PNM, New Mexico’s largest utility, has proposed a Grid Modernizing project that would install smart meters on ratepayers’ homes and businesses. Smart meters are digital, transmitting electronic devices that measure and record energy use.
Like any electronic equipment, smart meters will eventually fail (stop working). To ensure that equipment fails safely, the Engineering and Surveying Practices Act requires that PNM employ a New Mexico-licensed professional engineer (PE) to evaluate proposed projects and certify that all hazards have been mitigated.
To date, PNM has not designated a state licensed PE to review its Grid Modernization project. The Public Regulatory Commission (PRC)’s proceeding with this case, No. 22-00058-UT, currently focuses on PNM’s Benefit Cost Analysis (BCA). Ratepayers can comment on the BCA on Thursday, April 18. Info about how to comment follows items that ratepayers might note to PRC commissioners:
1. A comprehensive Cost-Benefit Analysis evaluates all of a project’s risks, including fire. As required by New Mexico’s Engineering and Surveying Practices Act, PNM customers deserve a NM licensed professional engineer to be in “responsible charge” of its Grid Modernization plan. To ensure safety, ratepayers deserve a licensed PE who performs comprehensive analysis of different of meters, including which grid modernization objectives each can achieve and which risks (including fire risks) they present. PNM’s Benefit Cost Analysis does not consider the risk of fire or its associated mitigation costs.
2. No engineer “in responsible charge” of PNM’s project has analyzed its Benefit-Cost Analysis to verify that it evaluates all costs and risks associated with smart-meter (AMI) deployment. PNM’s failure to designate an engineer in responsible charge disregards ratepayers’ safety and violates New Mexico’s Engineering and Surveying Practices Act. Where can ratepayers turn to ensure this project’s safety?
3. Smart meter fires pose a significant risk that PNM’s Cost-Benefit Analysis fails to address. From 2012-2015, shortly after most smart meters were installed in the U.S., the National Fire Protection Association reported a 59% increase in fixed-wire fires. See: “The Discovery and Science of Smart Meter Fires,” a presentation by forensic fire investigators at the 2021 California Conference of Arson Investigators, https://www.ourweb.tech/CCAI-presentation.pdf
Customers deserve a licensed PE in responsible charge who examines the National Fire Protection Association’s findings and who ensures that PNM’s selection of smart meters will not increase its customers vulnerability to electrical fires. PNM’s BCA has not considered this risk or associated mitigation costs. Where can New Mexicans turn to ensure that this project’s fire risks have been mitigated?
4. PNM’s BCA does not include a “coordination study,” which ensures that meters on PNM’s grid are not at risk of fault current or overvoltage. It ensures that fuses, breakers, and relays are properly sized so that meters will not catch on fire or explode. Only a coordination study can ensure that PNM’s grid is engineered to protect the meters within standards. Why has PNM’s BCA fail to include a coordination study?
5. PNM’s ratepayers deserve a PE in responsible charge to test customer-owned meter socket boxes and rate their sufficiency to withstand the torques and forces of remote switch operation. The BCA does not include costs for such a study or mitigation costs if customer-owned socket boxes are not tested for remote switch operation.
6. PNM’s CBA fails to compare its proposal to alternatives or to ensure that its proposal is the best option.
7. To ensure public safety, PNM’s Grid Modernization project must ensure the company’s adherence to all applicable laws, including New Mexico’s Engineering and Surveying Practices Act. The project must apply and harmonize all applicable laws, not just the grid modernization statute, an amended portion of the Public Utility Act. Who will ensure that New Mexico’s laws are applied and harmonized?
To Comment
As much as possible, comments about case No. 22-00058-UT should focus on the project’s economics and/or risks.
To write a comment, please address PRC commissioners Gabriel Aguilera, James Ellison, and Pat O’Connell by emailing their executive assistant, jennifer.baca@prc.nm.gov and the records dept at prc.records@prc.nm.gov.
The hearing will take place on THURSDAY, APRIL 18, FROM 2-5 PM. Each person will have three minutes to speak. You can comment in person, by telephone or Zoom.
The in-person hearing will be at the PRC's headquarters in the Bokum Building, 142 West Palace Street, Santa Fe, New Mexico. You do not need to register in advance to comment in person.
To comment by telephone or Zoom, sign up with Patrick Rodriguez. Contact him by phone (505) 490-7910 or by email at public.comment@prc.nm.gov
For more info: https://drive.google.com/file/d/1GdDjByLL0z1XbvAKSJrsY2tnCuU82HHX/view?usp=sharing