preliminary) ELCC [Effective Load Carrying Capacity] analysis, we talked about doing an ELCC analysis not just at a static point in time, but at a couple of different points in time throughout our forecast horizon, showing, that as the risk hours change, the effective load carrying capability of a given resource to meet those risk hours will change.

So, the amount of resources we're going to have to add over time is going to increase because the solar, the wind, and the storage are going to be adding less and less ELCC as their levels of penetration increase throughout the period of decarbonization.

Furthermore, you're going to have to deal with not just that net peak, but also the flattening of the net load as it wraps around into the early morning hours.

Is your key need, especially during summer peak, going to be capacity or energy in the 6-9pm window, so what happens when you thicken that self-generation slice at the top (Slide: “Hourly Load on Peak Day”) that just pushes your peak into the evening hours when the sun is going down or down? Is that right--partially-- so that this is just a snapshot and doesn't represent the full system dynamic? (Asked at July 6, 2022 meeting)
Asked by InterWest Energy Alliance on July 6, 2022. View meeting information here.

Response: PNM

Yes. And whether it's behind the meter solar or utility solar or utility scale solar, the more of it that we add, the more it's going to depress consumption that is not served by solar in the middle of the day. But the requirements that we have to serve when the sun starts to set are going to remain at those higher levels. We're going to have to have resources to cover that, depending on what else is added to the system, because you can't think about it as just solar, as you start to add more storage.

In the 2020 IRP Appendix M, there are some heat maps of the loss of load risk hours: As you go further down the decarbonization path, as you add more solar and then add more storage, the storage has the tendency to flatten out that peak, but you can only operate for a limited duration.

The solar will push the capacity needs into the early evening period. And then, as you add more storage, it's going to further shift that risk later into the evening overnight, eventually into the early hours of the morning.

So, you can't just think about it as this really short window in the near term. If we only had solar, it's going to be this near-term short window, but as we go further and further down the road, you're going to start to see that loss of load risk. And you can see this even in the presentation that E3 did on its Southwest study: The overall loss of load risk for the southwestern region by the time you get to 2030-2033, if all the utility IRPs are followed, you start to see that loss of load risk start to creep into overnight and early mornings because of the duration and limitations on energy storage.

The heat wave analysis that we're talking about here will likely have some input into the broader analysis that you've just summarized. If that's the case, if that's, if that's true, then I think that some of the assumptions that we've been talking about your today need to really be explained clearly so that we all understand what the cascade of assumptions is. (Asked at July 6, 2022 meeting)
Asked by InterWest Energy Alliance on July 6, 2022. View meeting information here.

Initial Response: PNM

[Perhaps we can continue this discussion offline to clarify how you're thinking about this presentation's use of weather variables in the development of the PNM retail load forecast.] This does not concern neighbors, or what our availability to purchase power from them is.

We've heard that the average temperature in New York or for PJM (PJM Interconnection LLC) was going up .7, and we don't really know what the trend is for New Mexico. I'd like to see a scenario that does take into account increased heat waves, the increased occurrence of heat waves in the summer, because that's what's going to stress your system. So, can we look at the trends we know about in New Mexico, project out increases in heat waves, and make a scenario for that? (Asked at July 6, 2022 meeting)
Asked by New Mexico State University on July 6, 2022. View meeting information here.

Update: PNM

The PNM modeling framework and Phase 1 modeling scenarios were discussed during the February 15, 2023 meeting.

The framework for modeling run requests was discussed during the March 15, 2023 meeting.

Is there any elasticity between behind the meter solar and community solar and electricity rates? If so, is that a significant factor? (Asked at July 6, 2022 meeting)
Asked by a member of the public on July 6, 2022. View meeting information here.

Initial Response: PNM

We'll have to have one of our rate design folks address this as well.

Initial Response: Itron

It's pretty complicated, right? Behind the meter and community solar is behind the substation anyway. We're not saying it doesn't necessarily change how much energy people are using, but it changes how much the utilities deliver. And, so, as it reduces the amount that utilities deliver, it reduces the amount of revenue they recover--if it's a volume based charge, not so much if it's a demand charge.

That means for residential, where you still have sort of a volume base charge, you're recovering less of your fixed costs, because you're delivering less energy, and, therefore, you're going to have to raise the prices to recover the revenue to cover those fixed costs.

So yes, there's definitely a relationship there and we are sure the rate people are working on that to find ways to make the system work financially.

PNM continued.

We'll have our rate group talk about that a bit as well. I would suspect that if there was a change in the way net metering rate works for residential, for example, you would see a reduction in the amount of folks that are trying to put behind the meter solar residentially. Because of the size of the credit paid to those customers would change.

We do think you will have to look at that if you want to properly incentivize behind the meter storage or distributed storage. Right now, our block rate is 8am-8pm. That period is too long, and the net energy metering rates potentially too high, to incentivize someone to add storage as well.

Is there much or any behind the meter by commercial industrial customers? And how does that affect your analysis? (Asked at July 6, 2022 meeting)
Asked by InterWest Energy Alliance on July 6, 2022. View meeting information here.

Initial Response: Itron

If you look down below, probably about right now, a quarter, maybe 30%, of the generation is nonresidential.

There's quite a bit in the water customers--water utilities that generate some of their own power. There's some in small commercial and general power categories. And then some of the really big customers actually have their own solar farms, but those are not behind the meter: Their solar farms are located near the transmission system somewhere and are putting the energy directly into the transmission system.

So, the really big non-residential solar generation often is not behind the meter, but there are entities like hospitals and some schools with parking lots covered with solar.

What factors contributed to the forecast and increased residential behind the meter capacity? (Asked at July 6, 2022 meeting)
Asked by NM RETA on July 6, 2022. View meeting information here.

Initial Response: PNM

We'll have one of our internal subject matter experts come in and talk about some of the specific drivers behind that. We'll make sure to keep that on the agenda for a Load Forecasting meeting in November.

Update: PNM

Topics related to this questions were discussed at the Load Forecasting meeting on December 15, 2022.

Why does the minimum and maximum difference each year increase significantly? (Asked at July 6, 2022 meeting)
Asked by NM RETA on July 6, 2022. View meeting information here.

Initial Response: Itron

That's a monthly cycle throughout the year.

If you put in twice as much generation, everything is twice as big. And so, the minimum is twice as big, the maximum is twice as big, and the range is twice as big. If you have twice as much solar, it's going to double the maximum generation; it's also going to double the minimum generation.

So, the gain is twice as big during the year, going from winter to summer. The winter generation is low because the days are short. The summer, the generation is high because the days are long. The biggest generation is usually in April or May, so that might show up in the June bills. As it gets hotter and hotter, the generation becomes less efficient--more light, but less efficient.

The question here is climate change impacts the U.S. at different rates, depending upon the region. What is the trend? What is the trend in the Southwest versus New York, versus PJM (PJM Interconnection LLC)? (Asked at July 6, 2022 meeting)
Asked by New Mexico State University on July 6, 2022. View meeting information here.

Initial Response: Itron

I've seen some national lab studies, but I don't know right off the top of my head.

Initial Response: PNM

We can try to pull together some of that trend information but our focus in this IRP is about PNM's service territories. We're making our focus our weather and our load forecasts. PJM is outside the context of PNM's resource plan.

It would be helpful to repeat this discussion in writing somewhere--the amount of increase per decade and the fact there are fewer cold days, more than hot days. Will there be a detailed report written? (Asked at July 6, 2022 meeting)
Asked by InterWest Energy Alliance on July 6, 2022. View meeting information here.

See PNM’s response to this question in IRP Report, July 6, 2022.


Why use 2015 to 2018? Why not use more recent billed sales data? (Slide 15) (Asked at July 6, 2022 meeting)
Asked by InterWest Energy Alliance on July 6, 2022. View meeting information here.

Initial Response: Itron

That's not a bad idea. It's certainly something that we could take a look at to see if anything's changed significantly relative to 2015-2018.

This is just doing the weights. Those weights are something that could be updated. We will look at whether we're going to do that or not.

PNM asked question.

Could you provide a little bit of additional context in terms of how the weights, or the weather variables are done? You're coming up with a weighted average weather variable that represents the PNM system, so what this would be really getting to is, has the load growth in the system proportionally changed such that the weighted variable for weather would then change because of that?

Itron continued.

If you look at the weights, like Albuquerque, on the cooling as 77.8% weight, that was based on that 2015-2018 billing data. So, it might be a little different--bigger, smaller, probably a little bit bigger.

I know this is preliminary. This is obviously a very big change, particularly on the residential. What are the big drivers of this change? (“Comparison 2022 vs 2020” [Non Residential and Residential Capacity Forecast slide]) (Asked at July 6, 2022 meeting)
Asked by Brubaker & Associates on July 6, 2022. View meeting information here.

Initial Response: Itron

This change is driven mainly by the high level of activity in the last couple of years. As a result, the new solar capacity values (red line) start diverging from the old values (blue line) before the forecast begins. The higher level of historical additions put the forecast on a different and higher path.

We’re not sure of what all the logic is that goes into that in terms of government, attitudes towards solar, and government money and so forth. So, there are a lot of things that go into it, we’re sure.

What are the components? Are you using government forecasts? (“Comparison 2022 vs 2020” [Non Residential and Residential Capacity Forecast slide] Slide presented was preliminary. Final numbers will be updated and posted in a future presentation.) (Asked at July 6, 2022 meeting)
Asked by Brubaker & Associates on July 6, 2022. View meeting information here.

Initial Response: PNM

That forecast, at least the near-term piece, was developed by PNM’s internal customer programs and customer behind the meter internal department. We can have them answer the question; we've already got a meeting set up.

In 2020 or 2021, we might have underestimated the amount of rooftop additions that year by 50%, so there's just a very, very strong uptick in the amount of customers who are trying to add behind the meter solar—there’s a lot of folks in the queue.

This was raised at our kickoff meeting—there’s some reworking the interconnection manual that will hopefully make it easier for folks to interconnect. All of those things are going into the change in the forecast from the behind the meter perspective.

Brubaker & Associates continued.

So, then I guess, what you're saying is that Itron received an input for the capacity growth that came from PNM?

PNM continued.
Yes.

Brubaker & Associates continued.

It would be great considering how much change is going in this versus 2020, We'll cover that in a future session. We have a further explanation of when there was shortfall. Let's understand how the projection over the time was developed.

PNM continued.

We can add that to our list.

In a future meeting September/October, one of our representatives from our customer account groups--who's really in charge of doing the behind the meter forecasting and oversees a lot of the customer requests and their connections--can talk about the uptake that they've been seeing, and the sheer demand for interconnection of behind the meter assets.

Has anybody started using a 50/50 weather forecast for their work? Are they starting to look at 75/25? Or 90/10? Is anybody starting to ask for anything other than a 50/50 weather scenario to look how should we be planning as we start to recognize more and more what's going on with the changing climate? (Asked at July 6, 2022 meeting)
Asked by PNM on July 6, 2022. View meeting information here.

Initial Response: Itron
The most interesting work is done by PJM, the transmission system operator up in the Northeast. They take each 30 years, but they take each of the last 30 years, of actual hourly weather data, and run it through. They've got an immense service territory. It could be cool in Chicago and boiling in Virginia, so coincidence is a real issue for them in terms of their overall system load.

Their way to deal with that is just to take the actual year of historical weather data for all the stations, and run them through the models, a model of what's going to happen next year, or in 10 years--run 1995 through, run 1996 through, run 1997 through--and when those patterns go through, you've got a different load forecast for that future year. You can post process those forecasts. They were doing that with daily models of zone peaks, and now they're looking at moving to doing hourly modeling.

So, that's the most detailed approach to understand the range of outcomes that you can get today, or in 10 years, with those various weather patterns.

That doesn't deal with the trend issue but the range that you can get today. Given that, just looking at the past history, that range includes anywhere a trend could take us in terms of the middle point. The middle point is moving slowly; the range around that is big at any point in time.

Understand that range is the key. The one scenario that Itron would do is going extreme--Let's find the most extreme weather and do an extreme weather run, an extreme year.

We're pretty focused on a summer peak for PNM, at least now, but an extreme year would be a year with a cold winter and a hot summer. Or maybe it's part of two years that accomplishes that.

Is the hourly weather data, both the temperature data and the global horizontal irradiation, assuming that's all in sync on an hourly basis? (Asked at July 6, 2022 meeting)
Asked by Brubaker & Associates on July 6, 2022. View meeting information here.

Initial Response: Itron

Yes. The actual observations are from NOAA. They usually make them about 10 minutes before the hour. And so, the number that you're getting for an hour, say, from noon to one clock, might come about 1250. So, it's highly synced in that sense.

The challenge is doing the forecast to keep that synchronization in place, so we do pick one weather pattern for all the forecast years, and just map the hottest day, the second hottest day, third hottest day, fourth hottest day, to that consistent pattern through time?

The global horizontal radiation data that goes with the hottest day is from what that looks like on the typical hottest days each month.

We've gone to painful efforts to keep that analysis going. It's not easy but it's something you want to do.

How would increased distributed generation, especially if it has some backup storage of its own, be factored into the modeling? (Asked at July 27, 2022 meeting)
Asked by a Member of the Public on July 27, 2022. View meeting information here.

Response: PNM

This question relates to the load forecast discussion we're considering. From the IRP perspective, we don't model the distribution system; we're modeling the bulk electric system. If there are distributed energy resources--let's just use behind the meter PV, for example--we do have an explicit behind the meter PV forecast that is developed in the process of developing our load forecast.

One of the things that we're thinking about doing that we don't have right now is, if we were to say, install a distributed energy resource management system, as well as have AMI [Advanced Metering Infrastructure], and the necessary grid edge technologies, which would give us visibility into the edges of the system. For example, right now, we can't see, specifically in real time, what individual customers have in terms of behind the meter generation, what's being consumed by their loads, and what's being delivered back to the grid. That's because we don't have AMI and other technologies on the system.

If we can get those systems in place, then we can have a better representation of your customer sign up and a better control of, say, behind the meter storage resources. One of the things that we'd be looking at is: What's the total volume or total penetration level of behind the meter PV that's on the system, and then, what's the total amount of behind the meter storage on the system that would be potentially coupled with some or all of that behind the meter PV?

If we had a DERM (distributed energy resource management) system that gave us control over that, rather than just having the net effects of those behind the meter resources reflected in our than net load, we might move those to being modeled as dispatchable resources, where, based on the system conditions, we would see the charging the system, charging and discharging those batteries, potentially accepting or turning down the export settings on inverters, depending on what system conditions best optimize the use of that behind the meter storage.

But, if that would be done, we would be taking an aggregate of all of those individual resources and aggregating them up to a bulk representation of those distributed resources. This gets into the same thing that the modeling presentation is alluding to in terms of the detail of the model performance: We don't have the computational power to do a combined, complete representation of the distribution system and each of those resources on a 20-year hourly basis to do overall system capacity expansion.

So, we need to work towards that. We're going to have to push our vendors in terms of the way they're developing these models. We're going to have to continue to keep an eye on computational power--what new forms of computing might be out there.

But in terms of the way we would have to look at distributed resources, we'll have to look at how we can aggregate those up to the bulk level, and what devices we have on the system that would enable us to have better visibility, control, and dispatch of those resources if we do aggregate them up to the bulk level.

Where in the futures and sensitivities models do you factor in the possibility of decentralization impacting on demand for PNM services? (Asked at November 2, 2022 meeting)
Asked by a Member of the Public on November 2, 2022. View meeting information here.

Initial Response: PNM

Do you mean decentralization of resources or decentralization of load? Could you clarify?

Member of the Public continued.

It just seems that looking far into the future, where the possibility is of people to kind of fork off, requiring PNM or backing up at home with their own batteries, all that kind of thing.

It may be too early, but I just keep wanting to see that somewhere rattling around in our thinking because customers could peel off in different ways. And that could impact the company in many ways. I don't know, it's probably demand.

PNM continued.

Thanks for clarifying.

The way that this is being considered is through our demand forecasts. The IRP, again, looks at just PNM's retail customers. If a customer were to become completely self-sufficient, and no longer be a part of the PNM’s retail system, they would not be included in the load forecast. That's not an obligation we would have to serve.

If the customers are incorporating their own resources behind the meter through additional adoption of behind the meter photovoltaic (PV) rooftop solar, essentially adding their own batteries behind the meter, those are things that we are incorporating through the load forecast.

So, we have a specific component in the load forecast that assesses a forecast of behind the meters: PV adoption. And there's going to be four or maybe five different behind the meter PV forecasts. One of them will be trying to back out all existing PV on the behind the meter PV on the system. One will be assuming there's no new incremental behind the meter PV, Then, there's going to be three different incremental behind the meter PV forecasts.

And so, each of these forecasts can be used as modifications to the overall retail load forecast and would reduce the amount of system requirements that would have to be added and, in turn, reduce the amount of retail sales to support those customers. That would be accounted for--with additional behind the meter storage additions.

Again, that would end up depending on how [those modifications] are operated. If they are operated just on behalf of any individual customer for their own benefit, that would manifest through a change in the load shape in one way.

On the other hand, if we were to look at the establishment, once we have AMI (Advanced Metering Infrastructure), of perhaps a distributed energy resource management system, we can start to model the behind the meter resources as something that has full visibility--not just a load modifier, but a dispatchable combination of resources that PNM could operate or dispatch, through an aggregated system for the benefit of the entire system. Thus, that would reduce the need for additional resources on the system.

Those are the ways we're thinking about it for this integrated resource planning cycle, and we'll have to continue to think about it going forward. Additionally, there's going to be independent forecasts for different building electrification as well as transportation electrification forecasts. And then a time of use, or time of day rate pricing sensitivity that will say, "Well, if enough customers joined this time of day pricing program and modify their behavior, how might that change the overall requirements of the system?"

So, that's the way we're looking at, at least from the supply planning point of view. And we would always keep in mind as well, when we're establishing what the needs of the system are, and we determine that so much solar might be needed, or so much storage might be needed, even if it's coming in at the utility scale, that it doesn't mean it's something that has to be done by the utility. It could always have a part for the customer to enable them to be part of the transition, so long as the resources are dispatched for the benefit of the system, and not dispatched for the benefit of any specific customer.

We know that this has been an ongoing question for years. And we hope that [this response] helps to think about the way we're looking at it this go around, from the integrated resources planning point. The key has to be about just what are we doing for our retail customers? And then how can we take lots of small, distributed resources, and think about how they could be aggregated up to the system level. Because when we're looking at the IRP, it is always looking at the bulk transmission system; we're not modeling down to the distribution levels.


Would electric vehicles [EVs] be a part of "Miscellaneous" [Slide 14]? (Asked at January 17, 2023 meeting)
Asked by NM RETA on January 17, 2023. View meeting information here.

Initial Response: PNM

I believe that electric vehicles are not included in the energy efficiency portion … We take care of that in a separate piece of the load forecast.

AEG continued.

Yes, it's included in miscellaneous end use in terms of where that's showing up on the electricity profile.

PNM continued.

And then the savings piece, if we wanted to think about that, would be about changes to the chargers or how those pieces would work.

But in terms of the overall load component of EVs, that's a separate load component on a different part of the load forecast.

AEG continued.

There is some small amount of energy efficiency opportunity from putting in ENERGY STAR level 2 chargers, which I think is included in our analysis. But, yes, we're not providing a forecast of electric vehicle adoption to PNM.

Does this [Slide 14] include IRA incentives, such as for heat pumps? (Asked at January 17, 2023 meeting)
Asked by InterWest Energy Alliance on January 17, 2023. View meeting information here.

Initial Response: AEG

No, we have not explicitly adjusted for any potential impacts of the IRA [Inflation Reduction Act].

I think that's a question we're getting on all of our studies. And it's great question. I think it's a little uncertain what impact those [incentives] are going to have on customer adoption. So, I think that's just something we're going to have to track in these studies to see what impact those actually have.

It's a little different in PNM's territory, also, because we are looking from the Utility Cost Test perspective. So, we're not in a jurisdiction where we were looking at the total resource cost test perspective--that might change things a little bit if it's really just bringing down the cost of the measure. But it's just unclear whether PNM would actually be able to reduce its incentives to still get the same level of energy efficiency potential or the extent to which those IRA incentives, whatever format they come through, are going to affect the baseline forecast.

PNM continued.

From PNM’s perspective, right now we're talking about potential savings of some baseline that could be achieved through energy efficiency programs. The IRA incentives would also need to then be accounted for on the load side through some incremental increase in overall adoption rates of switching from, say, natural gas heating to electric heating, heat pumps, things of that nature.

And we did talk about that last time. On the load forecast side, we do have some higher building electrification sensitivities. To what extent those will be adopted by customers in the PNM service territory is unknown. We'll have to just wait and see how that develops over time and incorporate data over time.

We are going to run at least one sensitivity case on our load forecast that includes a higher building electrification scenario. It is also important to consider, should that [increase in load] occur [on our system], what potential savings could be realized on the EE side through more efficient heat pumps or other things that could lead to differences in what the load forecast would be relative to potential savings due to the types of measures that AEG is talking about here.

On Slides 21 and 23, are the units in gigawatt hours as on Slide 22? What are the units there? (Asked at January 17, 2023 meeting)
Asked by NM RETA on January 17, 2023. View meeting information here.

Initial Response: PNM

Are you referring to the tables that talk about the achievable potential in 2025 and 2030?

NM RETA continued.

Yes, exactly.

AEG continued.

Yes, good question. Apologies for not labeling those. I think those are megawatt hours.

PNM continued.

Yes, these are megawatt hours, relative to a particular year, and then cumulatively, like on Slide 22, where you show gigawatt hours, you needed to convert from megawatt hours to gigawatt hours in order to capture the cumulative effect over time of those megawatt hour savings.

AEG continued.

So, these values are cumulative in this. Like on this table that shows that's shown here [Slide 23]. These are cumulative megawatt hours. It's just when we showed it at the system level; values were very large, so we converted them to gigawatt hours.

I'm curious to know what kind of measurement, verification, and evaluation [MV&E] PNM has done on past energy efficiency programs, and if it has any plans for MV&E going forward? (Asked at January 17, 2023 meeting)
Asked by Sandia National Laboratories on January 17, 2023. View meeting information here.

Initial Response: PNM

We do. We are required to do a M&V (measurement and verification) report each year. Those reports are filed each year and posted on our website as well as filed with the New Mexico Public Regulatory Commission.

PNM Energy Efficiency continued.

Back in 2004, the state passed the Efficient Use of Energy Act, requiring utilities to implement energy efficiency programs on the premise that it's more cost effective to incentivize customers to use less energy than it is to acquire more supply side resources.

So, to prove that premise, at the end of each year, we have an independent measurement and verification contractor look at our energy efficiency programs, at what we spent on them, and at the measure life; do a net present value based on the life of those measures; and compare the value of those benefits to the year one cost of implementing those programs.

So, we do [M&V] every year. That is a public document; you can find it on pnm.com/regulatory: Scroll all the way to the bottom and you can see those reports. Only the most recent two years are posted, but if you have any historical context or interest, let us know and we'll get them to you.

Sandia National Laboratories continued.

While you were talking, I did some Googling. I think I'm looking at the 2021 report. Apologies if this is a question that would be answered if I read the whole report. Does any of the measurement and verification involve randomized control trials? I don't see any discussion of the methodology in the table of contents, so that's why I'm asking.

PNM Energy Efficiency continued.

No, they'll do regression analysis. They'll look at historical use of a specific customer and compare it to what they're doing now. But nothing randomized. We’ll look at customer measures specifically and then they will do statistical analysis or just, say, based on this subset of customers, they will apply that to the whole segment if it's a large measure, like lighting.

Sandia National Laboratories continued.

I would strongly urge PNM to consider adopting what I'll call more rigorous methods for [MV&E] on energy efficiency because there are lots of case studies of energy efficiency not quite turning out how you might imagine it would from the sort of methods you're describing.

PNM Energy Efficiency continued.

Right, making a note.

Sandia National Laboratories continued.

But yes, that's going to depend on what the PRC will allow you to do, like withholding energy efficiency eligibility from half the customer base may not fly.

PNM Energy Efficiency continued.

I think that maybe a similar thing we do is in our behavior programs, where we send, just in its most simplistic form, letters to customers, or emails or texts, informing them of their customer use.

And so, our behavior programs have a control group and a treatment group. The treatment group there may be 350,000 and the control group is 50,000. So, you compare the use of those two segments, based on the information they're getting from the customers who've never got information.

Sandia National Laboratories continued.

Makes sense.

Another dimension you can randomize is the generosity of the incentive to see to what extent the utility needs to incentivize some energy efficiency measure to get a customer response, and that would then potentially change the utility resource cost estimates of these different bundles.

PNM Energy Efficiency continued.

Yes, we do a sensitivity analysis, which is basically that, and if you look at the [lighting report], they go into detail on how they perform the sensitivity of our incentive on the lighting measures. And so that's similar to what you're saying but we also have to weigh in the cost effectiveness.

So, we're trying to maximize the incentive as much as possible. Our utility cost test is 1.0. So, yes, if all our [UCT figures] were two and a half or something, then we know that we could increase the incentive and bring that closer to one to increase participation.

Modeling
Do you look at the various "flavors" of hydrogen and the various implications of their creation in this IRP process? (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

Response: PNM

We can certainly talk about the different flavors of hydrogen. Everything is on the table.

If we were going to do some type of hydrogen project, it would have to be green hydrogen: something that's being produced through renewable energy resources, electrolysis of water, and then, put back through a turbine.

There are a lot of use cases for hydrogen but generating power from it is probably one of the least efficient use cases. So, hydrogen is not going to be the only solution. When you look at storage, both in the load pocket and at the meter, hydrogen might do a little bit. You're going to have to look at compressed air storage, maybe pumped hydro.

In the last few PNM IRPs, there have been a number of energy storage projects that have been projected to happen--some estimated to be completed by this time. How many of those are hung up by supply chain problems that have been getting in the way of the solar? Do you know about the progress of those various solar storage projects? (Asked at May 25, 2022 meeting)
Asked by RETA on May 25, 2022. View meeting information here.

Response: PNM

We are making regular compliance filings and a couple of different dockets related to the status of those projects. Specific information related to those projects is case number 20-00128. It’s listed in the April 28, 2022, Kickoff Meeting presentation, which is on the PNM website. We are also making compliance filings related to the four projects that are replacing the San Juan coal plant. Other compliance filings are in docket 21-00215 related to some delays we are having.

These are for some of the resources that were supposed to come on in 2023, related to the Palo Verde lease return and associated resource procurements to replace and expand the capacity needed to serve our system in that timeframe.

Currently, none of the San Juan solar hybrid projects are slated to make their original expected online dates, which were supposed to be June 1, 2022.

PNM has entered into a few different market purchase contracts, and we've gotten permission to run the San Juan Coal Plant Unit Four through the end of the summer 2022 to ensure we are resource efficient for the summer, provided it is no different than we've been in years past.

Two of the projects we're expecting to be on by the end of this year, or very early next year, equal total 350 megawatts of solar and 170 megawatts of our energy storage. For the other two projects, it's unclear if they'll be able to make the summer peak of 2023: They're not going to be on until sometime further down the road, likely in 2024.

Between 2024 and some of the delays for resources in 2023, we're going through a similar exercise to the one we did for 2020. Canvassing the market, we recently issued a couple RFPs for delivery in 2023 and 2024 to see what's out there and ensure that we're going to have sufficient resources, subject to those previous approved resources, which are now delayed.

There are different reasons for what is causing the delays, some of which you can read about in the compliance filings. Part of the cause was that we didn't get timely approvals to bring those resources on. Part is due to the supply chain issues. Yet another part is related to developers who could not to deliver on their promises and are transferring ownership of those projects over to different owners.

The supply chain delays are predominantly related to solar. The Department of Commerce is investigating solar dumping, which has made a lot of developers unwilling to commit to prices and making it much harder to get the panels in place in time.

Looking at energy storage, lithium prices are going through the roof right now, which is tied to the automotive industry. A large spike in the price for energy storage is expected in the near term.

Solar and batteries are paired projects. You've got to have the solar combined with the batteries in order to get the tax credits. If you can't get the solar, the developers aren't willing to bring the batteries on and forego the tax incentives that were making those projects potentially economic.

We see a number of drivers and we're going through a number of different exercises to make sure that we're going to have sufficient resources to serve our customers. We feel pretty good about this summer, but we still have some work to do for next summer. We're going to be continually reporting to the Commission on our actions.

Will the proposed scenario form allow for different scenarios? And what kind of variables can we throw in there? (Asked at June 8, 2022 meeting)
Asked by CSOL on June 8, 2022. View meeting information here.

Response: PNM

We are going to do our best to give you a variety of things to choose and then make some delineations. That said, the ELCC values are not going to be something that can be readily changed.

If the question is about resources—if you wanted to, say, require X amount of solar by such and such a year, that's something that we could work with. Further, if you wanted to, say, exclude nuclear from consideration from any future resources, that's also something that could be done.

There are some limitations, but we can work with what the stakeholders want to try to do, as long as it's descriptive enough.

The scenario form will also be discussed in a future meeting.

Update: PNM

The framework for modeling run requests was discussed during the March 15, 2023 meeting.


Let's say you're using 100 samples for your simulation. So, for each sample, how are you varying the uncertainty? Are you varying the profiles? Are you considering the extreme scenarios for renewables? (Asked at June 8, 2022 meeting)
Asked by Sandia National Laboratories on June 8, 2022. View meeting information here.

Response: PNM

Yes. We're using a weather construct, modeling 40 years of possible weather, from 1980 to the present. For each one of those years of weather, we do a simulation with random forced outages. The construct is something like 40 weather years times many random Monte Carlo draws, giving us thousands and thousands of years, effectively, that we're simulating.

How are you modeling the solar and wind profiles for all the scenarios? (Asked at June 8, 2022 meeting)
Asked by Sandia National Laboratories on June 8, 2022. View meeting information here.

Response: PNM

We don't try to forecast necessarily what the solar or wind will be. Rather, we use a weather year concept: For the past 40 years of weather, we model what would happen to the PNM system, in terms of things like load and solar irradiance and wind productions. For each weather year, we model if that weather were to happen, again, what in particular, would it look like across the year? That's how we're capturing uncertainty.

Can PNM consider if we are asked to go carbon-free before 2040, or 2030, or 2033? (Asked at June 8, 2022 meeting)
Asked by CSOL on June 8, 2022. View meeting information here.

Initial Response: PNM

That would be something along the lines of a specific scenario request: Can we set up a model to look at having an earlier carbon free requirement before 2040? That's absolutely fair game for a scenario request.

We would need to make sure we document scenario questions formally. For example, once the form is on the website, fill it out. It'll probably have something like: Here's a load forecast we want you to use, and here's the commodity forecast exemption. Essentially saying, “What are the general pieces?” Is it going to be the same as our base case, and you just want an earlier carbon-free date? And there may be other things to tweak.

This way, we've got a record of your request; we know exactly what you're asking, and we can get that moving.

Once the scenario form is up, and some of the other input parameters are set, that will help to inform the way stakeholders want to specify requests for analysis.

Update: PNM

The PNM modeling framework and Phase 1 modeling scenarios were discussed during the February 15, 2023 meeting.

The framework for modeling run requests was discussed during the March 15, 2023 meeting.

Is there any potential for geothermal or some kind of heat from the ground coming into this mix? Are we looking up to 20 years out? (Asked at June 22, 2022 meeting)
Asked by a member of the public on June 22, 2022. View meeting information here.

Response: PNM

There is potential for geothermal. We’ll look in the deck of candidate resources that we'll be modeling. There has not been that much advancement. The only geothermal operation that we have within our current portfolio has actually had trouble maintaining their output schedule relative to what they would typically forecast.

There are some new advances in geothermal, though. We're keeping an eye on them and discussing the candidate resources on geothermal technologies. It would be great if some of them prove useful because geothermal is more dispatchable than traditional renewables.

Unfortunately, geothermal has not proven to be cost effective or able to be developed in a way that can provide the output relative to what we would need.

Can you provide the results of the one-week analysis? Would they be pretty quick to perform on the portfolios that come out of capacity expansion? (Asked at June 22, 2022 meeting)
Asked by a member of the public on June 22, 2022. View meeting information here.

Pending PNM Response

We've heard that the average temperature in New York (or for PJM Interconnection LLC) was going up .7, and we don't really know what the trend is for New Mexico. I'd like to see a scenario that does take into account increased heat waves, the increased occurrence of heat waves in the summer, because that's what's going to stress your system. So, can we look at the trends we know about in New Mexico, project out increases in heat waves, and make a scenario for that? (Asked at July 6, 2022 meeting)
Asked by New Mexico State University on July 6, 2022. View meeting information here.

Initial Response: PNM

We understand the question as asking if we could somehow work into the forecast an increase in the frequency and the number of heat waves in a given year. That's something we've talked about a bit internally, including some ways to do it.

The question is more appropriately covered in our reliability, stochastic modeling, and not necessarily something that we would build into a base load forecast. But once we have a properly calibrated load weather relationship model, we could, say, go to 2021, where we saw a couple of heat waves that were pretty geographically widespread, use that as kind of a base weather system, run that through the load weather model, and come up with a load forecast where we are using a period of time as opposed to using normal weather or something to that effect.

So, as we do the 2040 hourly forecasts, we're running a daily weather pattern through and that can be anything that we want it to be right now. It has a typical hottest day in each month, typical second hottest day, and down to the typical coldest day. So, it represents fairly the range of weather that we've seen based on those 20 years of history, and the hottest days. So, we've got 20 hottest days; you average them and that's our hottest day.

(Take the hottest day from each of the 20 years, freeze the 20 years, and average them.)

That's what's driving our peak forecast right now. And the day before and the day before it--those things matter in the modeling. So, the pattern matters as well. We can put whatever pattern we want and see what the implication is.

That is captured more in our stochastic reliability modeling. And in terms of the way you know a couple of increased frequency of events affect the system, even if you're putting in a different pattern, it's still normal weather, and it's still within the same operating temperature ranges.

It probably would not have that big of a difference on the general portfolio, depending on the duration of some of those events. Maybe you start to see a bit of an increase adoption of more firm dispatchable resources or longer duration storage. But overall, the frequency of events is that it's not going to change the capacity builds that much.

And then there are parameters in the model that we can look at and anticipate the impact of an additional degree to the day, the day before, and the day after. If we go through those three parameters, there's some number like 20 megawatts per degree. We'd have to look at the slopes to know what those are.

We welcome specific requests; for example, an ask to look at three extreme weather events per year throughout the period, with an increase of one degree per year. We want specific requests that we can put into a scenario development form to make sure that we're understanding the ask correctly.

Update: PNM

The PNM modeling framework and Phase 1 modeling scenarios were discussed during the February 15, 2023 meeting.

The framework for modeling run requests was discussed during the March 15, 2023 meeting.


Are you are still planning a technical session for stakeholders in the fall to discuss the import limit? (Asked at July 6, 2022 meeting)
Asked by Brubaker & Associates on July 6, 2022. View meeting information here.
Initial Response: PNM

Yes. We will do a session about the import limit and also one on external modelling.

If there are concerns about the way we're representing the external systems to PNM, they should be raised. By the time we get to October, the ELCC work is going to be complete; the planning, reserve margin, and calibrations are going to be closed. There will still be time to change those a bit but that session in the fall is going to be more about any information that would make us believe that we ought to change the level of imports that we're putting into the model.

If there are things structurally about the model in terms of the representation of the neighbors and other things, we need to be dealing with them now. We can take a closer look, recognizing there may be some interaction with the import limitation, when we're doing the external systems where the import limit was trying to capture some things that were not being modeled as detailed as when some stakeholders are now proposing.

That overlay of the market availability constraint is because you can't perfectly represent everything, and especially those imperfect deficiencies in the market. It's not like you're bidding everything into a common centralized market, and everything's being dispatched centrally.

So, we're trying to better capture those imperfections and then discuss them. Is it going to get us to the point where we're 100% comfortable that we are capturing everything? Probably not, but we think it's going to be an improvement.

Update: PNM

Topics related to this question were discussed at the January 17, 2023 meeting.

We can concede a lot about solar. But does wind generation also factor in here? Specifically, how much does weather impact the wind generation capacity for us and where does that come in? (Asked at July 6, 2022 meeting)
Asked by a member of the public on July 6, 2022. View meeting information here.

Response: PNM

There's not any behind the meter wind generation that we are aware of, or at least not anything readily available to customers in significant quantity to put wind generation behind their meter to use as some type of behind the meter production that offsets consumption at their own meter.

We certainly need to be aware of wind and we'll be modeling wind as a transmission level resource. We are not as familiar with any real way to do distributed wind or behind the meter wind. There's also no specific forecast associated with behind the meter wind additions.

Regarding weather, the impact is big. We can dive into seasonality and other things on wind production a bit more in detail and show some plots. But generally speaking, the heaviest wind production for New Mexico is in the spring, fall, and winter, basically from around Father's Day through the end of the summer when the wind output drastically drops.

Furthermore, there's a much greater wind production overnight and early in the morning; wind production tends to fall off during the middle of the day into the early evening when our consumption is the highest. That comes through in the ELCC analysis when we're looking at developing effective load carrying capability for different resource types. We see that effective load carrying capability for wind relative to when the risk hours are. We see large capacity factors for wind, meaning the ratio of total energy produced throughout the year to its theoretical maximum. We have a pretty high-capacity factor for New Mexico wind relative to a lot of other wind resources across the country.

The major issue is that wind tends to blow when it's not as much needed. You're still left with that gap in the summer, and especially in the early afternoons and evenings in the summer when our demands are the highest. Then, wind is just not contributing as much to meeting those demands, even though it's providing a pretty good energy resource over the course of the year.

Also, other things happen. Typically, with weather, when we get those really, really hot days, accompanied by high pressure heat domes, which typically coincide with very little wind. On those really stressful, high temperature days, you tend to see very, very low wind production.

When you get really, really cold days, there are times when wind resources have to be completely feathered. You're not dispatching if ice builds up on the wind turbines or other things occur that take them outside of their operating conditions. We saw that in Texas a bit during the cold weather event in 2021. And to some extent, we saw some curtailments of wind resources in our system because they got outside of the operating conditions for which they were engineered.

What kind of fossil resources are needed for the transition to a non-carbon state of affairs? (Asked at July 6, 2022 meeting)
Asked by a member of the public on July 6, 2022. View meeting information here.

Response: PNM

We need to keep all options on the table.

In particular, some of those natural gas resources that are only used in case of emergency, 2-3% of the hours of the year, and renewables are things that enable the transition. As we're moving down this path of decarbonization, we don't need to add combined cycles. At least PNM doesn't need to add a combined cycle or anything that is going to be producing lots of kilowatt hours over the year.

Having those resources that can ramp up quickly and provide energy when needed, under extreme circumstances, and then ramp back down, provides a safety net and a backup to the system as we're going through this transmission transition. These are things we need to keep on the table and in the public eye because people don't really understand them.

Sometimes, there's a misconception about a kilowatt hour versus balancing the system in real time--understanding what the inertia and other system stability requirements are. We will get to where we can do it without fossil fired resources. This is supposed to be a transition. We don't want to take too big of a first step that can end up leading to some type of reliability event that we could have prevented.

With the sales drop off, how does that impact on PNM for generation? And what is the impact on PNM's business model? (Asked at July 6, 2022 meeting)
Asked by a member of the public on July 6, 2022. View meeting information here.
Response: PNM

Generally, there needs to be enough resources under PNM's control to ensure that we can reliably operate the system. With all of that solar coming in, especially behind the meter, we get back the idea of having to have a lot of distributed storage and things that PNM can control in real time to operate the system reliability.

Ultimately, if you're going to have that much behind the meter solar generation, it would seem that you can't have it all with a total aggregate retail rate and net metering credit because there's not going to be enough left on the system. You'd have basically less than half the system paying for all the cost and then having to pay other people for that production when the real value of that energy is not the total retail rate.

Seeing that we have to recognize the ways we have to align the pricing structures in the payments for that distributed energy, what is it really worth to make this all work correctly?

This is a large area that's probably beyond the scope of the IRP per se. There will be grid modernization--the grid of the future. These discussions will happen at the policy level with decision makers. As you move towards this new system, fundamentally, pricing cost allocation, the way the utility interacts with its customers and handles all those distributed resources. needs to be reexamined and viewed in a different light because it's not yesterday's utility system where the utility is generating power.

Centralized plants and sending energy one way down to the transmission distribution network is going to mean a much more communicative grid and a much more bidirectional grid. In order to ensure that you're really comprehending how that's all going to work and how it's got to be paid for requires a reexamination of the way we view the different components and how we price those out.

How do you factor recharging batteries into this model? (Asked at July 6, 2022 meeting)
Asked by a member of the public on July 6, 2022. View meeting information here.

Response: PNM

We will dive into this more when we do our modeling.

