Public Service Company of New Mexico ("PNM"), through its undersigned counsel,
submits this consolidated response ("Response") to the written protests ("Protests") filed by the
New Mexico Industrial Energy Consumers ("NMIEC"), the Northwestern New Mexico
Legislators~ ("Legislators"), Southwest Generation Operating Co. LLC ("SWG"), Citizens for
Fair Rates and the Environment ("CFRE") and New Energy Economy ("NEE")2 with respect to
PNMs 2017 Integrated Resource Plan ("2017 IRP").3 NMIEC, Legislators, SWG, CFRE and
The Northwestern New Mexico Legislators include: State Senator William Sharer, State Senator Steve
Neville, Representative Rod Montoya, Representative James Strickler, Representative Paul Bandy, and
Representative Sharon Clahchischilliage.
The protests of CFRE and NEE were filed in Case No. 17-00192-UT. Upon consultation with the
Commissions Records Bureau, PNM was advised to file this Response in Case No. 17-00174-UT.
The Complainants filed their respective Protests to PNMs 2017 IRP as follows: (1) New Mexico Industrial
Energy Consumers Protest to Public Service Company of New Mexicos 2017 Integrated Resource Plan
("NMIEC Protest"); (2) Formal Protest to the Integrated Resource Plan proposed by Public Service
Company of New Mexico ("Legislators Protest"); (3) Southwest Generation Operating Co. LLC Verified
Protest of PNMs 2017-2036 Integrated Resource Plan ("SWG Protest"); (4) Citizens for Fair Rates and
the Environments PROTEST of PNMs 2017 Integrated Resource Management Plan ("CFRE Protest"); (5)
New Energy Economys Verified Protest of PNMs 2017-2036 Integrated Resource Plan and Request for
Summary Return of Plan or Hearing ("NEE Protest").
INTRODUCTION
1. On July 3, 2017, PNM submitted its 2017 IRP to the New Mexico Public
Rule"). The 2017 IRP identifies the most cost-effective portfolio of existing and new resources
that meets electric system demand, provides acceptable system reliability and operational
flexibility, and meets applicable legal and regulatory requirements, at a low projected customer
cost and cost risk profile across most scenarios. A significant finding of the 2017 IRP is that
retiring PNMs 497 MW share of San Juan Generating Station ("SJGS") in 2022 would provide
2. In the Protests, certain of the Complainants contend that PNMs 2017 IRP is
deficient under the IRP Rule4 and should be rejected by the Commission. See, NMIEC Protest,
pp. 3-14; SWG Protest, pp. 9-19; CFRE Protest, pp. 1-8, NEE Protest, pp. 4-21. In addition,
though not necessarily a basis for protest, certain of the Complainants raise questions related to
attributes, and replacement alternatives. See, NMIEC Protest, pp. 6-9; SWG Protest, pp. 8-17
and pp. 23-26; CFRE Protest, pp. 3-8, NEE Protest, pp. 10-21. Finally, certain Complainants use
the Protests as a venue to express dissatisfaction over PNMs resource procurement process.
See, SWG Protest, pp. 19-23; CFRE Protest, pp. 8-10; NEE Protest, p 21-23.
3. 17.7.3.12(A) NMAC provides that the Commission will review an IRP "for
compliance with the procedures and objectives set forth" in the IRP Rule. "Unless a protest is
4 The Legislators Protest does not state that PNMs 2017 IRP was deficient, but instead contends that the
NMPRC IRP guidelines are inadequate and fail to account for several significant factors such as job loss,
remediation costs, portfolio diversity and impact on state and local revenues. See, Legislators Protest, p.
1.PNM acknowledges the potential adverse economic impact of a SJGS closure on the local community,
but the issue before the Commission is simply whether the 2017 IRP conforms to the IRP Rule as written.
The Commission can make that determination without concluding that closure is in the public interest, and
acceptance of the 2017 IRP as compliant with the IRP Rule will not affect the Commissions decision in
any future abandonment proceeding.
2
filed that demonstrates to the Commissions reasonable satisfaction that a hearing is necessary,"
the Commission may accept an IRP without a hearing. Id. The Protests fail to demonstrate that
the 2017 IRP should be rejected by the Commission. The IRP meets all of the requirements of
the IRP Rule and should be accepted as compliant without further proceedings.
BACKGROUND
4. The Commission adopted the IRP Rule to fulfill certain requirements of the New
Mexico Efficient Use of Energy Act, NMSA 1978, 62-17-10 through -11 (2013) ("EUEA").
