PNM Resources : Rebuttal Testimony of Forrest Small

BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION

IN THE MATTER OF THE JOINT APPLICATION	OF	)
AVANGRID, INC., AVANGRID NETWORKS, INC.,	NM	)
GREEN HOLDINGS, INC., PUBLIC SERVICE COMPANY	)
OF NEW MEXICO AND PNM RESOURCES, INC. FOR	)
APPROVAL OF THE MERGER OF NM GREEN		)
HOLDINGS, INC. WITH PNM RESOURCES, INC.;		)
APPROVAL OF A GENERAL DIVERSIFICATION PLAN;	)
AND ALL OTHER AUTHORIZATIONS AND APPROVALS )
REQUIRED TO CONSUMMATE AND IMPLEMENT THIS )
TRANSACTION		) Case No. 20-00222-UT
		)
AVANGRID, INC., AVANGRID NETWORKS, INC.,		)
NM GREEN HOLDINGS, INC., PUBLIC		)
SERVICE COMPANY OF NEW MEXICO AND PNM		)
RESOURCES, INC.,		)
		)
JOINT APPLICANTS.		)
		)

JULY 29, 2021 REBUTTAL TESTIMONY

OF

FORREST SMALL

July 29, 2021

	TABLE OF CONTENTS
I.	Introduction and Purpose ....................................................................................................	1
II.	Overview and Key Conclusions..........................................................................................	1
III.	Comparison of Reliability of Avangrid Distribution Utilities to Other Utilities ................	2
IV.	Reliability of PNM and New Mexico Electric Utilities......................................................	4
V.	Distribution System Planning .............................................................................................	7
VI.	Conclusions.........................................................................................................................	8

JA Exhibit FS-1 (July 29, 2021) - Reliability Indices Reported to NMPRC

JA Exhibit FS-2 (July 29, 2021) - SAIFI and SAIDI for PNM, EPE, and SPS 2005 - 2020 JA Exhibit FS-3 (July 29, 2021) - Trend Lines for PNM and EPE

JULY 29, 2021 REBUTTAL TESTIMONY

OF FORREST SMALL

NMPRC CASE NO. 20-00222-UT

1	I. INTRODUCTION AND PURPOSE

2 Q. PLEASE STATE YOUR NAME, AFFILIATION, AND BUSINESS ADDRESS.

3	My name is Forrest Small. I am Senior Vice President of Concentric Energy Advisors, Inc.
4	("Concentric"), located at 293 Boston Post Road West, Suite 500, Marlborough,

1. Massachusetts 01752.
2. Q. HAVE YOU PREVIOUSLY FILED TESTIMONY IN CASE NO. 20-00222-UT?

7	Yes. On June 18, 2021, I filed Testimony in Support of the Second Amended Stipulation.

1. on behalf of Public Service Company of New Mexico ("PNM"), PNM Resources, Inc.
2. ("PNMR"), Avangrid, Inc. ("Avangrid"), Avangrid Networks, Inc. ("Networks") and NM
3. Green Holdings, Inc. (collectively, the "Joint Applicants") in the application regarding the
4. proposed acquisition of PNMR by Avangrid (such acquisition and associated corporate
5. organization steps as described in the application filed in this proceeding being the
6. "Proposed Transaction" or the "Transaction").
7. Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?

15	The purpose of my testimony is to respond to the testimony of Mr. Evan D. Evans on behalf

1. of New Mexico Public Regulation Commission ("Commission") Utility Division Staff
2. ("Staff"). My responses are to testimony regarding the reliability of Avangrid distribution
3. utilities, the reliability of PNM and other New Mexico utilities, and PNM reliability and
4. distribution system planning practices.