When you add a battery to the system, when it's charging, it's adding load to the system; when it's discharging, its serving load. We're capturing that dynamic as well the losses that come with everything.

Depending on the chemistry, or the type of energy storage, that loss is greater or less. If you're talking about lithium ion, typically, you've got an 87% round trip efficiency, if you want to fully charge your battery from a full discharge state, Let's just say it's a 100 megawatt 4-hour battery, so 400 megawatt hours. Put in 400 megawatt hours to hold 400 megawatt hours. You've got to put in 400 megawatt hours grossed up by another 15% to cover that loss.

And then once you put in all that energy--and it takes time to put it in because there's a charging rate if you have a 100-megawatt lithium-ion battery--you cannot charge more than 100 megawatts in a given hour. It's going to take over four hours to charge up that battery and that's going to be load on your system when it's charging, in order to be able to discharge for four hours later. You could discharge it over four hours, or over eight hours, but you're limited to that single volume of 400 megawatt hours in this example.

Looking at other chemistries--pumped hydro, for example, is typically 80% round trip efficient. Some of the other things we saw in the RFI from last year were that when you look at compressed air storage or flow batteries, you start getting down into 70%, 60%, and 50%. They all have different charging rates.

So, all of this is built into the modeling in terms of when we're picking the resources that go into the portfolio. The model fully sees and fully takes into account the charging rates, the discharging rates, the amount of energy, the contribution, the competing capacities--all of it. At the point when you're really, really down to that deep decarbonization, the ability to charge your batteries becomes completely limiting, especially when you have renewable droughts or other weather events that don't allow you to simultaneously fully charge your storage devices while meeting your load at the same time.

We are taking into account these different characteristics of the different technology types as we move forward. We've said in a couple of stakeholder meetings now that it's easy to think about storage--short duration and long duration storage are terms tossed around quite a bit--but eventually we need to consider the total volume of energy storage that we need and the charging rate we need to be able to store that volume of energy under certain conditions when we get into the winter with a predominantly a solar system producing much less energy because of shorter daylight hours.

If you need to charge up all of your storage in a shorter amount of time from solar, if it's a shorter daylight hour, you have to have a much higher charging rate than you might need in the summer. There are a lot of dynamics that go into this but each type of storage--batteries, pumped hydro. or other chemistries--has different characteristics. It is a matter of trying to figure out what types you need, where to locate them, and how to maximize that for efficient use of the system.

I understand that the answer to this question may be different in the near term versus the long term because I've heard PNM say many times now that we know where we're going to a zero-carbon system. How to get there between now and then? Can you address when the need pushes into the late evening, early morning hours? What do you see as the options, resource wise, to fill that gap? Bottom line: Are you aiming to fill that that need, at least in the near term, with a firm resource like gas? Or do you see some kind of battery storage capacity being able to fill that need? (E3 Study Key Finding #4, Slide 32) (Asked at July 6, 2022 meeting)
Asked by InterWest Energy Alliance on July 6, 2022. View meeting information here.

Response: PNM

The whole purpose of the IRP is to determine the mixture of resources, both near term and long term, which will best fulfill the needs of the system at the lowest reasonable cost while meeting all of our environmental constraints.

Certainly, as we you start to shift that peak or that risk out of overnight and into the early hours of the morning, a natural gas resource can meet that requirement. Storage can also meet it, if you have enough--and it's not just enough capacity of storage, but enough stored energy to last you all the way throughout the overnight when you've got to have enough resources on your system to charge while serving your other loads.

Adding enough storage will become a question of economics. When we get to 2040 and have to be 100% carbon free, it will be predominantly storage unless there is some type of hydrogen--new green hydrogen--or non-methane emitting renewable fuel that you can put through existing turbines.

Otherwise, you're going to have a lot more storage--whether it's pumped storage or lithium or flow or any other technology that's out there--but you're going to have to have enough capability of megawatt hours stored, plus some reserves to ensure you can serve those overnight loads. You might need to be able to do it for two or three days in a row.

If you want to be resilient to protect from a renewable drought, then you're going to have to have enough power electronics charging capability to charge quickly enough during periods of overproduction, to charge all of that storage up to have it ready to go, as opposed to flipping on a gas generator.

So, it can be done both ways. We're going to examine both ways. And we're going to report on the pros and cons of both throughout this IRP process.

Will there be a way for developers to know which locations will be the highest adjustments? This seems to indicate transmitted adjustments were made after bids are submitted to PNM. Will developers have access to the information later, that is to say their final project cost as calculated and adjusted by PNM? (Asked at July 6, 2022 meeting)
Asked by NMPRC on July 6, 2022. View meeting information here.

Response: PNM

If we're doing a full-blown RFP that's one thing. We need to make the distinction that an RFI and the integrated resource planning process are different from an RFP.

If we're conducting an RFP, which would lead to the actual procurement of new resources, when a developer submits a bid, they have to submit as part of that bid what their transmission costs are. That can be done by a transmission analysis performed by them or by some third party. There are a lot of engineering firms that can do that. That information would then be reviewed by PNM. If they don't submit transmission costs, or the transmission costs they submit seem unrealistic, they will be replaced by transmission costs and upgrade costs that are developed by PNM's transmission department for purposes of valuation of that RFP for the RFI.

Your question is if there's enough information in the RFI to have specific locations where we can come up with what that transmission component might be. As these offers are coming through the RFI, they'll be modeled in the IRP; we'll have to make some assumptions about where those resources might be located.

If they're all predominantly storage resources, unless we know for a fact they're going to be up in the Four Corners area, we'll apply some transmission adjustments to those. But they'll all be pretty consistent across the resources because, again, this is a pretty generic analysis.

This is not an RFP evaluation; it's an analysis where we'll be looking for the general trends. And if we start to see from these general trends that a storage technology that has, for example, a week's worth of storage duration seems to be economic--we then might be in the 2028-2033 time frame--we might put that in the action plan, and RFP will then seek to get very specific project information, including transmission costs that we would evaluate before we propose a procurement.

To the extent that developers are going to know what the transmission adjustments in the IRP are-- in the 2020 IRP transmission assumptions were in Section 7, showing the potential candidate resource transmission lines and what those costs were--that information is available, at least looking back at the 2020 IRP.

We can certainly be a bit more specific about it as we're developing the assumptions this time, but the developers have already submitted their responses to our RFI. They can massage those a little bit between now and September. Ultimately, we're going to be taking a look at that information and making our own adjustments to it to make sure that it's representative of what the additional costs would be for transmission.

It's going to be very generic. We don't have interconnection points. We don't have full load flow and other transmission studies that you would do through the RFP process.

Please give an example of what might be considered generic resource options. (Asked at July 27, 2022 meeting)
Asked by Sandia National Laboratories on July 27, 2022. View meeting information here.

Initial Response: PNM

So, what we mean by generic resource options is, there's a difference between generic resources and very specific resources that we would receive in a request for proposals.

So, by generic resources, all we're saying is that whether it's solar or storage, or wind or natural gas, turbines, or whatever other technology you want to think about, any of the resources that we're putting into the IRP, are not going to be specific resources from an RFP that would have, say, a spot in the transmission queue, and have a very specific location where they would be interconnecting, and then have a specific cost associated with that resource that's based on a bid offered into an RFP.

It would be a generic representation of that particular technology type that would have a representative cost to it. It would have an idea of the operating characteristics, but it's just not something that's specifically out there in our transmission queue. It would have an idea of the operating characteristics, generic siting costs, and construction expenses and an expectation of what property taxes, permitting, and interconnection would be.

Some consumer advocates acknowledge that this is a heavy lift for software programs. And yet, we know that huge computers exist in the world. Could you simply resolve that and do this really complicated multivariable modeling by investing a lot more money in your software? I realize that there are real constraints to the money you want to spend but if you spent more, what could you do? What's really possible out there? (Asked at July 27, 2022 meeting)
Asked by InterWest Energy Alliance on July 27, 2022. View meeting information here.

Response: PNM

This is not a software issue but a hardware issue. The simple answer would be you could throw more and more and more horsepower at it (the problem), but it doesn't necessarily mean that you're going to get to a better solution all that much quicker. The algorithms that are used underneath of (the current software(s)) are highly parallelizable; however, if you were to try to put all of this into memory at once, the problem is scale--when you're talking about just a binary integer problem, binary mixed integer problem, the problem size and complexity scales with two to the N, where N is the number of binary variables, if we have 20 years representation in there, and we have even just our system size and say you've got 300 different resource candidates, and some of them are thermal units like on the existing system.

Refer to September 24, 2019, IRP presentation when we were talking about problem size that's got 150 zeros after it in terms of the number of different choices that are out there. And you could paralyze this over hundreds of different computing nodes, but it doesn't necessarily mean you're going to get to the answer quicker or a more optimal solution. As for cloud computing, there's a misconception out there that with cloud computing, that we can just go out there and throw everything into these problems at once, solve it, and get the perfect solution. That's just not the case.

The computing technology that will allow us to make very significant progress to solving these types of problems much, much quicker is quantum computing, where you can represent variables not in a binary state where current digital computing works and you’ve just got processors that use “bits” that represent all values in terms of ones and zeros, where quantum computing is not limited by binary states and represents values using complex quantum mechanics.

That type of computing infrastructure will allow you to solve these problems much, much quicker. There's just not that much out there, that type of computing. It's still very early in its infancy and being worked on. The computers require significant engineering infrastructure to house the computer to ensure nothing interferes with the quantum states of the processors and commercially available computers as well as the reprograming of software to run on quantum architecture are still nowhere near ready for commercial deployment.

Are these results using the zonal model, or are you assuming a copper sheet model? Adding the nodal model and assessing/comparing computational tradeoffs with commitment constraints may be interesting to evaluate. (Asked at July 27, 2022 meeting)
Asked by Sandia National Laboratories on July 27, 2022. View meeting information here.

Response: PNM

These results are using a zonal model. We're not using a copper sheet model.

Yes, it'll be interesting to move forward and see what the nodal model does. What we can say is that with the nodal model right now, if we wanted to run a full representation of the entire western interconnect, enforcing full commitment of the resources, just for production costs, it does not include capacity expansion.

A single year run takes a little over 24 hours to solve. So, you could extrapolate on that and say to do 20 years we're going to need more time. And yes, we can parallelize some of that. Maybe year one doesn't clearly need to lead to initial conditions for year two.

But then if you wanted to throw the capacity expansion on top of that, that's a really, really big problem because you'd have to come up with some representation of the transmission system. Then, on the DC load flow side to put into the capacity expansion, force all those constraints, may be something that is just computationally intractable.

We'll be doing some testing on that going forward. It may take a year and a half to develop some simplifications and come up with a more constrained zonal model based on information you glean from the nodal model.

There might be some other things you have to do but, currently, the way things are typically done is you're not doing a nodal capacity expansion merely due to the computational intractability.

Based on Slide 15, it seems pretty safe to assume that those lower cost energy efficiency bundles are going to be selected by the capacity expansion plan. So, I don't see the harm in free solving the model and saying, if the energy efficiency bundle costs less than $35, less than $25 a megawatt hour, just force it in and don't spend the computational power to figure out what should be obvious. (Asked at July 27, 2022 meeting)
Asked by Sandia National Laboratories on July 27, 2022. View meeting information here.

Response: PNM

That's certainly another approach, We could force everything that's $35 or less, or $50 and less, and still have the $50 bundle as a choice variable. Or, instead of just doing $50, do 50, to 60, to 70, to 100 and divvy that up.

But the one thing we see here (Slide 14) is, as we go out in time, the very small tranches were actually the highest cost tranches. So, we need to make a note to go back and double check and make sure that the color scale on this slide is correct.

But, as we're moving up in time, generally what we saw is the amount of available energy got smaller.

What is it going to take for you to include thermal storage? (Asked at July 27, 2022 meeting)
Asked by CSOL Power on July 27, 2022. View meeting information here.

Response: PNM

We are not taking any options off the table.

We did have some thermal storage offered in an RFI last year. The concepts were not fully developed enough for modeling, unfortunately. We're still going through the RFI this time. If there's enough detailed information for us to put that into our Integrated Resource Plan, we certainly will.

We are not discounting or precluding any types of storage. Using existing or new technologies, we have to make sure we have enough detailed information to model accurately, or as best as possible.

When you assume the renewable energy drought, did you assume less need? (Asked at July 27, 2022 meeting)
Asked by CSOL Power on July 27, 2022. View meeting information here.

Response: PNM

The answer to that is no. We were taking the renewable production that was typically used in our, reducing the renewable production, but keeping the load at the same level as before.

That might not be a 100% correct assumption, but part of it is due to the expected proliferation of behind the meter generation such that when we have a reduction, say, in solar, we're going to see higher loads due to the reduction in the behind the meter solar that's reducing what's seen at the meter typically.

How feasible is pumped storage in the desert Southwest and New Mexico? How much water is consumed through evaporation? What are the assumptions about water availability during summer peaks? With monsoon failure? (Asked at July 27, 2022 meeting)
Asked by InterWest Energy Alliance on July 27, 2022. View meeting information here.

Initial Response: PNM

So, there are two projects that we’re aware of that were offered into the RFI last time. The information associated with evaporative losses was presented in the disclosure of the RFI and the public advisory process last year. There is a pretty reasonable amount of evaporative losses.

There are two projects that are currently going through the Berg licensure process that we’re aware of in the desert Southwest here, in terms of the water availability during summer peaks. That really gets down to your question about the evaporative losses. It would be a one-time fill of how many acre feet. We can go back and check the presentation from around January 2020.

So, once you’ve got the water filled in the water rights, I believe one or both of these projects might have been on tribal lands, and the water would be coming through the water rights and supportive of coming from those tribes that would be in support of these projects. And then there would be evaporative losses, but beyond the evaporative losses, it’s more of a closed loop system. It’s not within the river networks.

With monsoon failure, again, these are one time fill and then you’ve got the evaporative losses to account for each year.

The pumped hydro assumptions were covered in the 2020 presentation and the 2020 IRP. There was information as well within the IRP write up. We need to go back and double check if the evaporative losses were fully documented in the IRP.

Update: PNM

The evaporation rate and pumped hydro assumptions for RFI response in the 2020 IRP were not disclosed. PNM has researched the evaporation rates associated with pumped hydro systems and can provide the following information:

Pumped hydro systems can be open or closed loop: An open loop system is connected to a flowing water feature (like a river), while a closed loop system is not (the same body of water is moved back and forth between reservoirs). Evaporative losses from the reservoirs will depend on a multitude of factors, including the climate and area in which a project is sited, the size of the reservoirs, and whether or not those reservoirs are covered. Coverage of one or both reservoirs can substantially reduce evaporation.

PNM issued an RFI for Resources Available for Future Generation in March 2022 and received two responses from pumped hydro storage developers. Both responses described a closed loop system with an initial reservoir fill of approximately 5,000-acre feet, with expected refill due to evaporation of about 500-acre feet per year (~10% of initial fill) if both reservoirs were left uncovered. However, both proposed projects included a plan for coverage of at least one reservoir to control evaporation. Other water discharge was estimated to be negligible.

A presentation covering the RFI responses was given on October 17, 2022


What is the renewable contribution to total generation assumed in 2035? When this scenario is run, where are you at in your ETA ramp? (Asked at July 27, 2022 meeting)
Asked by NM RETA on July 27, 2022. View meeting information here.

Response: PNM

The ETA between 2030 and 2039 requires us to have 50% of our retail sales coming from RPS [Renewable Portfolio Standard] eligible resources. From 2032 to 2039 there are also requirements that we are serving our system with an average carbon intensity of 200 pounds per megawatt hour or less. So, those two items would be reflected in these simulations.

This is not something that we need to dive into in too much detail at this point--or what the total amount of renewables are. This is more a proof of concept on improving the long duration storage modeling.

The best answer to some of these questions can be found by reviewing the scenarios in Appendix J in the 2020 IRP, where you could get an answer, based on the scenario and sensitivity, regarding what the total amount of renewables on the system were versus other resources.


Could you be specific about what parameters from this PHS (pumped hydro storage) analysis would feed back into Encompass capacity expansion models? (Asked at July 27, 2022 meeting)
Asked by New Mexico State University on July 27, 2022. View meeting information here.

Response: PNM

What we're talking about is one of the parameters within Encompass called net inflow and net outflow in the capacity expansion model.

When we're looking at the amount of energy in excess of what was dispelled from the reservoir in a given month, what are we expecting the net increase in the reservoir level to be from month to month, or the net decrease in the reservoir from month to month, would be an input for the capacity expansion model to make sure that there was a representation.

The capacity expansion is looking at a representative on peak day and off-peak day for each month. And then, based on the number of days in each month, it is scaling up the operational characteristics from that representative on peak and off-peak day to come up with a representation of what the total costs and total operating parameters were, based on that simplifying assumption, even though it is doing an hourly piece and ensuring that the chronology is maintained.

Now, one of the ways that Encompass maintains the chronology for resources within the capacity expansion model is that it will say that the last hour of a month must be equal to the first hour of a month. And that gives it a kind of cyclical chronology. And you're not saying. "Okay, well, I could go from, say, August 17 to September 11 and then back to August." Rather, you're always doing a loop back of, say, August before moving to September.

Because of that, you have to give it an idea, then, of what you would expect--the net position relative to that starting and ending monthly or that it would be increasing or decreasing to allow for these seasonal shifts, or month to month shifts of energy.

So, we can run a simulation that gives us an idea of a full year memory--the entire problem is going into computer memory at once, giving it perfect foresight of all of the conditions as it's solving that problem simultaneously for each of the variables.

We take that information and then feedback from it to better represent the resource and the capacity expansion. That will then allow the model to give a better idea of which additional, renewable, or other resources are needed or not needed, given the longer-term storage resource.


Are the capital costs of the specific storage technologies a viable parameter in the modeling? Or is the storage cost model a generic unit cost? (Asked at July 27, 2022 meeting)
Asked by NM RETA on July 27, 2022. View meeting information here.

Response: PNM

The cost by technology may vary dramatically.

There will be a cost tied to each technology type when we're looking at generic resources. So, there would be a capital cost variable operating cost, fixed operations, maintenance cost, and safer pumped storage--which would differ from lithium-ion storage, which would differ from combustion turbines, which would differ from any number of other things.

Each individual generic technology type is represented with its own individual cost, operating parameters, and efficiency cycles.

What is the minimum duration requirement that was built into the assumptions for LDES technologies? (Asked at July 27, 2022 meeting)
Asked by Sandia National Laboratories on July 27, 2022. View meeting information here.

Response: PNM

There is no minimum duration requirement per se. We are doing this as a proof of concept. This particular proof of concept is looking at a rather large, but known, potential pumped storage hydro project that was a 1500 megawatt under 1000 gigawatt hours, so maybe almost 70 hours of duration.

There are other technologies out there that we're aware of that are 100, 150, or more hours of duration--lithium, you can just stack more cells on--and so, we're not looking at this and saying there's a minimum duration requirement to qualify as long duration storage. What we are looking at is: What are the different technologies out there, and how do they, given their efficiencies and other things, start working within the context of our system?

We've said this in different stakeholder meetings, and we think that really what we need to do at some point is disaggregate the idea of duration. You need to have an idea of what the total volume of energy storage and megawatt hours are going to be on your system. Then, you should have an idea of the most constrained periods, which are going to be--if you're looking at charging from solar--mostly in the winter, when you've got the shortest daylight hours.

And what is the charging rate? If we will need to fill storage, we need to have that volume of storage necessary to meet hourly, daily, weekly, and seasonal demands going forward. So, there's no prescriptive duration per se that denotes long duration versus short duration versus medium duration.

We're going to need all of those on our system and we're looking at the modeling techniques that will best allow us to compare the tradeoffs of costs and benefits associated with those different technologies.


Following up on the question about water availability, broadly, how much activity is being seen on promoting evaporation reductions of systems that have been used in other parts of the world, such as the ancient canal system from the Middle East, and also in Peru, where aqua like structures run underground? This is just clearly an issue beyond the IRP, but I'm putting it on the record here. (Asked at July 27, 2022 meeting)
Asked by a member of the public on July 27, 2022. View meeting information here.

Response: PNM

We're going to be focusing on the water associated with the pumped hydro, as well as the utilization of water by the other parts of the system within other generation technologies. We agree that if we want to have a fully sustainable society, we're going to have to start looking at closed loop systems, including under underground systems for water delivery.

That doesn't necessarily mean we're going to limit everything. Trying to fix leaking underground pipes when they're buried is pretty difficult. So, there's a lot of work that needs to be done overall to move to a truly sustainable society. Right now, we're obviously focusing on the electric system here in New Mexico.

Considering that to even consider hydrogen--the power generation industry is energy intensive--is dangerous and takes away from an easily decarbonized electric grid. How do you justify this analysis? (Asked at July 27, 2022 meeting)
Asked by CSOL Power on July 27, 2022. View meeting information here.

Response: PNM

We are considering all options at this point. The industry is looking at hydrogen, considering the modeling techniques to make sure that we are looking at this in the most rigorous way. Most utilities out there, if we look at them, are keeping hydrogen on the table as a mechanism for energy storage and it could be part of a decarbonized system.

We believe we are in line with the industry view that this should be considered as part of an IRP analysis.

Looking at the payback and generation plots (Slide 28), I was just curious about the terminology payback first generation. It sounds like difficult math: If you're getting more than you're putting in. (Asked at July 27, 2022 meeting)
Asked by Sandia National Laboratories on July 27, 2022. View meeting information here.

Response: PNM

The payback is the term that's being used for the amount of energy being put into the system to be converted and stored.

So, the round trip on the hydrogen that we've got here is roughly 28% round trip efficiency. We've got to put in, say, three and a half megawatts from the grid to get one megawatt back to the grid, after being converted, the hydrogen, stored, and then put back through a turbine.

The turbines were roughly 10,000 to 10,500 heat rates, so the turbine itself was about 500, or 33% efficient. Hydrogen has about 1/3 the heat content of gas, and there's the power needed to run the electrolyzer [hydrogen generator]. So, this system here is about a 28% round trip efficiency.

If you compare that to pumped hydro or lithium, those are in the 80, 85, 87% range. And then other storage technologies fall in between.

The 28% may be a bit rosy. We're trying to use some data from manufacturers that are working on developing and selling each of these components; we're relying on some of that data. We don't have an actual hydrogen system on our system, or hydrogen production system on our system that we can actually pull live data from.

The payback is charging energy that includes all of those pieces, to get to the point where it can, then, come back to the grid.


What did the results look like with higher medium import assumptions rather than low import assumptions (Slide 30)? (Asked at July 27, 2022 meeting)
Asked by InterWest Energy Alliance on July 27, 2022. View meeting information here.

Response: PNM

Those results are in the 2020 IRP at the end of Appendix M.

The other things we have been talking about are those import assumptions, especially out into the 2035-2040 time frame. We do not expect that there's going to be near the surplus of energy in the market, especially during non-solar producing hours.

If we consider the transformations of most of the systems in the West, you're building in assumptions that we can rely on our neighbors to charge our storage devices, or that they would potentially sell us energy out of their storage devices to help us meet our net peak loads. We think this would be an incorrect assumption, until we can move forward in time and see what's really going on.

As a utility, we know that if we only have four hours’ worth of storage, and we’re not sure whether we’re going to need it in a few hours, we're not going to sell that to somebody. Right now, and going forward, the predominant source of energy, as we saw from the regional resource adequacy study performed by E3, is going to be solar and storage additions.

So, the idea that we're going to have a lot of available imports to charge our storage devices, especially during off peak, is just something we don't think we can support.


What is the proposed percentage of hydrogen to natural gas for the combustion turbines? (Asked at July 27, 2022 meeting)
Asked by CSOL Power on July 27, 2022. View meeting information here.

Response: PNM

We're showing a proof of concept on the 100% hydrogen utilization in a year far down the road, towards the end of the 2030. These are once we get to a carbon free system.

Blending presents its own unique characteristics: There is work to be done in terms of modification of plant equipment, pipelines--all the things that would need to be accommodated for hydrogen blending. Also, volumetrically, hydrogen contains 1/3 of the heat content of natural gas. So, even if you were to do a 50/50 blend, volumetric-wise that doesn't represent a reduction of carbon by 50%.

So, in light of pathways to 100% carbon free, blending doesn't really get you there. Blending might reduce a little bit of carbon, but you'd have to volumetrically add in 80 or 90%-- volumetrically blend 80 to 90%, hydrogen relative to 10 or 20% gas just to do 50% reduction in the carbon emissions from that type of setup.

From the modeling we've done, all of the graphs are from 100% hydrogen.

What's the readiness technology level for burning hydrogen? (Asked at July 27, 2022 meeting)
Asked by CSOL Power on July 27, 2022. View meeting information here.

Response: PNM

There are facilities in operation today that can do this. PNM does not have any on its system currently, but there are certainly turbines out there that can burn 100% hydrogen. There are some that will need additional work to get them up to burning 100% hydrogen, depending on which turbine technology and company you are looking at. There is certainly already the ability to electrolyze water into hydrogen and store it.

So, the technologies exist. It's really a matter of which turbine you want to use, what the costs are, and where we see those going.

For the most expensive energy efficiency bundle, maybe it would make sense to model that and multiple bundles if the EE products are different. (Asked at July 27, 2022 meeting)
Asked by Brubaker & Associates on July 27, 2022. View meeting information here.

Response: PNM

For some additional information on the EE (energy efficiency) bundles and how they're developed, AEG will return to discuss that when their study is complete. But you can see some of the information in the August 25 presentation in the 2020 IRP.

Each bundle comprised a number of different measures. For each year, the characteristics of each measure are used to determine what the weighted average life and weighted average price of that bundle is. Certainly, one of the ideas that we've mentioned earlier was that perhaps it makes more sense to break apart that $50 bundle and do a few different price tranches—50 to 60, 60 to 80, and so on—and then, for each deal, determining which price points you wish to measure and what the overall shape of each bundle would be, given the measures that are in that bundle and those price points.

We can consider all of these ideas with AEG and provide them direction on the ways we want to do the different tranches of the bundles.


Would PNM like to comment on whether the source of hydrogen matters for meeting RPS requirements--whether the current RPS requirements or lifecycle are purely at the point of degeneration, or how and if that is a part of the overall IRP analysis, especially in the longer timeframe? (Asked at July 27, 2022 meeting)
Asked by NMPRC on July 27, 2022. View meeting information here.

Response: PNM

Hydrogen is not a renewable energy resource under the Renewable Energy Act, so hydrogen in and of itself, whether it was produced by renewables or produced through some other process like steam methane reformation, would not count towards meeting the RPS.

Any hydrogen production of generation would have to be a part of the 20%. If we're looking at 2040 and beyond, it would have part of the 20% of generation that could be attributable non carbon emitting resources, but not necessarily renewable resources. Depending on the resources that are used to produce hydrogen, whether they are renewable resources, or whether you do it through steam, methane reclamation, or some other process, additional renewable resources on the system could count towards the RPS and increase the percentage of RPS that we're meeting.

That being said, the Energy Transition Act requirements relate to retail sales. And it's not necessarily that the loads from electrolyzers would necessarily be retail sales. That could be considered station service or other things.

So, there are a lot of little nuances that would go into this issue and how the regulator's would view each of those pieces. But the RPS is a percentage of retail sales. And it is related, not to life cycle, but specifically to the amount of energy we are required to deliver to the retail end use customers.

Whether additional regulations or laws come through in the future that talk about full supply chain emissions and other things remains to be seen. In the Integrated Resource Plan requirements, we have to meet our renewable portfolio standards that are relative to generation production by renewable eligible resources under the Renewable Energy Act, and that ratio of the production to retail sales--whether it's 20%, 40%, 50%, or 80%, corresponding steps from 2020, 2025, 2030, and 2040.

Does ignoring generator minimums by using partial instead of full commitment for the capacity expansion miss some of the value storage provides by charging during periods when generators are at a minimum? (Asked at July 27, 2022 meeting)
Asked by Grid Strategies on behalf of InterWest Energy Alliance on July 27, 2022. View meeting information here.

Initial Response: PNM

If we go back up and look at these plots (Slide 13), what we actually see is that there's greater storage utilization in the partial than in the full commitment. We attributed that to the fact that, in this situation, you could commit at lower than the actual minimum load.

So, when we think about this, there's a binary variable that represents whether or not a unit is committed. Under the full commitment, that binary variable in a given hour would represent a zero or a one but in a partial commitment, It could represent, say, a point for the 40%. That 40% would then be applied to the minimum loading of, say a CT, if it's minimum loading, say it's 100 megawatt CT, and its minimum loading is typically 40 megawatts.

Now, rather than doing that, if you do the partial commitment, it's 40% of 40, or 16 megawatts. So, then we can have our thermal unit committed at a lower level, which allows for greater storage utilization. If we still need to commit that thermal unit under full commitment, but it's committed at a higher minimum load because the percentage is no longer applied--it's either a zero or a one--you actually end up seeing a little bit lower utilization of storage.

PNM continued.

We've done some testing on the capacity expansion and partial commitment. And for the most part, we're seeing the same resources, the same expansion plan, and in both scenarios, we're seeing the same resources being added on both sides.

So, from at least the capacity expansion side, we don't think we're missing, anything,

InterWest Energy Alliance continued.

I can see how it can go both ways. It does look like in that slide that it reaches a little bit lower dispatch in the earlier years in the partial commitment, but then it does do better in the last year.

We're basically going to be curtailing renewables because you've got your pure thermal generation running at its minimum. And the storage can provide value by charging and absorbing what would have been renewable curtailment, if the minimums are lower, removed entirely, then that benefit is less appreciated.

But we can see also how that can be offset by what you were talking about, that effectively, the partials give you lower minimums on the thermals.

PNM continued.

The thing to take away is that, in our testing, whether we're running a partial or full commitment on the capacity expansion itself, it is just computationally intractable. But that is not the case when we do some limited tests. And were we to do, say, a full commitment on a shorter time period, or reducing the system builds, it ends up being the same whether we're doing partial or no or full commitment.

That gets into the same idea we had here (Slide 12): having a three-step process where we're starting with a simplified solution.

When we have our more simplified representation and settings, and when we have to put more and more years of data and choices into the model, then, as we move forward and move down, we've got the expansion locked. But we need to make sure we're getting the right representation of long duration storage. Then, we can move down further and do a full commitment.

So, by the time we get to the end, and the overall system metrics that we're reporting, we've gone through various levels of details and got down to a full commitment.

We are getting pretty comfortable with the way this is working. There's no computationally perfect solution at this point. But all the tests that we're doing right now at least are showing that this process is working very well. And by the time we get to the end, we do have the full representation of all the commitment decision variables when we're running the production costs.

Slide 31 shows that if you had, say, a 100 megawatt 4-hour battery storage system, you could dispatch it for 50 megawatts for 8 hours. Would that have any effect on the life of the batteries themselves, or are there any concerns along those lines? (Asked at July 27, 2022 meeting)
Asked by NMPRC Utility Division Staff on July 27, 2022. View meeting information here.

Response: PNM

Discharging at a lower rate would not have much effect on the batteries. Typically, the factors, at least with lithium, that most affect the overall life of the batteries are if you go through deep discharges, multiple cycles per day, actually keeping energy stored in for too long.

A lot of the vendors are telling us that over the course of a year you want to have a 40 to 50% average state of charge. So, discharging it over a longer window would actually reduce the number of cycles you would have in a given day or over a given year. It may actually limit the degradation as opposed to add to it.

Has the recent decision in the Supreme Court of the United States decision regarding EPA air quality program and implementation affecting requirements for PNM CO2, as used for IRP purposes? (Asked at July 27, 2022 meeting)
Asked by NM RETA on July 27, 2022. View meeting information here.

Pending PNM Response.

Thank you for the review of the RFI results. Very interesting. Are there technologies or projects that you expected to receive responses on but did not? (Asked at October 17, 2022 meeting)
Asked by InterWest Energy Alliance on October 17, 2022. View meeting information here.

Initial Response: PNM

We were thinking we would see more folks who had offered responses to the previous RFI in 2019 update their responses to some degree. We only got that for a few of these submittals. So, we were a little perplexed by that. But that's not to say we're going to discount or ignore any of those previous submittals. We'll continue to work with the labs and other folks to evaluate where those technologies are, and try to get updated cost estimates, among other things, for those technologies.

It's like the Rumsfeld quote: “the unknown unknown.” We don't know what not to expect or what to expect, because some of these things are so new that you just don't know what's out there. And we're trying to cast a broad net, to get as much information as we can.

So, this is not going to be the last time we do this type of exercise. I think you'll end up seeing this as a part of our IRP process going forward, trying to get as much information out there as we can.

Maybe fusion was one that we would have hoped to have seen, but we didn't. We've had a few interesting calls with some folks on that. That's always been on the radar; it seems like that could be the silver bullet, but we didn't get any fusion informational responses.

Are these storage ponds [on Slide 22] open or covered? (Asked at October 17, 2022 meeting)
Asked by a Member of the Public on October 17, 2022. View meeting information here.

Initial Response: PNM

We had multiple submissions, and all of them had plans to cover at least one of the reservoirs. The water usage associated with pumped hydro, not counting the initial fill, is mostly associated with evaporative losses. So, developers now are coming up with innovative ways to cover the reservoirs to really cut down on those evaporative losses.

Member of the Public continued.

Would PNM consider that a primary feature that has to be included in any pumped hydro system?

PNM continued.

That really comes down to the cost benefit analysis. Minimizing water usage, especially in a water constrained region, such as the desert southwest would be very, very important, but we would need to get better information on the evaporative losses both with and without the covers as well as the cost of the covers maintenance, things of that nature.

And whether it would end up being a third-party project that is contracted to us just through the operational output or whether it'd be something that PNM would be constructing or having constructed and taking ownership of.

All of those different factors that go into play but holding all else equal, having something that reduces evaporative losses is way better than something that does not.


In the past, we've seen some basis differences between the New Mexico and Texas sides of the Permian, partly due to a lack of gas processing capacity in New Mexico and less pipeline takeaway capacity here. That trapped gas in New Mexico can help lower price for New Mexico utilities. Has that changed? (Asked at November 2, 2022 meeting)
Asked by a Member of the Public on November 2, 2022. View meeting information here.

Initial Response: Siemens

We do consider that. So, part of the model that we have looks at demand and supply. So, if supply is decreasing, we reflect that. And if demand is increasing, or decreasing, that's reflected as well. So, we look at how much gas is flowing on each pipeline to determine what the base is or the price is at those hubs.

A lot of that Permian gas not only obviously goes to serve the LNG export market, but it also goes to Mexico and some of that gas actually flows across to Arizona and California as well.

So, there is gas. That Permian gas is going out west more. In terms of prices, because you have a shorter leg, and the fact that you have a Permian price or Waha price that's below Henry Hub, that's why you would see lower prices in New Mexico. Does that answer your question?

Member of the Public continued.

Yes, that that was what I was driving at. Part of the New Mexico gas used to have to travel into Waha, and then to get west. So, it sounds like all that's taken into account.

Siemens Response continued.

One more comment.

The upper band there [on Slide 19] for CO2, we look at that as a P95 type case.

Another way we also look at it is in terms of if the political system or government was very keen on achieving this as an environment where everybody agrees, you get some action. And then, in that case, you could say, “Okay, well, we agree that climate change is a big problem, we're all going to do whatever needs to happen to solve that.” And if everybody kind of works together, then this is what that black line could look like.

But in reality, we know people don't necessarily play that well in the sandbox. And then you get those other scenarios.

How has volatility been incorporated into gas forecasts after winter storm Uri? Is there a method to back cast this methodology to test its accuracy? (Asked at November 2, 2022 meeting)
Asked by InterWest Energy Alliance on November 2, 2022. View meeting information here.

Initial Response: Siemens

When we do volatility, we do volatility in three increments.

For the first three years, we go back and look at the volatility that's happened over the shorter term. And then, as we move past the medium term, we use a five or 10 year. And then, when we go longer term, we use 15-year prices to come up with those volatilities. So that's what's reflected in our analysis.

We don't necessarily say, “Okay, well, something happened last year, so, let's reflect that going forward for every year.” We're still more conservative from that standpoint, in terms of how we model.

Initial Response: PNM

So maybe that'll drive another question, at least on our end. When you're talking about the statistical envelopes, let's say, your P10, P50, P90 values, and you're coming up with some baseline and then getting an envelope around that statistically, you're having to put in some volatility parameter--whether it's a mean reverting GBM, or whatever, statistical stochastic process you're going to fit around that.

And you're [likely] going to use some historical data to parameterize that stochastic process.

And so, you are likely capturing the increased volatility from gas prices that corresponded with the hurricane Uri event when determining that volatility parameter that you would use to determine your envelope. Is that right?

Siemens continued.

Yes, exactly. We are using historical. It's just that the historical we're looking at is, for the shorter term, sort of what happened in the near term.

And then, longer term is based on more typical 15-year type volatility.

So, we are looking at historical volatility. And I believe, I'm not the quant [quantitative analyst], but we look at daily volatility over those time periods to come up with the three areas of the forecast.

PNM continued.

And typically, at least with stochastic models, it's not like a deterministic process where you're going to go back and try to ensure a back cast; this is closely to a single point estimate as they call that in the statistical terminology. But you would want to ensure that you’re within your stochastic process outcomes, that you're talking about a 90% confidence interval, and that what you might have seen historically fits within that.

So, maybe the better question, or could we address, is if we were looking at the envelopes that are generated is a Uri type event and the volatility associated with that potentially going to fit within that envelope, or is that such an extreme case, that's more of a one-in- 100-year type of event that would be outside the typical confidence bands.

Siemens continued.

I would think if you have a one-in-100-year [event], it would probably be outside of the confidence bands. However, some component of that would be reflected in it. So, we don't look at that year and say, "Okay, well, every year is going to be like that. Let's see what that looks like."

You mentioned stochastically, when we do the stochastic analysis, we effectively have a band that goes from P5 to P95. And that's again developed statistically, like you said, but I would say, "No, an event like Uri could be outside the 95th percentile.”

But keep in mind, this is a P90 on the gas side that we have. So, if we were to do a P95, it might capture that.

PNM continued.

Right, and then when you're simulating out those stochastic processes, whether you're doing 100 or 1000, or whatever simulations, and typically, in a random walk style analysis or something similar, there's always the probability that that Uri style event could manifest through that random process.

But the probability of that is going to be very, very low. So, the question would be, maybe, "How many iterations or how many forecasts would you have to simulate before you see something like Uri?" And Uri was a pretty extreme event. So, I'm assuming we would think we would have to generate a very large number of random walks in order to see that type of event manifest.

But you're again, just trying to address the question here.

InterWest Energy Alliance continued.

But I guess my question is really, how [do we do] weather modeling [if]--I think there is an understanding--extreme weather events are becoming more common and not going to remain the same? So, I think looking at the historical likelihood is probably not the way to accurately capture the next 20 years of these events if--and I think the

agreement is on the weather modeling side--these historical events are going to become more often and potentially more than a one-in-100-year event.

PNM continued.

When we're talking about weather, we would tend to agree with you. And so, in terms of the weather that goes into our renewable production profiles and our demand forecast, that is a little bit different. We would leave it up to Siemens to talk about how that may go into the gas forecast.

But specifically talking about the gas forecast, we, through the Energy Transition Act, can't add any heavy carbon emitting resources. We're not looking to add coal plants or combined cycle facilities, something that's going to have significant carbon emissions due to the RPS requirements, the carbon free requirements, and the carbon intensity requirements that we have to meet.

So, really, the natural gas price forecast, for all intents and purposes, is really going to drive the utilization of our existing gas fleet. And that's already in the ground and not really subject to future looks at until we start thinking about when we're going to get out of those plants. Any type of new natural gas additions would be very low capacity factor, peaking plants that would be used solely for reliability purposes, break glass in case of emergency.

So, we don't think that trying to get extreme weather analysis into the gas forecast is necessarily the best use of resources, given the framework that we're looking into here. And when doing planning, we're always starting with a weather normalized load forecast, and then we're trying to get production profiles renewable that are associated with those. And then we'll start to look at changes and things.

So, you'll remember that the resiliency report that we did, and talked about in our second and third meetings, kind of drew out some key differences between different portfolio types and how we might address the resiliency needs of the system--it will be generating, and we'll be talking in our next meeting about the load forecasts that we'll be using, along with weather normalized load forecasts that will be used for planning and different scenarios. We're also going to be looking at some P90 value forecasts and how that might change the overall planning requirements.

So, we would say that the discussion on weather is more targeted, we would think, to the renewable production profiles and the demand forecast, not necessarily the gas forecast here.


Are the capital costs for the CT (Combustion Turbine) [reflective of a] 100% hydrogen capable turbine? (Asked at November 2, 2022 meeting)
Asked by InterWest Energy Alliance on November 2, 2022. View meeting information here.