Section 62-17-10 (2005) of the EUEA addresses utility integrated resource planning and requires
utilities to file integrated resource plans with the Commission to "evaluate renewable energy,
resources on a consistent and comparable basis and take into consideration risk and uncertainty
of fuel supply, price volatility and costs of anticipated environmental regulations in order to
identify the most cost-effective portfolio of resources to supply the energy needs of customers."
The purpose of the IRP Rule is "to set forth the commissions requirements for the preparation,
filing, review and acceptance of integrated resource plans by public utilities supplying electric
service in New Mexico in order to identify the most cost-effective portfolio of resources to
supply the energy needs of customers." PNMs 2017 IRP contains all of the elements required
At a general level, the protests are not concerned with IRP compliance so much as
the outcomes of PNMs analysis. This is not a claim PNM failed to satisfy the IRP Rule, but
rather that the answer when following the rule is undesirable from a given Complainants view.
The 2017 IRP conforms to the requirements of the IRP Rule, and Table 13 in Appendix G of the
2017 IRP, entitled IRP Rules Checklist and attached hereto Exhibit 1, methodically sets forth
how and where the 2017 IRP meets each requirement of the IRP Rule.
6. A review of the Protests reveals that while Complainants express opposition to the
2017 IRP in terms of non-compliance with the IRP Rule, their real concerns are about certain
substantive conclusions of the report which they find objectionable as a matter of public policy.
Some Complainants want to see coal-fired generation continue to run through the end of its
useful life, regardless of what economic analyses show. Some believe PNM should be retiring
Four Comers Power Plant ("FCPP") now, regardless of what the economic analyses show.
Others object to the economic consequences to communities based on actions which were
identified in the 2017 IRP modeling results. The Protests include allegations speculating about
PNMs motivations regarding future cost recovery, allegations of bias and predetermination of
modeling outcomes, arguments about future cost recovery for any stranded assets, and
accusations about whether PNM has fulfilled its responsibilities under the regulatory compact
that governs the relationship between the Commission, PNM, and customers.
7. The problem with the Protests is two-fold. First, the allegations impugning
PNMs motivations and the integrity of its analyses are baseless. Second, the arguments drift far
afield from the Commissions charge with regard to the 2017 IRP under the IRP Rule, i.e., to
conduct a "compliance review" and "review the utilitys proposed IRP for compliance with the
procedures and objectives set forth" in the IRP Rule. The protests object to the public policy
outcomes that would occur if the most cost-effective portfolio and four-year action plan set forth
in the 2017 IRP were implemented by PNM and approved by the Commission. The IRP Rule
makes clear, however, that an integrated resource plan is simply a planning document and that
additional proceedings are necessary to implement actions contained in the IRP. 17.7.3.12(B)
NMAC. Acceptance of an IRP neither permits nor requires PNM to close SJGS in 2022 or take
other actions set forth in the IRP. Therefore, the public polity-driven objections in the protests
cloaked as compliance violations should be rejected because parties will have a full opportunity
to bring forward these arguments when PNM seeks Commission authorization to proceed with
8. Complainants raise public policy considerations with respect to the future of the
PNM system and generation mix. Similar concerns were expressed in a recent letter sent to the
Commission from the Legislative Finance Committee. Indeed, the IRP acknowledges that
impacts on communities from potential changes to PNMs generation mix are considerations as
PNM evaluates next steps. The question here, however, is whether the 2017 IRP has met the
requirements of the IRP Rule. The contents and detailed analysis contained in the 2017 IRP, as
RESPONSE TO PROTESTS
9. In the Protests filed by NMIEC, SWG, CFRE and NEE, numerous allegations
regarding supposed deficiencies, errors and uncertainties are raised with respect to the 2017 IRP.
A close examination of the 2017 IRP itself, and especially Table 13 of Appendix G, shows these
allegations are without merit. While not responding to each and every statement and inference in
these Protests, PNM addresses select major topics raised in the Protests as delineated below.
10. The Public Advisory Participation Process. NEE asserts that PNM simply paid
"lip service" to that statutorily-required public advisory process by not considering matters raised
Pursuant to paragraph 19 of the Amended Stipulation approved by the Commission in Case No. 13-00390-
UT, between July 1, 2018 and December 31, 2018, PNM will "make a filing with the Commission... to
determine the extent to which SJGS should continue serving PNMs retail customers needs after June 30,
2022."
by interested stakeholders in the 2017 IRP in any meaningful way. NEE Protest, p. 10, Van
Winkle Affidavit, p. 6.
