22-00154-UT

Key events and scheduled submissions in this proceeding include:

- May 8, 2025: Workshop #1 on wildfire resiliency and mitigation planning.
- July 17, 2025: Workshop #2 on risk assessment and insurance best practices.
- September 15, 2025: Workshop #3 on vegetation and grid hardening strategies.
- October 23, 2025: Workshop #4 focusing on the path forward, summary, and next steps.

For each workshop:
- Specific agendas and additional details are to be finalized and posted prior to the respective dates.
- Presenters must file any presentation materials utilized in the workshop in the docket no later than three days after each workshop 1, 1.

Docket No. 22-00154-UT concerns an inquiry by the New Mexico Public Regulation Commission (NMPRC) into electric public utilities’ vegetation management plans and wildfire mitigation practices. The proceeding was initiated in response to the increasing risk and incidence of wildfires in New Mexico, including fire ignitions linked to power lines, exacerbated by drought and strong winds associated with climate change 1.

Key activities and developments in the docket include:
- The Commission required all investor-owned utilities and rural electric cooperatives in New Mexico to submit their current vegetation management plans and other wildfire protection practices for comprehensive review and identification of best practices under worsening weather and climate conditions 1.
- Utilities such as Public Service Company of New Mexico (PNM) responded by filing updated wildfire mitigation plans and public safety power shutoff (PSPS) frameworks, detailing advancements in vegetation management, infrastructure hardening, improved risk assessment, and communication protocols 2, 3.
- The docket included a series of scheduled workshops (2025) to address wildfire mitigation strategies, grid hardening, and the path forward, with participation from utilities, advocacy organizations, government agencies, and other stakeholders 4, 2.
- Workshop materials, presentations, and annual reports on wildfire mitigation expenditures and activities are required to be filed and made publicly available in the docket 4, 5, 6.

The overarching goal is to ensure utilities’ wildfire prevention practices are robust, improve coordination among stakeholders, and potentially inform future rulemaking or directives to further mitigate wildfire risks associated with electric infrastructure in New Mexico 1, 2.

Key stakeholders in the docket regarding electric utilities' wildfire mitigation and vegetation management plans before the New Mexico Public Regulation Commission include:

- Public Service Company of New Mexico (PNM)
- Southwestern Public Service Company (SPS)
- Western Resource Advocates (WRA)
- Coalition for Clean Affordable Energy (CCAE)
- County of Bernalillo
- Other utilities: Duncan Valley Electric Cooperative, El Paso Electric Company (EPE), Kit Carson Electric Cooperative, Lea County Electric Cooperative, New Mexico Rural Electric Cooperative Association

Positions on the proposal to establish a series of workshops addressing wildfire mitigation:

- Support: Staff of the Commission and the Mora/San Miguel Electric Cooperative support the motion for workshops.
- No Opposition: The City of Albuquerque, New Mexico Department of Justice, Kit Carson Electric Cooperative, Lea County Electric Cooperative, and El Paso Electric Company do not oppose the motion.
- No Position: Springer Electric Cooperative and Tri-State Generation and Transmission Association take no position.
- No other parties provided a position by the time the motion was filed 1.

Other involved governmental and organizational stakeholders (suggested for workshop participation):

- New Mexico Energy, Minerals and Natural Resources Department’s Forestry Division
- New Mexico Department of Homeland Security and Emergency Management
- Forest Stewards Guild
- New Mexico Office of the Superintendent of Insurance
- U.S. Department of Agriculture – Forest Service Southwest Region 3
- National Fire Protection Association
- International Association of Fire Chiefs
- State Fire Marshal
- New Mexico Association of Counties
- New Mexico Municipal League
- Representatives from local and county-level fire departments
- Representatives from New Mexico’s Indian nations, tribes, and pueblos

These groups are suggested for inclusion in the process to provide expertise and facilitate coordination, but their explicit positions for or against specific proposals are not detailed in the provided excerpts 1.