Initial Response: Siemens

These turbines are probably not. Most of your utility scale turbines are the larger ones, and they're generally speaking, depending on exact model 30% [hydrogen] capable today with little to no change.

There are some models that are 100% capable: They tend to be the smaller machines, think more like 50, 60, 70 megawatts, units that used to be more in oil and gas service running compressors in the field. We're used to using sort of weird gas combinations and things like that. These can be upgraded for nominal cost over time if needed. That's actually an interesting option to think about in later years--to keep assets sort of functioning and useful as hydrogen becomes available.

Initial Response: PNM

That's exactly how we looked at it in our last IRP, and we were planning in this IRP that there's no requirement that we have to burn 100% hydrogen today; we just have to meet our RPS, our carbon emission intensity requirements, and eventually the 100% carbon free requirements.

To the extent a natural gas, aero derivative, or combustion turbine could be brought on the system for capacity purposes, run a few percent of the hours in the year to maintain reliability. and then, over time, be converted to 100% hydrogen capable when we need to be 100% carbon free and adding on a conversion cost at that point, that is how we handled it in the last IRP.

As indicated, the conversion costs, especially when you think about going forward in time, are going to be pretty minimal. There's not that much that really needs to be done to the turbine, It's just the fuel injectors, the first set of blades, some things that are not a complete overhaul.

Siemens continued.

That's correct. The bigger challenge may be just the hydrogen getting the same amount of energy. Hydrogen is sort of roughly three times the volume of natural gas. So, there may be some piping changes. But the turbine itself is not too bad. Control systems are a real nominal upgrade.

It really depends on how far you're going to go. You can phase it over time, go from 30%, to 50%, to 70%, to 100%, kind of stage your cost. if you will.

PNM continued.

Right. And as indicated, volumetrically, you need almost three times the amount of hydrogen, the relative natural gas due to the lower heat content. And so, even if you're doing heavy duty blending, until you do 100% hydrogen, you're probably not getting much past 50% carbon reduction even without an 80% blend.

Siemens continued.

So, you can get some advantage for a certain price, and each project can be sort of considered on its own merits.

PNM continued.

We are keeping all options on the table. We don't think that hydrogen is a silver bullet. There's a lot of different things that are going to go into decarbonizing the system, but certainly something like hydrogen that can provide long term storage can provide reliability functions. A little bit of inertia and spinning masses and other such things has a lot of benefits to it. And there may be other benefits outside of just the power electric generation sector for hydrogen, such as the transportation sector, heating sectors, things like that.

Siemens continued.

That's right. And the IRA (Inflation Reduction Act) provides a lot of support for hydrogen and some of the other decarbonizing technologies.

PNM continued.

Right. And that's not built into these forecasts, as you've indicated. These are all pretty [much] IRA, capital assumptions.


Do the battery costs include total system cost, and do they include augmentation? (Asked at November 2, 2022 meeting)
Asked by rPlus on November 2, 2022. View meeting information here.

Initial Response: Siemens

These are total system costs. These do not include augmentation. If augmentation is appropriate for a given client arrangement, if you want to keep the capacity at a certain level, then we build that in when we do the modeling. So, we'll phase out a certain portion of the capacity and add it back in at the price and at the time appropriate.

How long a timeframe for project operation economic life will you use? (Asked at November 2, 2022 meeting)
Asked by rPlus on November 2, 2022. View meeting information here.

Response: PNM

That's really resource dependent. It depends on what type of technology and what type of resource we're talking about. For something like energy storage, it’s probably the battery energy storage --lithium ion--that's going to be in the 15-to-20-year life[span] and the same thing for solar, but maybe solar will be 30 years. We have to take a look at what we're getting from some of the technology manufacturers. Same thing for wind. When we think about natural gas, combustion turbines [are] probably going to be a little bit shorter of an economic life to reflect being carbon free by 2040.

In the last IRP, we assumed we would depreciate any new natural gas resources by 2040. But then in 2040, they would incur a new capital cost to convert them for full hydrogen operations; that would start a new depreciable life.

For some of the other things that we're seeing in our RFIs, the longer lead time and larger plants like pumped hydro, using something more like 40 or 50 years is probably not inappropriate. And then for some of the other technologies that are a little bit more nascent, we'll have to do some research and determine what we think is appropriate for an economic or technological life that we'll be using.

All that will be published in our Integrated Resource Plan appendices--maybe Appendix I. We have to double check that, but one of the one of the appendices requires us to publish all the different candidate technologies we're looking at and the different economic life, technical life, operating characteristics, capital costs, things of that nature.

Where in the futures and sensitivities models do you factor the possibility of decentralization impacting on demand for PNM services? (Asked at November 2, 2022 meeting)
Asked by a Member of the Public on November 2, 2022. View meeting information here.

Initial Response: PNM

Do you mean decentralization of resources or decentralization of load? Could you clarify?

Member of the Public continued.

It just seems that looking far into the future, where the possibility is of people to kind of fork off, requiring PNM or backing up at home with their own batteries, all that kind of thing.

It may be too early, but I just keep wanting to see that somewhere rattling around in our thinking because customers could peel off in different ways. And that could impact the company in many ways. So, I don't know, it's probably demand.

PNM continued.

Thanks for clarifying.

The way that this is being considered is through our demand forecasts. The IRP, again, looks at just PNM's retail customers. If a customer were to become completely self-sufficient, and no longer be a part of the PNM’s retail system, they would not be included in the load forecast. That's not an obligation we would have to serve.

If the customers are incorporating their own resources behind the meter through additional adoption of behind the meter photovoltaic (PV) rooftop solar, essentially adding their own batteries behind the meter, those are things that we are incorporating through the load forecast.

So, we have a specific component in the load forecast that assesses a forecast of behind the meter PV adoption. And there's going to be four or maybe five different behind the meter PV forecasts. One of them will be trying to back out all existing PV on the behind the meter PV on the system. One will be assuming there's no new incremental behind the meter PV. Then, there's going to be three different incremental behind the meter PV forecasts.

And so, each of these forecasts can be used as modifications to the overall retail load forecast and would reduce the amount of system requirements that would have to be added and, in turn, reduce the amount of retail sales to support those customers. That would be accounted for--with additional behind the meter storage additions.

Again, that would end up depending on how [those modifications] are operated. If they are operated just on behalf of any individual customer for their own benefit, that would manifest through a change in the load shape in one way.

On the other hand, if we were to look at the establishment, once we have AMI (Advanced Metering Infrastructure), of perhaps a distributed energy resource management system, we can start to model the behind the meter resources as something that has full visibility--not just a load modifier, but a dispatchable combination of resources that PNM could operate or dispatch, through an aggregated system for the benefit of the entire system. Thus, that would reduce the need for additional resources on the system.

Those are the ways we're thinking about it for this integrated resource planning cycle, and we'll have to continue to think about it going forward. Additionally, there's going to be independent forecasts for different building electrification as well as transportation electrification forecasts. And then a time of use, or time of day rate pricing sensitivity that will say, "Well, if enough customers joined this time of day pricing program and modify their behavior, how might that change the overall requirements of the system?"

So, that's the way we're looking at, at least from the supply planning point of view. And we would always keep in mind as well, when we're establishing what the needs of the system are, and we determine that so much solar might be needed, or so much storage might be needed, even if it's coming in at the utility scale, that it doesn't mean it's something that has to be done by the utility. It could always have a part for the customer to enable them to be part of the transition, so long as the resources are dispatched for the benefit of the system, and not dispatched for the benefit of any specific customer.

We know that this has been an ongoing question for years. And we hope that [this response] helps to think about the way we're looking at it this go around, from the integrated resources planning point. The key has to be about just what are we doing for our retail customers? And then how can we take lots of small, distributed resources, and think about how they could be aggregated up to the system level. Because when we're looking at the IRP, it’s always looking at the bulk transmission system; we're not modeling down to the distribution levels.


What is the minimum duration requirement that was built into the assumptions for LDES [Long Duration Energy Storage] technologies? (Asked at July 27, 2022 meeting)
Asked by Sandia National Laboratories on July 27, 2022. View meeting information here.
Response: PNM

There is no minimum duration requirement per se. We are doing this as a proof of concept. This particular proof of concept is looking at a rather large, but known, potential pumped storage hydro project that was a 1500 megawatt under 1000 gigawatt hours, so maybe almost 70 hours of duration. There are other technologies out there that we're aware of that are 100, 150, or more hours of duration--lithium, you can just stack more cells on--and so, we're not looking at this and saying there's a minimum duration requirement to qualify as long duration storage. What we are looking at is: What are the different technologies out there, and how do they, given their efficiencies and other things, start working within the context of our system? We've said this in different stakeholder meetings, and we think that really what we need to do at some point is disaggregate the idea of duration. You need to have an idea of what the total volume of energy storage and megawatt hours are going to be on your system. Then, you should have an idea of the most constrained periods, which are going to be--if you're looking at charging from solar--mostly in the winter, when you've got the shortest daylight hours.

And what is the charging rate? If we will need to fill storage, we need to have that volume of storage necessary to meet hourly, daily, weekly, and seasonal demands going forward. So, there's no prescriptive duration per se that denotes long duration versus short duration versus medium duration.

We're going to need all of those on our system and we're looking at the modeling techniques that will best allow us to compare the tradeoffs of costs and benefits associated with those different technologies.

Is anyone recovering the H2O after hydrogen combustion at utility scales? (Asked at July 27, 2022 meeting)

Initial Response: PNM

That's something we can definitely look into and see if we can find any information. There are some closed loop test systems out there. If anybody's doing that at utility scale up, it's just in test systems at this point.

Update: PNM

We haven’t been able to find specific discussion regarding projects that implement a water recovery system after hydrogen combustion. We expect as time progresses, more information will become available.

For more information concerning current pilot projects, Clean Energy Group produces a list of hydrogen pilot projects across the US which can be found using this link: https://www.cleanegroup.org/ceg-projects/hydrogen/projects-in-the-us/

So, the on-peak non-solar hours, the reason that's higher, that's mainly due to the fact that those would be your morning ramp and your afternoon ramp prior entering the evening hours? Is that right? (Asked at December 15, 2022 meeting)
Asked by PNM on December 15, 2022. View meeting information here.

Initial Response: Siemens

Correct. So, your load is still high, but your solar generation is not quite there so it's your kind of 8 a.m.--I think on peak solar is 8 a.m. to 5 p.m.--and your 6pm to 7pm time period is included in those on peak non-solar hours.

PNM continued.

My other question is, are you using the standard block--like, 6 by 16, 6 days a week--as the on peak definition and then the subset of the on peak solar is at 8 a.m. to 5 p.m.?

Siemens continued.

Right. We just broke out the solar hours.

This curve to me does not show any penetration of storage (referring to Slide 14). Is that correct? (Asked at December 15, 2022 meeting)
Asked by InterWest Energy Alliance on December 15, 2022. View meeting information here.

Initial Response: Siemens

It doesn't necessarily reflect it very well in this curve, but there is storage built into these prices.

PNM continued.

Each of the portfolios uses an optimized capacity expansion in order to come up with the overall penetrations of solar wind storage, everything across the WECC in order to meet the total WEBB capacity and energy requirements. The prices from the dispatch, or what's shown here, are based on those optimized portfolios.

Siemens continued.

These two graphs are the same. They represent the same exact thing, just at a different pricing hub. So, any storage that was built within the capacity expansion for the overall West region is reflected in these price curves. And so storage may have alleviated it.

I couldn't tell you exactly what this graph would look like if storage was not included,

But even despite the fact that there is storage, you do still see kind of a pretty intense duck curve.

Does the Palo Verde on Slide 14 refer to the pricing at the Palo Verde hub, or the price and the Palo Verde power plant? (Asked at December 15, 2022 meeting)
Asked by Sandia National Laboratories on December 15, 2022. View meeting information here.

PNM Response

It's the hub price. Spot price trading to occur at the Palo Verde hub to reflect going forward.

My question goes back to your slide [Slide 11] on your market drivers and capital costs in particular. You mentioned a number of factors that you looked at on those cost assumptions and one of them was some preliminary assumptions on the IRA [Inflation Reduction Act]. I'm wondering if you can give us some more clarity or detail on what your assumptions were on the IRA. I understand the rules have not come out. It's early days for everyone but I'm wondering how you took that into account. (Asked at December 15, 2022 meeting)
Asked by InterWest Energy Alliance on December 15, 2022. View meeting information here.

Initial Response: Siemens

So, these particular lines, or outlook, these graphs don't reflect the IRA. We have a couple [charts] here, and these are preliminary. These were developed shortly after the IRA was passed in August [2022], so there are probably some minor changes that have gone forward into this.

But as of this outlook we have a solar ITC at 30% through 2032, dropping to 26% in 2033 and then 22% in 2034 and then down to 0 after 2034.

After that, there is no ITC for solar, hybrid solar, hybrid solar plus storage, and standalone storage.

And then we have a 15 dollar wind PTC going through 2033, as well as a $15 PTC for SMRs until 2032, and a $35 PTC for CCS units through 2033.

PNM continued.

Just to clarify. Those assumptions were worked into the capacity expansion when you [Siemens] developed the power prices, but what's shown on the screen here does not have those assumptions worked in. And we are working with Siemens right now to put together the specific updates.

That will reflect that before we actually get into the overall hierarchy modelling. These curves were developed, and the scope of work was developed initially before the IRA was ever passed. So, that's why these are presented right now without the IRA impacts.

I'm not quite following all that pricing that was just presented [in response to that question from InterWest Energy Alliance on cost assumptions--regarding Slide 11]. Could we get a slide or something to show that in the future? (Asked at December 15, 2022 meeting)
Asked by a member of the public on December 15, 2022. View meeting information here.

PNM Response
Yes, we can revisit all of the IRA assumptions.

What Siemens just spoke to was the provisions of the tax credits that are listed in the Inflation Reduction Act that was passed back in August [2022]. And then they were just saying, specifically, what each of the individual tax credits were that could apply to the different technologies.

I understand the curves here [Slide 11] don't reflect or include these PTC assumptions, but do you have a sense at this point how much [the IRA (Inflation Reduction Act) tax credits] will affect these price curves? (Asked at December 15, 2022 meeting)
Asked by InterWest Energy Alliance on December 15, 2022. View meeting information here.

Initial Response: PNM

Of course, there will be an effect. I think the most important question is: "What will the relative economics be between the different technologies when [the IRA tax credits] are applied to all of the price curves, and what attributes are provided by the different technologies in terms of meeting the overall demand and energy requirements while maintaining reliability of the entire system?"

We heard Siemens say that in their capacity expansions, which didn't model all of the IRA tax credits, they saw predominantly solar, storage, and aero derivative or other combustion gas turbines being added in order to meet the flexible ramping requirements of the system.

InterWest Energy Alliance continued.

I guess my question still is do you have a sense of the extent [the IRA tax credits are] going to change your analysis here, or what you're showing in these graphs? Is it going to be a significant effect or do you think it's just tweaking without really changing the trend here at all?

PNM continued.

These curves here are just talking about the overall cost, not the revenue requirements.

Revenue requirements would take the tax credits into account and again it's really the relative economics between the resources that are going to determine what the overall portfolio is. So, we don't know that we're prepared to speculate on any individual technology curve here--how it may or may not be impacted by the tax credits.

Again, what Siemens says, and what we would expect to see likely in our analysis as well, is you're going to see a proliferation of renewable resources, energy storage resources, and likely some combustion turbines in order to help with those flexible ramping requirements until you get to a point where you can't have any carbon emissions.

Could you elaborate on the methodology used to obtain the hub pricing forecast? You mentioned that you did a capacity expansion model on the Western interconnect. Did you then run a nodal production cost model for each year, or the forecast obtained from the capacity expansion planning model? (Asked at December 15, 2022 meeting)
Asked by Sandia National Laboratories on December 15, 2022. View meeting information here.

Initial Response: PNM

It's running a zonal pipe and bubble format across the entire WECC but doing an 8760 for each year.

Siemens continued.

Yes, that is exactly it. So, we do run our capacity expansion to get the overall WECC build out. And then from there we incorporate that into the WECC; we run a zonal 8760 with the various price hubs. There are different bubbles and we just get it from that zonal output.

PNM continued.

And that's very similar to what we're doing in-house behind the scenes here at as well.

We've brought in the full Encompass national database as well as the nodal version of Encompass.

We're still getting the nodal version of Encompass calibrated, but you wouldn't expect to run that for every year; you might do a few years of nodal analysis.

But for the internal price generation that we're doing, it's a very similar method to what Siemens has done here--taking their international gas price forecast and other market drivers, running them through a capacity expansion, and then a zonal production cost within Encompass as well.

So. here, what we're seeing is the results of the Siemens analysis from the bottom up.

Will the hub prices change as the IRA [Inflation Reduction Act] credits are included? (Asked at December 15, 2022 meeting)
Asked by a member of the public on December 15, 2022. View meeting information here.

Initial Response: Siemens

Our preliminary view of the IRA tax benefits are included within these hub prices. The PTCs and the ITCs that were incorporated while creating the build out were incorporated into this particular model and baked into these particular prices [on slide 14].

PNM continued.

So, these prices would already have embedded within them the effects of the IRA.

[Speculating], this would be more reflective, still, of overall a bilateral trading, or maybe even a quasi-day ahead market.

But, maybe [if Siemens would] comment on the dispatch, it's not a bidding logic, though, that you would see in an overall organized market structure.

You would probably think that the prices, especially in the solar hours, if solar resources are taking PTCs and offering them into a market, like the wind resources in MISO or SPP, at high negative prices, could actually put a much further depression on prices in an overall organized market structure.

Siemens continued.

Right, and there is a bidding availability within Aurora, so you can [model bids] at those negative prices. [For modeling purposes], it usually isn't necessary to bid those negative [prices], since solar hours already have such low cost--[solar is] going to generate that free energy, because it's got a PTC.

But [IRA tax credits are] largely used within the capacity expansion model, and the selection and the economic benefits of being selected within the capacity expansion and the overall choices for the capacity expansion, not so much for the dispatch costs necessarily, although it does; it is included within the dispatch costs as well.

I have a question about the carbon price forecast. Could we flip back to [Slide 10]? The reference case forecast reflects a carbon policy starting 2025 ... On the federal price, do you do you foresee any possibility that the incoming Congress will pass this, a federal CO2 price, or what exactly is the story that would explain a federal price going into effect in 2025? (Asked at December 15, 2022 meeting)
Asked by Sandia National Laboratories on December 15, 2022. View meeting information here.

Initial Response: Siemens

I personally cannot quite comment on this one in detail.

Carbon and the gas prices were viewed in a little more detail by someone else. I'm more than happy to jot that down.

PNM continued.

We can take that back.

Overall, the thought process that we've seen with carbon price development is we've been anticipating federal action for a long time. And there really hasn't been any for purposes of getting a baseline target here. We don't view this as being unreasonable. It may be offset by a year or two, but we do anticipate that in the future there is going to be some type of federal action; it's just a matter of when it starts.

Overall, the carbon price forecast really isn't going to be a predominant driver in the overall selection of resources, mainly due to public policies requiring specific RPS requirements or carbon emission reductions.

Whereas in the past, you might have needed that carbon tax in order to incentivize different actions, at this point, given all the public policy agenda items that are out there for various entities in the WECC, it's those things that are going to be driving the portfolio changes, and any potential carbon action on the tax side is less of a driver.

Sandia National Laboratories continued.

Yes, that makes sense. I would tend to agree that the capacity selection will be driven by RPS and tax credits, but I imagine the carbon price assumption may affect the production cost modeling in terms of clearing prices for power; if the marginal unit is a combustion turbine, the power price will be different, depending on whether or not that resource is subject to a carbon tax.

PNM continued.

Certainly, and we would imagine that if we look at some of the hourly data, that we see greater effects of the carbon prices on market prices for the nonsolar hours in the near term. But as the underlying portfolio changes over time, as you move further out in time, there's less and less impact of any CO2 price on the overall hourly market prices.

I was just wondering if we could obtain copies of Siemens' slides. (Asked at December 15, 2022 meeting)
Asked by PNE USA on December 15, 2022. View meeting information here.

PNM Response

Yes, all of these slides will be posted to our website following the presentation here today. So, if you would just check back on the website, you'll see that any of the presentations from this meeting or previous meetings can be downloaded there.

View Slides Here

In your trends that you're seeing -- if you could go back to your high temperatures [Slide 26] -- I understand that's [an average] over 24 hours. But are you seeing an increase in daytime temperatures or are you seeing an increase in nighttime temperatures or are you seeing both or neither or a blend? (Asked at December 15, 2022 meeting)
Asked by InterWest Energy Alliance on December 15, 2022. View meeting information here.

Initial Response: Itron

Yes, we've been looking at that. Overall--the growth--there is some warming. It's on the verge of statistical significance; it's T-statistic is close to 2, a little under. It's about a half degree for a decade.

So, it is there in the day; you see it if you look at the darker orange numbers. There's a few more days above 85 as we move to the right, except for 2003, which has the most days, so, it kind of pins it down on the left.

But, yes, there is some warming going on, but it's nothing like what we will see when we get to the extreme scenario. That's a way past what we would ever get from a global warming scenario, if we did one.

InterWest Energy Alliance continued.

I'm just wondering if you're seeing that primarily in daytime temperatures or nighttime temperatures.

Itron continued.

It's a little bit of both.

The nighttime temperature is a little tricky. You basically have a very dry climate there and so the nighttime temperature can drop pretty fast. Unless it's humid, and then they kind of get stuck at the dew point. And so, there is some of that going on.

We've seen that in other places that the highest high isn't necessarily getting that much hotter, but it's not cooling off as much at night.

It's warming, but a lot of the warming is not in terms of hotter days; a lot of it is in terms of less extreme cold days.

Do the behind the meter PV numbers include community solar? (Asked at December 15, 2022 meeting)
Asked by a member of the public on December 15, 2022. View meeting information here.

PNM Response

They do not. The community solar is going to be interconnected on the distribution system. It's not going to be behind a customer meter. That will be accounted for on the supply side, not on the load side.

Looking at the nonresidential curve on that top graph [Slide 33], and it looks like you're assuming or forecasting that nonresidentials, which I assume include both commercial and industrial--kind of your medium commercial and your larger load customers--are going to be adopting some behind-the-meter generation, but not at the same rate as residentials, or not to the same extent. Is that the trend that you guys have been seeing so far: that commercial and industrial customers don't want to use behind-the-meter so much; they just want to use more of PNM’s system? (Asked at December 15, 2022 meeting)
Asked by InterWest Energy Alliance on December 15, 2022. View meeting information here.

Initial Response: PNM

We can't speculate on the reasons they would or would not choose to do behind-the-meter solar, but what we can say is, from the interconnection data and what is presented here, initially, the nonresidential installations exceeded the residential installations. But in more recent history, and what we expect to see going forward, there is a much greater adoption rate for residential customers versus nonresidential customers.

Itron continued.

Yes, it crossed over in about 2016. They were tied and then the residential has just taken off compared to the nonresidential. And there were some big additions here in the water and wastewater area, where they have sort of put in enough solar to sort of zero out their loads in the high price-10 years period for them. For some of those, there's actually a reason why they've taken it to the point that they have.

InterWest Energy Alliance continued.

I just was wondering what your assumption there was based on. Is it based on what you're seeing now, what you hear from commercial and larger customers and what their plans are in the future, or is it just a guess essentially based on not much?

Itron continued.

The residential tracks real well with the EIA, Energy Information Administration, forecast for the mountain region in terms of kW per household, and the business one tracks real well with their kW per square foot, kW per employee kind of numbers.

So, that's what we've sort of tied into there.

Could we elaborate on the assumptions used for the increase in the residential solar, and does this assume full AMI [Advanced Metering Infrastructure] deployment? (Asked at December 15, 2022 meeting)
Asked by Sandia National Laboratories on December 15, 2022. View meeting information here.

Initial Response: PNM

The underlying assumptions would be more along the lines of there's no hosting capacity issues, there's no delays in interconnections, tax credits are extended, etc. All of those types of things that will influence the overall customer behavior.

Now, this, again, is not up to PNM to tell customers to go and do this. We can't force them to do anything. This is all up to customers and whether they want to spend their own money on installing these systems.

Itron continued.

Yes, that sounds right. There is a point if you extend this line at that slope for another 20 years or so, where it creates problems. There's got to be a place to put [the solar generation]. There are definitely things that are going to have to be done to support this level of adoption.

Does this also assume that net metering is allowed to continue, is that an implicit assumption within the model, or is that not considered? (Asked at December 15, 2022 meeting)
Asked by PNM on December 15, 2022. View meeting information here.

Itron Response

I don't know that there's an explicit assumption on that, but certainly anything that's tied into recent adoption rates, those adoption rates reflect whatever arrangement is in place.

And, obviously, if you change that and say, instead of giving you full retail price, we're going to give you the marginal value of that, that would be a big difference in terms of the economics for the customer.

Does this electrification scenario [Slide 41] incorporate the new IRA [Inflation Reduction Act] tax credits and rebate programs? (Asked at December 15, 2022 meeting)
Asked by New Mexico Attorney General's Office on December 15, 2022. View meeting information here.

Initial Response: Itron

No, not explicitly.

PNM continued.

This would be an assumption that there's some New Mexico policy that's enacted that requires all new construction to be electrification-only and incorporate some conversion of existing homes and dwellings from natural gas heating to electrified heating. Is that correct?

Itron continued.

Yes, it would probably take PNM's involvement to make this happen. Some sort of incentive to get people to make these changes because it's costly--the change to convert systems.

So, we didn't model this is an economic decision given tax incentives and all that. These are the assumptions: When a new home was built, it's no longer going be natural gas or propane, and that 2% convert. Those are sort of the assumptions behind the scenario.

For this analysis on the rates [Slide 42], was it considered to be a voluntary or a mandatory time of use rate? (Asked at December 15, 2022 meeting)
Asked by Sandia National Laboratories on December 15, 2022. View meeting information here.

Initial Response: Itron

What turns out, if it's voluntary, is that people have to opt in. Some people will do that, especially if it's advantageous to them.

But, if it's an opt out program [where] it takes some action on your part to not get put on it, then most people just stay on it because, from their perspective, they don't even really hear about it or know about it.

So. this is an opt out program and the assumption is that 20% of the people opt out, 80% stay on the program.

PNM continued.

So, in other words, it's a mandatory time of use rate for residential customers, beginning in 2030. But as your fourth bullet there says, you're assuming that 20% of the residential customers who are put on this program opt out of it.

Itron continued.

Right.

I'm seeing your numbers here [Slide 31] about your peak, your summer peak day being 2.6 degrees warmer, your winter peak day is 12.2 degrees colder. I'm going to reiterate my [previous] question [to be clearer.] For example, the summer peak day, being 2.6 degrees warmer. Is that effect more from nighttime temperatures being warmer or daytime temps being warmer? And then same question for your winter peak day being 12.2 degrees colder. Is the larger contribution to that from nighttime temps being colder or daytime temps being colder? I understand what you're looking at is an average [Slide 29]. I'm just wondering--you may not have this information--but. in developing your average, were you able to notice or identify whether the contribution to the change in temperature is more from daytime or nighttime? I understand you might not have done the analysis. I'm just wondering if when you did, did you notice that at all? (Asked at December 15, 2022 meeting)
Asked by InterWest Energy Alliance on December 15, 2022. View meeting information here.

Initial Response: Itron

We didn't really study that and it doesn't show at all here.

These are just the average temperatures and. in fact, in the actual modeling of the hourly loads, we just use the daily average temperature at this point. We're not actually using the hourly temperatures, although that's certainly possible. But we didn't. We're just using current days--average temperature in the prior two days--average temperature to drive those hourly models.

I'll go ahead and put something together that looks at this top row.

And we'll just get the mins and maxes, just see what see what, in fact, we're doing for this hottest day, [what] is the average of this day.

And those days that have a max and a min, we can certainly look at them, and all these days have a max and a min.

So, we will just look at them all and see what we think.

InterWest Energy continued.

Thanks.

It just seems like that's an important consideration. I understand from climate research that especially here in the Southwest, some of the effects we may be seeing in temperature, in average temperature increases, may be more from increases in nighttime temps versus daytime temps.

But that of course may have effects on your loads as we've been seeing here and all your graphs and so on.

So, I just think it it would be useful to kind of tease out, if you reasonably can, what is actually driving those changes in temperature, and whether that makes a difference to your forecasts.

Itron continued.

Yes, we have all the hourly data, so we certainly can pull those max and mins up.

On the modeling side, at least, you're calibrating 24 different hourly models to that daily average temperature. And so, I'm assuming, of course, those are going to be statistically significant. So, you're capturing the effects of the increasing daily temperature, whatever the daily temperatures are on an individual hourly basis. It's not like you're ignoring the hourly piece of it. And so, if you were to change this framework up and look at more hourly data on the temperature side, you'd be recalibrating each of those models and it probably is not going to change that relationship much. And when you do this, each time you reforecast a load, you’re recalibrating to more current load/weather relationships. So, if there is a change in that relationship, that's going to be captured within the calibration process before you reforecast. (Asked at December 15, 2022 meeting)
Asked by PNM on December 15, 2022. View meeting information here.

Initial Response: Itron

Yes, that's true.

The actual hourly model uses data, let's say, maybe 2017 to 2022, somewhere in the last 5 years or so.

It is possible to do hourly models that use the hourly weather hour by hour and we often do that in operational forecasting systems. So. next day forecasting.

But for the sort of more long-term look and just load shape forecasting, it just becomes more complicated-- especially defining normals, so instead of using an actual hourly weather forecast, now you're having to define normal hourly weather, which gets us into these issues, like, what is the right thing for the low and the high.

So, a lot more there, but there is definitely the possibility to go down that path in future efforts. if that's an important thing to do, to actually use the hourly weather data in the models.

PNM continued.

But from your work, so far, what you've seen is that's more important in near term, operational forecasts and less so, in long term, 20 year resource, planning type forecasts.

Itron continued.

Right. In the operational forecast we're bringing in hourly cloud cover and hourly wind speed, and solar radiation, and all those things.

Even then, it's not just the current hours temperature; the lag hours matter as well. And even the prior day.

So, it's a much more complicated model and it's worth doing that extra complication for that short-term, operational forecasting.

PNM continued.

On the long-term side, it's not necessarily worth that, what we need to make sure, what we do, is have a reasonable enough forecast capturing some of those extremes.

That will allow us to have a system that's resource sufficient, having enough reserves to make sure that if we get into the operational hour and things are going a bit different than expected, we've got that additional capacity to ensure we can safely and reliably serve our customers.

As I'm reading it, the high PV [photovoltaic] scenario included 1,141 megawatts of total PV on the system [Slide 35]. Looking at the 2020 IRP most cost-effective portfolios (MCEPs), the no-new-combustion scenario, obviously that's the scenario that would end up with the most PV, and that portfolio has 3,165 megawatt hours of solar. This doesn't line up in my mind that our high PV scenario from last time around [which] appears to be 3,165. You seem to have about one third as much solar in what you've modeled. So, maybe someone can explain this and if not, would you please do a scenario that matches what I expect will come out again this time in the model? (Asked at December 15, 2022 meeting)
Asked by New Mexico State University on December 15, 2022. View meeting information here.

Initial Response: PNM

You're actually comparing apples and oranges there.

What we have here is the behind-the-meter PV impacts. And if you look at that bottom right plot, you'll see that there's actually a little bit more than double the amount of expected behind-the-meter photovoltaic additions that customers would put behind their meter in this IRP forecast compared to the 2020 IRP.

When you're referencing the 2020 IRP, it is the amount of utility-scale solar additions

that were added over the forecast period.

So, what we would expect likely to occur is, because there's so much more behind the meter solar photovoltaic in this IRP, there probably is going to be a decrease in the amount needed on the utility-scale side.

New Mexico State University continued.

Okay, that makes sense. So, right, because [Itron is] forecasting load, and this is part of net load, it's important to their modeling, but the system,wide resources provided by PNM probably don't factor in here. Do they factor in anywhere?

PNM continued.

If we go back to the slide that shows the hourly loads and the effects of the behind the meter PV [Slide 52 "Hourly Loads"], the yellow there is the effects of the behind-the-meter PV. And so then anything that's not in yellow, we're going to be designing the system to meet those new customer demand and energy requirements.

And so, if we think there's going to be more and more of that load met by behind-the-meter photovoltaic, we're going to have less utility scale, we would say energy resources, but we're going to need still probably just as much if not more storage and other capacity resources in order to make sure that we can reliably serve our customers.

Now, when we put this into the model, we will have within the model, the loads, the meter PV. And then [we would] be optimizing a capacity expansion portfolio around that for utility scale resources that will meet the rest of the customer demand and energy requirements.

[Speculating], this is more than double the amount of behind-the-meter PV [currently on the system], [and, when also considering the community solar additions], we're going to see less overall utility-scale solar added to the system as a result.

New Mexico State University continued.

Okay, [that] makes sense about the behind-the-meter as I look at this lower plot

where almost 1000 megawatts of power is provided by solar in the middle of the day. That must be all the solar. Right? Not just behind the meter?

PNM continued.

No, that's just behind the meter.

New Mexico State University continued.

So, where is the other solar?

PNM continued.

This is all relative to the load forecast. [This is only the BTM solar embedded in the load forecast].

[On slide 54] it seems like there's a lot of different variables there with different high, medium, and low assumptions. And then there's probably even more. I guess you do have economic forecasts in there. So, I guess, in general, there's a lot of variables with three different choices. So, it turns into a very large combinatorial problem. I was just curious if you could comment on the methodology for coming up with these different combinations. Was it based off of just going back and forth on what scenarios you think are critical and would have an effect on your IRP outcomes? Or was there some other kind of mathematical scenario reduction techniques out there? That might be getting too into the weeds here. When do you know when you feel comfortable with all these scenarios and how you book-ended them? (Asked at December 15, 2022 meeting)
Asked by Sandia National Laboratories on December 15, 2022. View meeting information here.

PNM Response

This table kind of originated as a work product between us, Itron, and some other consultants that we work with, in developing the IRP.

And the purpose of the IRP is to make sure that we capture enough different future states of the world to be sure that our plan is robust enough going forward, that we can pivot as needed, depending on if circumstances have changed. So, this represents what we thought [was] a good combination of likely future states of the world from the load forecast point of view.

And then we've got different combinations of sensitivity factors and otherwise that would affect what the assumptions are on the supply side and economics associated with resource choices.

Yes, this is really what we're thinking would capture the range of the envelope that we would need to put together on the load side to be comfortable that whatever future state we have is going to be somewhat in there, that we've done modeling associated with it.

And we can start to, if we think we've missed something, for example, [we could] take some differences between cases that are similar, except for one sensitivity factor. We [could then] isolate that sensitivity factor and then maybe add that on somewhere else.

That's the general reason, or the general rationale behind these various scenario definitions--thinking to ourselves what are the things that we think will really be the main drivers in the load forecast, and how might they change as one-off scenarios, or within combinations with each other, and then how will that then flow through to the overall portfolios that we need to think about as we're developing our plan for the future.

Is the BTM [Behind the Meter] solar assumed to be mostly fixed-tilt? (Asked at December 15, 2022 meeting)
Asked by a member of the public on December 15, 2022. View meeting information here.

Initial Response: PNM

The behind the meter is pretty much all fixed-axis, especially for the residential.

Itron continued.

Yes, I would say that we're assuming that [new installations reflect current installations regarding fixed-tilt].

My personal guess would be that it's almost all fixed-axis. But really [what we're] using is your measured generation data, so whatever mix is in your base is also in the forecast.

But again, my assumption would be 99% fixed or more. I don't think I've ever seen a rotating residential system. Most of the commercial system is parking lot shading kind of systems. It's all fixed. Wastewater guys, maybe, they did some [tracker systems].

But whatever is in the historical data is; we're just [using that mix]. We're just forecasting it to remain that way.

Can a residential customer participate in the pilot without having a smart meter installed? (Asked at December 15, 2022 meeting)
Asked by Sandia National Laboratories on December 15, 2022. View meeting information here.

Initial Response: PNM

[To clarify, you are asking if a customer would], in order to participate, either have to get an AMI meter or an interval meter of some sort, or could they participate with a legacy [meter]?

PNM (Pricing) continued.

No, what will happen is this: When someone signs up to be on the pilot, their existing meter will be swapped out for a cellular interval meter. So, it has to be an interval meter so that we can study, we can do load research, and [we can] understand how things are shifting.

We don't have AMI [Advanced Metering Infrastructure], so these are cellular meters. These are the same type of meters that the transportation electrification program is using also to load research for the EV rates that we have proposed.

And so, they cannot participate without having one of these new meters.

If you were a customer that had a behind-the-meter photovoltaic [BTM PV] system, and you were getting a net metering benefit on the current residential 1A rate, would the value of net metering from BTM PV change as the time-of-day rates are implemented or if the customer enrolls in the TOD pricing structure? (Asked at December 15, 2022 meeting)
Asked by PNM on December 15, 2022. View meeting information here.

Initial Response: PNM (Pricing)

Right now, because they're welcome to sign up for the [1 B] time of day [pilot] rate, it's not restricted to non-solar or anything like that. But there is that issue of then they're paid out of the rates in effect when their solar is generating. So, it's true that it is not probably a rate that they are going to want to sign up for at the moment.

But going down the road, because we would like to move to having time of day rates for the entire customer class, and at some point, making them mandatory, that is the long, long-term goal of this program.

But it's also true that this wouldn't be the only rate and there would be customer choice ... recognizing all these different things that customers bring to the system. When we design a new rate for a new customer class for net metering with rates specific to them -- that's a possibility too. In which case, it could be a time- of-day structure, but [one] that recognizes benefits that solar brings in or something like that.

So, that's certainly one of the issues that is in the issues section that we think about and that we want to talk about with the PRAC (Pricing Advisory Committee), that we talked about internally because having just this one time-of-day pilot be the only thing in 15 years is not our end goal. This is just one option.

And this is our first step to study who is interested in it, who can respond, and how we can make this better for the whole customer base.

PNM continued.

It could be, like you said, if there needs to be a different rate structure, maybe that helps the BTM PV folks, but also recognizing that the value of solar to the system goes down over time (as more and more of it is on the system).

Although a fair point to this would be is that this type of structure that you're promoting, even if you have behind-the-meter PV, it could incentivize behind-the-meter storage as well, to take advantage of that short duration, but high priced, net peak period.

PNM (Pricing) continued.

Exactly. And then when they discharge, they get a different price as well. The structure recognizes that. And so, that's a totally different paradigm than what we have right now, but it's what's coming. And so, we need to discuss these issues now so that we're ready.

PNM continued.

And in an ideal world, we want to see storage with every piece of solar that's out there. In order to make the system work as best possible, we want to incentivize storage as much as possible.

PNM (Pricing) continued.

For sure. Pricing and rate design is all about providing the price signals that encourage consumption that benefits the grid, the system, and the customer base as a whole. So, this is the first step at designing something better than what we have right now.

[How] might changes in usage patterns be included in the pilot as more people continue to work from home instead of going into a central workplace? (Asked at December 15, 2022 meeting)
Asked by a member of the public on December 15, 2022. View meeting information here.

Initial Response: PNM (Pricing)

We would expect to see just the usage patterns of residential change from being a spike here in the morning [referring to Slide 74], as people are getting ready for work or school and leaving during the day. And then, they come home, and it ramps up to being more evened out or maybe not as much of a drop in the middle of the day, too, because not everybody will work from home, but more do. So, there's that.

But then that would also offer more opportunities for those people to be able to do things in the off-peak hours, such as, if they don't have smart appliances that allow themselves to pre-program -- whether it's the washer and dryer, the air conditioning, [or] the thermostat in the winter (although the thermostat's usually natural gas heating).

That might open it up to more people who could take advantage of this rate. That's one thought initially.

PNM continued.

And from just the overall [perspective], we saw from Itron's presentation the large increase in overall residential usage during Covid. That might give us an idea of what the usage pattern change might be if we examine, say, pre-Covid versus during-Covid times on residential hourly data -- what customers were doing during those times.

But that wouldn't reflect the change of the rates, though.

PNM (Pricing) continued.

Right, not at this point, but it could in the future and especially now is probably somewhere in between--not at the height of Covid when everyone was working from home, but not pre-Covid (and it will never go back to that).

And so, now we're still probably somewhere in between and as a few more years go on, we [will] see where it settles and then we can respond appropriately with price signals.

Member of the Public continued.

It seems to me that If there's some way to unobtrusively monitor this as part of the pilot, it will be important to know what the shift is of people not working in central workplaces.

And I think it's one of those areas where we kind of need to think of how we can find some measurement of that, too--just to track it better and get more nuance.

PNM (Pricing) continued.

Yes, I agree.