11. PNM Response. NEEs assertions concerning the public advisory process for the
2017 IRP are not only unsupported, they are wrong. The 2017 IRP discusses the public advisory
process and how the attendees actively engaged in the planning process by discussing the
planning assumptions and approach, providing comments, sharing concerns, and proposing
alternative scenarios, assumptions, and methodologies for consideration. See, 2017 IRP, pp.
137-140. PNM held ten public advisory meetings throughout the course of the year-long IRP
process addressing topics ranging from the particular requirements of the 2017 IRP related to
SJGS, to electric grid reliability, PNMs baseload resources, PNMs existing transmission system
(and possible transmission additions), emerging technologies (including storage), and fuel and
carbon costs and projections. See, 2017 IRP, p. 138. In the public advisory process, PNM
provided data so that advisory group participants could perform independent analyses and
provided a preliminary draft report on April 20, 2017, in advance of finalizing the report, to
allow time for review and feedback by participants and other stakeholders. See, 2017 IRP, p.
139. After the preliminary draft was issued, PNM held an additional six public comment
meetings throughout its service territory, in Farmington, Alamogordo, Deming, Silver City,
12. The public advisory process resulted in significant contributions to the 2017 IRP.
recommendations regarding which areas and topics in the draft IRP were covered adequately and
which required more analysis. The discussions between PNM and the public participants
resulted in tangible revisions and modifications to the draft IRP. For example, in response to
6
public advisory process feedback, PNM included a discussion of how resource planning affects
PNMs business, provided additional and detailed explanation as to why PNM is not considering
repowering SJGS with natural gas, developed and considered portfolios with higher levels of
renewable supply, and conducted further assessments of near-term and long-term potential of
batteries and other storage technologies. See, 2017 IRP, p. 139. Furthermore, public advisory
process participants expressed interest in the key question of continuing versus retiring SJGS in
2022. Through the public advisory process, participants raised concerns about the impacts of
resource planning decisions on customers, environmental impacts of IRP decision points, and
how advanced technology may be deployed to address resource planning challenges. PNM
considered and addressed each concern. The public process ultimately made the 2017 IRP filed
13. NEEs unfounded assertion that the entire public advisory process was a charade
discounts the time, effort and contributions of all participants to the process, and certainly should
not result in a finding that the 2017 IRP fails to comply with the IRP Rule. NEEs assertions are
shown to be unfounded not only by the 2017 IRP itself, as described above, but by the comments
PNM accepted comments and feedback throughout the [public advisory] process
and responded to the public comments in its published analysis. PNM also
responded to numerous data requests from public participants by providing load,
resource, performance and other modeling parameters, inputs and outputs
throughout the process.
At 2 (August 2, 2017). WRA recommends that the Commission accept PNMs 2017 IRP as
filed, as do the Coalition for Clean Affordable Energy and the Interwest Energy Alliance. See
identify the most cost-effective portfolio in the 2017 IRP. NEE Protest, pp. 1; 6-8, Van Winkle
Affidavit, pp. 5-6; CFRE pp. 1, 8. Additionally, NEE claims that there is no match between
PNMs most cost-effective portfolio load & resource table and PNMs Strategist runs that
15. PNM Response. The most cost-effective portfolio is a centerpiece of this IRP. The
assertion that it was not identified is without merit, and based on a near-willful misreading of the
The 2017 IRP summarizes the most cost-effective portfolio beginning on page 128.
