24-12016

Key events and submissions in the proceeding regarding the first amendment to NV Energy's 2024–2026 Joint Natural Disaster Protection Plan (NDPP) are as follows:

- December 18, 2024: Nevada Power Company (NPC) and Sierra Pacific Power Company (SPPC), collectively NV Energy, filed a joint application for approval of the first amendment to the 2024–2026 NDPP with the Public Utilities Commission of Nevada (PUCN), initiating Docket No. 24-12016 1.
- December 30, 2024: The Nevada Bureau of Consumer Protection filed a notice of intent to intervene 2.
- January 22, 2025: Multiple parties, including Smart Energy Alliance, Wynn Las Vegas, Caesars, MGM Resorts, Nevada Resort Association, and major gaming groups, filed petitions for leave to intervene 2.
- January 23, 2025: The presiding officer held a prehearing conference to discuss procedural schedules, discovery, and interventions 1, 2.
- April 1, 2025: Continued prehearing conference scheduled in person and via Microsoft Teams/Zoom 2.
- April 8, 2025: Deadline for staff, BCP, and intervenors to file prepared direct testimony 2.
- April 22, 2025: Deadline for NV Energy to file prepared rebuttal testimony 2.
- April 24, 2025: NV Energy filed notice of appearance and witness information in the docket 3.
- May 1, 2025: Hearing scheduled to begin in person and via Microsoft Teams/Zoom, with additional days reserved as needed (May 2 and May 5, 2025) 4.
- Protective orders were issued on March 5, 2025, and confidentiality procedures were discussed and set in subsequent orders 5, 4.

The procedural schedule has otherwise remained unchanged as of March 13, 2025 4.

Docket No. 24-12016 before the Public Utilities Commission of Nevada concerns the first amendment to the 2024-2026 Joint Natural Disaster Protection Plan (NDPP) filed by Nevada Power Company and Sierra Pacific Power Company, both doing business as NV Energy. The central focus is on proposed changes to the NDPP, particularly regarding labor resource plans, budget adjustments, and the inclusion of new or amended projects and expenditures related to wildfire mitigation and grid resilience.

Key issues include:
- Requests for regulatory approval of incremental labor resources dedicated to NDPP implementation, with debate over whether such positions and costs should be recovered through NDPP-specific rates or in general rate cases (GRCs), as outlined in recent amendments to Nevada regulations 1, 2, 3.
- Budget adjustments for existing and new NDPP activities, including system hardening, situational awareness improvements, and mapping corrections. The financial tables indicate both increases and reductions in forecasted expenditures, with explanations provided for the changes 4, 5.
- Questions about the appropriateness of certain costs and positions being included as NDPP amendments versus being considered part of the utilities’ normal course of business, and the proper mechanism for cost recovery 2, 1, 6.
- Oversight, tracking, and reporting requirements, including the integration of advanced technologies and federal grant funding (e.g., Department of Energy’s GRIP grant), and the need for improved procedures for fire risk management and outage planning 7, 8, 6.
- Intervenor participation and standing, with trade associations and consumer groups seeking to represent the interests of large energy users and retail customers affected by changes in NDPP-related rates and services 9.

The docket involves significant stakeholder engagement, including regulatory staff, consumer advocates, and intervenors, all addressing the scope, cost recovery, and execution of NV Energy’s wildfire risk mitigation and disaster protection programs.

The main stakeholders in this docket (Docket No. 24-12016) are:

- Wynn Las Vegas, LLC
- Caesars Enterprise Services, LLC
- MGM Resorts International
- SNGG (joint petitioners: Boyd Gaming Corporation, Station Casinos, The Venetian)
- Smart Energy Alliance (SEA)
- Nevada Resort Association (NRA)
- Bureau of Consumer Protection, Office of the Nevada Attorney General
- NV Energy (Nevada Power Company and Sierra Pacific Power Company)
- Public Utilities Commission of Nevada Regulatory Operations Staff

Positions and Proposals:

1. Petitions to Intervene:
- Wynn, Caesars, MGM, SNGG, SEA, and NRA all petitioned for and were granted intervention. They argued that the commission's decisions would directly affect their electric rates and services, and that no other party could adequately represent their interests. None of the parties objected to these interventions 1, 1, 1.

2. Stakeholder Interests:
- Wynn, Caesars, MGM, SNGG, SEA, and NRA are large energy users or associations of such users. They are primarily interested in how NV Energy’s proposals (including rate increases and service changes) will affect their costs and service reliability. Their interventions are generally neutral but are focused on protecting their own interests regarding rates and service terms 1, 1, 1.