20	II. OVERVIEW AND KEY CONCLUSIONS

1. Q. PLEASE PROVIDE A BRIEF OVERVIEW OF YOUR TESTIMONY IN
2. RESPONSE TO OPPOSITION TO THE SECOND AMENDED STIPULATION.

23	I understand that since the Stipulation was filed, settlement discussions have continued

1. with Staff and other non-signatories and in some cases testimony in opposition to the
2. Stipulation is intended to reflect consensus positions on amendments to the Stipulation

1

JULY 29, 2021 REBUTTAL TESTIMONY

OF FORREST SMALL

NMPRC CASE NO. 20-00222-UT

1. which non-signatory(ies) would find acceptable. In response, the Joint Applicants propose
2. to modify and enhance certain Stipulated Regulatory Commitments.

3

1. My testimony here addresses the reliability of Avangrid distribution utilities and how the
2. reliability metrics of these companies compare to utilities in the states in which they
3. operate. I also discuss the reliability metrics of PNM and how they compare to other
4. utilities in New Mexico. Finally, I address the potential negative consequences of excessive
5. focus on the worst performing distribution feeders in response to penalties.

9

10 III. COMPARISON OF RELIABILITY OF AVANGRID DISTRIBUTION

11	UTILITIES TO OTHER UTILITIES

1. Q. PLEASE BRIEFLY SUMMARIZE THE TESTIMONY YOU RESPOND TO IN
2. THIS SECTION OF YOUR TESTIMONY.

14	In this section of my testimony, I address the testimony in opposition to Stipulation of Mr.

1. Evans who objected to the comparison of reliability performance between utilities.
2. Q. WHAT CONSIDERATIONS SHOULD ONE MAKE WHEN COMPARING THE
3. RELIABILITY PERFORMANCE OF UTILITIES?

18	As stated in a recent paper by Concentric Energy Advisors1:"when evaluating electric
19	reliability, it is crucial to recognize that power outages result from numerous factors,
20	including, but not limited to, weather, vehicle accidents, equipment failure, and wildlife on
21	energized equipment. Every part of the US has unique reliability challenges, and utilities
22	design and maintain electric systems accordingly." Mr. Evans correctly points out in his
23	testimony that customer density, vegetation, distribution system infrastructure, and
24	operational technologies can influence the reliability performance of different utilities. In
25	addition to these factors, the number of customers a utility serves, and the geography over
26	which each utility operates can have a meaningful impact on how systems are designed
27	and operated.

1 Avangrid Networks Reliability and Service Quality, Concentric Energy Advisors, June 2021.

2

JULY 29, 2021 REBUTTAL TESTIMONY

OF FORREST SMALL

NMPRC CASE NO. 20-00222-UT

1. Q. HOW DID YOU COMPARE THE RELIABILITY METRICS OF THE AVANGRID
2. DISTRIBUTION UTILITIES TO OTHER UTILITIES?

3	Avangrid operates distribution utilities in Connecticut, Maine, and New York. I elected to

1. start by comparing each Avangrid distribution utility to other investor-owned utilities in
2. the same state. Comparing utilities in the same states meant that utilities would likely
3. experience similar weather conditions and tree cover. Consolidated Edison Company of
4. New York was not included in the analysis due to its densely urban service territory and
5. distribution system. Within each state I compared the SAIDI of each Avangrid utility with
6. the other utilities in the same state.
7. Q. PLEASE SUMMARIZE HOW THE SAIDI OF THE AVANGRID UTILITIES
8. COMPARED WITH OTHER INVESTOR OWNED UTILITIES (IOUS) IN THE
9. SAME STATES.

13	Over seven years from 2013 to 2019, the Avangrid utilities in Connecticut, Maine, and

1. New York have a lower average SAIDI (excluding Major Event Days) than other IOUs in
2. the same states. When Major Event Days are included the Avangrid utilities in New York
3. have a higher 7-year average SAIDI than the average of the other New York IOUs. The
4. Avangrid utilities in Connecticut and Maine have lower 7-year average SAIDI (including
5. Major Event Days) than the other IOUs in those states.

19 Q. WHAT CONCLUSIONS DO YOU DRAW FROM THE FOREGOING

20 COMPARATIVE DATA?

21 Avangrid's reliability metrics are similar to those of other comparable utilities in the

1. Northeastern United States. Severe weather events in heavily forested areas can have a
2. significant affect on the reliability performance of utilities in these areas.

3