Figure 50 on page 129 illustrates the most cost-effective portfolio capacity additions and
Table 44 shows the loads and resources plan, including each type of generating resource,
for the first 10 years and Table 76 shows the loads and resources plan for the entire 20
The most cost-effective portfolio is provided in Table 128 on page 198 of Appendix M
16. Emission Rates and Health/Environmental Effects. SWG claims that the 2017
IRP fails to present correct emission rates. SWG Protest, pp. 2, 8, 17-19. CFRE asserts that the
2017 IRP does not acknowledge or evaluate the hazardous health risks of maintaining its coal
and nuclear plants. CFRE Protest, p. 8. NEE also protests and objects to PNMs 2017 IRP and
its most cost-effective portfolio therein because, allegedly, the IRP fails to properly evaluate
risks to PNM, its customers, and investors due to PNMs reliance on coal in the face of
8
17. PNM Response. The IRP Rule requires that a utility "present emission rates
(expressed in pounds emitted per kilowatt-hour generated) of criteria pollutants as well as carbon
dioxide and mercury." 1.7.3.9(C)(12) NMAC. Contrary to SWGs claims, the 2017 IRP
correctly includes this information. Table 8 on page 30 of the 2017 IRP shows emissions in
lbs/MWh for NOx, CO, SO2, PM, CO2 and in lbs/TWh for Mercury for facilities in PNMs
resource portfolio, as required by the IRP Rule. With regard to the issue of health effects and
risks as raised by CFRE and NEE, the EPAs allowed emission rates and concentrations for
criteria pollutants are developed based on human health and environmental considerations. The
ongoing compliance with the applicable emissions limits set by EPA and state and local
environmental regulatory bodies by the listed facilities demonstrates that the protection of human
health and the environment is addressed as required under the IRP Rule. Additionally, the Palo
Verde Nuclear Generating Station ("PVNGS") is licensed and inspected by the Nuclear
during the planning period. PVNGS does not emit GHGs and uses treated sewer effluent for
18. Resource Replacement. SWG asserts that the 2017 IRP calls to replace the
existing Valencia Energy Facility power purchase agreement ("PPA") between SWG and PNM
that expires in 2028 without proper evaluation. SWG Protest, pp. 5, 8-13. NEE believes that
PNM failed to address or evaluate the cost effectiveness of SJGS, the FCPP and the PVNGS to
determine whether those resources are still economic or useful for its customers, or whether a
portfolio without those resources was more cost-effective for PNMs customers over the twenty-
year planning period. NEE Protest, p. 4. CFRE asserts that PNM failed to adequately analyze
risks, actively seek the lowest possible price, and compare its recent investments in PVNGS to
alternative resources. CFRE Protest, pp. 6-8. NMIEC argues that the IRP appears to be the result
of a biased predetermined process favoring the phasing out of coal generation NMIEC Protest,
pp. 14-16.
19. PNM Response. As part of the 2017 IRP, PNM put forth the most cost-effective
portfolio to meet PNMs customers energy needs from 2017 through 2036. See, 2017 IRP, pp.
142-149. Contrary to Complainants accusations, the 2017 IRP does not identify specific
resource replacements, but instead identifies that the most cost-effective portfolio reduces
customer cost through the replacement of base load resources with resources having lower
operating costs and greater flexibility to produce energy that better matches customers projected
energy use. See, 2017 IRP, p. 144. Contrary to SWGs assertion, the 2017 IRP identifies the
types of resources PNM will need when the Valencia PPA expires in 2028, including a 187 MW
of natural gas-fired peaking resources. See, 2017 IRP, Appendix N, p. 141. This capacity need
could be fulfilled by extending an existing PPA (with Valencia for example) or procuring a new
20. For planning purposes, PNM assumed the Valencia PPA ended in 2028 pursuant
to its terms. PNM also assumed that SJGS, FCPP, and PVNGS will continue to provide power
to PNMs customers pursuant to their existing operating agreements. PNM invited NEE during
the public advisory process to explain why other assumptions would be appropriate, but NEE did
not respond. E.g., Exhibit DVW-C(2) to the Affidavit of David Van Winkle (email exchange
between PNM and NEE in which PNM explains it does not "have a contractual option to exit
[FCPP] before 2031" and asks NEE to provide a basis for its assumption that PNM may exit
earlier.) Most important - and contrary to select Complainants allegations of bias in resource
selection - PNM states in the 2017 IRP that the next step following the IRP will be to issue an
10
all-source request for proposals ("RFP"). The RFP will refine the mix of replacement resource
types identified in this IRP (natural gas peaking, renewable energy and, potentially, energy
storage) to specific projects that could be proposed for NMPRC approval in later filings. Bidders
will be free to submit bids for any type and size of resource. See, 2017 IRP, p. 148. PNMs
commitment to issue an all-source RFP for replacement resources illustrates the most cost-
effective portfolio will be constructed with the best resources compared to the feasible
alternatives.
21. Energy Storage. SWG is concerned that the proposed most cost-effective
portfolio in the 2017 IRP does not include energy storage resources during the twenty-year
planning period or four-year action plan. SWG Protest, p. 8, pp. 23-26. NEE points out that
PNMs consideration of storage was limited to its sensitivity analysis. NEE Protest, p. 4 and pp.