The docket identifies two primary areas of growth related to wildfire risk management in New Mexico utility operations:

1. High Fire Risk Areas (HFRAs)
2. Methodological and Technological Advancements in Risk Assessment and Mitigation

1. High Fire Risk Areas (HFRAs):
- HFRAs are specific locations within PNM’s service territory where wildfire risk and potential consequences are elevated. These areas are delineated based on factors such as vegetation, terrain, meteorology, population density, and proximity to the wildland-urban interface.
- PNM has identified 10 HFRAs in New Mexico containing company infrastructure, with further subdivision into Tier 1 and Tier 2 areas:
- Tier 1: More urbanized, less contiguous flammable vegetation, lower likelihood of wildfire spread, faster emergency response.
- Tier 2: More susceptible to sustaining wildfires due to environmental conditions like contiguous vegetation, poor access, and steep terrain.
- Identification of HFRAs uses historic fire perimeter data, geographic information systems (GIS), and artificial intelligence (AI) tools to assess and map risk profiles and inform targeted mitigation strategies 1, 1.
- Key considerations in HFRAs include:
- Prioritizing vegetation management and wildfire mitigation projects.
- Enhanced community engagement, especially in areas with tribal lands and the wildland-urban interface.
- Regular risk reassessment and refinement of mitigation strategies as environmental conditions evolve 1, 1.

2. Methodological and Technological Advancements:
- The docket highlights ongoing development and implementation of new methodologies and technologies to improve wildfire risk assessment and management:
- Adoption of AI-driven geospatial fire risk assessment tools to refine landscape hazard assessments, enabling more precise identification of high-risk zones.
- Use of LIDAR (Light Detection and Ranging) and high-resolution imagery for detailed inspections of transmission and distribution lines within HFRAs, supporting asset inventory, virtual inspections, and prioritization of vegetation work 2, 3.
- Development of GIS-based inspection systems for enhanced data management, analysis, and reporting, facilitating quicker and better-informed decision-making 3.
- Evaluation and piloting of infrastructure upgrades such as non-expulsion fuses, covered/insulated overhead conductors, and selective undergrounding of lines to reduce ignition risk.
- Participation in collaborative research initiatives (e.g., EPRI’s climate resilience program) to stay current with industry best practices 3.

Key considerations for these advancements include:
- Ensuring that new risk assessment methods are validated and adapted for diverse New Mexico environments, including high desert terrain.
- Integrating community and stakeholder input, especially from local, tribal, and emergency management entities, to balance public safety with operational impacts.
- Continuous refinement of vegetation management practices to promote low-risk plant communities and maintain safe clearances around infrastructure.
- Regular review and adaptation of wildfire mitigation plans as climate and environmental risks evolve 1, 2, 3.

The docket identifies several financial and timeline risks and concerns:

Financial risks and concerns:
- Utilities such as PNM requested significant increases in revenue requirements to cover wildfire mitigation, vegetation management, and infrastructure maintenance expenses, with specific allocations (e.g., $900,000 for wildfire mitigation, $2,000,000 for vegetation management, and $1,500,000 for infrastructure maintenance) 1.
- The commission requires detailed annual reporting on the costs and effectiveness of these expenditures, indicating a need to closely monitor spending and ensure cost-effectiveness in wildfire mitigation activities 1.
- There are concerns regarding the adequacy of current vegetation management plans and whether they are sufficiently protective given challenging weather and climate conditions, which could result in higher future costs if plans are deemed inadequate 2.
- Funding challenges are explicitly mentioned as obstacles to implementing vegetation management and wildfire mitigation plans, with utilities asked to detail these challenges and potential solutions in their responses to the commission 3.

Timeline risks and concerns:
- The commission has established specific deadlines for utilities to submit vegetation management plans, wildfire protection practices, and responses to bench requests (e.g., July 6, 2022, and November 17, 2022), with potential risks if these deadlines are missed or if responses are incomplete 2, 3.
- The evolving nature of inspection programs and the integration of new inspection types over the coming years present uncertainties in the timeline for achieving comprehensive wildfire risk mitigation 4.
- Workshops are scheduled throughout 2025 to address wildfire mitigation strategies, with agendas and materials required to be posted and filed in a timely manner, adding procedural timeline pressures for all parties involved 5, 5.
- The commission is aware that delays or inadequacies in plan implementation could have a devastating impact on safe, reliable electric service and could increase wildfire risk 2.

In summary, the docket highlights concerns about escalating costs for wildfire mitigation and vegetation management, the need for transparent and effective use of funds, challenges in funding and implementation, as well as risks related to meeting regulatory and procedural timelines.