I wrote down your question and comment and I'm trying to capture comments that I can take back to the pricing group [so] we can continue to work on and refine.

So, as a part of this pilot program we're going to work with a measurement and evaluation group that will set up the pilot--like the recruitment strategies--so that we can try to recruit all types of customers, so we can see how they respond to the rate. And then we'll create a survey to measure how people are shifting, which load research data can give us an indication of their satisfaction with the program, and the number of people recruited. They'll help us create the goals for the program so that we can have some concrete measurements at the end to say how did this work.

And certainly, looking at the percentage of people working from home now is something that we should take into account. I don't want to say permanently working from home, but, like, whether they're working a hybrid schedule or not so that, as you say, we can capture the nuances of residential work patterns from home in the future.

Member of the Public continued.

Yes, I think the trick is this needs to be a bit unobtrusive because you didn't really want to get a situation of invading people's privacy to do that. And I think that makes it a trickier thing to have to figure out--what can be good markers.

I'm beginning to learn how your slides are working [referring to Slides 70-74], but, basically, "off peak" rates mean high peak, peaking renewable power/solar power generation. Do you think we could find another term so that we don't get the word "peak" used in different ways twice? (Asked at December 15, 2022 meeting)
Asked by a member of the public on December 15, 2022. View meeting information here.

Initial Response: PNM (Pricing)

We can think about that. Although "on peak"/ "off peak" is the standard for how these rates are described. We'll take it back to pricing and think through it.

Member of the Public continued.

I'm just saying, and maybe it's just because of my long engagement with the process here at the IRP, [but] I think of peak, and then I'm looking at these rate charts and I'm seeing that the "peaks" we talk about are really the off-peak rates.

PNM (Pricing) continued.

There are off-peak and on-peak rates. So, yes, that term is used in connection with on and off throughout.

Member of the Public continued.

Yes, but right now we're talking about it in terms of rates; when we talk about generation, it's kind of like the reverse of that.

PNM continued.

I understand what you're saying and, you know, before we had the large proliferation of renewable energy, the rates aligned with the time period where you expect the peak load to occur.

What we're seeing now is because of the amount of renewable generation on the system, the high-cost hours no longer align with the peak load hours; they align with the net peak hours or the loss of load risk hours.

And so, when we are talking about peak rates we are talking about the high-cost rates, the peak pricing rates and not necessarily what aligns with the gross peak load hour because that's no longer the main driver of system risk and system cost.

Member of the Public continued.

And we don't have to have that conversation now; I've just realized I had to do a flip in my thinking in order to follow this conversation today.

PNM (Pricing) continued.

And that's an important part in terms of how we communicate this to residential customers, because we're trying to get them to sign up.

I appreciate your comment and your pointing that out and it's something that we should think about as we create promotional materials to tell people about this rate.

Member of the Public continued.

Yes, I feel in every field we get caught in our jargon and our terminology and so we just need to know how it gets out there.

Hawaii doesn't require storage with behind-the-meter [BTM] solar. But the rate structure is such that nearly 80% of customers who went solar in 2020 included storage. Hawaii ended net metering and went to net billing. So, the proliferation of storage was done through price signals. (Asked at December 15, 2022 meeting)
Asked by Sandia National Laboratories on December 15, 2022. View meeting information here.

PNM (Pricing) Response

Perfect. That's the kind of thing that we're thinking of, or that we look to a state like Hawaii and then think about would that work here, if that's something that we want to consider.

So, thank you.

As cost allocation will change, is some change in tax structure expected to make up for the government revenues that will be lost as we use less fossil fuels? (Asked at December 15, 2022 meeting)
Asked by a member of the public on December 15, 2022. View meeting information here.

Initial Response: PNM

Setting aside gas taxes for vehicles and things like that, [where you] might have to come up with a miles tax or something, if you're talking about all electric fleet. But that's a little bit set aside from what we would do here at PNM; the PNM customers at least pay a gross receipts tax on their electric bills.

And so, that would be applicable to our total revenue requirements. So long as we're recovering our overall revenues, if any individual customer reduces or changes their usage patterns to optimize their change in their costs, that would change the gross receipts taxes to the state of New Mexico a little bit. But I think that's something that needs to be kept in mind with how the legislature is going to look at what their revenue needs are going to be relative to the overall gross revenues collected by all the different businesses throughout the state.

Member of the Public continued.

I think you've covered it. I think it's just we need to keep an eye on the fact that those fees that come off of the extractive industries are going to be impacted in those revenue streams, and they are going to be somewhere else in the system-- but they could impact us as well.

PNM continued.

Right, and I guess what I would keep in mind there is just because New Mexico goes to 100% carbon free for its electricity, or even if it goes 100% carbon free economy wide, that doesn't mean that neighboring states or other states who would want to purchase fossil fuels extracted in New Mexico couldn't continue to do.

So. I don't think that just because New Mexico goes carbon free means it's an end to the oil and gas industries within New Mexico, because they can sell those products elsewhere and there's going to be additional opportunities for them to try to come up with renewable natural gas, or hydrogen from SMR or any other things where they could participate in terms of trying to transform their business models to something that is more sustainable long term, if the overall United States is going to a decarbonization strategy.

But just because we go faster doesn't mean that's the end of the oil and gas industries--here in New Mexico, Texas, everybody else around us still will be consuming those fossil fuels.

Member of the Public continued.

I don't have an illusion about that, but basically, as we shift our fuel to the renewables, it does change that that mix. That's all.

Always like to keep these things on the table.

Is the example of Hawaii indicating a move toward more fixed or variable rates? [This question relates to an earlier comment from Sandia National Lab regarding BTM [behind the meter] solar and storage in Hawaii (Hawaii residential rate structure incentivizes storage paired with rooftop solar.)] (Asked at December 15, 2022 meeting)
Asked by a member of the public on December 15, 2022. View meeting information here.

Initial Response: PNM (Pricing)

Yes, I would say it's certainly open for discussion about how we move forward. We're aware of Hawaii as a state with high PV [photovoltaic] penetration, and then how they've moved to that next stage.

So, looking at what other states do and their experiences is one way we think about how to address these issues in New Mexico.

But, no, we haven't made any decisions one way or the other, or even brought that type of discussion or that issue to the PRAC (Pricing Advisory Committee).

Sandia National laboratories continued.

Yes. ... I was looking at Hawaii's recent rate reform, that the public utility commission there approved, and the primary emphasis is on moving towards a default time-of-use rate where they're going to have pretty high ratio of the on peak in the evening hours, and then, really low [prices] in the middle of the day.

I think there was some mention also of extending a non-coincident peak demand charge to residential customers, but I don't think their decision included any fixed charges.

Given the changes taking place at the PRC, when is your anticipated decision on the rate case filing and pilot proposal? (Asked at December 15, 2022 meeting)
Asked by Sandia National Laboratories on December 15, 2022. View meeting information here.

PNM Response

We asked the commission to issue a final order in the rate case, by December 1, 2023, and then rates would take effect shortly thereafter … January 1, 2024.

We have to walk a fine line here, because that is an ongoing proceeding with the PRC, and certainly subject to litigation. So, we can talk about it a little bit but there are going to be certain things, depending on when we get there that, we might just have to turn away and say that would have to be handled in the rate case venue.

I [recall from a previous presentation] that PNM gets a lot of economic development inquiries that they turn away. How will your analysis and forecast take that into account? Do you plan to hold a public advisory meeting on this topic and identify how economic development opportunities may affect your forecast and needs? (Asked at December 15, 2022 meeting)
Asked by InterWest Energy Alliance on December 15, 2022. View meeting information here.

Initial Response: PNM

We're not turning anybody away. We work with our economic development team very closely. And so does the pricing department. We work with them to figure out what proposals we can work with and what time frames we can work with.

Given the current state of the system, if a customer comes to us and they say, "We want to hook up 300 megawatts of load in 12 months," we're only a 2000-megawatt system and we don't have that much additional capacity. And trying to build a new generation facility that quickly is virtually impossible, especially with supply chain constraints and otherwise. We might say to them, "Well, what flexibility do you have on your time frame?"

We are doing our best to work with every single inquiry that comes to us, figure out how we can get them to come to the state if possible, and [determine] the time frame that they're working on. Typically, they're talking with us and many other service territories and it depends on what incentives there are--not necessarily just utility incentives--but if there are economic development incentives through different state agencies, city agencies, other IRPs, or other things that might be offered.

The electricity portion is usually one of the very small components that goes into decisions for customers wanting to site in a specific area, unless their overall cost for their process is dominated by electricity.

[Referring back to the initial question]

So, if we look at what we did in our 2020 IRP, it's a very similar process to what we're going to do here. In that 2020 IRP, we had a base load forecast and that's really what we wanted to have Itron present on today: Overall, what is the known forecast that we can surely count on? And so, Itron presented that sans the [rate 36 B customers (and that will be added into the forecast as well)].

Then, we're going to have multiple incremental economic development sensitivities that we're going to look at. And we'll have a range of those sensitivities that we'll run through our models and look to see what has to happen on the supply side in order to serve those customers, both from an RPS requirement for carbon intensity and carbon emissions free requirement.

Certainly, it's going to, depending on the amount, drive the needs for the load serving side as well, not just from the supply side, but also from substation, transmission line, distribution, all those types of upgrades, and those things that are really not considered necessarily within the IRP at this point.

So, we are going to have different economic development scenarios.

If the request is to have our economic development group come in and talk a little bit more about specifically what they're seeing from the development community, we can talk to them and see. But a lot of those conversations are highly confidential (governed by NDAs, et cetera). So, at a bare minimum, we can come back to this at a future meeting, and at least present the range of economic development scenarios we'll be looking at.

InterWest Energy Alliance continued.

Thank you for that answer. I completely understand the need to retain confidentiality on this. I'm not looking for a specific identification of companies or whatever--that's confidential.

But it seems to me that [PNM is] getting essentially besieged with economic development and expansion opportunities that you just couldn't cope with, or that the system couldn't handle. And it may be a timing issue. Maybe other issues. Could be all kinds of things, but it seems to me that this is an important factor for the state and for PNM. And if your current forecasts don't at least take into account that factor, then it's missing something.

And so I'm wondering, how do you plan in your IRP to include that factor going forward, understanding that you've established for us how you look at the baseline today? But then adding onto the baseline, I think that's an important factor that many of us would be interested in knowing; how you plan to deal with that and having a range, let's say, would be useful.

We understand you can't identify particular projects or companies. but what are the ranges that you're looking at that may be realistic or high, medium, low, whatever?

It just seems like that factor is missing so far.

PNM continued.

I understand your point and it's not missing; it's something that we're going to include. We just didn't present that information here today. We were presenting the base forecast and the base scenarios.

I believe it was the [August] 25th presentation from our 2020 IRP, September 25, 2020 [link: August 25 presentation ], right before we talked through Itron's slides, we showed how we were putting together some economic development scenarios. And in that IRP, I believe we had six different economic development scenarios set up. They were all incremental to the base forecast. We did analysis on them and presented those in the overall range of results.

We're going to do something very similar here. We're going to have a range of economic development scenarios that are going to be incremental to the baseline forecasts. Those loads are not going to be as weather sensitive, or to the degree that the residential customers or the commercial customer class are driving what Itron presented here today.

So, what we can do is take any one of those scenarios that Itron talked about earlier. Going back to some of Itron's slides [Slides 54-55], if we were to look at this matrix or correspondingly this chart [Annual System Energy Scenarios], any one of these, we could add economic development scenarios onto a low, mid, high, highly probable, or low likelihood.

But does it make sense to add them onto every one? Probably not. I don't know that adding economic, high economic development onto a low economy scenario would make sense. So we're going be taking that into account when we put this together,

So, this is from the August 25, 2020, meeting from our last IRP [page 79, August 25 presentation ].

This is kind of akin to what Itron was presenting today, where we start off with our base forecasts. But then here [page 80] we have each of these incremental economic development scenarios, and we're going to be doing something very similar. We can come back and present something like this. We're still working with the economic development group to try to put together what their thinking is--what's a low, a mid, a high, a highly likely scenario.

What we know about the queue right now for economic development is that if everything in the queue that we would want to bring the load onto the system for between now and 2025/2026 were to occur, it would double the size of our system. Pragmatically, it's impossible for us to add that much generating capacity, transmission capacity, distribution systems, substations, and all that to accommodate all that.

We know that not all of it's going to happen. I get your point.

The idea is, well, what can we do in order to maximize the potential to capture those loads? A lot of it's going to come down to what support we can get to go do things ahead of time because, if we go and do things ahead of time, we can court those customers that want to come in on very quick schedules.

But if we go and do things ahead of time, and those loads don't materialize, that means that the existing customers are going to be paying more because we've done additional investments expecting load to come that never materialized.

So, it's going to be a balance there of well, "What is it that your PNM customers, regulatory commission. or you as a stakeholder and others are willing to accept us doing: the "build it and they will come" approach versus just working with new customers and saying, "We've got to wait until you ink your load on the dotted line and then we can start making these necessary investments and securing enough capacity to serve you."

Right now, we just don't have the excess capacity that we can slide new loads into and serve them on day one if they are significant in size.

InterWest Energy Alliance continued.

Yes, I completely understand but the thing is if you don't ask the question of your customers, parties, the commission, you'll never get the answer and you'll never be able to move forward. So, I agree it's a question of do you take a "build it as they come" approach, which is kind of small ball, versus "build it and they will come."

In terms of what it is that you build to entice folks to come, I don't know what that is. I have no idea. I have no idea if it's more substations or whatever. I would leave that to you guys as experts, but it seems to me worthwhile to take a look at this as a key factor and to maybe ask your partners here, your collaborators, the question and pick the brains of your experts in terms of "Do we want to ask the question? What's the question? And what do we do with the answer?"

So, anyway, those are thoughts for you to consider and I think many of us would appreciate having a session on this issue. I think it would be useful.

PNM continued.

Well, appreciate that feedback and we can certainly make sure that we can present our economic development [ED] scenarios. We can have a more detailed discussion overall on ED and see what they can present in terms of the types of customers and things of that nature.

Just from what I know, they are getting many, many more requests now than they ever did. And those types of customers are demanding renewable and clean energy. They want to come in quicker than we've ever seen, be hooked up faster, and they're much, much larger. Given that we're a small system, the "build it and they will come" approach is really what we would need to do in order to court some of these customers on the time frame that they would want.

But it's not going to be a do one or the other or a third. It's going to be we have to make investments in the generation system, the transmission system, substations, distribution, all of that ahead of time, in order to make sure that we're ready when one of these large customers comes and says, "I want to be hooked up and serving my manufacturing process within 12 months."

And that can place a lot of risk on both parties. We definitely would like to have the discussion. I'm sure you're aware that we have an RFP that we issued back in the beginning of November for resources that would deliver in the 2026/2027/2028-time frame. We certainly could talk about that if there is support enough for us to ask the commission for some excess generation to enable some economic development, but that's only one of the things.

There are supply chain issues -- I know that our transmission department would tell us right now, if they need to go and get a high voltage transformer in order to interconnect a customer, and they have to order that transformer today, it is probably not going to be here for 18-24 months. If the customer wants to be hooked up in 12 months. even if we had the generating capacity, that's still a problem on the load-serving side.

So there are a lot of things that are going on. I think that having the conversation is great, but it's a conversation that needs to happen in multiple different stakeholder venues other than just the IRP.

InterWest Energy Alliance continued.

That could be. I just think it is an important factor for the IRP as well.

PNM continued.

I agree with you.

To make sure I'm understanding this right--this slide [Slide 11], which I think is helpful--what you're trying to do with Phase 1 is you got … a large set of scenarios, and you want to try to … weed out the ones that are fairly clearly not going to perform well, such that it really wouldn't be efficient to go on running against all futures. So, if I understand right, what you're proposing to do on the screening is that it would be a more limited set of futures. Is that kind of what you're proposing to do, and basically run that first initial set of scenarios against the more limited set of futures to see what it produces and whether there's clearly some scenarios that are not worth pursuing because the economics, or what have you, aren’t working? (Asked at February 15, 2023 meeting)
Asked by NM AREA on February 15, 2023. View meeting information here.

Initial Response: PNM

Yes, that's exactly right.

What we have you can almost think of it like a funneling process, a screening process, some way of taking a large number of scenarios and trying to figure out if there are just ones that don't pass the sniff test. That's because of whatever characteristics, maybe it's very high-cost.

And the screen that we were thinking about--again, looking for feedback here, if others have ideas--is we would do two capacity optimization runs, both based on the current trends and policy future: one would just be the base future, and one would be that base future plus a significant amount of economic development load growth. And so, we would come up with two portfolios of resources with those capacity optimization runs.

Then, we would do our detailed production costing on both of those portfolios using the standard 50/50, weather normalized load forecast, which would be the basis for the capacity optimizations. And then also stress test it deterministically and [through] EnCompass with our 90/10 load forecast. So, we plug in a portfolio based on the 50/50 weather forecasts [and] run it against the 90/10 and see if that type of case gives us another piece of information as to how robust these portfolios are in adapting to different weather conditions.

And then, if we need to, we can also run it through [SERVM] as well. But that would give us a few data points to tell us, overall, on our base case, how did the cost [performance] look if we stress test them against an extreme weather case, how robust are these portfolios to changes in the load forecast? And then do the portfolios, or the types of resources included in the portfolio. Again, maybe it's a long duration storage project; does that resource potentially have an advantage over just general solar, wind, lithium storage, and enable economic development? And is that something that we would want to consider as a part of how robust the portfolios are, as well?

So, that's how we were thinking about it. And then, it could be that all the scenarios make their way through the screen, if they all are very competitive with each other. It could be there's a bright line that says, "Well, five of the 16 can be weeded out." And then we'll start moving the more competitive ones into the analysis with the rest of the futures.

NM AREA continued.

I guess two follow ups focusing on the last slide [slide 11]. [If I understand correctly], item 1, under the screen area, is the actual future, and item 2 is a sensitivity to that future.

Are you going to define what the current trends and policy future look like and the assumptions for that?

PNM continued.

We would be doing the current trends and policy future and then a sensitivity of that future with the high economic development or strong economic development assumptions. Then, do some additional testing on the production costs, both on the base load forecast, and then the extreme weather forecast, and we could drop that into SERVM as well.

Initially, we're thinking we would want to see just what the EnCompass results were.

We do have some slides later on to show the various assumptions for the different futures. The current trends and policy will be similar to what was looked at last time. It'll be your kind of mid load forecast, our mid gas prices, our mid CO2 prices, our mid technology curve.

So, all of the baseline assumptions, so to speak.

Does the company see this [Slide 14] more as something that the economics are showing has promise, or should be explored? Or do you foresee that there will be a reliability-based business case that really long-term storage of this nature might be necessary, or dispatchable resources in the alternative? (Asked at February 15, 2023 meeting)
Asked by NM AREA on February 15, 2023. View meeting information here.

Initial Response: PNM

I think that all of the work that we've done, and the literature that can be reviewed, shows that in decarbonizing a system, one of the fundamental things that's going to be needed is some type of firm dispatchable resource, whether that's in the form of non-emitting fuel that you can put through a combustion turbine, whether that's long duration storage, or anything else. You could build up a lot of shorter duration storage and dispatch over a longer time period, but everything that we've been looking at says that long duration storage is something that's worth a good, detailed look.

Ultimately, the cost characteristics are going to be part of the decision-making process, We'll be examining that through the IRP and any subsequent RFPs. But from a reliability and resiliency standpoint, from just the overall way that the system needs to be in order to get truly decarbonized, having some type of firm dispatchable resource and long duration storage or something else is one of the fundamental tenets that we see as necessary to get us there.

NM AREA continued.

Yes, ... I see this with some other utilities, working as a stakeholder in [other] IRP process[es], they've been advocating something similar like this, whether in case that utility was combined cycle with carbon sequestration.

But I guess the key seems to be like I have seen, and I really liked to see. I would encourage the company to … more concretely demonstrate with analysis the need, or the steps and resources, if they believe they're needed. I think it would really help the process.

So, just want to provide that feedback.

PNM continued.

Definitely appreciate that.

E3 has done some pretty deep decarbonization studies that have always shown that a firm dispatchable resource is one of those things that enable decarbonization of the system.

If we look at our 2020 IRP, we compared just the ability to add on some hydrogen combustion turbines--I think 280 megawatts of hydrogen combustion turbines, displaced a combined 1500 megawatts of lithium storage and solar.

So, trying to figure out what you need and how much we’re going to "overbuild" to decarbonize the system, if you don't have those types of firm dispatchable resources in the form of long duration storage or in some non-carbon emitting fuel, you have to have significant amounts of additional renewable and shorter duration storage resources put online.

[The IRP staff] has been working on an example that kind of shows some of the tradeoffs--really trying to get to carbon free, and what the requirements are. Just anecdotally--we do have some analyses on this--we think back to that resiliency study that PNM and E3 did, when we wanted to replace the 200 megawatts at Four Corners, we said, “Well, if you just do an LOLE basis, you could do it with 160 megawatts of gas, or it could have been 100 megawatts of solar, 100 megawatts of 4-hour storage, and 50 megawatts of 2-hour storage.”

But then if you wanted to make it equivalent on an EUE basis, not just a frequency basis, but a measure of the amount of load not served, that 2- and 4-hour storage had to become 14-hour and 16-hour storage, in order to get the normalized levels of EUE the same.

[We did a presentation for NM RETA recently where] we did a little hypothetical example: What if you have a 100 megawatt, your high load factor load, and you want to serve that just with solar and storage, as you move up to 100% carbon free, and to do that 100 megawatt load, just on a solar and storage basis, you're going to need 405 megawatts of solar, 260 megawatts of 6.65 hour duration storage, because you're going to be charging that up over such a short time frame in the winter, and then discharging over 12- or 13-hour window in the longer time frame.

You start to get this tradeoff on charging times and the overall amount of energy you need stored on the system. So, longer duration could just be a pseudo way of saying, “Well, we need to make sure that we have a total amount of enough energy on our system to meet these requirements as well.”

And to do the resiliency piece of it, it's going to take a lot more than just the short duration stuff.

NM AREA continued.

And I do like the EUE approach looking at that because all LOLE results really have the same outcome.

PNM continued.

Yes, if you're only looking at the frequency, you're not looking at everything.

NM AREA Response

Thank you.

Are you including identification of additional or new demand side resources like load shifting, time-of-use rates, interruptible rates, demand response programs, [and] energy efficiency as you identify the resource mix necessary to enable a carbon free system? (Asked at February 15, 2023 meeting)
Asked by CCAE on February 15, 2023. View meeting information here.

PNM Response

We are [doing something] similar to what we did in the last IRP. ... [in the December 15 meeting there was a lot of information on the energy efficiency modeling.]

We are taking the energy efficiency modeling that we did last time and trying to make some enhancements to it. But we're essentially modeling energy efficiency on the supply side where it's a selectable resource and the model can pick energy efficiency programs, depending on what the cost characteristics of its other choices are.

We are going to continue to model the DR [Demand Response] programs that we have. We have a time of use rate sensitivity load forecast that we'll be modeling.

In terms of additional demand response programs, in the last IRP, we did model extensions and expansions of the demand response programs. The toughest thing there is just making sure that we can always identify the type of program characteristics needed to enable that type of program.

What I mean by that is, if we make the DR programs too rigid, it's unlikely customers will sign up. If we make them too flexible, can we really count on them. And so, we've got to strike that balance.

But we are going to be looking at each one of those things that you've identified there in terms of time-of-use rates, demand response programs, energy efficiency, etc.

This slide [Slide 15] refers to your RFI, Are any of the demand side resources part of the RFI? (Asked at February 15, 2023 meeting)
Asked by CCAE on February 15, 2023. View meeting information here.

PNM Response

We did not have any demand side resources offered into the RFI per se. There were a couple of software solutions that could make the aggregating of distribution level demand side resources more efficient. But the RFI did not come back with any specific demand side characteristics.

You indicated Valencia, that you would be doing sensitivity modeling. In what context? Are you going to be doing that through the IRP process? Is that something that's going to be included? I'd like to get a little more detail on what you mean by allowing that asset to retire, or expire. and to allow a generic replacement to come in. (Asked at February 15, 2023 meeting)
Asked by Onward Energy on February 15, 2023. View meeting information here.

Initial Response: PNM

So, our base assumption is going to just be--this is why we've done it in all of our previous IRPs as well--that for any PPAs that come to term during the study horizon, our base assumption is going to be those expire and are replaced with whatever the economic choice of generic resources there would be at that point in time. And it's our intention to do the same thing with Valencia in this in this IRP.

Now, we were not anticipating doing any sensitivities around that. The 2026/2028 RFP could be utilized as something that would examine alternatives to Valencia in that time frame. So it's a little unclear whether more detailed analysis through this IRP would be necessary, given there's an RFP that covers the time frame when the Valencia resource contract will come to term.

Onward Energy continued.

If I understand you correctly, are you indicating that there's currently two RFPs out there looking at that event horizon, to the 2026/2028 time period, but that in this IRP, you will not necessarily look at the sensitivities involving the expiration of the Valencia lease agreement?

PNM continued.

In this IRP, our base assumption is going to be that the PPA expires and will be replaced with whatever candidate resources are available in this specific scenario that we're looking at. There are many different scenarios.

There is an RFP that was issued in the beginning of November [2022] that spans the 2026/27/28 time frame. Those responses for the resources in the 2027/28 time frame are due today. And we will be doing the RFP evaluation for resources delivering in 2026/27/28 in parallel with this IRP.

So, to the extent we get to some case filings or other things that could work their way into the IRP, we will try to embed that information in there. But for this IRP, given that we already have that RFP out there, doing a lot of analysis around the sensitivities of Valencia just doesn't make sense.

Onward Energy Response

Got it. Thank you.

My question is kind of generic in nature. I was just wondering what you're going to do about those southern resources. Also, I understand [it], you really don't use much of the southern new resources in the northern part of your system. But you're going have to do something about those also, aren't you--relative to going to zero carbon sometime in this time frame? (Asked at February 15, 2023 meeting)
Asked by a member of the public on February 15, 2023. View meeting information here.

Initial Response: PNM

Absolutely, we will. And you're exactly right, there is very limited transmission ability for us to bring power up from the south to north or deliver power south from the north.

So, they're almost, I would say, two independent systems. Of course, they're not completely independent of each other. But the majority of the load in the south has to be served from our southern resources; the majority of the load in the north has to be served from northern resources. And we will have to take a look at what we need to do relative to those southern resources. In particular, the two combined cycle plants Afton and Luna that provide a lot of the energy for our southern loads, as we get close to that 2040 horizon, will have to be replaced with other technologies.

And so, we do have the model set up in a way where, when we're looking at the generic additions, we can identify, relative to the northern and southern parts of the system, where those generic conditions will be coming in and making sure that we are still able to serve both the southern and the northern loads. And we're not modeling as just a single point, but there are multiple bubbles and pipes connecting each of those things.

So, the focus of this particular IRP isn't going to get quite into the southern resources other than in a very generic way. As we move forward in time--I would say in that 2035 to 2040 time frame where a lot of those decisions on the southern gas fleet are going to have to be made, as well as on any of the residual gas assets up north.

But right now we would anticipate the southern gas fleet continuing to operate, up until the time we need to be carbon free.

Member of the Public continued.

You also have the Luna station up north, which is relatively new. And then the second part of that question is: Is there any transmission possibility that might be an alternative to help get some of that southern resource up to the north in whatever timeframe that might be appropriate?

Is that any kind of an option that you would look at? Probably not through modeling, but through some other kind of analysis? I don't know what that would be.

What I'm trying to say is: Is there an option, a possibility of a reasonable option, for bringing some of that southern generation to the north by additional transmission?

PNM continued.

I'm not aware of any transmission that's currently being constructed or underway. We certainly are looking with our transmission group at different alternatives that would allow for better flows. So, I wouldn't say that anything is off the table at this point. But there are no specific studies going on that I'm aware of for new transmission to bring power from the south up to the north.

Member of the Public continued.

Is there any way of using displacement, like the Sun Zia line, or anything like that?

PNM continued.

Well, the Sun Zia line, as far as I know, is still going to be in the south. And even if it has resources that could be tapped, you'd have to build, because it's going to be a [HVDC] line. You'd have to have a converter station that would be added to the system to convert it back to AC power, and that would still be in the southern part of our service territory. So, there would still need to be some additional work done if we were to take any power off of that Sun Zia line to get it back up to the load zone in the north.

We'll have to take an examination of that as as we find out more about the Sun Zia line and anything that would interconnect to deliver power across it.

Member of the Public continued.

My understanding is--probably wrong on this--that with Sun Zia you could have one DC line, and the other AC. They may have both. I don't know why they're doing that, but that's what I understand. So, that may be something you might want to consider.

PNM continued.

Yes, we're definitely keeping there all the options on the table. And if there was a way for us to take some power off the Sun Zia line and get it up to a load zone in a cost effective way, we'll definitely consider that. Just right now, what we're seeing is that the additional transmission, to go from south to north, at least so far as what's been looked at, there's just not not enough of a benefit as we sit here today. But that could change with the Sun Zia line or other other alternatives that make themselves known.

I ran across a recommendation about reviewing the reliability requirements for all the changes that are occurring, and considering inverter-based resources to maybe somehow be modified or the operation be modified to look at it and see if that can be used in response to operating reserves, which I think is going to impact, [that is] the change to renewables is certainly impacting the operating reserve and what you need to have. I'll send that report to you if you haven't looked at it. (Asked at February 15, 2023 meeting)
Asked by a member of the public on February 15, 2023. View meeting information here.

Initial Response: PNM

That'd be great, and I agree with you 100 percent.

The operating reserve requirements in the world of the heavy renewable system are going to need to be reexamined, and how the system is operated when it's dominated by inverter-based resources instead of spinning masses. It's still a challenge. I don't think anybody has the final answer yet, but we know we're told to go do it.

I'm wondering, how realistic do you think this more accelerated forecast [Slide 16] is compared to the stable forecast? I mean, are you seeing inquiries that you think may actually hold water, that may come to fruition? That lead you to believe that an accelerated forecast may be what actually come to pass, and that's why you want to look at this kind of a scenario more seriously? (Asked at February 15, 2023 meeting)
Asked by InterWest Energy Alliance on February 15, 2023. View meeting information here.

Initial Response: PNM

So right now, the way that I would respond to that is that right now, when we're getting inquiries, the inquiries are mainly from folks who want to come to this system sometime between today and 2026 or 2027. And so, when we think about much beyond that, it's really speculating on what level of sustained inquiries we're going to get.

I can't get too specific because these are mostly your confidential discussions that we have with potential customers. But, in the last couple of months, we've been providing a lot of information to some potential customers, and we don't know if they're going to end up coming here or not. One of them is 100 megawatts, and another one was between 100 and 300 megawatts, depending on what the design build out of their facility would be. Another one was a 300-megawatt customer.

We're seeing a lot of activity from very large customers that are interested in coming here. But the electric supply is one of many considerations that any potential new customer is going to consider when deciding to come here. So, the accelerated scenario here is that we just want to make sure we have an understanding of what it would take should something like this occur, Maybe it doesn't occur in such a linear trend. Maybe you get one or two 300 megawatt customers, and then you have a lull for a few years. And then another one comes in.

We definitely want to see what it might take to handle something like this because there is the potential to have a sustained amount of growth over a long period of time, and you will want to be ready for it.

InterWest Energy Alliance continued.

That makes sense. And it's likely to be fairly lumpy, right? I mean, I agree with you: You might get several companies that want to come on in a particular economic cycle, and then you might have a lull after that. So the resources you bring on will likely be in chunks, right?

PNM continued.

Yes, the resources would likely be in chunks; the load would likely be in chunks.

Now, the load will have some type of ramp characteristic to it. Most of the time, when you bring a facility on, it's not going to go from zero to 100 megawatts overnight. But we have to have the resources on ahead of time to make sure we can serve them. The macroeconomic climate will determine a lot of it, too: how we're doing relative to neighboring systems, what tax incentives are out there--both at the state and the federal level, who knows. With what's in the IRA [Inflation Reduction Act], incentivizing hydrogen production, you may see a boom of hydrogen production facilities; you may see a boom of more lithium facilities.

We don't know what's going to be, but we need to make sure that, whatever it is, we have an understanding of what it would take to be able to serve that load.

InterWest Energy Alliance Response

Thank you. Appreciate it.

Do the generic resources modeled have a location assigned with them? Due to the improbability of having any new transmission built to accommodate projects, I understand these generic resources to be placeholders. But is there an expectation that they are reasonable or possible that needs to be established? (Asked at February 15, 2023 meeting)
Asked by NMPRC on February 15, 2023. View meeting information here.

PNM Response

With the generic resources, we are going to be modeling them with different geographical characteristics.

Through some of the recent RFPs that we've done, as well as some other data that we've gathered, we've got different cost estimates, say, for solar, that would be in the northwest versus solar that would be sited near to the load pocket versus solar that would be out to the west of Albuquerque.

So, we can come up with different cost forecasts, as well as we're looking at putting together different production profiles, based on their geographical locations. Then, we're modeling the system with different resources zones and transmission deliverability. And so, you will start out by saying, "Well, what is the transmission deliverability on the existing system?'" Then, we're going to have to have some assumptions in there about what incremental transmission would cost to deliver from some of these resources zones.

So, we're doing our best to try to get an idea of where the different resources would need to be sited. Now, there are limitations, of course, on what we can do in this type of modeling versus doing a fully nodal model, as well as using generic resources versus something that's actually built into an RFP. So, subsequent to the IRP, we could end up seeing RFPs that lead to very similar geographic sightings for resources. It could be that the average doesn't capture the low cost resource in a given area and so you might see some differences as well.

Did that answer your question, or do you have any follow ups?

NMPRC Response

Perfect. Thanks.

Why not include a Phase 1 scenario and base plus expanded solar, especially in the load pocket [Slide 17]? (Asked at February 15, 2023 meeting)
Asked by InterWest Energy Alliance on February 15, 2023. View meeting information here.

Initial Response: PNM

I guess I'm not sure what you mean by that. We will be modeling different geographic locations, including the load pocket for different resources, including solar. And in the base technologies only, there will be the ability to add additional solar and storage--both in and out of the load pocket.

InterWest Energy Alliance continued.

I was just thinking I see you've got a base plus wind expansion--I think what you're trying to do there is focus on your transmission needs. So, it just seemed like you didn't have a similar category for expanded solar. But I think what you're saying is you're kind of lumping that into your base technology scenario. Right?

PNM continued.

So, let me dive more into some of the specifics here.

In the base technology scenario [Slide 18], we're going to talk about this as being mainly generic type resources because we already have the amended contracts for the things coming in 2023 and 2024. So, in the base technology scenario, we're going to be allowing new solar additions, beginning in 2026. And that can be in different geographic regions: it could be in the northwest part of the state, it could be out west, in western New Mexico, it could be in the load pocket, it could be down south. And there are different amounts of solar that could be added at any one of these locations for triggering potentially a proxy for some transmission investment that would need to happen in order to deliver you more than that amount of solar that would come on, or whatever resource it is.

Then the storage, we're also allowing that to start in 2026. The way we're going to do this storage modeling is that we're essentially going to be modeling for the generic battery storage, 4-hour variants that could be converted to 8-hour at some point, either right away so it could come on as an 8-hour battery, or it could come on as a 4-hour battery and then convert to an 8-hour battery at some point in time in the future.

So, those are the two main things that would be able to come into this base technology scenario prior to 2033.

And then we're going to allow in the base scenario new wind to come on in 2033 and beyond. The reason why we're picking 2033 is there's a lot of time to do transmission, of course, and we have the reduction in the carbon intensity requirement that occurs in 2032, going down to 200 pounds per megawatt hour. What we saw in our last IRP is that the generic wind additions, in 95% of the scenarios we looked at, occurred right at the same time as that decrease in the carbon intensity requirement because, essentially, when we get down to that 200 pounds per megawatt hour, we're having to decarbonize the non-solar hours and we've probably gone as far as we can with solar.

And so, we either need to build more solar and storage to timeshift that energy to help decarbonize the non-solar hours, or we're going to have to find a non-carbon emitting resource that can deliver in the absence of sun. That's kind of where the wind is coming in.

If we compare and contrast this against the base plus wind expansion scenario, in which we allow the wind to come in, say, by 2030, do we see a pretty big economic advantage of trying to accelerate investment in transmission and get access to new wind to help us decarbonize the non-solar hours in advance of the 2032 requirements? We thought the best way to do this was to make sure that we have a clear contrast between some base case that doesn't allow the wind to come in until after that requirement and something that happens before then.

So, that's where we are drawing the distinction there on the wind expansion pieces.

PNM update

After some initial analysis, PNM has chosen to model generic storage as 4-hr storage only.

Does this exclude the “least cost among all of the bids” with reasonable transmission expansion scenario [Slide 18]? I just wonder if you are: A) overemphasizing the cost of the new transmission, the transmission plus wind scenario; and B) not allowing the market to bring forth the best local mix of all, which we cannot predict through the scenarios, [and] which I feel is somewhat too narrowly focused. (Asked at February 15, 2023 meeting)
Asked by InterWest Energy Alliance on February 15, 2023. View meeting information here.

PNM Response

I guess I'm not sure what you mean by least cost among all of the bids, There are no bids--that's for an RFP. What we're doing here is looking at different RFI responses.

We've got a lot of ... information on generic resources. The computational complexity prevents us from throwing everything in the model, pressing "solve," and getting the perfectly optimal solution, given the limitations on technology and computing power at this point.

So, we do think that the way we're going about it, trying to look at these different scenarios, is going to help us get to a good mix of resources. And as we start to work through this year, we're certainly going to be working towards the most cost-effective portfolio.

If you have some ideas, and you want to throw them out there, we're happy to consider them.

In terms of the transmission costs, our transmission group had worked up a transmission cost estimate for a new line that would kind of run on a similar right of way to Western Spirit, to enable more wind to come in from the east. I think it was in the $500 to $600 million number and would take seven to 10 years to construct.

That's one of the reasons why we're taking a look specifically at this wind expansion scenario, trying to understand some of the benefits versus the costs associated with moving down that path.

Will the scenarios consider placing new resources at retired sites, like Four Corners or San Juan? (Asked at February 15, 2023 meeting)
Asked by SWEEP on February 15, 2023. View meeting information here.

PNM Response

So, Four Corners ... if we are able to exit, say, in 2025 or 2027, that plant is still going to be operating. APS is the majority owner and so putting something at that site would be completely contingent on whatever the rest of the owners would want to do.

At San Juan, we will be modeling generic resources that could be in the northwestern part of the state, but we're not getting down to the level of detail to say that this is going to utilize the existing infrastructure or something like that.

When we look at specific siting requirements--that's done through an RFP evaluation, and if there are bids into an RFP that would have an interconnection point that would utilize some of the existing San Juan switchyard or bays--we would evaluate that through the RFP. For example, the San Juan solar project that's supposed to come on now in 2024, that was part of the original San Juan replacement portfolio; its point of interconnection is going to be into the San Juan switchyard.

Have you excluded the flow battery technology which was in the previous IRP? (Asked at February 15, 2023 meeting)
Asked by New Mexico State University on February 15, 2023. View meeting information here.

Initial response: PNM

[This gets to a previous point that] it's not necessary to model every specific chemistry type or every specific model of a turbine or anything like that.

The flow batteries aren't quite as efficient--at least what we've seen in the round-trip efficiency data--compared to, say, lithium, but they are better than some of the other tech, other chemistries we've seen out there. We would hope to see flow batteries getting offered into some RFPs in the future and be able to compare and contrast the specific prices of those for specific projects against other technologies.

In this particular IRP, we're just going to be modeling for generic storage--those 4- and 8-hour variants of an 85% round trip efficiency storage devices.

We know that storage is going to be a big part of the system going forward, and we hope to see more of those chemistries getting offered into some RFPs in the future.

But no, we're not going to be modeling all of the different chemistry, so to speak.

PNM update

The 2023 IRP will incorporate 4-hr 85% RTE storage, and 10-hr flow batteries with 60-70% RTE.

What percent hydrogen fuel do you anticipate these new gas resources being converted to? (Asked at February 15, 2023 meeting)
Asked by Synapse Energy for the New Mexico Attorney General on February 15, 2023. View meeting information here.

PNM Response

Post 2039, it's going to have to be 100%. hydrogen. For some of the earlier conversions, we still would be looking at what would it take to do 100% hydrogen power with natural gas likely as a backup fuel. We weren't considering really any specific blending ideas, mainly because blending hydrogen, while possible, due to the volumetric differences and heat content differences between hydrogen and natural gas, even if you did a 50/50 blend of hydrogen to natural gas volumetrically, that's only like a 20% reduction in the carbon--just due to the heat content of hydrogen versus natural gas.