19-21, Van Winkle Affidavit, p. 6. CFRE observed that PNM should have given consideration
to the rapidly declining prices of battery storage. CFRE Protest, pp. 1, 10.
22. PNM Response. Energy storage is discussed in the 2017 IRP at pages 65-67. This
discussion includes Table 24, which describes nine different energy storage technologies. The
2017 IRP explains that PNM included two versions of battery storage in the capacity expansion
modeling: (1) a 2 MW, two-hour storage battery, and (2) a 40 MW, four-hour battery, with prices
based on recent battery acquisitions in neighboring service territories and verified using the
Electric Power Research Institutes ("EPRI") cost database. See, 2017 IRP, p. 67. NEE states
PNM "only" conducted a sensitivity analysis related to storage. That sensitivity analysis
included varying sizes and capacity of storage, and analyzed reliability impacts of one or more
storage projects. See, 2017 IRP, pp. 124-125; Appendix O, pp. 201-207. Additionally, the 2017
IRPs Four-Year Action Plan states PNM will pursue several actions associated with the SJGS
11
abandonment, which includes issuing an all-source request for proposals. As discussed above,
the RFP will refine the mix of replacement resource types identified in this IRP, and energy
storage is an eligible resource option for purposes of this RFP. See, 2017 IRP, p. 148.
23. Rate Impact. NMIEC alleges that the 2017 IRP failed to provide any clear
presentation of the actual rate impact of PNMs proposals on its customers. NMIEC Protest, pp.
3-6.
24. PNM Response. NMIECs allegation fails to recognize that beyond the NPV of
the most cost-effective portfolio, an estimate of annual rate impact is not required by the IRP
Rule and cannot be provided at this time. Consistent with the IRP Rule, 17.7.3.9(g) NMAC, the
2017 IRP identifies the top ranked resource portfolio based on NPV of total utility costs while
meeting loads within reliability requirements, emissions mandates, construction limitations, and
RPS and energy efficiency requirements. See 2017 IRP, p. 94. A comparison of NPVs indicates
the relative rate impact of the various portfolios but identifying the timing and level of rate
changes for individual customers or customer classes is not only beyond the scope of the IRP,
but dependent on the ultimate resource selections approved in CCN and other implementation
proceedings. The IRP Rule makes clear that follow-on proceedings are necessary to implement
actions contained in the IRP; those proceedings are where the rate impact of specific PNM
decisions should be provided and reviewed. Contrary to NMIECs claim, nothing in the IRP
"require[s] the abandonment of its.., share of [SJGS] in 2022", FCPP in 2031 or any other
existing plant, or the acquisition of any specific new resource. NMIEC Protest, p. 3.
Implementation of the IRP findings is reserved for later consideration by the Commission.
17.7.3.12(B) NMAC.
12
REQUEST FOR RELIEF
25. Based on the foregoing, PNM respectfully requests that the Commission accept its
13
PNM EXHIBIT 1
Consisting of 6 pages
PNM EXHIBIT 1
Page I of 6
IRP Rules
Table 13. IRP Rules Checklist
43
PNM EXHIBIT 1
Page 2 of 6
9.C. 12.a the utility shall provide the percentage of kilowatt-hours Customers Table 2
generated by each fuel used by the utility on its existing
system, for the latest year for which such information is
available
9.C.12.b to the extent feasible, for each existing supply-side Planning Table 8 and
resource on its system, the utility shall present emission Considerations Appendix J
rates (expressed in pounds emitted per kilowatt-hour
generated) of criteria pollutants as well as carbon dioxide
and mercury
9.C.12.c to the extent feasible, for each existing supply-side Description of Appendix J
resource on its system, the utility shall present the water existing resources
consumption rate
9.C.13 a summary of back-up fuel capabilities and options Description of Existing
existing resources Thermal
Resources
9.D.1 The utility shall provide a load forecast for each year of the
planning period; the load forecast shall incorporate the
following information and projections
9.D.l.a annual sales of energy and coincident peak demand on a Customers Appendix A
system-wide basis, by customer class, and disaggregated
among commission jurisdictional sales, FERC jurisdictional
sales, and sales subject to the jurisdiction of other states
9.D.l.b annual coincident peak system losses and the allocation of Customers Load Forecast
such losses to the transmission and distribution and Appendix
components of the system A
9.D.l.c weather normalization adjustments Customers Load Forecast
and Appendix
A
9.D.1 .d assumptions for economic and demographic factors relied Customers Load Forecast
on in load forecasting and Appendix
A
44
PNM EXHIBIT 1
Page 3 of 6
9.D.1 .e expected capacity and energy impacts of existing and Customers Load Forecast
