01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the Study Scoping Process section (3).
No response submitted.
03: Please supply any comments related to the Load and Resource Zones section (4).
No response submitted.
04: Please supply any comments related to the Load and Resource Zones - Subregions Used for Determination of Monthly FSPRMs section (4.1).
No response submitted.
05: Please supply any comments related to the Load Modeling in the LOLE Study section (5).
The text in this section refers to "Table 3" however, the BPM shows "Table 1. Example Historical Weather Stations". Is this just an error, Table 3 vs. Table 1?
Is it correct to assume the NW region has four primary weather stations, and 4 back-up stations, while the SW has just 5 primary stations?
PNM’s concern is the 5 locations are an average of 690 miles away from our major load pocket. Comparing Albuquerque’s Average high and low (www.usclimatedata.com) to a cumulated average of the 5 SW weather stations during binding months equates to:
- Winter High +2.55 degrees
- Winter Low +1 degree
- Summer High -1.5 degrees
- Summer Low +3.1 degrees
Should any one of the 5 SW Stations have a data quality issue these averages could be skewed wildly. As an example, Albuquerque load compared to both Scottsdale and Casper individually saw consistent double-digit variances across most months.
06: Please supply any comments related to the Generator Modeling in the LOLE Study section (6).
6.4 Solar Resources
PNM has similar concerns as stated in load modeling. The difference between our major load pocket and the 5 identified SW weather stations.
07: Please supply any comments related to the Generator Modeling in the LOLE Study - Thermal Generator Modeling section (6.1).
No response submitted.
08: Please supply any comments related to the Generator Modeling in the LOLE Study - Storage Hydro Qualifying Resources section (6.2).
No response submitted.
09: Please supply any comments related to the Generator Modeling in the LOLE Study - Wind Resources section (6.3).
No response submitted.
10: Please supply any comments related to the Generator Modeling in the LOLE Study - Solar Resources section (6.4).
No response submitted.
11: Please supply any comments related to the Generator Modeling in the LOLE Study - Energy Storage Resources section (6.5).
No response submitted.
12: Please supply any comments related to the Generator Modeling in the LOLE Study - Run of River Qualifying Resources section (6.6).
No response submitted.
13: Please supply any comments related to the Generator Modeling in the LOLE Study - Demand Response Programs section (6.7).
No response submitted.
14: Please supply any comments related to the Generator Modeling in the LOLE Study - Behind-the-Meter Generation section (6.8).
No response submitted.
15: Please supply any comments related to the Generator Modeling in the LOLE Study - External Capacity Modeling section (6.9).
No response submitted.
16: Please supply any comments related to the Generator Modeling in the LOLE Study - Contingency Reserves Modeling section (6.10).
No response submitted.
17: Please supply any comments to the LOLE Study section (7).
No response submitted.
18: Please supply any comments to the FSPRMs Calculations section (8).
No response submitted.
General Comment
PNM appreciates the opportunity to comment on BPM 102.