So, when we're talking about hydrogen, we're typically talking about 100% hydrogen utilization sometime in a post-2030 time frame, or likely 2039 time frame, when we expect that the turbine manufacturers will have the majority of their turbans converted to the ability to handle 100% hydrogen.

We are hoping the new rules provide more transparency about the least cost, least risk path options offered by the bids while protecting confidentiality because the projects available in the market are hard to predict. (Asked at February 15, 2023 meeting)
Asked by InterWest Energy Alliance on February 15, 2023. View meeting information here.

PNM Response

I'm not sure if you're talking about the IRP rule or the procurement part about it for the RFP.

Certainly, when we get into the RFP evaluations, we have to protect the bidder data. But when we get into those case filings, of course, we've been making the data available on an anonymized basis. So, I guess we'll just have to see where we go from here.

In terms of the RFI responses, we did go through those in some previous presentations to give us an idea of what some of the projects out there might be. And, once we get to an RFP for those timeframes, we'll see what gets offered in.

It sounds like, in these scenarios, the main one that would involve looking at transmission as part of it is the wind one. Is that is that pretty much right? Are there any others that you can see [where] having a transmission option as part of it would make a difference or would be useful? (Asked at February 15, 2023 meeting)
Asked by NM AREA on February 15, 2023. View meeting information here.

PNM Response

The wind one will be the key one because the good wind resources are mainly in the eastern part of the state and would absolutely require new transmission to access. All of the analyses will have a transmission component built into them, either through a proxy transmission hurdle or the explicit modeling of the pipes and bubbles.

And so, we'll be taking a look at the transmission component in that sense.

But I just try to be a little bit wary of putting too many eggs in a pipe and bubble basket, when it's really the nodal models in the interconnection process that are going to govern what transmission is actually constructed.

Now, the wind one is a bit of an exception because we know for a fact, in order to get that wind we're going to have to add new transmission, where with the other resources, you might be able to find some cheaper alternatives than building a totally new line kind of thing.

Have you already covered the hydrogen fuel cost scenarios, or will it all come from electrolysis? (Asked at February 15, 2023 meeting)
Asked by New Mexico State University on February 15, 2023. View meeting information here.

PNM Response

It's a combination of both. In the hydrogen scenario that I have on the screen here [Slide 23], that would be looking at electrolysis where we would be putting electrolysis, storage, and combustion equipment at a single site.

In the scenarios where we just would have gas projects converting in the 2040 time frame, that'll assume similar to what we did in the 2020 IRP: that there's some type of hydrogen economy that can deliver hydrogen at a set price. We'll be starting with some of the prices that we put together last time and having to work through making some adjustments to try to reflect what cost decreases we think are reasonable, given the new tax incentives that will be available to those producing hydrogen, probably with the price of natural gas as being the floor price, relative to hydrogen.

How do you treat the electric energy needed for electrolysis? (Asked at February 15, 2023 meeting)
Asked by a member of the public on February 15, 2023. View meeting information here.

PNM Response

Within the model, it's a kind of an endogenous modeling of the power demands for the electrolysis. The power is then converted into hydrogen, which is then put into a storage tank, and then combusted back through a turbine.

So, we're modeling it from start to finish with the load requirements of the electrolysis, the storage volume that's considered within the storage device, and then the efficiency cycled through the turbine.

My question follows up on [the question regarding the inclusion of transmission expansion]. [At Slide 22], I thought I heard you say that you were also going to look at, along with perhaps using the Luna and the other site that's in the south, north/south transmission capacity expansion as part of that. And that's completely understandable. I'm assuming that if you look at a base plus solar expansion, that you would similarly need to perhaps, depending on the geography, if you wanted to site solar, say, for example, in the south, where you might get better capacity factors and efficiencies and so on, you'd also need to look at transmission expansion on that north/south route. I'm wondering, why not look at this more holistically, so that you're not just saying base plus carbon capture, and we'll lump all the transmission costs into that ... and then base plus solar, will lump all the transmission costs into that .... Why not look at it more holistically to see what benefits the north/south transmission expansion could provide you--with a diversity of resources, not just at your existing gas sites, but also add solar or a combination of things? (Asked at February 15, 2023 meeting)
Asked by InterWest Energy Alliance on February 15, 2023. View meeting information here.

Initial Response: PNM

Fundamentally, what you're asking is, "Are we going to consider a north/south transmission expansion?"

InterWest Energy Alliance continued.

Yes, and I guess it sounds like you are, but you're kind of lumping it into these scenarios separately, instead of looking at it more holistically. So, I'm wondering, why not do it with a more holistic look at what the benefits would be Instead of lumping all the costs into one scenario versus another? It seems like that's kind of artificially narrow, in that the benefits would exceed just that simple scenario. They would be broader, so why not look at it more broadly?

PNM continued.

It gets back to the computational question--the computers and the models out there. You're just not capable of simultaneously putting everything in and optimizing and coming up with the magic answer.

Any transmission analysis that's done here--and we tried to make sure that the folks understood that from the transmission presentations--is not what's going to drive transmission investment. The IRP is just not where that's going to happen. We can take a look generally at some transmission-related things and see, at a very high level, what benefits there might be, but until you're doing your actual nodal production cost modeling, load flow studies, and other such things, you're not going to be doing anything that's really going to drive transmission investment.

And then there's a separate process for that [we've presented on previously] And there's a separate stakeholder process. There's a separate application process, of course.

So, the primary focus of what we're going to be doing with the IRP is trying to look at the different generation, storage, supply, demand-side alternatives. We'll do our best to capture some of these transmission pieces of it.

I know that you brought up PacifiCorp as an example, so to speak. PacifiCorp's IRP, while they do some endogenous transmission modeling, is not where their transmission investment flows out of. It just gives you a little bit of idea of trying to understand some of the interactive effects for resources, but, at the end of the day, the transmission is going be done in a completely different realm, with a completely different analysis that's going to drive those investments.

We certainly can take a look at, if we were to do a scenario where we put a north/south line in there for free and look at a difference [in NPV] on that without having that line in there and how the power flows might change a little bit.

But, at the end of the day, until we actually have a transmission study done that can actually determine what that line characteristic would be--and we're going to continue to operate those southern gas plants up until we actually have to take them off the system--serving that southern load really is going to be fundamental to those southern gas plants.

So, I get what you're saying. I know that, in an ideal world, we put everything in one model, we press a button, and we get the magic answer. Unfortunately, that's not where we're at today. And the value of doing transmission modeling with pipes and bubbles in an IRP is very, very limited. Transmission analysis really needs to follow very specific siting of resources, terminal and start points of lines, nodal production costing, power flow analysis, and other things that are just well beyond what can be considered in a 20-year IRP.

InterWest Energy Alliance continued.

Yes, I understand. I know we've gone through this before. It just seems more and more obvious as you go through these scenarios now that transmission constraints are becoming more and more of a sizeable factor in your consideration of generation and storage resources in the IRP. So. essentially saying you can't deal with them in the IRP just raises questions about the validity of your analysis then if you're not able to cope with one of these large factors.

That's not a question. It's just a frustration, I guess.

PNM continued.

Yes, I appreciate the perspective but, again, I think if you look at virtually any utility out there and the way they're doing IRP, transmission is just not a factor in the IRPs--at least you're not doing IRP as the basis for justifying transmission investments. That's really a different process.

And I think the industry understands that we need to move in that direction. We've got the Encompass nodal model. We brought in our transmission group, which is working on putting together a better network representation. We're hoping by the time we get to the 2026 IRP that we'll have a better solution.

But as we sit here today, the tools that are available to us, and the amount of information that you can get from a pipe and bubble model relative to transmission, just isn't the level of detail that you need in order to say we need to invest in transmission. The best it could do is say, "This looks promising. And let's go study it further."

InterWest Energy Alliance continued.

Let me just ask, [regarding the base plus wind expansion scenario on Slide 21]. Here, presumably, it sounds like you recognize in this scenario that you need to add transmission in order to unlock the wind expansion. I think that it seems like you're saying here that you can do that for wind. Why can't you do that for solar?

PNM continued.

The wind you can almost think of as a radial line that you need to go out there, even a large gen tie to go out and capture that wind. There's no more way to bring wind into the load center without adding some transmission. Our transmission group did some analysis on what the cost of an additional line would be.

And in terms of actually modeling that, we don't have to model the transmission line itself if we don't want to because it's essentially just taking the wind out and saying that you're going to add enough transmission for such a cost that you can deliver it all to load. And if you think about it like a radial line with nothing else that would be going onto it, it's a very simple way of trying to capture both of those pieces.

We're talking about adding things in and around the load zone or at other points on the system. We can get some general ideas for what the transmission system or others can handle from solar. But there are lots of different points where we can put solar on the system. There are lots of different places where you can interconnect. There are lots of different transmission solutions that could be done to try to allow better connections or better flows of things. And if any one of those assumptions is a little bit off, the outputs are going to be a little bit off as well.

So, if the RFP comes in with a price for solar in the northwest, that's 10% cheaper than what we're modeling here, but if the cost of the transmission is 5% more, you may end up seeing that the better solution is to do something somewhere else. That's why the idea of trying to do pipe and bubble transmission modeling can give you a little bit of insight into some high level scenarios, just like this one here: This type of wind scenario lends itself well to being able to say, "Well, even if I don't put a cost for the transmission element in there, if I could deliver, say, 800 megawatts of new wind, and I assume the transmission is even free, on a net present value basis, what's the cost differential between that and my base case scenario, and is that enough to justify potentially investing in the transmission?"

Then, maybe it says, "It's worth looking at more." We still then have to go to the transmission group. They're going to have to determine what the actual type of conductor, what the actual line route is going to be, update their cost, figure out time frame, go through the full transmission study process. So, at best, this is just going to be a tool to say, "We should study this more." It's not going to say, "Go and build this line."

InterWest Energy Alliance continued.

I completely understand. But I guess the question I'm asking is that it seems like you're depriving yourselves and all of us with the same analysis, kind of analysis, with respect to a known transmission constraint north/south.

And as we all know, the solar resources in the south are very good. And you also have two gas plants there that you're looking at potentially converting to hydrogen, or something. It just seems to me that you're depriving yourself and us of looking at the benefits of doing that holistically by addressing the transmission constraint; that's a known constraint.

So, again, I understand your answer, but I just think you are missing a big chunk of what you could be doing here.

PNM continued.

Okay, I appreciate the perspective. We can talk about a way to put in an expanded north/south line and see how that might change the production cost of the system. And is that a change with production costs of the system, on the net present value basis, get us to a point where I would say it warrants a new study from the transmission side of the house.

The difficulty there is still going to be that with a pipe and bubble model, you're not adequately capturing what the actual power flows are going to be because the pipe and bubble does not enforce the physics of the way the impedances on the system work.

And so, we can put some effort into that. We can do a free north/south line and we can see what the net present value difference is. I suspect that the solar resources in the south are not so much better that they're going to justify a transmission line of that cost or magnitude, especially when the natural gas plants down there reasonably don't need to come out of the portfolio until the late 2030s. And so, you're continuing to operate those with the transmission limitations that we have versus spending money on a new transmission line that isn't potentially needed right away.

We'll take a look at it. We can try to do that. It's just that I don't think that you're going to get the level of certainty coming out of that analysis that you're hoping for.

InterWest Energy Alliance continued.

Thanks. I appreciate you agreeing to take a look at it. Nothing that comes out of this is going to be completely definitive because you will have RFPs, and so on. So, if what comes out of this is the identification of the need to study transmission constraints north/south or elsewhere, I think that's a good thing. It's a step in the right direction.

PNM continued.

I would encourage you also to attend the stakeholders group for the transmission piece because that's really where that analysis should be done--the north/south kind of studies would be better suited in a transmission point of view.

What is the source of electricity for electrolysis--on site solar or wind? (Asked at February 15, 2023 meeting)
Asked by a member of the public on February 15, 2023. View meeting information here.

PNM Response

It's really just going to be whatever power is on the system. We would assume that the electrolysis is grid connected, which would essentially just consume power from the grid. What we've seen in the modeling that we've done is that it very much coincides with periods when there is excess solar on the system, but there's not going to be a requirement that it's got to be coupled with, say, behind-the-meter renewables for the electrolysis.

I just had a question mostly on ... [Slides 20 and 21] How would different demand response futures be considered? Are we looking at it as a resource that could be competing against typical supply side? Or is this more of a key assumption like a forecasted modifier? (Asked at March 15, 2023 meeting)
Asked by SWEEP on March 15, 2023. View meeting information here.

Initial Response: PNM

Similar to what we did in 2020 IRP, energy efficiency and demand response resources will be modeled as selectable alternatives and compete against supply side alternatives on a cost basis.

SWEEP continued.

Okay, That's good. And then for the behind the meter PV forecast, is there a battery component to that as well?

PNM continued.

The behind the meter PV forecast is specifically just a PV piece right now. We've been discussing internally, as one of the cases we might look at as well if we wanted to put batteries there. It probably requires a DRM system and allowing it to dispatch on behalf of the overall utility benefit, not just trying to allow individual customers to optimize the operations against their own tariff. We're thinking about the way that we might look at that.

I think that's something that would be an interesting topic for the modeling subgroup, but that is something we've been considering. Yes.

SWEEP continued.

Okay, so it sounds like through the modeling subgroup there can be a discussion about how the different components in your grid modernization case might augment these assumptions.

PNM continued.

I don't know that I'd say they would augment the assumptions here on the screen [Slide 21].

These are all individual inputs that have been developed and then put in. If we're talking, hypothetically speaking, let's say it like this: What if we had an incentivized program that would allow customers to get a rebate or discount on their rate structure if they were to put a battery at their house along with their behind the meter photovoltaic, but allow the dispatch of that battery be optimized by the utility? What are the things that would be required to do that?

Then we would need to have a DRMs-type platform. We would need to have the advanced metering infrastructure in place. Assuming those costs are accounted for, and we have this programming, what would the adoption rate of that program be? So, we have to decide what the sizing constituents of that are, how many batteries might be able to be stalled year over year. But then allowing that to be a resource that can be aggregated up at the bulk transmission level, dispatched against our load, and as an offset to what other supply side resources might need to be added by the utility.

Maybe we can look at an NPV delta then a VAT against your base case and say, “Well how much does that save?” And then, “Does that then give us some numbers on ways we might be able to look at what type of incentives could we offer in order to make that program a reality?”

I just wanted to bring up your answer to my question about hydrogen prices. Was it that you're tracking hydrogen prices as gas prices? So, it seems like the gas price does continue to be relevant. (Asked at March 15, 2023 meeting)
Asked by New Mexico State University on March 15, 2023. View meeting information here.

PNM Response

For the hydrogen price, we might say there's a floor on the price of hydrogen that equals the natural gas price forecast, but the hydrogen price we'll be looking at a couple of different ways.

One would assume in a hydrogen economy that you just kind of have a delivered product. The other would be self-producing the hydrogen. But those would be all influenced now by the production tax credits available and investment tax credits available for hydrogen production storage and equipment through the IRA [Inflation Reduction Act].

So, we would have a very separate and distinct pricing for hydrogen. Maybe it's a good idea to think about doing a low, a mid, and a high there. But the hydrogen price was something that we were going to endogenously develop through the modeling, specifically, of electrolysis storage and conversion to electricity within the model, as well as looking at the potential forecast for an assumed delivery price of hydrogen but trying to capture the effects of the IRA tax credits on that were not available during our last IRP.

I look at this IRP sensitivities [Slide 22], and you go from left to right, with the changes on the various assumptions, and I'm trying to compare this to the IRP core futures. It seems like you've got more categories, from left to right on the slide you’ve got up right now versus what you have from top to bottom, on the slide before on core futures [Slide 21]. I'm wondering, is there a version of this RFP sensitivity slide that can be made that essentially lays out the four core futures at the top of it, or something, just so that it's easy to see how the four core futures compare under all of the things from left to right versus the sensitivities? (Asked at March 15, 2023 meeting)
Asked by NM AREA on March 15, 2023. View meeting information here.

Initial Response: PNM

We could think about doing that. The previous slide [Slide 21] identifies, for example, in the current trends in policy, we've got our load forecast assumption, and that would tie to here. We didn't list the mid load forecast because that's not a sensitivity. Everything's always the sensitivity around the mid.

So, yes, let me think about how we might be able to do that.

We're saying that here's the core case for current trends and policy. And then, if you wanted to go to one of these components, and do a sensitivity to that, you would go to this next slide [Slide 22] and say, “Okay, well, if I want to go to the [EV?] adoption forecast, instead of using mid, what are my choices?” Well, EV adoption falls under the behind the meter; it's a customer behavior, so I could go with a high or a low.

NM AREA continued.

Yes, I guess what was kind of throwing me a little is that the sensitivities, the way you're presenting them, are not just a modification to one or two things on one of the four core futures; but rather, they're almost a way, at least they're striking me--maybe I'm misunderstanding--almost like as independent futures that are defined.

PNM continued.

I see what you’re saying. That's a bit confusing.

No, these are only meant to be a change to a single thing. So, let's say that we would look at what's highlighted in a given color or bolded is the change. it's not affecting anything else would be the way to

NM AREA continued.

Are they all essentially all sensitivities to current trends and policy? Would that be fair to say? Am I getting that right?

PNM continued.

They're all sensitivity factors to the reference pieces and current trends and policy, yes, but the bolded (colored either in black, red, or green) is showing what's changing. And it's just trying to categorize the change both across the top and going down the left hand side.

I see that's confusing. Let's think about a way to modify this. But each of these only represents a single change to the given factor.

NM AREA continued.

And I did notice that I think you guys did a good job putting this first stuff together. I'm not seeing things obviously missing. I do wonder how you want to work the feedback, assumingly, when we ultimately may have nothing we think is missing or needs to be added or is unnecessary on this list. But what do you perceive as a feedback process, given we also look into the facilitator process or really transitioning to that?

PNM continued.

We've always been asking for as much feedback as possible sent into our IRP website or email. At this point. I think it can go through [PNM] or [Gridworks]. And if there's the ability to scan it and mark it up and annotate and say here's what we think is wrong or missing and send it back in. Or, you can provide us just a verbal feedback at a meeting or working group. And I think there's multiple opportunities or ways to provide that feedback.

NM AREA continued.

Okay, so you're not setting any hard deadline or anything on this yet, at this point.

Gridworks continued.

I would suggest you keep track of any notes of things you think need to be considered, or if it's good as is, and then when we have the facilitated conversation on this, it could be even as early as the main workshop.

Two things.

One, keep track of any of your thoughts because we'll probably start out the conversation with the great work that PNM has already done because they've incorporated much of the feedback that you've heard already from the public advisory process. There may be some new things to consider. So, start from this.

Then, we’ll hear your comments through the facilitated stakeholder process.

I'd say keep track of any of the thoughts that you have on the material presented to date. And, if you have the opportunity to compare those notes with any of the other stakeholders, when we all come together, we'll know if there's strong support from lots of the group or nobody in the group.

You're welcome to do that offline. But I'd say keep track of your comments, and we'll incorporate them when we get together later in the process.

PNM continued.

And I would say the impetus is on feedback on certain things sooner rather than later, because, if you're thinking that we're missing something that has to be developed, that takes time, and we have a hard deadline when we need to file the IRP.

So, we've been asking for feedback over the preceding 14 months, trying to figure out if there's additional load forecasting errors that folks want to develop. Nobody spoke up, just as an example. And so, given the time constraints, there may be things that just are incapable of being done.

NM AREA continued.

That's a fair warning. And thanks [Gridworks] for your comments as well.

Are the energy efficiency technology bundles documented in a prior slide deck? (Asked at March 15, 2023 meeting)
Asked by SWEEP on March 15, 2023. View meeting information here.

PNM Response

Yes, the energy efficiency technology bundles were discussed in our January [2023] meeting.

I don't think we were looking for a lot of feedback on the development of those bundles. Those are one of those things, at this point, it's going to be tough to change. If there are things on here you want to get together and discuss or provide some feedback on quickly, we can talk to AEG, which we worked with on the development of those bundles for the energy efficiency bundles. But if you're trying to go back and rework those, depending on what the changes might be, it would be a difficult thing at this point.

So, we should probably take an action item on that to get to get you that material.

Public Comments and Reponses
There are no questions posted to this category.
Reliability-Resilience-Resource Adequacy
When do you plan to file the 18% planning reserve margin, if you have not already? (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

Response: PNM

We mentioned the 18% reserve margin in the 2020 IRP and then the portfolio we forwarded in our Palo Verde filing included resources to take us up to that 18% level, which the [Public Regulation] Commission approved.

That is likely to be just the first step. We're going to have to continue to increase the amount of reserves on the system as we take more and more steps towards a carbon-free system.

Depending on what you do with distributed resources and how that may interact with a more dynamic system, we'll have to figure out exactly what those numbers are. But just going, for example, from 18% was calibrated to .2 LOLE [Loss of Load Expectation]. If you go to .1, that 18% goes up to 21%. If you start to think about these other reliability metrics, like unserved energy or other things, you may find there is a tradeoff between what the planning reserve margin number is and whether that actually meets a different reliability metric, depending on how it was calibrated.

What other studies, in addition to the Southwest Resource Adequacy Study and the PNM Resiliency Study, are underway now? (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

Response: PNM

Those two studies have been completed, but we'll be doing a second phase of the resiliency case study. We are deciding how to incorporate other topics into this IRP. There are implications, key takeaways, coming out of the first two studies that are helping to inform how we might want to look at other ideas.

Please clarify what you mean when you say, as the system moves toward more decarbonization technologies, PNM wants the system to act the same. It's my understanding that these newer technologies inherently require a system that acts differently, maybe more nimbly, and utilizes energy sources in a different way. (Asked at April 28, 2022 meeting)
Asked by a CCAE on April 28, 2022. View meeting information here.

Initial Response: PNM

That comment referred to our thinking about the way we would plan a system for reliability purposes, for resource adequacy purposes, if the traditional metric that is used is loss of load expectation and we are designing a system to meet a loss of load expectation metric, say, .1 or one day in 10 years expectation of a loss of load event.

Now, with a traditional system that had dispatchable resources, if an event were to occur, meaning if there wasn't enough supply to meet your demands, and you had to enter a load shed event, there would be associated with that event the amount of expected energy not served, the amount of peak capacity or a peak demand that was not able to be served--things of that nature that you can't tell from only looking at the loss of load frequency measure.

The question to the group was, ‘If we're looking at designing a carbon-free system, would you expect the system to behave in the same way from a reliability or resource adequacy perspective, resiliency perspective, as the more traditional system?’

So, if the probability of having a load shed event is the same for a traditional system and a deeply decarbonized system, would we be willing to allow, for the sake of the deeply decarbonized system if it occurs, the magnitude to be worse?

That's the question that will be posited in the next stakeholder meeting, where we dive into the recent resiliency study, which revealed some very interesting things concerning a traditional system versus a decarbonizing system. For example, if we design to just a loss of load frequency standard, the way the system would behave, should an event occur, can be very, very different.

Update: PNM

Relevant topics are covered in the E3 study and May 25 PNM Public Advisory Group meeting materials:

E3 Study, Resource Adequacy in the Desert Southwest

May 25, 2022 Public Advisory Meeting materials

Will you do any kind of analysis regarding the contingency reserves rather than just the planning reserves? (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

Initial Response: PNM

The contingency reserve requirements are set by WECC and NERC, and then we have some reserves and sharing agreements. We will be monitoring those to determine if we think the reserves currently on the system can handle the disturbances.

We are also partnering with Sandia National Laboratories. They recently finished a report. looking at operating reserves and trying to come up with a way of formulaically determining the right amount of operating reserves for a system as we have more and more renewable resources and energy storage. It's just a first pass but we understand it's a very big problem. And we're very encouraged that Sandia wants to work with us on this and there are a number of other projects we're working on with them. We recognize that the static reserve issue is something that will need to be looked at in a more dynamic fashion.

Initial Response: Sandia National Laboratories

In working on this study and speaking with PNM, we both felt it was important to think about the kind of variability that will be on the system in just a few years as the PNM system goes from about 330 or so megawatts of utility scale PV now to 1500 or so and in just two or three years. It's quite an incredible change for the system in such a short time.

So, because the level of solar is so low, comparatively, right now, there isn't a lot of experience with how much variability that is going to be in the system. We really wanted to look at what kind of variability the system may see in a few years, and how much in the way of reserves might need to be set aside to deal with the solar variability. That can be handled by batteries, it could be handled by gas turbines, but there will be the need to set aside some amount of capacity to deal with that variability.

PNM continued.

We are working with Sandia on a number of projects. Maybe they can talk about some of those projects at a future meeting. We're excited with our partnership--literally in our backyard, just down the road. Our work with them goes on behind the scenes. We appreciate all the work that they're doing with us and the insights they provide.

Can the system be more robust in an extreme weather event? (Asked at April 28, 2022 meeting)
Asked by a member of the public on April 28, 2022. View meeting information here.

See PNM’s response to this question in Grid Modernization, April 28, 2022.


Was your assumption in this study a 4-hour battery? And if not, why? And if it was lower than that, why? What are you seeing on the horizon in terms of the likelihood of reasonable technology for a longer-term battery in the future? (Asked at May 25, 2022 meeting)
Asked by InterWest Energy Alliance on May 25, 2022. View meeting information here.

Response: PNM

Slide 48 shows the constituents of the portfolios, each of which we put through our standard resource adequacy framework that was designed to meet the 0.2 LOLE [Loss of Load Expectation] standard. Now we're moving to .1 in this next planning cycle. But we already had our IRP model set up, designed for 0.2 LOLE or one day in five years.

We designed these portfolios to let our resource planning software choose between different types of resources to meet the given resource adequacy metric and replace the 200 megawatts of Four Corners with a few different types of portfolios. So, for Four Corners, no new combustion portfolio was 96 megawatts of solar, 108 megawatts of 4-hour battery, and 48 megawatts of 2-hour battery. That was what the model selected as the economic portfolio, the least cost portfolio under the no new combustion framework. So, no new gas resources or combustible resources were allowed.

That would meet that one day in five standard and a similar look was done for the other portfolios. One of them is all gas and the other two are a mixture of a little bit of gas, a little bit of renewable, and a little bit of storage. We designed these four potential replacement portfolios--and these are generic resources. They weren't based off of an RFP. So, it's really the same idea of the IRP type framework, but they were designed to meet that set, resource adequacy standard.

And then we jumped into this resiliency framework and tested each of those portfolios for those different scenarios we described.

We're exploring a number of different things [for the longer-term battery]. Similar to the last planning cycle, we've issued an RFI to look at new technology that could help us meet our carbon reduction goals. Along with that, we actually issued a second RFI to look at any potential long duration storage that might have long lead times, which would be deliverable in the 2028-2033 timeframe. The first round of responses is due back June 15. Follow ups are due through September. (See also the April 28, 2022, discussion of extreme weather in Grid Modernization.

We are always talking to other vendors as well. We know there are other longer-duration storage technologies out there, many of them still in pilot phases. In an early stage, you can add additional duration, of course, to lithium batteries, and you end up asking if it is really a question of duration. Or should it be a question of total value? And because you can increase the total capacity for the same volume—forget equivalent duration—you'd have the ability to utilize, say, a 4-hour 100-megawatt battery; if you had an equivalent 200-megawatt 2-hour battery, the total value of stored energy is the same. And you could run it on a discharge. Just like a 100-megawatt 4-hour battery, you could run it like a 50-megawatt 8-hour battery; it gives you some flexibility, as well as allows you to increase the charge rate.

So, there might times in the wintertime, where your excess solar production is constrained to a narrow set of hours due to the shorter daylight hours, in the summers, you might want to look at doing increased size on the charging piece as well.

There are a lot of different ways to tackle this problem, and we're exploring them all, including one of the specific questions teased up for a phase two type study: How should we be looking at the problem? Is it strictly duration? Is it really volume? because you want to take into context what the charge and discharge rates could be, as, again, you can have a 2-hour battery that's the same as a 4-hour battery--just charged, discharging at a lesser rate?

We're going to do more presentations on batteries.

Once the RFI results are in, we'll hopefully have, like last time, multiple different technologies to look at: pumped hydro flow, batteries, maybe iron, air core batteries, lithium, gravitational storage, and a number of other different types of storage.

We visualize the future system as having a number of different pieces to it. You're going to have to have distributed resources. You're going to have to have long-duration storage. We have to have short-duration storage. Some of it is going to have to be at the renewable resource sites themselves. Other pieces will have to be in the load pocket so you can maximize the efficiency that transits the transmission system. There is just a whole lot that we still need to figure out, and we're still in the early stages.

This work is very important because it's giving us ways to analyze some of the issues and the right questions to ask.

Have you thought about what market structure would make the conservative use of the battery versus the sort of straightforward arbitrage use more likely or profitable? (Asked at May 25, 2022 meeting)
Asked by a member of the public on May 25, 2022. View meeting information here.

Initial Response: E3

Most of our reliability analysis has been done more for the utility. What we're talking about here is potentially only a handful of days a year, so the battery could run an economic arbitrage mode for the majority of the year. But then it's just being more conservative for just a handful of hours.

Initial Response: PNM

PNM being a vertically integrated utility that does not participate in an RTO [Regional Transmission Organization]. We are a member of the [Western] EIM [Energy Imbalance Market], but it doesn't give you any type of resource adequacy attributes; you've got to carry your own weight when you go into our market. We focused this study on how we would start to improve resiliency and reliability in that context.

This is a great question to add for stakeholders going into phase two of this study: What are some of the next steps we would want, and how can we incentivize? That type of behavior would certainly be one of them.

From PNM’s perspective, it's a matter of how we design the battery algorithms and control systems and ensure that, if you're in a typical operating zone, they can be dispatched for economic arbitrage or other products. But, given the state of the system, if you get outside of that operating zone, and given all the forecasts and other things that would be coming into a real-time control system, there would be a switch essentially that would move that battery from being unable to do the arbitrage opportunities to instead being conserved for reliability operations, especially for these extreme weather events.

You might have the ability to see those extreme weather events coming, but even if you get a weather forecast, you might not know how bad it's going to be. Again, from PNM’s perspective, not participating in a market yet, if you start to see the problem manifest a couple of days ahead of time, you’d get those batteries charged up, but you just don't release them because you might need to rely on them for some significant event over the next couple of days.

E3 continued.

From the market’s perspective, the question relates a little to the topic of capacity, accreditation in general, and the obligations that come along with receiving capacity credits, whether through a bilateral resource adequacy program or an organized capacity market in a centralized construct. Normally, what will happen is that when you sign up to provide capacity towards a resource adequacy requirement, which will come along with some sort of market obligations, as well as potential penalties or incentives for performance during specific periods.

So, perhaps we should think about how, in addition to responding to the natural price signals of the energy market, we might provide the right incentives or sort of signals to the storage resources to be there when we need them most, even if it means forgoing some amount of opportunity and energy arbitrage.

PNM continued.

Along those lines, maybe it's something that relates to an energy limited resource, especially a short-duration resource, the capacity, and payment structures through markets that need to be based on state of charge and occur more frequently throughout the day or week, as opposed to having a monthly kW month or annual capacity payment that would be more attributable to resources that have infinite duration and supply.

Did you assume in the scenarios any changes to the hardening of any of the facilities for either extreme heat or extreme cold? (Asked at May 25, 2022 meeting)
Asked by a member of the public on May 25, 2022. View meeting information here.

Initial Response: PNM

In 2011, we learned a lot, and PNM has been going through a number of winterization and hardening operations for its existing system. That's one of the reasons the system performed very well during the 2021 winter event.

The study did look at what happened if the system wasn't hard, and if there was either, common mode type failures or “extreme cold weather correlated forced outages.” We did look at that as one of the sensitivity cases, where we assume that some of the new resources that were coming on would already have that type of weatherization. So, in the situation where you had this cold weather, correlated forced outages, they would affect the existing system, but not the new resources.

Update: PNM

Additional detail can be found in posted resources covering this resiliency topic – see additional material for the May 25th meeting.


When you say extreme weather scenarios, are you talking about a specific duration? (Asked at May 25, 2022 meeting)
Asked by a member of the public on May 25, 2022. View meeting information here.

Response: PNM

Each of these scenarios was roughly a one week-long weather event. For example, the 2020 heatwave was roughly August 14 through August 20. The cold weather event was February 13 through February 19.

We’re focusing in on one week but when we ran the simulations, we ran the whole year, but we parameterized the simulation so that they included in that time period those one-week periods, the weather conditions that occurred, the outages that actually occurred, the market conditions that occurred, and other factors.

We ran the simulations for a full year to make sure we were getting the right mix of Monte Carlo forced outage draws. The results, then, focused in on how the systems performed during those one-week events--one in the summer, one in the winter.

The different scenarios are on slide 48, 55, and 56. Tables on Slides 55, and 56 go through what the different scenarios for the winter event and the summer event were and give a brief discussion on why we thought this was a good a good sensitivity case to study.

How do you think joining an RTO [Regional Transmission Organization], or forming an RTO would affect some of the conclusions you've reached? (Asked at May 25, 2022 meeting)
Asked by InterWest Energy Alliance on May 25, 2022. View meeting information here.

Response: PNM

So, there is a potential benefit--certainly, a long-term planning benefit in terms of helping to optimize the capacity across the region a bit more. But this certainly doesn't completely eliminate the need for new capacity resources--just perhaps dampen it a bit.

I know an RTO is not a short-term fix, but shouldn’t your longer-term look include looking at RTO development and doing the transmission upgrades and new builds needed, first identifying those, and then including them in your planning? Doesn't this all support that direction for your IRP? (Asked at May 25, 2022 meeting)
Asked by InterWest Energy Alliance on May 25, 2022. View meeting information here.

Response: PNM

In order to get to a deeply decarbonized PNM and the West, you're going to have to have a lot broader coordination, likely involving transmission and RTO type organizations to make that work.

A future meeting will discuss transmission planning and how that may or may not work in the IRP situation.

PNM as a company will continue to look at opportunities for collaboration and potentially joining an RTO, but it's going to take a while for something like that to materialize, probably not in this decade.

When we start thinking about transmission planning in the Integrated Resource Plan, there are some specific things that make that more difficult than people think. It has to be looked at a bit differently, including the models we will use.

We are bringing in a nodal production cost model, an enhancement to the current Encompass product we use. In order to really analyze transmission, you have to be able to look at the nodal aspects of things and have specific types of models that take into account the DC power flow to really understand the way the transmission flows are going to work.

Pipe and bubble is okay. I know there are some entities out there like Pacific Corp that incorporate a pipe and bubble transmission type topography and incremental transmission into their IRP. But that doesn't substitute for the type of work you'll actually have to do when you're doing real transmission planning, and generation interconnection studies.

PNM retail system only represents about half of the overall usage of the entire BA transmission system. And then we think about moving that out more broadly into the entire WECC. There are going to be benefits to doing some collaborative planning, but in the Integrated Resource Plan, we have to show what the resources and associated investments are on behalf of the retail system only.

Given the fact that 50% of the transmission system is in the FERC jurisdiction used by non-PNM retail entities, there has to be a much different way you look at the way that transmission system investment and other things might be done--especially in light of the Open Access transmission tariff, the obligation that we have to do things for customers who might not necessarily be a part of the PNM retail system.

There are a number of idiosyncrasies that might make PNM different than some other entities out there. We were considering trying to do transmission planning in the context of integrated resource planning, as opposed to letting the transmission planning department do transmission planning and then hopefully joining an RTO down the road.

PNM update:

Transmission was discussed at the following meetings:

September 13, 2022

October 6, 2022

Your regional scope includes New Mexico and Arizona, but it does not include California or any other part of the Southwest. How do you think your conclusions would change if you added California? (Asked at May 25, 2022 meeting)
Asked by InterWest Energy Alliance on May 25, 2022. View meeting information here.

Initial Response: E3

That's correct. The focus was Arizona and New Mexico.

Had we included another region, like California, within the bubble of a study like this, one of the effects that we wouldn't expect to see is that, with a little bit more diversity in loads and resources, there might be some opportunity to share resources in terms of their contributions towards resource adequacy. Now, that does assume or contemplate this perfect ability to share resources across the extent of the system, which might not be possible given transmission constraints, as well as the sort of institutions around the bilateral markets that exist today.

So, in some sense, there may be a theoretical physical benefit to a broader sort of footprint, but there are also limits on how much of that is achievable today.

Those are some of the conclusions that we've reached in this study. If we had included California, I don't think our perspective on this would really change at all. In fact, it might become even a little bit more extreme. We do know that California is at the same time facing a very immediate and real need for new investment in capacity. We've seen this reflected in recent decisions from the CPUC [California Public Utility Commission], including the midterm reliability decision, which, if you're following that process, is the one that authorized over 11 gigawatts of new capacity resources within the state by 2025-2026.

At the same time that we're looking at a historical rate of capacity additions needed within the southwest region, California is in a similar boat itself in terms of needing to move very quickly but facing challenges in terms of near-term deployment and supply chain resources.

You talk about LOLP being the gold standard, like moving to ELCC and different types of ELCC methodology. How are you looking at the net energy peak for this scenario? Or are you just looking at one hour in the peak summer evening after solar has ramped down? (Asked at May 25, 2022 meeting)
Asked by Pine Gate Renewables on May 25, 2022. View meeting information here.

Initial Response: E3

We used an LOLP [Loss of Load Probability] model to simulate the sort of dynamics of this grid on an hour-by-hour basis over the entire course of the year in order to identify which periods we expect to be the most constraining. Naturally, that leads us usually to find that those net peak periods are the ones that will be the greatest challenge to reliability. You’ll see that reflected in some of our results. In order to identify those periods in the first place, you do have to begin with the survey across all the different conditions, whether it’s peak, net peak, or any other part of the year: How does the relative sort of balance of loads and resources stack up against each other?

Initial Response: PNM

As it relates to PNM, throughout this IRP process, we’ll talk about the different values that energy storage provides, and how the economic analysis is conducted and takes into account the different value stacking of energy storage services.

Regarding ELCC [Effective Load Carrying Capacity] analysis, when you're running the loss of load probability models, you're going to rerun those every so often as your system changes. The amount of effective load carrying capability for a resource is going to be relative to the risk hours of the system, which will change as the system changes, and use the accounting mechanism to relate that back to your peak period.

You see the declining ELCC per solar because the risk hours are moving further and further away from the gross peak to the net peak, and where the contribution then of the solar resource, in and of itself, no longer provides the same capacity for the hours of risk on the system as it did at the time when the gross peak was the risk.

So, we are rerunning those loss of load probability models every so often. This will capture the dynamic changes of the system, and how the relative effect of load carrying capabilities of each resource type changes as the risk hours of the system change.

How are you thinking about the participation of storage in the market, given it might not be a wholesale electricity market by then? What are all the different services that the storage is providing? Does that change with the type of market structures? (Asked at May 25, 2022 meeting)
Asked by Pine Gate Renewables on May 25, 2022. View meeting information here.

Response: E3

In this effort, we're mainly focused on the questions around having enough capacity on the grid during the most constrained periods to maintain reliability. Our focus was not necessarily to conduct a detailed assessment of all of the different sorts of operational dynamics at play down to, say, the 5-minute interval at every instance of what the system looks like; or look at how energy storage behaves in different market constructs, whether it's providing ancillary services or energy, or some combination of the two.

Our focus is really on the periods where you need those resources the most: Will there be charge left in the tank for those resources to dispatch discharged to the grid? And so that requires some representation of the sort of charging and discharging cycling behavior of those energy storage resources. But it's not a really detailed operational analysis of the minute-by-minute or five- minute-by-five-minute sort of dispatch dynamics of the grid, under different market constructs.

It seems to me that [your resource planning] approach could also be for, say, planning on the contingency reserve requirement, or instead of maybe a severe event, it could be a severe curtailment of some generation resource or market resource. Could something like this be applied to that, assuming that the current standard doesn't change? (Asked at May 25, 2022 meeting)
Asked by a member of the public on May 25, 2022. View meeting information here.

Response: PNM

The contingency reserve or contingency reserves are set through the reliability coordinator. Through this type of framework, if we start to see more and more load shed, and we're thinking about how we build this framework into our planning, it can lead to a utility such as PNM carrying more resources. And if our operators think that they need to carry more contingency reserves, whether it's in the form of storage, quick start gas, or anything else, that will manifest itself through the planning process and that mechanism.

There's nothing that says we can't carry more than what's required. We just can't carry less.

Have other systems reached 100% decarbonization? There should be others like Hawaii and Vermont and a couple of other states that maybe are planning on it? What are they doing? (Asked at June 8, 2022 meeting)
Asked by CSOL Power on June 8, 2022. View meeting information here.

Response: PNM

This is going to be a growing area of work though nobody is at 100% right now. We're going to be figuring that out, and PNM is going to be one of the ones leading the way, just given where our system is going to be in 2023. If we're thinking about 1500 megawatts of solar, 700 megawatts of storage, and 600 megawatts of wind on a 2000-megawatt system, we're past California. We're way down the path ahead of just about anybody else.