proposed demand-side resources and Appendix
A&N
9.D.l.f typical historic day or week load patterns on a system-wide Customers Append A; n/a
basis for each major customer class by customer
class
9oD.2 The utility shall develop base-case, high-growth and low- Customers Load Forecast
growth forecasts, or an alternative forecast that provides and Appendix
an assessment of uncertainty (e.g., probabilistic A
techniques
9.D.3.a The utility shall explain how the demand-side savings Customers Load Forecast;
attributable to actions other than the utility-sponsored Energy
demand-side resources for each major customer class are Efficiency
accounted for in the utilitys load forecast and the effect, as
appropriate, on its load forecast of the utility-sponsored
demand-side resources on each major customer class
9.D.3.b The utility shall compare the annual forecast of coincident Cu~omeB Appendix A
peak demand and energy sales made by the utility to the
actual coincident peak demand and energy sales
experienced by the utility for the four years preceding the
year in which the plan under consideration is filed. In
addition, the utility shall compare the annual forecast in its
most recently filed resource plan to the annual forecast in
the current resource plan. In its initial IRP filing, the utility
shall provide information demonstrating how well its
forecasts during the preceding four years predicted
demand
9.D.3.c The utility shall explain and document the assumptions, Customers Load Forecast
methodologies, and any other inputs upon which it relied to and Appendix
develop its load forecast A
9.D.1 The utility shall provide a load forecast for each year of the
planning period; the load forecast shall incorporate the
following information and projections
9.E.1 utility-owned generation L&R Table Appendix N
9.E.2 existing and future contracted-for purchased power L&R Table Appendix N
including qualifying facility purchases
9.E.3 purchases through net metedng programs, as appropriate L&R Table Appendix N
9.E.4 demand-side resources, as appropriate L&R Table Appendix N
9.E.5 other resources relied upon by the utility, such as pooling, L&R Table Appendix N
wheeling, or coordination agreements effective at the time
the plan is filed
9.F.1 In identifying additional resource options, the utility shall Potential Resource Appendix K
consider all feasible supply-side and demand-side Additions
resources. The utility shall describe in its plan those
resources it evaluated for selection to its portfolio and the
assumptions and methodologies used in evaluating its
resource options, including, as applicable: life expectancy
of the resources, the recognition of whether the resource is
replacing/adding capacity or energy, dispatchability, lead-
time requirements, flexibility and efficiency of the resource.
45
PNM EXHIBIT 1
Page 4 of 6
9.F.2 For supply-side resource options, the utility shall identify Potential Resource Appendix K
the assumptions actually used for capital costs, fixed and Additions
variable operating and maintenance costs, fuel costs
forecast by year, and purchased power demand and
energy charges forecast by year, fuel type, heat rates,
annual capacity factors, availability factors and, to the
extent feasible, emission rates (expressed in pounds
emitted per kilowatt-hour generated) of criteria pollutants
as well as carbon dioxide and mercury
9.F.3 The utility shall describe its existing rates and tariffs that Customers; Existing
incorporate load management or load shifting concepts. Description of Demand-Side
The utility shall also describe how changes in rate design Existing Resources; Resources
might assist in meeting, delaying or avoiding the need for
new capacity
9.G.1 To identify the most cost-effective resource portfolio, Analysis Results; ApperJdix L &
utilities shall evaluate all feasible supply and demand-side Determination of M
resource options on a consistent and comparable basis, MCEP
and take into consideration risk and uncertainty (including
but not limited to financial, competitive, reliability,
operational, fuel supply, price volatility and anticipated
environmental regulation). The utility shall evaluate the
cost of each resource through its projected life with a life-
cycle or similar analysis. The utility shall also consider and
describe ways to mitigate ratepayer risk
9.G.2 Each electric utility shall provide a summary of how the
following factors were considered in, or affected, the
development of resource portfolios
9.G.2.a load management and energy efficiency requirements Analysis Results; Appendix L &
Determination of M
MCEP
9.G.2.b renewable energy portfolio requirements Analysis Results; Appendix L &
Determination of M
MCEP
9.G.2.c existing and anticipated environmental laws and Analysis Results; Appendix L &
regulations, and, if determined by the commission, the Determination of M
standardized cost of carbon emissions MCEP