3. Positions on NV Energy’s Proposals:
- The excerpts do not provide explicit statements of support or opposition by these stakeholders for or against specific NV Energy proposals. Instead, stakeholders have intervened to ensure their interests (mainly regarding rates and service) are protected and represented in the proceeding.
- Regulatory Operations Staff (PUCN staff) have taken a position against NV Energy’s request for regulatory asset cost recovery for labor resource positions in a plan amendment, arguing that such recovery should occur in a general rate case, not in a plan amendment 2, 3.
- The Bureau of Consumer Protection is participating but the excerpts do not detail whether they support or oppose specific proposals in this docket 4.

Summary:
- All major intervenors are seeking to protect their interests as large energy customers or representatives of such customers.
- No explicit support or opposition to specific NV Energy proposals is detailed for the intervenors; their participation is mainly to represent their interests in the outcome.
- PUCN staff oppose NV Energy’s attempt to recover labor resource costs through a plan amendment rather than a general rate case.
- No objections were raised against the interventions themselves.

In conclusion, most stakeholders are intervening to protect their interests rather than take a clear position for or against NV Energy’s proposals, with the exception of regulatory staff, who oppose certain cost recovery methods proposed by NV Energy 1, 2, 3.

The docket identifies several key areas of growth:

1. Vegetation Management and Ground Fuels
- Activity in vegetation management has increased 10 times since 2019, but administrative and field oversight has grown less than double. This has led to quality assurance issues, increased regulatory scrutiny, and challenges in scaling the workforce for seasonal needs. There is a recommendation to leverage technology, like predictive growth cycle tools and remote imagery, to prioritize and manage work more efficiently. NV Energy is piloting Aidash for remote sensing and predictive analysis. Coordination between ground fuels and aerial tree trimming is also recommended for operational efficiency and better fire mitigation resource allocation 1.

2. Data Analytics and Technology Integration
- NV Energy is expanding its use of advanced analytics, artificial intelligence, and cloud-based platforms (e.g., Microsoft Azure Data Lake, machine learning for wildfire risk estimation, Palantir Foundry for fire incident analysis, and Aidash for vegetation management). The company focuses on continual evaluation for compatibility, scalability, and relevance to avoid obsolescence and stranded assets, often using annual or triennial contracts. Participation in industry working groups keeps the technology portfolio current and responsive to evolving risks and requirements 2, 3.

3. System Hardening
- There has been a shift in resources to address urgent needs in system hardening (e.g., redesigning positions for field execution, onboarding contractors). Resource constraints have led to challenges in maintaining standards, oversight, and achieving capital system hardening milestones. Lessons learned from installation failures (e.g., with covered conductors) have prompted improvements in standards and training. The workload for system hardening design and construction is significant and requires additional trained resources to meet targets 1.

4. Situational Awareness (Wildfire Cameras & Weather Stations)
- NV Energy is expanding its network of wildfire cameras and weather stations to improve localized forecasting and real-time risk monitoring. However, the placement and configuration of these assets have not yet been optimized with formal models. The company continues to fill data gaps and finalize locations, with the goal of maximizing fire risk reduction relative to cost 2.

Key considerations for each area include:
- Adequacy of oversight and administrative support as activity scales.
- Adoption and optimization of new technologies to improve efficiency and risk mitigation.
- Ensuring proper training and standards in system hardening to avoid failures.
- Formal optimization of asset deployment (cameras, weather stations) for maximum impact.
- Resource allocation to balance between high-risk and non-high-risk areas.
- Leveraging industry collaboration and benchmarking best practices from peer utilities 2, 2, 1, 3.

The excerpts identify several financial and timeline risks and concerns discussed in this docket:

Financial Risks and Concerns:
- Grant funding for resilience initiatives and advanced technology requires increased tracking, reporting, and community engagement, which introduces additional oversight costs and complexity 1.
- There is debate over the proper cost recovery mechanism for NDPP-dedicated labor resources. Regulatory staff question whether it is appropriate to seek cost recovery for additional labor resources through plan amendments instead of including such costs in a general rate case (GRC). This creates uncertainty over when and how these costs can be recovered, and whether they are incremental or part of the normal course of business 2.
- The cost and allocation of pilot project expenses, such as the Aidash pilot (total $249,700, with $76,590 for non-tier areas), may need to be adjusted in budgets and recorded as incurred, indicating potential budgetary and accounting concerns 3.

Timeline Risks and Concerns:
- The extension of project windows (e.g., grid resilience initiatives extending beyond the standard NDPP timeframe to 60 months) could delay implementation and finalization of project scopes, approaches, and funding applications. The timeline for negotiations and project scope definition is uncertain 1.
- Amendments to the NDPP process and requirements for post-hearing legal briefings on cost recovery could prolong regulatory proceedings, leading to delays in decision-making and implementation 2.
- Integration challenges and vendor dissatisfaction (e.g., with the Firebird camera pilot) have affected the effectiveness and timeline for deploying wildfire detection technologies, requiring a change in vendor and system integration before additional deployment can proceed 3.

Overall, the key concerns involve cost recovery uncertainty, extended project timelines, increased oversight requirements, and delays stemming from technology integration and regulatory process debates.