Does FERC have any standards for utility? (Asked at June 8, 2022 meeting)
Asked by CSOL Power on June 8, 2022. View meeting information here.

Response: PNM

No. FERC designates reliability coordination to NERC, which has a number of different entities working underneath it. Those entities do maintain operating contingency reserve requirements that they monitor for all of the balancing area authorities, but planning reserve requirements, number of resources on the system, LOLE [Loss of Load Expectation], and other things, are left to the individual balancing area authorities and their state regulators to determine what is appropriate.

This battery penetration is assuming it’s all lithium-ion batteries, and you’re stating that it’s 4-hour capacity. Are you going to include other studies on other energy storage methodologies or technologies? (Asked at June 8, 2022 meeting)
Asked by CSOL Power on June 8, 2022. View meeting information here.

Response: PNM

The particular chemistry doesn’t make a difference on the ELCC [Effective Load Carrying Capacity]. It's the duration that will make a difference on the ELCC. Yes, there will be different presentations of different ELCC curves at different durations, just like was done in the last IRP. If you were to go to Appendix M in the 2020 IRP, you can see ELCC curves for 2-, 4- and 6-hour storage; we can extrapolate up from there, but we do run multiple iterations.

Does this particular graph (Slide 18) relate to battery penetration in megawatts? How does that relate to the percentage of the capacity of the system? Or it’s related to solar and wind? (Asked at June 8, 2022 meeting)
Asked by CSOL Power on June 8, 2022. View meeting information here.

Response: PNM

This is a marginal ELCC curve for 4-hour storage, so the parameterization around the existing system would have been the known wind and solar that had been approved for the system, which, in this case, was around 607 megawatts of wind and 1026 megawatts of solar.

This was how the existing system was parameterized for the 2020 ELCC study. In terms of the penetration level, we're roughly a 2000-megawatt system. As you go up, if you're getting to 1000 megawatts, that's roughly 50% of the system on a nameplate basis, but what this would be saying is that on an effective capacity basis, it would only be at 60%.

That's the whole idea behind the ELCC piece: You need to understand relative to the amount of nameplate capacity of a resource--how much can you actually count on when you really need it. And the greater the penetration, the less you can count on it.

Have you considered accounting for predicted extreme weather? We know the climate is changing and these extreme events are becoming more common. The weather is definitely getting hotter. Looking backward may not be sufficient to give us a realistic view of what's going to be happening in the next 40 years. Is there any effort to work with NOAA? I'm sure that they have done some modeling as to predicted weather. (Asked at June 8, 2022 meeting)
Asked by CSOL Power on June 8, 2022. View meeting information here.

Initial Response: PNM

One of the things we've been talking about in our load forecasting discussions is to look at 2020 or 2021, where we saw a summer heat event and a winter event. If we were to take a calibrated, load weather relationship, do some specific sampling of the weather variables from those known years, and increase the frequency of them or maybe increase the magnitude of those temperatures, could we then use that to create what we think is more representative of a load weather relationship 10 or 20 years from now as it's affected by climate change.

The uncertainty is going to be how quickly we see this transition to more extreme weather happening. We know we've been seeing more frequent events, but history is not always the best predictor of future events. How do we start to get our hands around it? What is the right increase of frequency? Or what is the right increase of magnitude of temperatures? Both in terms of cold and hot. It's something we're thinking and talking about.

We don't know that it changes the way we would do traditional resource adequacy modeling. It does offer up a separate idea about how we would consider resiliency or extreme weather by creating perhaps a single weather year--we'll call it climate change weather--that we would be then utilizing to test a portfolio that's developed using the traditional resource adequacy framework.

And then, are there additional things we need to do in order to protect ourselves against the effects of climate change when we put in the extreme weather pieces?

Initial Response: E3

What we see is that forecasting the climate is more in the realm of possibility. For example, ‘Next year, it'll be a hot summer.’ What is incredibly challenging computationally is forecasting hourly temperature for the next 10 years.

For the 2020 IRP, we took the weather as is for the resource adequacy work, but we have explored taking the trend out of the weather. So, if we see a trend of a degree and a half or two degrees higher over a 40-year period, whatever the numbers are, we can adjust 1980 weather up by its amount, 1990 by a little bit less. It's a simplistic way of trying to get all the weather years on the 2020-type basis. That's going to increase temperatures a little bit in the earlier years and have very little impact on the most recent years.

The harder question and the question that's going to actually impact results more would be how to make the prediction of what is going to occur. And so, there are a couple different ways we could do that. The difficulty is defending whatever you assume. If we assume that 2020 was a very hot year, and we want to either put more weight on that or duplicate that event more frequently, that's something that can be done in the modeling. The difficulty is who applies and how you apply those probabilities and the frequency of when they occur.

If we are looking at the temperature just rising, there is an easy way to get to that. At the end of the day, your results aren't really going to be impacted that much. But to the extent we change the frequency and have these extreme events occurring more often, it's a harder thing to do. More likely it’s going to impact the liability and ultimately the planning reserve margins much more.

PNM continued.

We welcome ideas from stakeholders on what is a reasonable approach for adjusting the frequency of events, or temperature increases going forward. The whole purpose of the technical sessions is to start trying to take ideas from a high level and work them in the modeling framework.

Regarding the distribution of uncertainties, you mentioned that you had book-ended the window of your uncertainties. Are there any? Have you investigated looking outside that window at extreme cases that might not have happened over the past 40 years? That might be an interesting exercise. (Asked at June 8, 2022 meeting)
Asked by Sandia National Laboratories on June 8, 2022. View meeting information here.

Initial Response: PNM

This question gets into the reason for the resiliency work that we just did--drawing the separation between traditional resource adequacy modeling and how we need to start thinking about extreme events. How do we want to start utilizing that framework for some of these IRP portfolios?

So, for example, we saw in the presentation of the resiliency study that traditional resource adequacy modeling is about those stochastic variables that are pretty well understood and have pretty well-defined probability. But when we get into the resiliency type framework or extreme weather analysis, we could use some stochastics within that, but we really have to come up with some deterministic scenarios in the way we parameterize.

We want to use the question posed here as a way to springboard into this next step of thinking about how we start incorporating that framework into the IRP. Are we running our most cost-effective portfolios through the same type of resiliency framework? Is there something else that makes sense?

We do need to move in that direction, not just focusing on the traditional RA modeling, but also taking some ideas and lessons learned from our resiliency work and extreme weather analysis to come up with a second framework.

Update: PNM

See also Technical Session #3: July 6, 2022.

Are you using Monte Carlo simulations with forced outage rates of the resources to run the LOLE models? (Asked at June 8, 2022 meeting)
Asked by Sandia National Laboratories on June 8, 2022. View meeting information here.

Response: PNM

The answer is “yes.” We're using SERVM [Strategic Energy & Risk Valuation Model software] to calculate the LOLE [Loss of Load Expectation]. That is a sequential commitment and dispatch with Monte Carlo outages. And we capture all the intermittency related to solar and wind. So, we're using solar profiles and wind profiles, which change by weather, and we're capturing all those different uncertainties in the model.

If we are looking at establishing a baseline level of service or capacity for summer or winter resilience, are there any contractual requirements if greater demand is placed on the West as a whole, such as if Hoover or Glen Canyon Dam are no longer able to supply power? This may, if there are contractual agreements, affect the sizing of systems. (Asked at June 8, 2022 meeting)
Asked by a member of the public on June 8, 2022. View meeting information here.

Initial Response: PNM

PNM does not have any contractual requirements, aside from its participation in the reserve sharing group. That's a very narrow window: If there was a contingency or some other thing that happened among the SRSG [Southwest Reserve Sharing Group] members, PNM may need to be able to provide a proportionate amount of contribution to aiding in the reserves for the group.

PNM doesn't have any contractual off takes from the Hoover Dam. But if entities such as NV Energy have some uptake from the Hoover Dam and if the dam no longer is able to produce as much energy and capacity as it has in the past, the main effects that PNM would see are a smaller available market or the other entities that are trying to cover that loss of power are now trying to purchase energy capacity in the same market that PNM is participating in, reducing liquidity and driving up prices and scarcity.

We do not have any contractual obligations to cover anybody else's share if some of those hydroelectric facilities are no longer able to produce it at historic levels. But we would be impacted indirectly through what we might be seeing in terms of ability to procure capacity and energy on short- or long-term markets.

Initial Response: E3

The risk of increasing drought or sustained drought in the West, and its impact on power markets, particularly in the Southwest, is something that we tried to explore a bit in our study. The main effect would be indirect through its impact on the availability of the market during the times when you need it.

How is transmission going to be worked into the IRP? What assumptions are going to be made about market support? What are the plans to tackle ELCC? (Asked at June 8, 2022 meeting)
Asked by Brubaker & Associates on June 8, 2022. View meeting information here.

Response: PNM

Brubaker & Associates and InterWest Energy Alliance have filed some comments regarding a number of things related to this topic and we're hoping that you are going to share some of your ideas with us.

This IRP is not going to be able to do a full-blown integration of transmission. We'll have a specific technical session on transmission, and we'll see what we can do. We're working with our transmission group, and bringing in the nodal version of Encompass, which is our power planning software.

Doing generic transmission doesn't make a lot of sense; you really need to have a known starting point and ending point for the lines to try to figure out where the resources are going to be. We have some ideas, similar to what we did last time, in terms of ways to modify the pipe and bubble setup. We don't believe we're going to have the nodal version ready to go. We're still getting that setup data worked out.

So, we're thinking about ways where we can take some information, perhaps from the previous higher-level RFPs, which have some regional differences in prices, and work with some of the transmission information that was in the last IRP to better understand how some of the resource pieces would work. But that obviously doesn't take into account transmission upgrades that might work better on congestion management within the existing system.

We want to try to do what we can to be sensitive to stakeholders' desires to have more transmission related information in the IRP but it's going to take a little bit more time before we can get to a full-blown integration of transmission there.

On the market import piece of it, at this point in time, we don't have any information that would tell us that we should be allowing for more market. We're going to see what happens over the summer. What we're seeing right now is that the markets are still severely constrained. We haven't said anything about going to a tighter requirement on the market. We think we're probably going to stick to where the market requirements are. But we do have a commitment with the stakeholders to meet this fall to talk about the market assistance in the modeling. That'll be definitely something that we're going to discuss.

We're going to be updating some of the neighboring modeling and the server model to help try to capture more specifically how our neighbors' portfolios are going to change over time. That may add some additional insight into how the market imports are working out.

We saw in the Southwest Resource Adequacy in the Desert Southwest study that, if everything is aligned, there's enough on the entire region; but just because the model says there's something there for the entire region doesn't mean the individual actors within the region are really able, and willing, to share that, given what they might want to hold back for their own needs.

What we have actually talked to some counterparts about is that they may not be willing to sell if they're getting in trouble, because they don't know that, if they let resources go, they're going to be willing to meet their needs if, for example, a unit trips, or especially if further down the road it's a question of more storage related for capacity.

So, we think at this point what we're going to be moving towards is a continuation of the same market assumptions that we had in the last IRP. But we're definitely willing to talk about that. We know there are questions about a formulaic way to do this and other things we can be looking at. But right now, our wholesalers are very limited in what they're able to do.

Day ahead and bilateral transactions are really what we're focused on concerning this question. It's not what can you get a year ahead and put on your L&R table; rather. the question is, if we go in with an open position, what do we actually think we can get a day ahead in real time?

As far as the ELCCs, we do have some thoughts. We're going to be updating the ELCC study. We have some thoughts on some ways to use some information from last time to get some better synergy values. Again, if there's any work that stakeholders or others have been doing, it would be a great springboard into the modeling framework.

We also need to be cognizant of the limitations of Encompass and how can we work the synergy ideas into the way that the internal ELCC logic is implemented within Encompass. We've got some ideas, but maybe others have some ideas, too.

And then we may have some information from others that are just starting to tackle ELCC issues for renewables more in depth. So, we’ll be glad to forward some information on that as it becomes available to us. That might be helpful in the discussion.

[In response to the question about tradeoffs, I would definitely go for carbon-free over .1 LOLE. That's just my statement: I would choose that we go carbon-free first. I would rather have one less day of no power, considering all the extreme weather events that are going to result from carbon emissions.] (Asked at June 8, 2022 meeting)
Asked by CSOL Power on June 8, 2022. View meeting information here.

Response: PNM

For clarification, we were asking, ‘What's the way we would rank things regarding the reliability versus the environment costs tradeoff?’ We would hazard a guess and we could appreciate that many stakeholders would be okay with a less reliable system if we could get towards carbon-free faster.

While doing the planning, have you taken into consideration the inertial requirements of the system to maintain frequency security as we replace more conventional generation with renewable resources? (Asked at June 8, 2022 meeting)
Asked by Sandia National Laboratories on June 8, 2022. View meeting information here.

Initial Response: E3

Yes, the short answer to that question is “no.” This isn't a study that has looked at those questions around the inertial requirements of the system. It's purely focused on when we stack up all the capacity within the region on an hour-to-hour basis: Is there enough total capacity to supply the region's demands?

Initial Response: PNM

From PNM’s perspective, it’s the same answer to some extent. The way we're looking at it from the integrated resource planning perspective is looking at the resources--the loads, the typical economic and reliability related production costs simulations. Outside of this group, more in our operations department, they are doing more work on inertial requirements, taking a look at power flows, transient dynamic stability analyses within the transmission and distribution systems. And, even today, they're starting to see things come up in terms of the ability to maintain inertial requirements under specific disturbances, depending on how many renewable resources are producing at that given point in time.

So, that is a focus within the company. It has not been worked up into the integrated resource planning process, yet. It's more of an operational issue.

Does the [electrification of the larger economy] impact the loss of load probability or the loss of load expectations in any way? (Asked at June 8, 2022 meeting)
Asked by a member of the public on June 8, 2022. View meeting information here.

Response: PNM

As long as we're building up expectations of increased load into the load forecast, we are using in the loss of load probability modeling, then we would be capturing those effects, and we would be targeting additional resources to be included in the portfolio to meet that additional load.

The work could fall short if there's an increased movement towards building electrification, or there are other aspects of electrifying the economies that are not foreseen within the load forecast, as well as load forecast errors within the loss of load probability modeling leading to increased loss of load risk if you're not adding enough resources to cover that uncertainty.

We have been talking with E3 about the question regarding the difference between planning reserves and contingency reserves. We will also follow up on the question of setting our planning reserve margin requirement and doing our loss of load modeling or resource adequacy modeling.

Doing the IRP cycle every three years, we're putting in our best estimates of the load forecast when we're doing our load modeling and setting up what our reliability metrics and our ultimate planning reserve margin requirements will be. Within the service framework, one of the Monte Carlo variables is load forecast uncertainty, and that's separate and apart from the load uncertainty associated with weather, and so you have some of the LOLE [Loss of Load Expectancy] risk that is then embedded within the model is associated with what happens if we under forecasted the load--not just the weather changing the load more than we expected.

Doing the IRP every three years we also get a chance to redo, reset, the Planning Reserve Margin (PRM) if we need to procure additional resources. So, we don't think that the entire economy is going to electrify so quickly that we won't be able to adapt as we're moving through this iterative planning process.

Your [example in the presentation] used a 2-hour battery. That doesn't seem to be a good assumption. Why not use a 4-hour battery since those are available now? (Asked at June 8, 2022 meeting)
Asked by InterWest Energy Alliance on June 8, 2022. View meeting information here.

Response: PNM

It was just an illustrative example. The whole purpose of the IRP is to determine the mixture of resources and storage. It's a mixture of capacity and duration that we're going to need to meet our reliability requirements. Some different durations of storage will have different ELCC values.

Given the penetration of storage that we're expecting on our system relative to what's already been approved by the Commission, we don't even think four hours is going to be doing a whole lot of justice to our system going forward; we're going to be needing to look at six, eight, and even longer storage when we think about what's happening in other jurisdictions. For example, California has been starting to add some eight-hour batteries--PG&E recently did an RFP that looking only for an eight-hour battery.

So, even four hours is too short at this point, if you've got even a modest amount of storage on your system, as a penetration of batteries on your system grows, the finite duration of that battery is going to limit the amount of load carrying capacity it has. And that's what leads to that decreasing ELCC for storage.

[Recalling concerns expressed (by Grid Strategies, LLC) in response to the 2020 IRP]. I think the thing to think about is that you are making assumptions about where you're going to be in different time frames so that you can divide up the synergistic benefits across the different resource types. Is this in any way directing an outcome and the economic optimization that will take place later? And what might be revealed is if you start going in a different direction in the optimization, then you are assuming where to balance and what the resources are going to be? You might be pretty close, and it is certainly going to be a lot closer than what was previously assumed to be benefits. (Asked at June 8, 2022 meeting)
Asked by Brubaker & Associates on June 8, 2022. View meeting information here.

Initial Response: PNM

So, if there are other ideas stakeholders have considered, we would love to hear them; you can share anything with us in a presentation for stakeholders this year or next,

You do have the question of whether the synergistic values you're inputting are driving the results too much or, by using the 2020 IRP as kind of framework, assuming that it was relatively close in its outcomes, we would think that this should be a reasonable approach. [Perhaps there is a] better way to do it--We'll talk with Anchor Power Solutions about whether they can build something like this into the optimization model.

If you had enough ELCC parameters done, you could set up within the optimization a binary variable for each different equation, relative to the bounds of the penetration levels of each resource type and have a sensitivity factor on each. And then that binary variable has to sum to one. So, you're only at one equation in the given point in time. But if you come up with, say, 50 different equations for each year, and you've got to add that for the 20 years of the optimization, you're introducing 1000 binary variables--that's very computationally expensive.

So, if there's a way to do it within this framework, which is 100% polynomial time, it's because it's all continuous variables, as opposed to adding those binary variables--it gets a little bit more computationally efficient.

Initial Response: E3

Regarding the 2020 IRP, we don't want to say there wasn't any synergistic value out in the future, because even our existing starting point had 1500 megawatts of solar. So, when we looked at marginal battery, there was some synergistic value captured, and that is why we didn't feel like it was as necessary.

But we do believe that if that 1500 MW of solar goes to 3000 MW, there's probably even some additional, so we don't want to leave stakeholders thinking that last time there was no synergistic value out in the future, because the starting point might have been somewhere between 300 and 600 megawatts of storage and 1500 megawatts of solar.

Brubaker & Associates continued.

I think why it became such an issue the last time was that when you did the San Juan Unit 1 & 4 replacement resources, we just sort of iterated on the economic analysis back and forth between Encompass and SERVM.

So, for PNM particularly, a lot of the issues on synergies became more apparent and accountable, because, ultimately, with SERVM economic numbers, and then the IRP and the Palo Verde lease replacement cases, we really relied on the economics from Encompass, which I think was good. But then the concern was capturing the energy benefits. So, it was good that part of it was captured but I think the idea is to try to definitely get more into it.

PNM continued.

That is absolutely what we're trying to work towards. We did a really good job with the near-term synergies, if we're thinking about the Palo Verde case, when we're talking about doing replacements, in 2023, and we know that our 2025 calibration was pretty much spot on. So, we don't see too much of an issue there.

We know that everything's going to change before we get to 2040. We're trying to look at pathways now, doing things to sharpen the pencil and working down that route. Now, the most important part of this IRP is the action plan. We want to show our pathway, but we want to make sure that the near-term action plan is the primary impetus.

You might have to potentially look at both LOLE and EUE. This raises a question: Which is more constraining? The other thing that comes to mind is that it may be that EUE is a better metric than LOLE when it's looked at more carefully; it more optimally identifies how much capacity you need to get a certain level of reliability or, more broadly, resilience. (Asked at June 8, 2022 meeting)
Asked by Brubaker & Associates on June 8, 2022. View meeting information here.

Response: PNM

This is exactly right. When we think about what's the right baseline, if you had a traditional system that was designed to meet a LOLE [Loss of Load Expectancy] metric, there would be a certain amount of EUE [Expected Unserved Energy] we associated with it. So, what the baseline we should be using? Is there something else?

If you're going to do a planning reserve margin requirement, are you still going to base that on LOLE? Probably. If you're going to use a EUE ELCC study, you're going to need to probably adjust your PRM [Planning Reserve Margin] or you're going to have a situation where, if you're using EUE-based ELCC curves, you're exceeding your targeted PRM; if it's based on LOLE in the event where you've got EUE being more binding metric.

These are all things we are definitely should be considering and looking for feedback in terms of the right way--or the perceived right way--to go about this. we don't think anybody would question that at some point in time it's going to be energy that's more constraining than capacity.

Is storage duration critical? Or is storage volume more important? And what is the cost tradeoff? I would say it depends a little bit on what the application is. Are we trying to firm up wind and solar or are we trying to use it as backup? That's something I would be willing to help with as well. (Asked at June 8, 2022 meeting)
Asked by Sandia National Laboratories on June 8, 2022. View meeting information here.

Response: PNM

Once again, we'll up take you up on that. And we've been doing a little bit of looking at things here. And it kind of depends, when we look at the system going forward, we've got carbon intensity requirements: We've got to start serving our customers, on average, with 400 pounds of CO2 or less beginning in 2023. This is related to Section 10D of the energy transition, and that goes down to 200 pounds in 2032. And then, of course, carbon free by 2040.

When we start to think to think about it, we've done this with some different load shapes, depending on what you want. And then, of course, there's incremental, potentially carbon generation in the system that, if you've got gas resources on margin, and if you start thinking about that, you’ve started trying to figure out, say, I want to do this all with solar and storage, how much charging capacity do I need? And how much total volume of energy do I need, depending on what those carbon requirements are to offset things?

By time shifting your solar from on peak into the off peak, maybe you should say excess solar and, some of the preliminary things we found is that, really, a lot of the requirements end up being driven by the winter period, especially as you get towards carbon free, because you have the shorter daylight producing hours. And you need to have that greater charging rate in order to sufficiently charge your storage resources. But then you're going to discharge them at 1/3 of the nameplate capacity to allow for a greater durational discharge over a period of time to sustain, from a sun set to sunrise kind of thing.

So, it's a very interesting topic. If that's your area of expertise, we would love to learn from you. And if you get if you got some papers, and you want to sit down and talk, we'd love to have you over in the office, or if you want to give a presentation, you're welcome to do so. Yes, we appreciate the insight that you can work with us. That'd be great.

So, the way we size the storage, it mostly can be customized to various applications. We were looking at the mean downtime. That's another important metric as far as reliability is concerned.

How do we establish a baseline for portfolio metrics such as EUE, which has been around for a long time now? If you look at literature that goes back to 1970s, you can see the matrix calculated there. So, there’s a lot of literature out there which have used IEEE test systems to calculate the EUE for a lot of systems and a lot of scenarios. Maybe that is something you would want to look at as a starting point for establishing a baseline. And I can help you with that if you want. (Asked at June 8, 2022 meeting)
Asked by Sandia National Laboratories on June 8, 2022. View meeting information here.

Response: PNM

Yes, we're doing some digging for that. It would be terrific if you have any publications or links that you could send to share.

Can you apply the SERVM stress test to the significant low carbon portfolios you produced in your IRP capacity expansion model? (Asked at June 22, 2022 meeting)
Asked by a member of the public on June 22, 2022. View meeting information here.

Response: PNM

The answer to that is “yes.” That's essentially what the resiliency study was doing now.

SERVM [Strategic Energy & Risk Valuation Model] works on a year-by-year basis, rather than doing all the study years at once. In the resiliency study, we looked at 2025: The big change in the portfolio we were considering was the removal of 200 megawatts of affirmed dispatchable coal generation and what some of the replacements for that might be. So, what we did was look at that IRP type portfolio for 2025.

Moving forward into the current IRP, we certainly can set up alternative years and look at, say, 2040. When we are not anticipating being carbon-free, we can look at an interim year—such as the main years where we saw some big changes in the portfolio. Along with 2014, another big year is 2032, when we have a new carbon intensity requirement that we have to meet.

That's one of the questions we wanted to pose to stakeholders: Is it appropriate, or should we be taking a look at, say, for the most cost effective portfolio some of those key years or do we want to look at 2025, 2033, and 2040 and run through some of those same resiliency and stress tests, making sure that if we're going to be decarbonizing we are meeting all these different reliability metrics, as opposed to just meeting the loss of load expectation metric? The genesis for that question was this resiliency work, seeing that there are different portfolios with different types of resources; while they can be normalized for equivalent probability of loss, a load event will perform differently if an event occurs.

We need to keep talking about fossil fuels: how they are being phased out and where those options are. Sometimes additional, more attractive fossil fuels, like gas versus coal, need to stay in the conversation in this transition period because the public doesn't really understand this issue very well. (Asked at June 22, 2022 meeting)
Asked by a member of the public on June 22, 2022. View meeting information here.

Response: PNM

We agree with you 100%. A transition should happen over time, not overnight.

You know, having some gas resources that are seldom used, but used when you really need them, is an important backup to this system. A lot of entities across the United States are still doing that. For example, Duke Energy has a carbon reduction plan. They operate in North Carolina and South Carolina, and they've got legislation that requires them to reduce carbon by 70% from 2005 levels by 2030. One year, while they will be getting out of coal completely, they are still planning to operate and potentially add new gas resources along with solar storage [and] things of that nature.

Keeping all options on the table is really important. So, we don't think that we should be taking gas off of the table for our list of candidate resources. There are gas technologies that are efficient that can be converted to non-carbon emitting fuels down the road. And that can provide that reliable backup service for those renewable droughts and other periods of time when you really need to make sure that you've got a reliable system.

So, we appreciate the comment, At this point in time, we want to keep options on the table and make sure that we're talking openly, factually, and honestly about what we need to keep the system reliable, that can help us in this transition, and make sure that this transition is successful.

We've heard that the average temperature in New York or for PJM (PJM Interconnection LLC) was going up .7, and we don't really know what the trend is for New Mexico. I'd like to see a scenario that does take into account the increased occurrence of heat waves in the summer, because that's what's going to stress your system. So, can we look at the trends we know about in New Mexico, project out increases in heat waves, and make a scenario for that? (Asked at July 6, 2022 meeting)
Asked by New Mexico State University on July 6, 2022. View meeting information here.

Initial Response: PNM

We understand the question as asking if we could somehow work into the forecast an increase in the frequency and the number of heat waves in a given year. That's something we've talked about a bit internally, including some ways to do it.

The question is more appropriately covered in our reliability, stochastic modeling, and not necessarily something that we would build into a base load forecast. But once we have a properly calibrated load weather relationship model, we could, say, go to 2021, where we saw a couple of heat waves that were pretty geographically widespread, use that as kind of a base weather system, run that through the load weather model, and come up with a load forecast where we are using a period of time as opposed to using normal weather or something to that effect.

Initial Response: Itron

So, as we do the 2040 hourly forecasts, we're running a daily weather pattern through and that can be anything that we want it to be right now. It has a typical hottest day in each month, typical second hottest day, and down to the typical coldest day, So, it represents fairly the range of weather that we've seen based on that 20 years of history, and the hottest days. So, we've got 20 hottest days; you average them and that's our hottest day. (Take the hottest day from each of the 20 years, freeze the 20 years, and average them.)

That's what's driving our peak forecast right now. And the day before and the day before it--those things matter in the modeling. So, the pattern matters as well. We can put whatever pattern we want and see what the implication is.

PNM continued.

That is captured more in our stochastic reliability modeling. And in terms of the way you know a couple of increased frequency of events affect the system, even if you're putting in a different pattern, it's still normal weather, and it's still within the same operating temperature ranges.

It probably would not have that big of a difference on the general portfolio, depending on the duration of some of those events. Maybe you start to see a bit of an increase adoption of more firm dispatchable resources or longer duration storage. But overall, the frequency of events is that it's not going to change--the capacity builds that much.

Itron continued.

And then there are parameters in the model that we can look at and anticipate the impact of an additional degree to the day, the day before, and the day after. If we go through those three parameters, there's some number like 20 megawatts per degree. We'd have to look at the slopes to know what those are.

PNM continued.

We welcome specific requests; for example, an ask to look at three extreme weather events per year throughout the period, with an increase of one degree per year. We want specific requests that we can put into a scenario development form to make sure that we're understanding the ask correctly.

Update: PNM

The PNM modeling framework and Phase 1 modeling scenarios were discussed during the February 15, 2023 meeting.

The framework for modeling run requests was discussed during the March 15, 2023 meeting.


We're mostly learning about how the baseline was developed for load, and how the stochastic scenarios affect production on the reliability side, but does the reliability model also apply stochastic variation to this baseline load forecast? Where would different load scenarios go? (Asked at July 6, 2022 meeting)
Asked by New Mexico State University on July 6, 2022. View meeting information here.

Response: PNM

Yes. The SERVM model that does our stochastic reliability modeling has 40 years of historical weather data. And it does stochastic variables, stochastic analysis on the load, as well as the renewable production related to the weather.

Take 2011, a year mentioned here as extremely hot in the desert Southwest. If it was sampling from the 2011 weather year, the model would then pull out the weather and apply that weather to the load as well as to the renewable production for a given sample day. You'd have that correlated effect of that weather year being applied to the base load shape, and the base, renewable production shapes with that stochastic weather uncertainty.

There are other stochastic variables--forced outage rates, economic uncertainty, other things in the stochastic model as well. When all are put together when we run that model, there are 40 different historic weather years, and a number of other stochastic variables. We end up having a little over 1000 single runs to represent stochastic hourly production cost runs. There are actually five-minute production cost runs that assess production cost and reliability for a given calendar year.

Shouldn't your heat wave analysis also include a length in time, depth in temperature, and demand and geographic breadth since these are assumptions that affect your assumptions regarding market availability? My point here is that in the last IRP analysis, some of the assumptions regarding availability of market resources regionally depended upon your assumption about heat waves, how deep they were going to be, how often they were going to be, and how regionally broad they were going to be. And the assumption was that everyone else in the region is going to be encountering the same heatwave at the same time. So, they're all going to be holding on to their resources. And there will be none that PNM could potentially draw from. My question is, if you're going to apply that same assumption this time around--I think that there's an underlying assumption in this cascade of assumptions regarding your heat wave analysis--are these heat waves becoming more geographically broad so that everyone in the Southwest experiences the same heatwave at the same time? And is it as deep for everyone at the same time, and does it last as long over the same time span for everyone so that your market availabilities are limited? (Asked at July 6, 2022 meeting)
Asked by InterWest Energy Alliance on July 6, 2022. View meeting information here.

Initial Response: PNM

The last time we did not assume that there was no ability to purchase from our neighbors during times of maximum constraints we did assume that there was a limited ability. We didn't just allow for unfettered transfer of energy within the model.

When we're doing the IRP, we have to look at PNM retail, and we have to make certain assumptions about the boundary conditions outside of PNM retail. There's more load and more resources in the PNM Balancing Authority (BA) and then there are other loads and resources even beyond what we saw in 2020. And that's where the assumption that you're referring to came about-- when we had that geographically wide heatwave in 2020, I believe is August 14-20.

There were maximum constraints in the market, and we were not able to purchase more--the day of maximum strain was August 18, or 19. when we were not able to purchase. There was one hour when we were only able to purchase 25 megawatts; another hour, we're only able to purchase 75 megawatts, despite having basically an unlimited price; we were paying over $1,000 a megawatt hour, and we just weren't able to get anything.

And so, what we've been seeing, and we've been talking about is that there has been a drastic decrease in the number of counterparties available in the bilateral markets, there has been a drastic decrease in the number of transactions. We know that there are more and more retirements of resources going on and systems are getting constrained. We saw in Arizona recently that a planned natural gas plant expansion was denied.

We are talking to our traders every day and understand what the market conditions are like. And as more and more firm dispatchable resources get retired, as more and more systems you have predominantly are solar and then storage for capacity going forward, we do believe it is less likely that utilities, especially in the near term, are going to be willing to share energy if it's coming out of an energy limited resource like storage.

So, we're not making any decisions yet on what our assumption around the market availability for resources would be for times of maximum constraint in our reliability modeling. We'll revisit that after the summer and see if there's any new data to consider. Right now, we're thinking we're still going to use the same assumptions as we did in the IRP last time.

In 85% of the lowest hours, there were no constraints in the model for that. And when we look at the top 85 or the top 50% of load days, if it wasn't a gross load period, the market was limited to between 200 and 300 megawatts of market assistance during those peak gross load hours. And then when we got into the peak net load hours that were reduced down to 50 megawatts, consistent with what we saw during the 2020 heatwave when we weren't really able to purchase anything, and it was those hours, as the sun was setting and there were maximum drawn resources into California and otherwise, when we talked about some of the limitations in the model as well.

We're trying to update the modeling of our neighbors--the change in their resources based on their IRPs so that way, we can understand some of the better implications of how the market dynamics may change as regional systems change, not just as PNM's system changes. We were only modeling one timeline away, say Arizona, for example. Most of our imports come from west of us from Arizona. We got negligible transmission capacity coming in from the east and from the north. And there's not much availability to be able to bring things in across white path 47 from the south.

So, most of what we get is coming in from the west. And Arizona also sells a lot into California. And we didn't have California in the model as a sink. All of that energy that might have been excess in Arizona was assumed to be made available to PNM at a perfectly efficient market, which is just a simplifying assumption.

That's why we have to look at some of the actual data of what is occurring during these times of key constraints and not just say, well, anything a model says is 100%. And that's some of the flavor behind what we're looking at when we're trying to take the reliability modeling forward.

But the heat wave analysis per se is something that, as we model PNM loads, we need to consider outside of the PNM retail system when we consider that it is more in the context of what we think we could reasonably count on to bring in from other systems during times of constraint.

The more we take out of our control, the more we sell, we put ourselves at risk. Should we be planning that we're an island? Should we be planning on limited amounts? Or should we plan on unlimited amounts? And should we add to risk to the system?

Is it a balance?

Update: PNM

See also Load and Energy Efficiency Forecasting topics discussed during December 15, 2022 meeting.

Will there be a more in-depth discussion of the first step discussed in this process? That is, the ELCC and PRM [Planning Reserve Margin] calculation methodology and SERVM? (Asked at July 27, 2022 meeting)
Asked by Form Energy on November 2, 2022. View meeting information here.

Response: PNM

We've had a few stakeholder presentations on ELCCs and the PRM methodology. There's some specific information in the June 8, 2022, and June 22, 2022, presentations, as well as in our September 15, 2020, presentation from the 2020 IRP.

We can certainly try to address any specific questions you might have. And we'll have more presentations once the ELCC study has finished. But in terms of having anything immediately coming up, unfortunately, we've already gone through some of that information. So, are there any specific questions you might have in that regard?

{Form Energy representative responded that he had nothing further -- He would go back and review the earlier material.]

Does the energy market input include future PNM membership in an RTO in the later years of the IRP? (Asked at July 27, 2022 meeting)
Asked by NM RETA on July 27, 2022. View meeting information here.

Initial Response: PNM

There's no specific representation of an RTO within the model going forward.

If we take a step back, we'll see that there are two different places where we look at energy markets in the modeling.

The first would be when we're setting up our planning reserve margin requirements to SERVM. What level of market support from external entities outside of PNM’s control are we willing to allow to contribute to the planning reserve margin requirement?

The second piece would be when we do the capacity expansion modeling. We do not allow that, except for whatever that specific reduction to the planning reserve margin requirement is, as an input. We don't allow purchases to be used to meet capacity and energy requirements when determining what the preferred resource bills will be for any scenario, nor do we allow sales to be included. We don't want to have the system being built for speculation; we want to make sure that we're picking the right resources to meet our requirements for our retail load.

That's what we have to do in the IRP--look only at our retail load. We don't even look at the whole balancing area, the requirements under the New Mexico rule, or our retail load in the IRP analysis.

And then when we do the more detailed production costings, once that capacity expansion is finished, and the portfolio for that given scenario is set and locked in, we re-dispatch the system on a full chronological hourly basis every year for the full 20 years. And we allow economic purchases and sales to be included in that there's no restriction in that representation, in terms of the amount of capacity or energy that can be done in any hour, except for what we believe are limitations at the liquid hubs where we trade.

So, we're typically saying that’s roughly 250 or so megawatts. And that corresponds to when we do a lot of our trading; we can typically do 250 to 300 megawatts of economy trades without incurring significant transmission cost. If we go beyond that, then there's transmission or hurdle rates that typically have to be included. That's the general setup.

We do fully anticipate that the West will move towards an RTO in the next 10 or 20 years. It's difficult for us to say exactly when. And it is even more difficult than to say, once they are created, how quickly we can do transmission planning. How quickly then could transmission lines get built?

So, there are a number of assumptions. We are supportive of the idea of an RTO but cannot say specifically when it will occur. And then to assume interconnection capabilities beyond what we already have here today is pretty speculative.

We will discuss some of these things a bit more in a future meeting on transmission modeling.

We've talked about this a little bit in the past when we brought in the Encompass nodal version of the model, which will allow for a full transmission constrained economic dispatch, not just of PNM retail system, not just at the BAA, but of the entire western interconnection. But it's going to be some time before we have that model, fully calibrated. Then, trying to use it going forward is something that's going to take place over time, at least as it works its way into the Integrated Resource Plan.

So, for right now we're focusing on what we've been able to see for economies within our existing operations. And regardless of whether we would be in an RTO or not in an RTO, we would not want to plan the system in a way that's going to be maximizing resource additions for the year to make purchases or sales. We still would have the obligation of finding a least cost solution for our retail customers, depending on how that RTO is set up, whether there's a capacity market, sharing of capacity resources, and other things, would depend on the market design of that RTO.

Update: PNM

Transmission topics were covered during September 13, 2022 and October 6, 2022 meetings.

Please describe why ELCC is used only for wind, solar, and storage. PJM's results from the recent [2022] winter storm Elliot in Texas and 2020’s Texas winter storm Uri showed significant severe thermal outages during peak need times. (Asked at January 17, 2023 meeting)
Asked by InterWest Energy Alliance on January 17, 2023. View meeting information here.

Initial Response: PNM

We can talk about that a little bit, but that was also in the presentation that one of the members of [the InterWest] team, Michael Goggin, presented at a previous meeting. We've committed to look at this.

Fundamentally, one of the things that needs to be kept in mind is that the loss of load risk hours for PNM’s system are currently in the summer. And so, when looking at thermal outages in winter conditions, that is not likely to modify ELCC results or PRM results or LOLE results for PNM's system. As we are still a summer peaking system and the risk hours are in the summer, winter outages like that are unlikely to affect the overall LOLE and system requirements.

Astrape continued.

I think you covered the main points [regarding] summer LOLE systems.

We don't really see this winter impact. We did, as part of a previous resiliency study for PNM that we worked on with E3, look at the cold weather outages over the last few years. The units actually performed quite well.

So, Atrape’s MO is really to look at the data. And if the data doesn't show that we've seen those cold weather outages, then we won't capture them. Even if we did put in some additional cold weather outages, I think it would take a very significant amount to really start surfacing much winter LOLE.

But I do want to make the point about our reserve margin accounting. I know we're not talking about it today. We do capture thermal resources on a UCAP basis. So, we are essentially reducing their nameplate by some discounted value: we're using one minus EFOR (effective forced outage rate).

If there was substantial cold weather outages, and there was winter risks, yes, I could see calculating more of a winter ELCC for those resources.

PNM continued.

You hit it on the head. The data just doesn't show it with our system, in terms of the way our units have performed. There were a lot of winterization efforts that had gone into our fleet following the 2011 cold weather event. The data just doesn't show what the PJM data shows.

You have to keep in mind that those are different systems or different units. They have different attributes and different risk hours associated with them. So, we can't just take a PJM analysis and assume that it can be applied equivalently to PNM’s system.

Is 650 megawatts of storage the recommended minimum for the PNM system to have operational by a certain year? (Asked at January 17, 2023 meeting)
Asked by NM RETA on January 17, 2023. View meeting information here.

PNM Response

The 650 represents the known procured storage resources we expect to have online by January 1, 2025. So, that's where that number comes from. If we were to go back, a few slides where Astrape had the starting point assumptions for wind, solar, and storage, the 607 megawatts is the wind we currently have on the system, actually, and we don't have any approved changes to increase that level of wind by the time we get to January 2025.

And if folks that were to do some more digging. that 607 is actually 657, but there's 250 megawatts of wind that are behind the 200-megawatt interconnection. So, it's never possible to get 657 megawatts out to the system. It's capped at 607.

Then the 1,531 megawatts of solar and 650 megawatts of storage represents PNM’s existing solar, and while there is no storage on the system yet, all incremental solar and storage additions that have been approved by the [Public Regulation] Commission, either in existing contracts, new contracts, and amended contracts have been filed with the Commission and are expected to be online by January 1, 2025.

So that's, that's where those numbers came from.