9.G.2.d fuel diversity Analysis Results; Appendix L &
Determination of M
MCEP
9.G.2.e susceptibility to fuel interdependencies Analysis Results; Appendix L &
Determination of M
MCEP
9.G.2.f transmission constraints Analysis Results; Appendix L &
Determination of M
MCEP
9.G.2.g system reliability and planning reserve margin Analysis Results; Appendix L &
requirements Determination of M
MCEP
9.G.3 Alternative portfolios. In addition to the detailed description Analysis Results; Appendix L &
of what the utility determines to be the most cost-effective Determination of M
resource portfolio, the utility shall develop a reasonable MCEP
number of alternative portfolios by altering risk
assumptions and other parameters developed by the utility
46
PNM EXHIBIT 1
Page 5 of 6
9.H.1 The utility shall initiate the process by providing notice at Public Advisory
least 30 days prior to the first scheduled meeting to the Process
commission, interveners in its most recent general rate
case, and participants in its most recent renewable energy,
energy efficiency and IRP proceedings; the utility shall at
the same time, also publish this notice in a newspaper of
general circulation in every county which it~ serves and in
the utilitys b{llin9 inserts
9.H.l.a a brief description of the IRP process Public Advisory
Process
9.H.l.b time, date and location of the first meeting Public Advisory
Process
9.H.l.c a statement that interested individuals should notify the Public Advisory
utility of their interest in participating in the process Process
9.H.l.d utility contact information Public Advisory
Process
9.H.2 Upon receipt of the initial notice, the commission may Public Advisory
designate a facilitator to assist the participants with dispute Process
resolution
9.H.3 The utility or its designee shall chair the public participation Public Advisory
process, schedule meetings, and develop agendas for Process
these meetings. With adequate notice to the utility,
participants shall be allowed to place items on the agenda
of public participation process meetings
9.H.4 Meetings held as part of the public participation process Public Advisory
shall be noticed and scheduled on a regular basis and Process
shall be open to members of the public who shall be heard
and their input considered as part of the public participation
process. Upon request, the utility shall provide an
executive summary containing a non-technical description
of its most recent IRP
9.H.5 The purposes of the public participation process are for the Public Advisory
utility to provide information to, and receive and consider Process
input from, the public regarding the development of its IRP.
Topics to be discussed as part of the public participation
process include, but are not limited to, the utiiitys load
forecast; evaluation of existing supply- and demand-side
resources; the assessment of need for additional
resources; identification of resource options; modeling and
risk assumptions and the cost and general attributes of
potential additional resources; and development of the
most cost-effective portfolio of resources for the utilitys
IRP
9.H.6 In its initial IRP advisory process, the utility and Public Advisory
participants shall explore a procedure to coordinate the Process
IRP process with renewable energy procurement plans
and energy efficiency and load management program
proposals. Any proposed procedure shall be designed to
conserve commission, participant and utility resources and
shall indicate what, if any, variances may be needed to
effectuate the proposed procedure
47
PNM EXHIBIT 1
Page 6 of 6
9.1.1 The utilitys action plan shall detail the specific actions the Executive Summary Four Year
utility will take to implement the integrated resource plan Action Plan
spanning a four-year period following the filing of the
utilitys IRP. The action plan will include a status report of
the specific actions contained in the previous action plan.
9.1.2 An action plan does not replace or supplant any Executive Summary Four Year
requirements for applications for approval of resource Action Plan
additions set forth in New Mexico law or commission
regulations
48
BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION
I hereby certify that a true and correct copy of the Consolidated Response of Public Service
Company of New Mexico to Protests to 2017 Integrated Resource Plan was e-mailed to the
parties identified below and was hand-delivered to the parties designated for hand-delivery
identified below on August 11, 2017:
EMAIL ONLY:
2
GCG# 523766
Jason Marks, Esq. Rick Alvidrez
lawoffiee@j asonmarks.eom ralvidrez@mstlaw.com
3
GCG# 523766
Marcos Martinez Mark Fenton
mdmartinez@santafenm, gov Mark.Femon@pnm.com
4
GCG# 523 766
Briana Trujillo Nick Schiavo
BrianaG.Trujillo@state.nm.us naschiavo@santafenm, gov
MAIL ONLY:
5
GCG# 523766
Dated this 11th day of August, 2017.
By:
6
GCG# 523766