How would PNM view independent solar, whether on individual, for example, a roof, or DG (distributed generation) context adding storage? What might those installations look like? (Asked at January 17, 2023 meeting)
Asked by a member of the public on January 17, 2023. View meeting information here.

PNM Response

We would say that we can't require any individual customer to add storage, if they want to do something behind their own meter, as long as they go through the standard interconnection process, either for a rooftop edition or a small generator or large generator edition. We can't require them. We would like them to.

So, as we see more and more behind the meter storage added, PNM will likely need to start thinking about how can it best manage those additions, and it will likely be through other types of storage additions, whether on the bulk transmission level or on some targeted distribution feeders, to try to make sure that we can start maximizing the value of that solar energy that customers may want to put on their roofs--and ultimately would be putting back to the system as a part of their own interconnection.

So, the key takeaway from PNM’s perspective is there really shouldn't be solar additions at this point without storage additions. If we just continue to add solar, there are going to be times of high curtailments. That's not good for the system and not good for customers. If we really want to maximize the value of the solar renewable energy, there's going to have to be additions of storage along the way as well in order to best manage that.

And it's going to have to be targeted on distribution feeders. It's going to have to be at the bulk transmission level. We're going to have to incentivize customers to add their own as well. Now we can't require them to but storage and solar work together. So, we need to find ways to make sure that we're not going to be disproportionately adding one or the other.

The system is really the key takeaway from Astrape’s analysis here.

Is there a slide to show wind penetration to higher storage penetration? (Asked at January 17, 2023 meeting)
Asked by InterWest Energy Alliance on January 17, 2023. View meeting information here.

Initial Response: Astrape

Yes, [but] we don’t in this in this deck. This just shows the movement as solar increases.

We could go back and look.

PNM continued.

Here's the 650 storage [Slide 53]. We've got wind penetration levels there along the front axis. And if we were to take this and keep an eye on that front left corner point, that will say, "Well, if we keep wind the same, and we keep solar the same, and we just move forward in time, how does that front left corner point kind of change over time?"

You're adding storage, but the bulk of the additions and the portfolio ELCC is really being attributed to storage. There's very little, if any, interactive effect between wind and storage.

Astrape continued.

Yes, that's correct. I don't know that we can really glean it very cleanly from here.

But yes, certainly, that's something that can be looked at with the analysis we've done. We generally think wind and solar is the main interactive relationship there. So that's why we put that in here.

PNM continued.

Everything that we've looked at with Astrape shows that there's very little interaction between wind and storage. There's data out there, literature out there, that kind of says the same thing. And given where we're at on the solar proliferation, there's already all the benefit coming to the wind from where the net peak hours are.

So, the predominant interactive effect that we're seeing is between solar and storage. The wind ELCC at this point is almost independent, due to the way the rest of the system looks.

How much do the battery outage rates impact the study? (Asked at January 17, 2023 meeting)
Asked by a member of the public on January 17, 2023. View meeting information here.

Initial Response: PNM

We modeled them as an availability factor. So, the outage rates could have occurred at any point in time across the year. Holding everything else equal, if we had a 2% outage rate and, in the previous study, the maximum ELCC value theoretically could have been 98% for, say, a 4-hour storage device before we think about the penetration levels. And then this time, if we're modeling a 92% availability factor or an 8% outage rate, the maximum value that a storage device could see before accounting for those penetration levels is 92% instead of 98%.

So, you could think of it as a step shift downward in the starting point before each of the individual additional components that could degrade an ELCC over time were implemented.

Astrape continued.

That's it. You’re basically lowering the starting point of where your storage ELCC can start. You’re obviously from an LOLE perspective hurting reliability as well by having 600 megawatts of storage that now has a higher outage rate. Just like if I were to increase the outage rate on a coal unit or CT.

Is there any point at which you lower it [battery availability] well enough, it switches? That wind is better than solar for the system? (Asked at January 17, 2023 meeting)
Asked by a member of the public on January 17, 2023. View meeting information here.

Initial Response: Astrape

I think generally we're seeing wind ELCC is higher than the marginal solar ELCC already.

PNM continued.

If we were just adding a renewable resource without any storage, from a reliability perspective, wind would be better. That doesn't necessarily mean it's better from a cost perspective.

Because we don't see the interactive effect between wind and storage, as we do with solar and storage, the outage rates would have to go up pretty significantly if we wanted to say, “Well, when would we start adding wind instead of solar plus storage?” That might be a better question.

Astrape continued.

Yes. I would agree with that.

By adding significant amounts of solar, what's your level of curtailments? (Asked at January 17, 2023 meeting)
Asked by a member of the public on January 17, 2023. View meeting information here.

Initial Response: Astrape

We can pull that. The model certainly will calculate that. They're definitely increasing. And definitely, as you add storage with the solar, you can reduce that. So, we could certainly show what the curtailment looks like.

Member of the Public continued.

Are we talking 30%? 40%? This a significant amount of solar over generation in the summer hours, the peak hours.

I would assume if you're not keeping up with the storage, you're going to have significant amounts of curtailment that you're paying for and you're not getting the generation.

Astrape continued.

Yes, and that should flow through the economic benefits that get seen in the expansion planning model; that should play into the economics.

We see curtailment more as an economic issue than a reliability issue. As we talk to solar developers out there, it does sound as though they have the ability to curtail. Obviously, that can be put in the contract. So, it's not so much a reliability issue as it is economics; You're paying for solar that you're not getting. And so, you'd want that to be captured in the expansion planning results.

But in 2025, [we’d have to check] we've got 1,500 megawatts of solar modeled. We have 650 megawatts of storage. So, imagine the storage is helping out quite a bit, keeping the number reasonable, if you will, in 2025.

PNM continued.

From PNM’s perspective, there's still enough load in the summer, most of the time to where there's not going to be significant curtailments on the solar; [rather] more in those shoulder months. Peak solar production is really going to occur in May, because there is a bit of a degradation effect from the overheating of panels in the summer. So, you actually get slightly less output then, when you've got higher loads.

But we do agree curtailments will be more and more prevalent.

The degree to which there's going to be curtailments will also depend on how much our load grows and the storage that's added over time. To decrease curtailments by 1 or 2%, is it worth adding a significant investment in storage? That's a question, versus whether it's 10, 20, 30% curtailments.

I don't think we're seeing anything get up that high, especially in the near term. We're going to continue to keep an eye on it. And we've talked about some of the more nodal modeling capabilities that we're bringing in that'll help to pinpoint those curtailments a little bit more specifically.

But, as more and more renewables are added, there's going to be curtailments, there's no way to get around that. There's no way to deny it. It is an economic issue. And it's a cost trade off on whether it's more economic to curtail and potentially pay for curtailed energy versus make additional capital investment in storage.

There's no right answer. And from a contracting standpoint, there are ways to build the curtailments into contracts. And, ultimately, what that'll end up doing is leading to higher-price contracts if developers start building a certain level of curtailments into those contracts versus assuming that [the solar production from their facility] can't be curtailed.

I thought that adding more solar to the system was detrimental to it, or at least more detrimental than adding wind and storage. But from this presentation, I'm hearing the exact opposite. And so, I'm trying to reconcile what has changed from my [previous] understanding of it. (Asked at January 17, 2023 meeting)
Asked by a member of the public on January 17, 2023. View meeting information here.

Initial Response: PNM

I think the way I would characterize it is that just adding solar by itself is going to have very little value from a reliability point of view to the system. It's marginal ELCC is very, very low. It may have some energy value to the system, depending on the price of that resource.

And when we model--we're getting back to the curtailments a little bit--the renewable resources, we either model them as a PPA, and say that even if you curtail the resources, you’ve got to pay for those curtailments. Or if we model them as a capital cost, you're already incurring that capital cost, so you're not saving any money by curtailing them.

So, when we look at the economics that play out, you're really looking at the economics of the total cost of the resource or contract, not assuming that you save anything when curtailed.

And then thinking about the wind piece of it from a reliability perspective, in and of itself on a marginal ELCC basis, wind provides more reliability to the system, but there are going to be issues in getting that wind to Albuquerque, because there's not any available transmission, and it's going to take a long time to build transmission. It’s likely we couldn't get transmission to deliver wind for seven years or so, [according to what our transmission group presented earlier in this stakeholder process.]

But when we think about solar plus storage, as long as we're adding reasonable proportions of both--and I think that's one of the key takeaways from the updated ELCC analysis--there is a sweet spot of a ratio of solar to 4-hour storage. Of course, that ratio is going to be different if it's 8-hour storage, or if you take the weighted average of duration on your system. Fundamentally, there's a sweet spot in the amount of solar that will maximize the reliability contribution of that solar plus a storage resource, and we just don't see wind providing that level of combined benefit, in and of itself, or providing similar synergistic effects when combined with storage.

That doesn't mean there isn't value to wind. A lot of the value that we see in our modeling associated with wind is not from a reliability perspective, but from a carbon intensity perspective.

So, for folks who are unaware, one of the things that PNM is going to have to start doing is demonstrating compliance, starting with the 2023 operational year (note that the [Public Regulation] Commission has not yet promulgated the rules on compliance), every three years, with Section 10(D) of the Energy Transition Act. PNM must prove that it is serving its customers with 400 pounds of CO2 per megawatt hour or less, on average. And that drops down to 200 pounds in 2032.

And a lot of what we saw from the wind piece of it is that wind is the alternative resource to overbuilding solar plus storage to start decarbonizing the non-solar hours.

And so, the value from wind may not necessarily be from a reliability piece. But it can be from a carbon emissions requirement piece as we have to dip down into that 200 pounds per megawatt hour. Because by the time we get out to that point, we're probably going to have so much solar and storage on the system, the carbon emissions are no longer being created by serving daylight load, but by serving non-daylight load when you have natural gas on the margin.

If you think about it, the best natural gas resource out there is maybe 800 pounds per megawatt hour, if it's a combined cycle, or 1200 pounds per megawatt hour if it's a combustion turbine. And so, if I've got to serve an increment of load with a marginal gas unit, I'm going to have to offset that by anywhere from five to eight units of energy that is zero carbon.

So how do you best do that? That's where we're going to start seeing a lot of value to wind. Are we going to have the ability to do some type of pumped hydro or long duration resource that we can use to time shift significant amounts of solar energy into the off-peak hours? Do we have to do it with overbuilding shorter duration or mid duration storage? Or do we bring wind onto the system [since wind has a very different production pattern from solar].

And so, we have to think about all those different pieces.

Astrape continued.

To follow up, maybe the disconnect was overall value versus resource adequacy value. This story we've told as far as just resource adequacy values is pretty consistent and intuitive with what we've said in the past. So maybe it's more just the overall economic package. Obviously, the ELCC is a piece of that. So [perhaps] this is the disconnect.

Did you assume that Four Corners was in the mix in 2025? (Asked at January 17, 2023 meeting)
Asked by a member of the public on January 17, 2023. View meeting information here.

Initial Response: Astrape

Yes, Four Corners is still in the mix, 200 megawatts.

PNM continued.

Yes. We have not been granted the ability to abandon that yet. So, we did not assume it was out.

Regarding the difficulties in hours 18 and 20, is the forum for where PNM goes [to purchase power] all in WECC or can SPP offer any assistance? (Asked at January 17, 2023 meeting)
Asked by NM RETA on January 17, 2023. View meeting information here.

PNM Response

It's predominantly WECC. Regarding SPP: One of the other utilities in New Mexico, SPS, does have the ability to transfer power across the AC to DC converters at the Blackwater station and at another station. The problem there is that all the transmission is pretty well tied up and those converter stations are fairly unreliable.

So, the ability to count on getting some of that power scheduled across the converters and then actually deliver it to our load center is fairly limited. It is possible but it's not something that we would truly count on.

Transmission
Why doesn’t your list of current events include the interconnection docket 21-00266? (Asked at April 28, 2022 meeting)
Asked by REIA on April 28, 2022. View meeting information here.

Initial Response: PNM

Work on the interconnection docket is ongoing. We are reworking the interconnection manual, which, when done, will determine how the docket will affect the integrated resource planning process.

The interconnection manual and the interconnection process are governed by FERC and the Transmission side of the house within PNM, which is completely separate and distinct from the Generation group, where the IRP group falls. So, we have to keep a bit of separation in terms of what we would be discussing and what we would be thinking about in terms of interconnection and how that process works versus what we're doing on the generation side.

So, once a rule comes out, or once a change to the manual comes out, we'll see how we think that affects us. Ultimately, it's going to be a question of which resources are moved through that process and coming onto the system that we will have to ensure we account for in our modeling.

PNM Subsequent Comment

The interconnection manual updates rulemaking. We started this process to address two things: community solar and behind-the-meter rooftop solar. Community solar has a statutorily prescribed volume of solar additions to the system; we are absolutely going to include that in the IRP. Separately, we have a behind-the-meter rooftop solar forecast, also planned for the IRP, which is developed without consideration of the effects of how quickly or slowly interconnections can be processed.

I hope that one of the sub-topics of transmission will be the work that's being done around the West for regional transmission coordination (RTOs). What's being considered, by whom, and where? Is this an opportunity for PNM? Also, regional market opportunities because of what I've been learning is that for reliability in this age of increasing weather variability and penetration of utility-scale renewables, like we need a larger footprint, so I hope that's one of the sub-topics. (Asked at April 28, 2022 meeting)
Asked by WRA on April 28, 2022. View meeting information here.

Initial Response: PNM

We will have to dive into the transmission topics in one of the technical sessions.

There are certain things that can be done within the IRP perspective, and unfortunately, there are things we won't be able to do, at least not in this IRP. Transmission is a regional or broader issue, and the IRP is required to look at retail and not even the full PNM balancing area authority present some complicating factors.

We could benefit from some type of regional transmission organization or other type of transmission operation to get to a full decarbonization, but we can't do that alone. PNM is a very small utility in the West, and that effort is something that's going to take more than just PNM to get the ball rolling.

WRA continued.

Regarding historically marginalized front-line communities, we may also want to consider the location of generation--whether it is for the jobs that would be provided or such.

See the discussion regarding sub-populations in Grid Mod.

PNM continued.

In terms of location, where we site generation in marginalized communities gets more into an RFP type situation, where you're trying to determine where specifically and what specific projects you are going to be adding. The IRP is more generic in that we look for trends. We look for how much, say, solar, wind, battery storage, and other things we are going to need to get the system right. You don't see the specific locations until you have specific projects offered in an RFP.

We are trying to figure out ways to improve upon that. Currently, we are working with some of our software developers to go to a more nodal production cost modeling paradigm so we can incorporate more transmission work and location-specific elements into the planning process. I don't know if we're going to get there through this IRP cycle. It takes a whole lot of effort to get those databases set up and those models calibrated, as well as trying to run nodal models.

You have to have very specific transmission elements to include in terms of locations, impedances, and other characteristics, and then you have to have very specific generator characteristics to include in terms of locations that would connect to those transmission lines.

So, we want to have the conversation. That's why we have transmission analysis in the IRP as a topic. It's much more complicated than most people understand. We are committing to do our best with it. We are being 100% straightforward, but we don't know that we will fully meet stakeholder expectations in this planning cycle.

I was wondering if you’re thinking that a discussion around something like transmission for wind resources may have a place in the transmission analysis group? (Asked at April 28, 2022 meeting)
Asked by Sandia National Laboratories on April 28, 2022. View meeting information here.

Response: PNM

Yes, it has a place there. What we generally saw in the last IRP was that there was a tradeoff between wind coming in, around 2032, mainly centered around that reduction in the carbon intensity requirements and needing to decarbonize the off-peak hours versus a lot of additional solar plus storage and trying to time shift the additional solar energy to the off peak.

The major hurdle on wind is transmission, bringing it in from the east and getting enough support to try to get that transmission built as well as enough support to have a large enough wind farm to enable that transmission. If we consider the most recent transmission line, the Western Spirit Line, that was completed and energized with pattern energy (it's not PNM--PNM is not an off taker from that project), they had to start that line five years ahead of when they started the wind farm.

So, we have got to get into a paradigm where we can look further ahead through our regulatory process and other things to take those proactive steps when we may not need the resource for another 10 years from now. We will definitely talk about that in the transmission planning aspects.

Also, from the transmission point of view, and maybe from the holistic system point of view, right now we have enough transmission to serve a load reliably. Assuming you can have control over all of your resources, as we move towards a paradigm where we have more variable resources and more storage resources, we’re going to have to consider: Do we build the transmission system out enough to where you can deliver every single megawatt of renewables at the time it's produced? Do we accept some curtailments? Do you put storage both at the generator and in the load pocket? Or is there some combination of the three that enables the most cost-effective solutions for customers?

Yet another part about the transmission system design is that you have to figure out the most efficient way to utilize the existing system, and the things you need to add to that system to make it as efficient as possible throughout this transition.

The last time around you did some limited work when doing resource selection, allowing certain transmission upgrades or projects to be selectable in the optimization. Obviously, there are limitations on computing capability. Do you envision doing some of that this time around as well, [to the extent] it's workable and practical within current computing limitations? (Asked at June 8, 2022 meeting)
Asked by Brubaker & Associates on June 8, 2022. View meeting information here.

Initial Response: PNM

We're looking at the lessons learned from that last go round. One of the things that we failed to anticipate was that, especially in some of the higher load cases, there just wasn't enough combined transmission plus resources, on an ELCC [Effective Load Carrying Capacity] basis, to meet those very, very high load cases.

Our transmission group is very busy, and we don't know if they are going to be able to provide us with additional candidate transmission. One thought could be, ‘What do we leverage from the previous work?’ Are there some ways to have another piece of it, like the MISO MTEP [MISO Transmission Expansion Plan] process, for example? They’re saying, “What's in the queue? And how can we figure out different transmission solutions based on known projects in the queue?”

But then they're looking at adjusted production cost savings to look at the economic pieces of it. Well, if we've got generic resources, and not specific resources, trying to determine what the actual cost for those resources are, if you don't have an RFP, becomes a factor.

Can we go to the RFPs and say ‘Well, we have these four zones, is there a way to come up with differentials and pricing and maybe production shapes for these different zones?’ as opposed to being more generic? Then, that gives you a differential on both the transmission component and the resource component. But you're still only as good as those assumptions might be versus going to the actual RFP.

No matter what we do in this IRP, we're going to have to do a full transmission and production evaluation of an RFP in the future, so it's going to be somewhat duplicative work.

Brubaker & Associates continued.

We may have some information, at least ideas that were floated in Colorado about interactions between RFPs for resources, and what transmission projects are very well assumed to be available--how you factor that in. So, that might be helpful.

There were some concerns about the practicalities--some of the things that were uploaded in that study--and certainly some of our stakeholders may have similar concerns, so it may be helpful for you to share them.

PNM continued.

We'd be happy to take a look.

Of course, Colorado's transmission will be a little bit different than ours. But if there are lessons we can learn from their methods, we’d be happy to consider it. We—PNM and others--have been talking with Sandia National Laboratories about their research on integrating transmission modeling. It's a very difficult topic. The tough part is how to get this done in a way that actually provides value to the overall results and is not just nice window dressing.

How is transmission going to be worked into the IRP? What assumptions are going to be made about market support? What are the plans to tackle ELCC? (Asked at June 8, 2022 meeting)
Asked by Brubaker & Associates on June 8, 2022. View meeting information here.

See the discussion regarding market assumptions in questions asked at June 22, 2022, July 6, 2022 and July 27, 2022 meetings regarding Reliability, Resilience & Resource Adequacy.

If PNM is not connected to the SPP except through the Blackwater tie, how then can PNM take advantage of SPP/SPS resources? (Asked at June 22, 2022 meeting)
Asked by a member of the public on June 22, 2022. View meeting information here.

Response: PNM

Interaction with resources in the SPP [Southwest Power Pool] would be significantly reduced without the Blackwater tie. In recent years, interaction between PNM and SPP resources has been minimal. PNM also has ownership and capacity in the Eddy County tie in southern New Mexico could allow some ability to lean on SPP resources. This tie is at the end of life and options are being explored for possible replacement.

There are a few other AC to DC to AC converters between SPP and WECC that might provide limited power transfers between SPP and PNM. So, there should remain some very limited ability to interact with the SPP RTO, which includes SPS [Southwestern Public Service Company] here in New Mexico.

SPS, of course, is a subsidiary of Xcel and does have some resources in Colorado that we can potentially interact with PNM directly or indirectly through converters located in Colorado. But that's expected to be very limited and typically our interactions with other utilities are to the west of us not to the east.

Is transmission also an issue with wind that may be less of a transmission issue as solar? (Asked at July 6, 2022 meeting)
Asked by a member of the public on July 6, 2022. View meeting information here.

Initial Response: PNM


The transmission issue with wind is predominately related to the fact that there's not really the ability to add wind resources anywhere near the load pocket. And so, when we think about where the good New Mexico wind resources are, they're all out in the eastern New Mexico, Clines Corner, and further east. The transmission coming in from that part of the state is fully subscribed.

In order to get more wind into the system, we wouldn’t need to add more transmission, where the general geography and availability of solar allows for different resources that have solar resources to be added differently throughout the broader part of the state. They may not require transmission. We're getting to the point where the transmission system overall is pretty fully subscribed when you talk about firm transmission service.

And so there may have to be a different way of viewing the way that the transmission system is going to be used and operated. Maybe we need to start looking at energy only interconnects, where you allow for some curtailments, or you got to start putting the storage resources in the load pocket as well as having the resources be able to soak up some curtailments that might occur in order to use the transmission system as it currently exists without adding much more transmission.

It takes a long time to add transmission to what our transmission group will typically tell you; we've got to go through the standard process and build a new 100 mile or 150-mile line, and you're probably talking about a 10-year project from start to finish--from conceptualization, permitting, commission approval. and then actual construction.

And so, all those things we have to factor into the equation. Many think that transmission is going to be something that can get us over the hump of decarbonization. But unless we can build transmission faster, we might need to focus a little bit more on distributed resources until we can get that transmission built.

Member of the public continued.
I was aware of that, and it's always been a question of a concern for me--that transmission building doesn't seem to be a very immediate resolution to anything.

PNM continued.

Yes, you're exactly right. And we would like to be able to build more transmission and upgrade our existing transmission system and the backbone structure. The main PNM transmission lines were all built back in the 60s and 70s. We think that it would be prudent to add more transmission upgrades. The reality is that it's very difficult to do from a regulatory, permitting, and other process perspectives. Just because we want to do it doesn't mean that there aren't impediments to getting it done.

My understanding is that PNM is looking to link transmission to a particular resource in a particular location, and then ascribe the costs to that resource or development or whatever? Is that right? (Asked at July 6, 2022 meeting)
Asked by InterWest Energy Alliance on July 6, 2022. View meeting information here.

Response: PNM

The IRP is not a full-blown transmission analysis, and it was never meant to be one. There are things that we can do and things that we can't do.

We addressed transmission hurdles in the 2020 IRP, where there were four candidate transmission projects: one that would increase transmission capability from the Four Corners area, one that would go towards eastern New Mexico, one that would go to northwestern New Mexico, and one that would go south of Albuquerque, but not across cut Path 47 into the southern service territories. We had costs for those such that we knew what resources could generally be added in those different resource locations.

For example, when we would only assume what was available in the east, we said that to do that 800-megawatt transmission line had a cost of, say, $300 million, or X dollars per kilowatt of transmission. And then we would add those X dollars per kilowatt of transmission on to the dollar per kilowatt for wind. And so, the combined cost of the model would show that when making that choice to add wind it was a combination of transmission and capital for wind.

And we said that for wind, in particular, if you're going to have to build that whole big new line, you're not going to do it for less than 400 megawatts. So, we made an assumption that you had to take at least a 400-megawatt wind farm with half of the transmission line, essentially. And maybe there was some other party who would take the other half of the line that wouldn't go into retail rates.

That's another distinguishing feature about the transmission piece: We only look at New Mexico retail in the IRP. All of the transmission that PNM owns and what is in our balancing area authority; half of it is not used to serve our retail system.

So, you have to think about the things that are affecting the transmission system and how that would work when only half of it is actually utilized for the transmission of energy for the retail customers and only half is cost recovered from retail customers. The other comes from FERC jurisdictional

PNM, having acknowledged transmission constraints in the east, why not look at those as individual pieces of the IRP as well, instead of just linking it to particular resources? (Asked at July 6, 2022 meeting)
Asked by InterWest Energy Alliance on July 6, 2022. View meeting information here.

Response: PNM

This question gets into the difference between PNM retail and then PNM the balancing area.

The eastward constraints are because we have, aside from needing additional transmission, to bring in resources, say from the east, for new wind. If we wanted to go further east than that, we're up against the AC to DC to AC converting stations that interconnect us into the eastern interconnect. They're on a different frequency; they're asynchronous, essentially, to the PNM system. In order to transfer power between the eastern interconnect and the western connect where PNM is, that power should go through these AC to DC to AC ties, which are very old and not very reliable anymore, and would require significant upgrades in order to allow for greater deliveries.

Once that power gets across the ties, there are additional constraints then to get the power from across those ties to the PNM load centers. There really is a need for us to increase those ties and increase that transmission versus adding resources elsewhere.

The same thing could be said about going up towards the north, but that would all be power that's coming in from neighbors. Are we going to be able to count on that? Are we going to be contracting for long term obligations that would necessitate those transmission additions? And would that be cost effective, rather than building resources closer to our load center, and being able to control those resources

The IRP really is not the right process for assessing that.

Given that there are these fundamental differences between the way the PNM retail system works and how we plan for that versus the way you might think of doing broader regional transmission planning through an RTO, is one of the keys that will help us get to carbon free. But it's not going to be PNM that drives that process. We're just too small of a fish in too big of a pool.

Is a decent summary that you are largely approaching these transmission constraints in the IRP by planning for large projects, a couple of 100 megawatts where one or two developers will serve as a kind of anchor customer that will take responsibility for the transmission upgrades needed for their projects? (Asked at July 6, 2022 meeting)
Asked by NMPRC on July 6, 2022. View meeting information here.

Response: PNM

You might infer that somewhat from the wind example. But generally, we're just looking for trends in the IRP. When we get into an actual procurement, we will identify the specific resources and then apply to the [Public Regulation] Commission.

In a countervailing example, when we are looking at storage, or solar things that can be built much more modularly and added closer to the load pocket, we didn't require a minimum 400-megawatt size. There were different transmission options: For example, there was a transmission option looked like it could upgrade the load carrying capability just within the load pocket. And then there were two or three transmission options that were in the west and the north and a little bit in the south.

And because we see much more difference in size on solar and storage, we said that those could be picked up in much smaller increments, and so might marginally add some transmission upgrade costs, but in proportion to the size that was chosen for that specific resource type.

The IRP might say: In X year, we need only 25 megawatts of solar and storage at this location. It would only incur a transmission upgrade cost that was proportional to the dollar per kW cost of the transmission that was associated with the north or west, which was a lower cost than going to the east, but it didn't require that big hurdle in terms of a 400-megawatt size.

That's what we've been seeing in the RFPs as well. There's some work that can be done within smaller time frames. If you start adding those really big resources--200-, 300-, 400-megawatts--those are going to drive significant transmission upgrades. We'll get to a point where everything will drive that, letting you know that the transmission system is getting pretty fully subscribed.

There are little things that the transmission group can do to accommodate some smaller resources, but eventually we're going to run out of those and it's going to drive larger transmission upgrades.

NM AREA will be most interested in PNM's specific plans for its 2023 IRP to meet Ordering Paragraph B of the Commission's July 25 Order. (Asked at September 13, 2022 meeting)
Asked by NM AREA on September 13, 2022. View meeting information here.

Response: PNM

We're going to start talking about transmission modeling in the IRP generally, what we see across the country as well as specific events we'll be doing,

Paragraph G of the Commission's July 25 order, and the 2020 proceeding, is not part of the ordering paragraph.

The ordering paragraph’s particular section is Section B, which recommends we include a meaningful analysis of transmission and distribution constraints as well as see what other new requirements may come out to new or amended IRP rules.

We do know that there is an IRP rule scheduled for discussion, potentially a final order will come out of that in [the September 14, 2022] open meetings. We'll have to wait and see what that says.

You were focusing on the ordering section, and we will evaluate any new rules that come out then or otherwise that we have to take into account.

Are there withdrawal penalties for applicants? (Asked at September 13, 2022 meeting)
Asked by a Member of the Public on September 13, 2022. View meeting information here.

Response: PNM Transmission

They're not necessarily withdrawal penalties, but there are obligations for study costs, to continue through with study costs, and it will just double their study cost requirements as it stands today, but not any "withdrawal penalties."

To whom are you targeting this information? Is this to the general public or is this just specific financial interests? It seems that the general public is not very well informed about much of what was covered today. (Asked at September 13, 2022 meeting)
Asked by a Member of the Public on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

That's probably true but we try to get the information out through our open access website. Normally, the public is interacting with our site, where we have published every study we've ever done on the transmission system. We have all the information that's required out there. Folks can get a great feel for our system. I'm surprised at how few people use it. To remain in compliance with the federal rules, we make all information about the transmission system available to all parties, identically, and at the same time. That is a federal obligation.

So, this information would be available to the general public, on the internet.

Back to the chicken and egg problem. I want to put in a plug for proactive transmission planning. We’ve encountered this problem for a long time, and we found that the only thing that works is proactive transmission development. You know the CREZ (Competitive Renewable Energy Zones) example was kind of the first one that did this. At that point, it was kind of the risky and novel idea that we are going to designate these zones, we know where renewables are, and we think they’ll develop. And they did. We built it and they came. We’ve seen it replicated in SPP and MISO with the MVPs (Multi Value Projects) and [in California]. All these examples we’ve seen have been very successful. And given where the renewable cost trends are with the IRA tax credits, and most importantly with New Mexico state law basically specifying where your generation mix is, it seems to me there's extremely low risk that you would build transmission to these high real resource areas. And we know where these are, and the renewable resources are not going to change. We know where the wind is and where the sun is. It seems almost no brainer that if you were to build transmission, proactively plan transmission to those resource areas, maybe informed by projects in the queue, and even do some type of public season process where there are some deposits, some skin in the game, from developers to ensure they are real. That’s been used in other regions as well. I’m very confident this would work and get you much more cost energy at a lower cost of transmission because you could right size it to accommodate the scale of the project for one interconnect that you need to meet your load. Basically, you can do proactive transmission planning and incorporate this into your process. I think that is essential for doing this cost-effectively. (Asked at September 13, 2022 meeting)
Asked by Interwest Energy Alliance on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

Yes, I think there's no question that you're correct. And that's one of the things we're looking at is trying to do a longer-term transmission plan. And again, a transmission plan is only as good as where did loads decide to go and where did the generators decide to go?

We've talked about doing this internally and we haven't been able to execute it quite yet, but one of the ideas we’re knocking around is exactly what I talked about a little earlier: trying to break a system up into zones. One of the things we've been cautioned on is, as a company, creating winners and losers in the state. And so, we'd have to figure out a way to do that collaboratively with stakeholders and ensure that we're not discriminating in any way or creating some kind of disincentive for economic development in parts of the state that might not be on our top five or top ten list in terms of locations.

But we're working through those conversations to try to figure out how we might go about doing something like that because, again, we see value in that potential.

Interwest Energy Alliance continued.

Great, thanks.

PNM continued.

To follow up on that a little bit.

The example that you gave--CREZ--might have been legislated for that development, and the MVP projects and other things went through the RTOs. There's just a different planning process, different cost allocation, and recovery mechanisms that are set up.

PNM is a smaller utility. A half a billion- or billion-dollar line is approaching 25% of our total market capitalization as a holding company, not just even looking at PNM utilities. So, it's a difficult proposition. Unless there's some other way to gain additional financing, to try to stand up some of those things on speculation and take the risk when regulators have been looking for ways to write us off.

PNM Transmission continued.

The way we talked about doing it is trying to put the information out there so people can organize around the information. So, instead of us deciding--please come and give us a chunk of money to help us make it happen--It's empowering people with information about economic feasibility, permitting feasibility, and constructability incorporation in the broader system. Those kinds of things are what we'd like to arm people with, rather than trying to be at the center of taking a risk.

For transmission, for example, SunZia is somewhere in the $2 billion range. This company doesn’t have $2 billion to invest in a project like that today. The kind of thing we would hope to do is this idea of arming people with information and helping the market to organize itself.


When an interconnection is made for a specific generator, how much of that cost eventually goes into the transmission rate base? It seems like some facilities could be useful for interconnecting more resources and others might be only used for that one generator. (Asked at September 13, 2022 meeting)
Asked by Sandia National Laboratories on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

Yes, there are not going to be a lot of instances where a transmission line is exclusively for one person, unless it's like a DC line, where you can control those flows. Anytime you add a pipe to this system, the physics will be that those electrons will take the path of least resistance and those electrons may flow if there's an outage on some other part of the system.

Now, that new addition that we get for this network customer is useful to keep the system going. So, in an interconnected transmission system, we can't think of any scenarios where the transmission would not have a benefit to the broader system.

Sandia National Laboratories continued.

I'm wondering why, if it's just a radial line, you've got a solar facility and you've got a single radial line connecting it to the transmission, then you wouldn't expect any flows on that line, normally, right?

PNM Transmission continued.

We can't think of an instance where we've built a radial transmission line. There are radial generator interconnects, which is a different situation. We don't build those generator interconnections. Those generator interconnections are part of the generators because it's only when they get to the switching station, or substation, that we built to integrate them into the transmission system. And then everything is downstream from there. That's been these costs we're talking about.

Are you thinking in terms of incentivizing developers to focus on particular areas just to be more efficient with your dollars? Are you thinking that you will be focusing some investments yourselves to enhance the interconnection opportunities in particular areas, to kind of create the hot highway and they will come and focus on those particular areas? (Asked at September 13, 2022 meeting)
Asked by InterWest Energy Alliance on September 13, 2022. View meeting information here.

Initial Response: PNM (Transmission)

We would love to be able to do that. [We will address the chicken and egg issue later in this presentation]. We know people don't like chicken and egg kind of problems. But we have a hard time going to a commission to say, “I need a half a billion dollars to build a line that I have a specific order generator to go with.” And vice versa: There are generators and loads have a hard time getting interconnected if they don't have something to go to, or they now trigger a seven- or 10-year, half a billion-dollar event.

So, it's this quandary that we're in right now. Our planning--you're seeing this on the resource adequacy side--is this: This issue is driving the fact that we're building resources just in time and just the right amount for just the knowledge we have today, rather than doing what we've done historically, which is kind of going long.

But our regulatory paradigms don't support that because we might be wrong, right?

Say, we invest this half a billion dollars in flows, and the generators don't go where we set them. Now, we've put half a billion dollars of customers' money at risk for maybe not the payoff we thought we were going to get. We doubt that would happen. We think if we build it, they would come. The hard part is getting those folks who need it to give us that money to agree to do that. Speculatively, that's the crux of our issue here.

Am I to understand from the previous few slides (Slides 30-35) that these transmission options are all selectable in the IRP model? Can you describe what is selectable in the IRP model? (Asked at September 13, 2022 meeting)
Asked by InterWest Energy Alliance on September 13, 2022. View meeting information here.

Response: PNM

We cover later in the presentation some of the things we've looked at in terms of modeling transmission, the IRP, some of the limitations, and where we think we'll be going.

The short answer is that these are all looking at delivering resources to load. And the way we were looking at them in the last IRP ultimately was through the use of transmission cost adders, not looking at a specific representation of this in a pipe and bubble or other fashion.

Can you provide any color around the cost of the permitting/CCN labels on here (Slide 30)? The cost last time was obviously lower than this when we looked at it, a couple years ago in that IRP cycle. Is the permitting and CCN timeframe there five years, is that the entirety of the process or is there additional time on top of that for construction and other things that need to be done? (Asked at September 13, 2022 meeting)
Asked by PNM on September 13, 2022. View meeting information here.

Response: PNM Transmission

Typically, there would be more time on top of that for construction, potentially a couple of years on a project like this. For this one, the permitting is potentially not too complicated at this point, so that five years may be a conservative answer for this particular edition.

In most cases, and a lot of the transmission we look at that would be not at all conservative. We would expect to actually run into longer permitting times. The five-year total project is probably not unreasonable.

We're actually laying some groundwork today to try to make sure something like this could be built in the future. And the cost there is much higher than it was the last time. I think we're more in the $40 to $50 million range. But that's just factoring in what we've seen happening this year.

[Concerning AC/DC projects], is it in our interest, is PNM having discussions, particularly with Sun Zia, about essentially integrating the eastern end of that into the New Mexico system so that you take advantage of load diversity with other parts of the West, particularly, areas to the West--most notably California--that have built a lot more solar? There's a lot of cheap generation available during most of the afternoon in New Mexico that could flow west to east along those lines that maybe wasn't envisioned 10 years ago when those lines were initially sketched out. Is that something that would be of interest, is PNM exploring, potentially making some of those lines network elements? (Asked at September 13, 2022 meeting)
Asked by InterWest Energy Alliance on September 13, 2022. View meeting information here.

Response: PNM Transmission

That is a question that’s been raised internally. The hard part, again, is the capacities they are proposing. There has to be some kind of redesign scenario to make them useful for what the system could off peak. For example, the size of Sun Zia would absolutely overwhelm, and we'd have to figure out some way to get it up to where the load serving capability is.

We have spoken with and are working quite a bit with Pattern and Sun Zia from a logistics perspective and looking to share easements and in some cases to share colocation and those things. In those discussions, there hasn't been an interest at least in operating up interest in it. And number two, on the size of it, we don't know how it would be incorporated given existing plans because it would absolutely overwhelm the system and not be able to be incorporated without conditional changes to our system.

You've given some of the significant cost increases related to the repair of the AC DC converters. It may have doubled from the last time those were estimated, or something to that effect. Do you have an idea of what the cost of doing these lines today would be as opposed to when they were done just a few years ago? (Asked at September 13, 2022 meeting)
Asked by PNM on September 13, 2022. View meeting information here.

Response: PNM Transmission

We have seen cost increases. As an example, year over year, steel prices have gone up 92%. Transformers, poles, conductors are all ranging somewhere from 40 to 60% more expensive year over year. So right now, is not a great time of stability.

Price volatility is out of control--probably somewhere at 60 to 100% more expensive to go in today. [Current supply chain and potential labor issues may be contributing factors in the future.] These are unprecedented cost changes, at least in the last 30 years.

Are there interconnection costs that are network upgrades as well? (Asked at September 13, 2022 meeting)
Asked by PNM on September 13, 2022. View meeting information here.

Response: PNM Transmission

Yes, the majority of interconnection costs generally become part of the network upgrades as defined by FERC. There's a portion that's always dedicated to the specific developer in the interconnection process. And the rest is considered an integral part of the transmission system, although it also becomes part of the generalized transmission system and rate-based.

For resources that come online that do not have a defined customer yet--they're building and they're assuming that they will find a customer once it's built--how are we studying the network upgrades that may be required? (Asked at September 13, 2022 meeting)
Asked by PNM on September 13, 2022. View meeting information here.

Response: PNM Transmission

That's an interesting question. Typically, we really haven't seen that situation too much because most of them, if they don't have a customer yet, will not move forward. There's too much risk for them. The banking and the financing system almost mandates that they show who's going to be paying them revenue for a project.

So, it's not usual for us to actually have somebody move forward with a resource and not have a clearly defined customer. But if they did do that, we would not really be able to start without them telling us where they want the power to go. And if they haven't done that, then we don't even offer them what we would call firm transmission service. They always have to tell us at least where they're going to take some power in order for us to accommodate them from a transmission service perspective.

We do have some resources connected that have short term customer obligations, but from our perspective, they've arranged transmission long term with us to points on the system.

Do these developers have any responsibility for what they do to the system? They put their generation unit out there somewhere with a big wind farm. They put in the generator tie, and then they don't care what happens? Are there no controls? (Asked at September 13, 2022 meeting)
Asked by a Member of the Public on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

The FERC processed define the controls that are there. For the most part. They have to go through the FERC OATT (Open Access Transmission Tariff) process to get interconnected. There's a significant amount of risk that's put on them initially, if we are going to be constructing facilities to accommodate their requests.

There are two primary things there: the interconnection facilities, which get defined in the generator interconnection process, and then there's potentially network upgrades to move the power from the point of interconnection to a customer or some other point on the system that they've requested. So, there are potentially two types of costs we can run into in terms of accommodating that request.

The developer is on the hook to fund those upgrades initially upfront. Of course, if they take transmission service, they do pay for a portion of the transmission system as a result of that. So, they have a lot of risk from that perspective. If the project were to fail, and they didn't complete it, they would be out the money because we had pretty much collected from them as we build. In the end, FERC requires us to refund that money back to them, provided their facility is fully up and it becomes commercial.

There's risk on the front end for them for sure. They have to carry security on everything from the time that they enter into an LGIA (Large Generator Interconnection Agreement) until the time they actually move forward. They are carrying security on the construction costs we could incur.

PNM Transmission added.

In no case are we interconnecting something that would cause the system to not be able to maintain its compliance with reliability standards. That's the purpose of making sure, if we need network upgrades, that those upgrades are there to make sure no one else can be harmed.

Member of the Public continued.

So existing customers are essentially protected, and the system is essentially protected. But that gets back to the point you made previously about storage, which clearly becomes part of this conversation at some point.

PNM continued.

We are protected up front from the financial risk, where you are ensuring safe, reliable operation of the system, but those additional interconnections can change. As we've been talking about the flows, the way the system is operated, redispatch of the system, all within the normal operations allowed for by reliability standards.

PNM Transmission continued.

And the cost of the facilities does become part of the transmission rate base. It's not specific to any entity once it's been refunded. Generally, there may be some exceptions to that.

PNM continued.

So, the network upgrades, not the interconnection costs, after being refunded back to the customer, would then be flowed into the overall transmission revenue requirement, jurisdictionalized between FERC and retail customers, and could lead to cost increases that were not necessarily in support of the retail customers' own request.

PNM Transmission continued.

That's correct.


Do you have a thought why most of these interconnection points (Slide 26) are situated along the major transmission corridors? (Asked at September 13, 2022 meeting)
Asked by PNM on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

Most developers recognize that they have to get to an interconnection point with a transmission system. When they start looking at the fact that it's their responsibility to get to a point on the existing system, that becomes cost prohibitive if they're too far away. A lot of them are pretty savvy about trying to be as close to existing interconnection points as they can be.

PNM continued.

Because they don't want to trigger a large generator tie or a significant upgrade on the transmission system that would either take a long time or create a large cost burden?

PNM Transmission continued.

Right, it creates both a permitting uncertainty, you end up involving a lot more types of lands or landowners if you have to build a longer generator tie, and of course, the longer it is the more cost there's going to be.

In your in your off-peak period, where you've got high winds, high solar, you've got substantial flows to the northwest, are those off-peak periods times at which some of our neighbors to the west, and I'm thinking in particular California, they might still be on peak, or that they have higher needs that we can fill? I'm wondering if that occurrence can help us with some geographic diversity enhancements and filling neighbor's needs, when perhaps we have excess during these off-peak periods. (Asked at September 13, 2022 meeting)
Asked by InterWest Energy Alliance on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

We are allowing the EIM (Energy Imbalance Market) to dispatch our resources inside the scheduling hour to address those kinds of things. The EIM is taking place in real time to do that very thing.

PNM continued.

Though, if there's high solar output on our system, there's also high solar output on the California weather systems.

PNM Transmission continued.

You might see negative prices in the market.

InterWest Energy Alliance continued.

That's what I was wondering. How much of our off-peak excess, shall we say, can benefit the West? Or not?

PNM continued.

A lot of the wind resources we talked about--that 2000 MW, that 2500 MW--was in the eastern New Mexico areas already flowing towards California, scheduled into there. The power is going to flow inversely proportional to the impedance of the system. And then we’ve got to re-dispatch our generators in order to manage the contractual pass as best we can. And those create those inefficiencies.

PNM Transmission continued.

Internal constraints in New Mexico are potentially limiting the ability to get that excess to another party. We’re putting so much capacity into renewables that it exceeds what the transmission system is capable of – internally to the state. If you can get that to market, somebody could probably use that. The other big message here is that that characteristic plays a role in where and how much storage you need to help manage the energy picture.

PNM continued.

Those new flows are specifically a direct result of these non -PNM retail customers taking service under the Open Access Transmission Tariff to develop projects and move that power out to the west. And within a retail-only snapshot that would not be identified, but that certainly would have significant impacts on how you would design the retail system or any changes to the overall network given those third parties.

PNM Transmission continued.

That is a big part of it, but the other part is that even to serve New Mexico load, we build renewable capacity that at times will dispatch well above the level of the load, which means its going to go somewhere else. When you exceed your load in New Mexico and you’re generating more it’s going to flow out. It’s a combination of the two that leads to this scenario – you have a lot of capacity being built for renewables and it can simultaneously all generate, or close to all of it generate, at the same time.


How much do you anticipate that some users, perhaps even the non-retail users, which are perhaps [a] larger [segment], would peel off and become kind of separate independent nodes of their own to do their own power generation, solar with battery backup, things like that, and how would that impact the need for transmission? (Asked at September 13, 2022 meeting)
Asked by a Member of the Public on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

A lot of wholesale transmission is entities that are completely independent of PNM. They typically are interested in selling resources to a customer somewhere. But you really can't peel off from the transmission system. Everything kind of flows, the way it's going to flow once you inject their resources. They do pretty much define what resources they put in and how much energy storage they might have.

It's really up to the developers to decide what generation project or portfolio they want the transmission system to address.

PNM added.

As we understand the question, were you asking how might potential changes in the transmission system be recognized given customers’ personal desires to add their own generation, especially storage, and, would that change how might the design of the transmission system be effectuated in the future?

Member of the Public continued.

So, it might be the non-retail version, which we're not really dealing with, which we find a little bit concerning. It's helpful to have this presentation to get this bigger picture. But, when we're talking about the IRP, per se, it is concerning that these other factors can be such drivers. And it's hard to understand how that can be controlled very well.

PNM Transmission.

That is the crux of the challenge. That is what keeps us up at night. It really has been a challenge – FERC opened access to the transmission system in the 1990s. It is effectively wires available to anyone for any reason as long as they meet federal obligations, they get their piece of the pie. That is a federal regulation – not something we’ve developed or decided to do independently. That is the way the US grid is set up today. That is the thing that really makes things difficult on the retail planning side, given the volume – the Western Sprit project that went in this year, 100% of that is going out of state, but using the transmission system in New Mexico to do it. And that is allowed – that is what the rules say. You are picking up on the core issue here, it makes this IRP process very

difficult to give a good and complete picture of the transmission system when it’s focused on simply retail and one element of the transmission system.

PNM added.

We don't have any control over what the third parties are doing. And, hypothetically, if we were to look at just a retail snapshot of loads, resources, in the transmission system, it's possible that we could identify what could be perceived as a transmission solution that would help our retail actions.

But the presence of the non-retail customers and their utilization of the system and their own future interconnection requests could nullify any benefits potentially of some only-retail look at the transmission change, right? But one of the things is that if you don't look at the whole picture, you're not really getting the full solution.

PNM Transmission added.

This is not new. In New Mexico, we've always had a substantial amount of power moved out of state—one of the big changes, particularly out of the coal plants up in the Four Corners area, and to a lesser degree with the gas down in southern New Mexico.

So, energy moving out of state is not unusual. But the location of the energy moving out of state today is very different. It's in a very different location than those coal plants were. It's loading the transmission system in a very different manner.

Member of the Public continued.

I just continue to be concerned [about] the changes in the industry overall. The grid is 115 years old, or something like that. Really not very old, in the grand scheme of things. We're trying to look into a crystal ball that's pretty cloudy, looks like to me.

PNM Transmission.

Yes, that’s a good way to put it. It's hard to know what the perfect solutions are. We think that's the hard part. There probably won't be a perfect solution but we'll be trying to achieve reasonable solutions. When time passes, your vision will be 20/20, and it’s not that when you’re trying to make those investment decision in advance of what will ultimately transpire everywhere.


What about the thorny issue raised of cost allocation? Do you plan to provide input to FERC on that? What's your view on that issue? (Asked at September 13, 2022 meeting)
Asked by InterWest Energy Alliance on September 13, 2022. View meeting information here.

Response: PNM Transmission

Cost allocation has been the thorniest issue. Not everyone's aware of the Desert Star effort in the 90s to create an RTO (Regional Transmission Organization) in the West. And it seems that cost allocation is still a significant issue in the West. It's the thing that holds us back collectively as a group.

We're very anxious to see steady results on our RTO, very anxious to participate and be part of the solution. But not everybody feels that way. We’ve seen a lot of the attitude of: if even $1 changes in my equation, I'm not doing it. This, despite the potential improvements in efficiency and reliability. So, it's something that we're continuing to work. We have a manager who handles RTO participation.

And through the EEI (Edison Electric Institute) we are participating in those pieces of cost allocation that are part of the FERC NOPRs (Notice of Proposed Rulemaking). We must collectively come to some solutions here because there are a lot of efficiencies to be gained, as we saw in national studies, and as we know empirically through the success of the EIM (Energy Imbalance Market). There's really something to be gained here.

What kind of input have you as PNM had into the FERC process? I know it's early days, but what do you anticipate contributing into that, the FERC consideration of its rules? (Asked at September 13, 2022 meeting)
Asked by InterWest Energy Alliance on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

We're participating in the EEI, the Edison Electric Institute, the consortium of utilities across the U.S. that meets and puts together responses to federal and other rulemakings or policy issues. We are participating in the EEI processes to provide that on a broader basis. I think there's certainly value in contributing individually. But I think there's a much stronger and better voice to come through a more organized and well thought through approach that will participate in the EEI comments.

InterWest continued.

Can you share with us what are the objectives that PNM would like to accomplish? Or what's the message that you all want to send on these issues?

PNM Transmission continued.

There are some significant flaws in the open access transmission tariff process [because] when it was designed, it never contemplated the energy transition. And the rules reflect that. The rules are really why you see backlogs of multiple years in not only our queue, but in some of the ISOs who have applied to have a period of no study or no new requests, because it's been so overwhelmed.

So, the system is completely overwhelmed by the volume in the energy transition, making it pretty ineffective. We are very excited about some of the points that are being contemplated in the FERC NOPR (Notice of Proposed Rulemaking).

I'll give you an example: withdrawal penalties. It is one of the things that really slows the process down.

Generally speaking, folks get into the queues just to see. And when you see the volumes of folks that are coming in holding up these processes just to see, it is a really stagnating development. It is really a problem. And most folks end up withdrawing either after the first round of studies and the second round of studies, which then triggers a required re-study of the entire cluster.

We had 11 withdrawals and ended up with four rounds of re-study in each of the study processes. You can imagine that at 150 days a pop at least, that really puts things behind.

So, I'm quite excited about the FERC NOPRs. There's several of them out, but one of them is related to the whole process. Very happy to see some of the changes.

Interestingly, I'll note that some of the things that are being proposed in the FERC around the OATT (Open Access Transmission Tariff) are things we're already doing. We already do cluster studies. We already allow for multiple requests to be interconnected on the same interconnection.

There are a number of those, what they're calling "reforms" that we have adopted already and did years ago. So, because of the overwhelming interest in our queue, given our wind and solar potential in the state. Necessity is the mother of invention here. That's the route we've taken, and it seems that FERC is directing the rest of utilities in the U.S. to go that same direction.


In terms of all these other customers accessing PNM’s transmission system, whether to try to incorporate resources for PNM’s use, or to ship out of state, any of those that are not dedicated to PNM retail still affect the way the transmission system is operated. All the interconnection requests that PNM Transmission does from the federal Open Access Transmission (OATT) standpoint really is the primary driver in the manifestation of changes, investments in the transmission system. Is that fair? (Asked at September 13, 2022 meeting)
Asked by PNM on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

Yes, certainly the other customer usage is a very key driver in how we try to expand the transmission system and operate the transmission system. All of their needs are factored into operations and scheduling of the system on every day of the year. Today, we have to manage that every minute, every hour, every day, making sure that the transmission system usage has been indicated and that it's clear that that usage is within limits of the system.

PNM continued.

And we've got no control over what those third parties are doing from a PNM retail standpoint. But from the transmission unit, you have to accommodate each and every one of those requests, just the same as PNM retail use. It's 100% equal an open access to all.

PNM Transmission continued.

That's correct.

PNM continued.


We want to make sure folks are following along and hopefully start to understand a little bit of the differentiation between PNM the utility, PNM the transmission company, the open access transmission tariff, and PNM the Transmission Balancing Area. These are not all one and the same thing. They all are governed by different rules and regulations and different ways things must be looked at from the retail versus the FERC point of view.

Today, given the resources, the loads and the rights that we have, is there much of any more resources that can deliver into southern New Mexico to then be transmitted up to the northern load centers? (Asked at September 13, 2022 meeting)
Asked by PNM on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

There is potentially still some ability to do that. We tend to look at them on a case by case basis--where they're located exactly in southern New Mexico can make a difference. And PNM itself would have to acquire transmission capacity from another provider to move additional resources from the south to the north.

So, we would look at what we can do within rights in the south. What can we acquire from another provider in the south and then what can we provide acquire to move from the south to the north?

The existing resources in the eastern part of state, the 2,457 megawatts--it's probably about 500 megawatts that's actually contracted or delivered for PNM retail and the rest of it is wholesale being shipped out of state, or something to that effect? (Asked at September 13, 2022 meeting)
Asked by PNM on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

That's correct. We're subscribed to about 500 megawatts of those wind resources.

Are the 2023 additions for 840 megawatts (Slide 22) additions that are based on the latest updates from PNM to the Commission. that is, the resources that are actually expected to be in service in 2023? Has that been updated to match this number in line with that, or is it a different number? (Asked at September 13, 2022 meeting)
Asked by NM AREA on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

It should be in line with that. It represents some of that--it's still got some uncertainty around it, but it represents the 300 MW between San Juan Solar and Rockmont, the 300 MW Arroyo Solar, and the 190 MW of Jicarilla Apache Energy Center that was looked at as a Palo Verde replacement. It's pretty much what's in that 840 MW number and it includes the 50 MW of Jicarilla I.

PNM continued.

I think a better way to express this is from the transmission interconnection or large generator interconnection, this would represent those still active requests associated with the resources that have been approved?

PNM Transmission added.

Yes, it represents the resources that had been approved.

NM AREA continued.

Alright, so the dates on this don't necessarily line up with the latest expected in-service dates.

PNM Transmission continued.

That is certainly possible.

NM AREA continued.

Or the latest ESA (Energy Storage Agreements (ESA). It is like there's a pending expansion of the Atrisco Energy Storage Agreement, for example.

PNM continued.

That does not change the interconnection size. so, it wouldn't make a difference on the size here.

NM AREA continued.

You're right. I was forgetting that point. But the dates here don't necessarily line up. These are more based on the proposed interconnection dates, or approving your connection dates, but not necessarily latest status and projects, right?

PNM continued.

I think that's fair. This is still the work that these developers in their contracts, as a provider of the Commission, and standing in the interconnection queue, will be working with the Transmission Group, insofar as trying to get those interconnections finished and delivered by those time periods.

As we're continually updating the Commission, some of those things will change. But this does paint a pretty realistic picture of some of the changes that we will be seeing on the system over time.

PNM Transmission continued.

Just recognize that some of those resources may not be in 2023. It may be after that, but it does try to tie it back to what has been previously approved.


I just wanted to chime in that the Manchin Bill is currently still being drafted but drafts that are circulating include a cost allocation measure that would allow FERC to determine cost allocation for transmission. And so, I think that is improving some obstacles, certainly for DC lines. But I think cost allocation is one of the biggest obstacles for significantly sized transmissions because it benefits large regions. It's certainly a national network like this, which allows FERC to do that. There's also a parallel FERC effort looking at transition planning and cost allocation. So, there is federal action that is going to help on some of these issues. (Asked at September 13, 2022 meeting)
Asked by InterWest Energy Alliance on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

Yes, there is a lot of activity. And first, we'll talk a little bit about that to try to ease some of the dilemmas from the inherent problems with the process today. That will help all of us.

I have a question about your opinion about [Slide 15]. I see a 35-year study window here, and IRPs generally look at a 20-year study window. [Do] you believe like I do, that since transmission is such a long-term investment, IRPs don't really fully capture the benefits of investment, similar to the way that this study in front of us does? (Asked at September 13, 2022 meeting)
Asked by InterWest Energy Alliance on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

Yes, I would totally agree with you. And we're going to talk a little bit about the dilemma of how our FERC rules and the FERC process are really driving a short-term view of transmission expansion, when really what we can benefit from is a much longer-term view. Yes, we agree wholeheartedly. These are major investments.

We'll talk some about what it takes to develop a transmission project and the financial and time investment in permitting, regulatory approvals, and those kinds of things. All of that needs to get better to really get us to where we need to go. But thank you for your question.

PNM added.

I appreciate the question as well. We're going to get into more of the specifics for transmission within the IRP or where things might need to move towards, specifically related to perhaps a different connector called integrated system planning as opposed to integrated resource planning and how we might get to that point.

There are some very distinct nuances as well about the PNM system we will go over, specifically the vast amount of transmission that is planned for and utilized by non-retail customers, and the subset of the requirement that the PNM IRP only look at retail operations.

So, we agree that there needs to be a better job of transmission work. There are some significant limitations on why or how we can do things. And we hope to get to explain that before we get into the details of the IRP and transmission components.

I'm glad to hear you're looking at what it would take to replace or upgrade the converters. Are you looking at just replacing the same capacity? Or are you looking at increasing the capacity so you could transfer more across the ties? (Asked at September 13, 2022 meeting)
Asked by InterWest Energy Alliance on September 13, 2022. View meeting information here.

Initial Response: PNM Transmission

That's a really good question. We're looking at just replacing right now. Because even if we are to make that larger, with the technology of the HVDC converters, the size is a really significant factor. And we think if we were to increase the capability between the two interconnects, we're looking at doing a parallel device. Because of the way the technology is designed, it's not amenable to being a really large piece of equipment.

We also like to spread our risk. So, a lot of what we're looking at on the transmission nowadays is resilience. We know that extreme events or extreme people can cause harm to equipment and locations. And we're looking to try to spread risk as much as we can. Transmission development and additional HVDC cover capability will probably have to go hand in hand, given the transmission capabilities that are out there to support a bigger converter.

InterWest Energy Alliance continued.

So, I think what I heard, just want to make sure I got this right: You’re not looking so much to expand what you have at the existing ties, maybe adding another one? Is that what you’re thinking?

PNM Transmission continued.

That’s something that, if we were going to go down that road, we would do. We don’t have plans for one today. But we have had discussions with entities who are looking to expand the capability between interconnects.

This is a great segue into our next set of slides (starting at Slide 12), Were going to talk about an NREL (National Renewable energy Laboratory) study that talks about the benefits of these interties and the value in expanding and creating additional ties.

One of the things E3 talked about was scenario analysis, sort of the middle course method. PNM has done some co-optimizations. Very slow. Very limited. And you’ve done the approach of adding, also on the cost for the transmission as an adder. Could there be some potential, and maybe [this will] depend on RFP results, for [something like] PacifiCorp it did - they had a large collection of RFP results, so they had resource options. But they did some scenario analysis, basically comparing one portfolio—if you built a certain transmission project that had been identified in the past as potentially being beneficial—and then take another scenario with an alternative portfolio that’s optimized, assuming you don’t have that, and then compared [them]. Do you see any opportunity for potentially doing that? Though it might depend on what you’re seeing in your results, when you actually get in, to start doing the IRP. (Asked at October 6, 2022 meeting)
Asked by NM AREA on October 6, 2022. View meeting information here.

Response: PNM

We’re certainly going to consider different scenario analyses and whether or not they make sense. We think we’re still defining the scenarios we’re going to be looking at.

One that might pop out is a wind scenario where the transmission delivers that wind versus something where that’s not there. If you’re speaking of the Energy Gateway project, which, of course, has been working for a long time. Or, take other things like NV Energy, which did a scenario where they were looking at an additional north to

south line. Those were some very concrete proposed transmission lines that were not only justified for bringing on new resources, but also reducing significant amounts of congestion across the system.

And if we’re looking at transmission to just deliver resources, the ability to model a scenario or the need to model those as a scenario with anything other than a transmission hurdle may not make sense.

Do you see this as really a tool for better understanding congestion going forward because, again, the zonal models have limitations and it’s an art to putting those together, right? So, there’s some art to this but this would give you a much more accurate picture of the congestion situation. For example, you could run future portfolios for a sample year in the future, or you could look at are there congestion transmission projects that make sense for the PNM transmission system as a whole? That is, not just PNM retail but PNM retail and the other transmission customers? Is that how you’re seeing this? (Asked at October 6, 2022 meeting)
Asked by NM AREA on October 6, 2022. View meeting information here.

Initial Response: PNM Transmission

That’s a good question. This slide (Slide 31) was sort of intended to help possibly answer that.

I think the first thing we’re trying to do is to understand whether the portfolios PNM comes up with continue to make sense when we get better information on how they fit in with the transmission system. So, sanity checking the IRP portfolios is the first goal of this: when we put future expansion or resources PNM is proposing into these rungs, are we seeing anything unusual like transmission constraints that were not captured previously in the zonal model, and that would lead to curtailment or might lead to a different decision about where storage should be located?

So, informing the IRP process initially is the primary goal.

Going forward, we will certainly use it as a department to help quantify congestion in general, especially around interconnection and transmission service requests and how they might be impacted so we can provide better information to our customers.

In the deterministic approach we use today, you tend to be pretty conservative. You may have constraints you can’t honor all hours of the year. And that tends to come across as something that is too prohibitive, where, in reality, some congestion might be tolerable, and the correct economic decision is to live with it.

So, we’re trying to get a better understanding of those types of things. Also, from this type of modeling, the other thing we’ll look at is whether it’s providing insights to do a better job on capturing the zonal model. We can’t get away from doing the zonal modeling in the IRP to capture the 20-year production cost of the different portfolios; you’re still going to have to utilize a zonal model to do capacity expansion type runs and capture your total production cost over time. We’ll use it [the zonal model] to help see if we can come up with better insight on what looks like the real constrains to PNM. We may be able to, over time, actually have some of the zonal model capture some of those other company uses, we would probably have to aggregate a lot of that information, but there will be things we study to see if we can do a better job on the zonal modeling based on new information we get out of the nodal runs. And then of course it will certainly provide some significant insight into what transmission expansion seems to make sense over a long-range period. We’d be looking to try to extract specific transmission plans, that when you look at over a long enough period of time, the economics of adding them make sense.

PNM added.

What we see as the path for additional transmission modeling, or more co-optimized transmission and generation in the IRP is really going to be once we have the nodal model calibrated, we go through a process of determining how to use that information to better represent a zonal model. Or, perhaps to the point where computing power will allow us to run a reduced-form nodal model for capacity expansion, that would model better the transmission system in there.

Incorporating additional transmission candidates becomes an additional part of the problem, but its not something we’re considering, at least not initially – we need to get the nodal model set up right and make sure that we can utilize it in a way that we get some sensible results. In terms of running a full nodal analysis on IRP portfolios, that’s something we discussed but that again will take a lot more time to determine the best way to do that. For example, the transmission build-out that may be required if we have an economic development boom and the size of the system doubles. Additional transmission network required to service that load and the resources to service that load could be completely different from what you would represent in just a standard ordinary load growth case. Trying to assess what the loads and resources might be on a full nodal basis under some of these high load scenarios would require so many assumptions that it really makes sense to run those for a couple of key portfolios associated with the MCEP.

All of this is to say that there’s a lot more work to be done – we’re trying to give some nights into the work that we’re currently doing to try to improve our insights into the transmission system and how we’re going to be modeling that going forward, but its going to be some time until we can take those nodal databases and transfer them into information that can be used to represent in a different way within the integrated resource planning process. It’s going to take some time.

So, do we model contract path versus do we model just the physical flows relative to the inverse impedance of the system? (Asked at October 6, 2022 meeting)
Asked by Hecate Energy on October 6, 2022. View meeting information here.

Initial Response: PNM Transmission

Yes, models don’t really have a concept of contract path, so from that perspective, no. They do have the ability to model transactions, one area to another or from one part of a system to another, which may capture some of that. Typically, transactions are pretty uncommon in these databases, as provided.

We will probably try to simulate some things. But what we’ll be looking for initially is the services that are being provided to the net transmission customers. Are there any constraints actually being run into on providing those services? And if that’s the case, then we would have to dig into understanding who’s got the rights to be on that system, if somebody has to be re dispatched and stuff, which gets back into who owns the TSR (Transmission Service Rights), who has the wheeling rights.

And that’s particularly true going forward when you’ve allocated your system out close to limits in several different ways. As you go forward, you’re looking at how you manage that.

Hecate Energy continued.

That’s exactly what I asked because I’m familiar with the MISO market, premarket, post market. Post-market the TSR numbers went down drastically.

I’m struggling understanding the difference between these two (Slide 21). I’m assuming the initial modeled topology is essentially related to the slide previous to this. (Asked at October 6, 2022 meeting)
Asked by NM AREA on October 6, 2022. View meeting information here.

Initial Response: PNM

That’s correct. That’s where we had the actual pipes and bubbles from each zone. And each pipe had its own cost. And behind that pipe, you had resources that could utilize that pipe. And so that pipe had cost and had capability.

NM AREA continued.

So, as I’m understanding, was it done as a price adder to the indicidual resources? Or the pipe was actually one of the selectable, essentially resources, even though it’s transmission?

PNM continued.

Yes, it’s a lot of the pipe that was an actual asset that could be added or could be optimized within the capacity expansion.

NM AREA continued.

And really, this is the first time you ever tried any of that. I recall the discussion from the IRP report.

PNM continued.

Yes, that’s right.

NM AREA continued.

So, then my issue becomes better contrasting what the final model topology is actually doing

versus this.

PNM continued.

The final modeled typology is essentially cost adders for generic resources. And, and when I say that what I mean is that we don’t have those zones, those pipes and bubbles anymore. We just have generic resources that have cost adders for them, that can be added to serve our load, and it doesn’t really matter in terms of the 2020 IRP what zone it was added in. It was more just to account for the transmission costs that we know of today that would likely need to be added because you have generic resources added over time.

And so, we’re counting for the transmission costs there. But the generics would be added, as needed, to meet our demand and energy requirements.

NM AREA continued.

But is it a generic assumption regardless of where the generation is located?

PNM continued.

That’s true. So, what we did was to still use utilize the same information that we had before, which was we had all the information about the different locations of transmission projects and their costs.

PNM continued.

For example, in the eastern area where the wind was located, the transmission hurdle rate was based on the eastern transmission line. And so I think what you probably heard from E3’s presentation earlier is when you’re looking at just adding transmission to deliver to the load, the transmission hurdles are generally a reasonable methodology to do that.

When we’re looking at adding the transmission topology and requiring the transmission pipes to be added along to deliver the resources, all you’re seeing is a very similar resource that is added throughout the portfolio, you’re just seeing differentiations, in which transmission was kind of added when, and it was all based on the transmission prices, because there wasn’t enough differentiation on the resource prices.

In order to adequately do the combined transmission and resource modeling, you’re going to need to have not just differentiations on the transmission capital cost, but you need to have differentiations on the production profiles, capital costs, land costs, all those other things for the resource side.

And so that is something that is much more difficult to put together outside of an RFP process, because we don’t necessarily know what incentives a particular community or county is going to give to a developer for IRBs, or avoidance of property taxes, things like that. We don’t necessarily know what their land costs are going to be.

And so, if you don’t have a differentiation on the price side for the resources, it just becomes which transmission is cheaper, and it doesn’t give you the full picture.

So that’s one of the difficulties that we found here.

NM AREA continued.

Yes, I guess it is an order of magnitude question, though, on those differences in those costs, influencing a location.

PNM continued.

Well, it’s influencing the location, but it also influences the run times on the model.

NM AREA continued.

The more complicated the problem is, right, the more

PNM continued.

You don’t have the differentiation in prices, and you have all these similar resources that are priced similarly. And the only differentiation is that the transmission piece, the model, and trying to close its tolerance gap can hang up much longer, and it can lead to significantly longer run times.

And the value that you’re getting out of it is not good enough to say this is really what you would use to make a transmission investment decision.

NM AREA continued.

Right, this details where the model is selecting the projects, and selecting essentially the transmission and projects combined.

The second approach, though, is it a cost data approach. Is it a lumpy thing? Or basically is each resource—let’s go back to the eastern—are there multiple resources in the eastern that could be selected? Or is it one resource?

What I’ve kind of been trying to understand is, do we create this big hurdle because of lumpiness when doing the cost adder thing? Or are you doing something more granular?

PNM continued.

For the eastern resource, we had assumed, the original transmission line that was developed as a proxy by the transmission group was an 800-megawatt line, essentially, a Western Spirit II or a BB3 type line, that would have 800 megawatts of additional transmission capability. And there was a lumpy cost associated with that.

We model it as a 400-megawatt wind resource with half the cost of the transmission line, basically saying, there’s going to have to be some project to get this thing off the ground, maybe there could be, half of it goes towards FERC jurisdiction and half of it stays within retail. There might be some ability to have a partner in that situation.

So we didn’t take it down where you can do megawatt by megawatt, but we didn’t require the full 800 megawatts to be dedicated to retail.

NM AREA continued.

All right, that helps that so it’s more about a more granular thing, but not super granular, but not as chunky as you got to get this through this theory bit—the cost of this very big transmission project even for something smaller. But realizing you didn’t break until lots of little steps by just a few smaller steps.

PNM continued.

I just wanted to add that we compared the results of these two types of modeling efforts and what we really found is you’re adding the same resources, the same types of resources, and around the same amount of resources in similar years for both topologies.

And the interesting thing about the zonal modeling is, where we actually put in the transmission pipes or projects as hurdles, that you have to build those first, before you add resources behind them was that it was always adding the lowest cost one first. So, if you have $100 million project or a $500 million project, we’re always seeing the 100-million-dollar project, or at least the resources from those zones added first, along with that transmission project.

When you’re talking about, say, the different solar areas, wind was a little bit different. But then again, the difficulty is that when we go and we look at some RFP type data, there is differentiation of the prices, depending on where the projects are located. And having just generic resources in there without price differentiation, which, again, PNM does not have specific sites that we have interconnections at all across the PNM footprint. There’s very specific sites that we have.

And so, without the price differentiation, it just becomes what’s the cheapest transmission.

But when you’re doing the generation and transmission investments, through an RFP, it’s going to be the combination of what’s the cheapest generation, including the transmission. And that’s just a difference between an RFP evaluation, and something that looks at trends over 20-year time.



[Regarding Slide 20], I think what I heard what you say is that what you did is identify transmission projects from each of these five zones, but only in relation to a known generation resource within each of these five zones that needed transmission in order to get the energy to load. But if you didn’t have a known resource in one of those zones, there was no impetus to build any transmission. Is that about right? (Asked at October 6, 2022 meeting)
Asked by InterWest Energy Alliance on October 6, 2022. View meeting information here.

Initial Response: PNM

What we did was have PNM Transmission Group give us the potential transmission upgrade projects that they are aware of from these types of zones. And this is what the Transmission Group went over the last time we talked about transmission. For instance, the Transmission Group had three different transmission projects coming from the north, and each had their own cost and megawatts, incremental megawatts that you can deliver from that area or from that transmission line.

We utilize that information from each of the zones to determine what these pipes would represent. And then, for the bubbles for each zone, the way we set it up was to say, “Okay, you have the same technologies within each of the zones that you do across the board.” And that with the exception of the transmission zone east, where you had wind, and within the zones, the way we set it up was, to say, “Okay, well, you’re limited to adding resources from each of those delivery zones.”

There isn’t just this unlimited zone where you can just add as much as you want. So, you have to choose a zone to put your resources in, and you’re going to have to pick basically a pipe that you’re going to need to build.

It’s going to ask you to optimize. I was asking EnCompass to optimize around that type of problem.

InterWest continued.

It sounds like you didn’t take a fresh look at what the potential is in each of these zones. You just looked at what the known projects, or whatever, are from each of these zones.

PNM continued.

That’s correct. We did that to the east, for example. We know of a project from that zone. And that’s the project that the Transmission Group presented on. It’s an 800-megawatt project, with a cost on the order of $300 to $400 million. So, that’s the project that we modeled.

We didn’t go through and try to go beyond that and say beyond the 800 megawatts of that individual project that we’re modeling, you can add beyond that, because we don’t have a specific project or certain costs that we would tag on to that from this zonal modeling perspective.

InterWest Energy Alliance continued.

So, for example, with respect to the south zone, you didn’t look at the benefits and costs of adding more capacity to link up with, say, EPE (El Paso Electric) and resources that could be developed in the south to maybe enhance reliability. That wasn’t part of this modeling effort?

PNM continued.

That’s correct. That was not part of that modeling effort. The focus of this was to try and determine if there was an optimal set of transmission projects that, if needed to be built, if everything is, fully subscribed, and we have to build transmission, and we need resources to meet our load, what transmission projects will we need to build and when over the 20-year planning horizon?

InterWest Energy Alliance continued.

Okay, it sounds like this kind of modeling may not be the fit for what I just asked about. Is there some other modeling approach that would be better for looking at overall system improvements for reliability and linkages to other existing systems?

PNM continued.

And that's a good question. It kind of sounds like what you're asking is what is best for the transmission system? And this may be more of a transmission planning type of question. From our perspective, we're trying to do our best with the best information we have in terms of what transmission projects are out there.

And like we mentioned before, we are not accounting for the system reliability in any way in this type of zonal modeling framework. That's where transmission planning would have to come in. And this would be the idea of a coordinated effort between IRP and transmission planning on how to define what these zones may be, what the pipes may be, in that type of context. That's where that would have to take place.

But in terms of the 2020 IRP, this is how we did it last time.


Maybe [this is] related to the third option, the more complex and customized generation and transmission. With the zonal model, you get those transmission investments kind of from a zonal basis. So, I was just curious, in your screening of current IRPs, or even what you have (on Slide 15) on integrated system planning, what are some methods utilities are taking to kind of translate those aggregated transmission investments into actual transmission projects? (Asked at October 6, 2022 meeting)
Asked by Sandia National Laboratories on October 6, 2022. View meeting information here.

Initial Response: E3

In terms of taking a broad zonal sort of perspective on transmission, and actually translating that into specific projects, that kind of gets to this question of how does the IRP intersect or integrate with the transmission planning efforts, if at all.

One example that exists out there that you might take a look at is what's going on in California as it relates to their IRP process and the Cal ISO’s transmission planning process. Within California, the CPUC (California Public Utility Commission) administers a sort of top-down integrated resource planning process that's actually developing sort of a statewide resource portfolio that achieves the state's greenhouse gas goals.

There's then separately a process where that portfolio of resources--in the large quantities of solar and storage, and wind--are kind of mapped or downscaled to a much more granular level through a process that they call busbar mapping, which is essentially a process of taking all the solar and wind and storage resources and putting them on very specific parts of the system.

And then that portfolio and all that locational detail is handed over to the California ISO, who then goes through the paces of saying, well, with this highly granular portfolio of wind, solar and storage resources, what are the transmission implications of that portfolio?

So that's one example of a process where you've actually got two sides kind of working, trying to work together to sort of translate some of those less granular outcomes from an IRP process into potentially more specific transmission needs under a high renewable scenario.

Sandia National Laboratories continued.
That helps. I think MISO might do something very similar. I was just curious if you were seeing more utility level within these IRPs, or maybe we'll call them ISPs now. So, yes, definitely, ongoing work for sure.

When a generator joins a data collection process, there'll be some reliability updates assigned to it, right, based on the interconnection study. So, are we talking about upgrades? Can you explain that? (Asked at October 6, 2022 meeting)
Asked by Hecate Energy on October 6, 2022. View meeting information here.

Initial Response: E3

First, as I tried to lay out upfront, the IRP process is a little bit different from the transmission planning process. And so, a generator that's going through the interconnection processes, kind of within the utility’s transmission planning process, the Transmission Group will be assessing the need for the interconnection related projects and stuff like that.

In an IRP context, utilities aren't usually focused on individual projects, interconnection requirements. And to the extent that they're thinking about transmission in the IRP processes, it's actually usually larger scale conceptual projects that allow for the delivery of larger quantities of resources across a broader area. So, within the IRP, that's actually more so the focus when utilities are thinking about the transmission: It's what does it take to get a large quantity of resources from one part of my system to another?

Do any of these methodologies take into account benefits, such as reliability benefits, and assign a value to them that can then be assigned a dollar value instead of just the amorphous…it increases reliability but we're not assigning any value to it' that I've heard in several IRPs. (Asked at October 6, 2022 meeting)
Asked by InterWest Energy Alliance on October 6, 2022. View meeting information here.

Initial Response: E3

Within an IRP context, I don't think I've seen any examples where that sort of reliability benefit is quantified in sort of a dollar term.

What I will say is that the specific investments, or projects, that are often considered, are often characterized in such a way that they're meant to provide the reliability service that comes along with the resource that they're connecting. So, in that sense, there's kind of an implicit benefit that comes along with being able to take that resource and put it into the portfolio.
But I haven't seen it quantified as an explicit benefit in an IRP.

I think you need the cost of generation also, like different generation types will have different costs, right? Are you using any numbers for generation when you look at these scenarios and evaluations? [Slide 14] (Asked at October 6, 2022 meeting)
Asked by Hecate Energy on October 6, 2022. View meeting information here.

Initial Response: E3

This is largely a survey of what others are doing on this. But I will say yes, you're absolutely right. The generation cost is a very important piece of this.

And because this conversation is about transmission, we glossed over or skipped over a lot of the dynamics that might be in play in terms of how resources are being represented, both in terms of cost and their capabilities. And absolutely, that's an important part of the equation here.

Hecate Energy continued.

I kind of thought that, too. Basically, I guess what I was getting at is I'm used to the PROMOD type evaluation of transmission where I use the LMP (Locational Market Pricing) and things like that. But, hopefully, I’ll learn things as I go.

E3 continued.

I appreciate the comment. And maybe it makes sense to just point out [your mention] of PROMOD, which is kind of in the production cost family of resources. Within the context of an IRP, many utilities are starting one step removed from that, which is with a capacity expansion model.

This is the approach that PNM uses as well, where you're explicitly looking at not just how does the system operate, but what are the costs to build all the resources to make that system possible and optimizing around not just the operations of the system, but the investments as well.

Hecate Energy continued.

I didn’t explain it well. Well basically, what I'm looking at is, like MISO or ERCOT; they have the transmission economic evaluation. So, basically, the cost of the transmission upgrade, and then what are the benefits? So, it includes the societal benefits also.

And then I think it's like 14% of benefits the first year. That is the passing criteria for transmission, economic transmission. So that's the type of that value. The benefits are calculated, based on PROMOD, and probably there may be other inputs to calculate. It's like over a period of time or, I think, in the case of ERCOT, the first year. MISO runs several years, up to 20 years or something like that. Several PROMOD cases to find the benefits of transmission upgrade to loads. The MISO process has benefits to load and generation and so the reduction in costs to generation and things like that.


Would you say it's fair to say that the scenario analysis approach works particularly well when a utility has identified various candidate transmission projects or expansions that have clear strategic benefit? And if scenario analysis kind of works well for identifying when those projects really become either cost effective or have significant benefits to justify moving forward? [Does] it work well, in that respect? (Asked at October 6, 2022 meeting)
Asked by NM AREA on October 6, 2022. View meeting information here.

Initial Response: E3

That's a pretty fair characterization, you might say, when or if those projects have significant benefits, because it could be that you conceptually identify a project that you think might have benefits, but then you put it through the paces of the modeling, and you might find, well, actually, there's another strategy that seems to be superior to it under the sort of uncertainties that we're operating in.

But I generally agree with the spirit of your comment.

NM AREA continued.

I guess I get that from [when] PacifiCorp identified the strategic projects like a decade ago, mostly. And the question [is] always: When is it justified? And so, their use of scenario analysis has helped them to justify projects and when not to pursue them.

E3 continued.

You raise a good point there, too, which is, once again, it's taken PacifiCorp and Idaho Power kind of a long time, from the point at which those projects were originally conceptualized and identified as potential strategic projects, to the point that they're at today.

So, it maybe there's something to learn from that: that there is sort of a long history that's led them to the point they've gotten to.

NM AREA continued.

I guess where I'm thinking is that where you can't do everything, but it may be important for a utility to identify what those types of strategic projects or opportunities are so that then they can be further analyzed in a scenario analysis type approach.


It's more of a comment. You've partly acknowledged [that] there are some exceptions, but not just in CAL ISO/MISO. PacifiCorp, for example, [with the] Gateway South project that was fully integrated in their most recent IRP. And the decision was integrated on both the resources and moving forward with that transmission project. And it could be argued, to some extent, some of NV Energy’s recent transmission developments are tied together. I mean, not so much in an IRP, but the consideration of resources was a major driver moving forward [with] those transmission projects. So, I agree, it's somewhat in its infancy, but it is happening. And there are examples. (Asked at October 6, 2022 meeting)
Asked by NM AREA on October 6, 2022. View meeting information here.

Initial Response: E3

We appreciate the comment, and you're actually kind of one step ahead of us, because PacifiCorp was actually one of the case studies that we were going to call out later in this presentation as maybe a leading example of a utility that is kind of farther ahead on this spectrum. When we get there, if you have any comments you want to add in at that point, we'll be happy to have a further discussion about it.

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