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WMECO Reply 7-17-12 Final

WMECO Reply 7-17-12 Final

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Published by: masslive on Jul 20, 2012
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COMMONWEALTH OF MASSACHUSETTSBEFORE THEDEPARTMENT OF PUBLIC UTILITIES
 ________________________________________________ )Investigation of the Department of Public Utilities on its)own motion into the preparation and response of )D.P.U. 11-119-CWestern Massachusetts Electric Company to an October)29
th
, 2011 snowstorm.) ________________________________________________)
REPLY BRIEF OFWESTERN MASSACHUSETTS ELECTRIC COMPANY
Donald H. Wells, Jr., Esq.Western Massachusetts ElectricCompany100 Summer Street, 23
rd
Floor Boston, MA 02110617-345-1366July 17, 2012
 
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COMMONWEALTH OF MASSACHUSETTSBEFORE THEDEPARTMENT OF PUBLIC UTILITIES
 ________________________________________________ )Investigation of the Department of Public Utilities on its)own motion into the preparation and response of )D.P.U. 11-119-CWestern Massachusetts Electric Company to an October)29
th
, 2011 snowstorm.) ________________________________________________)
REPLYBRIEF OFWESTERN MASSACHUSETTS ELECTRIC COMPANYI.INTRODUCTION
OnJuly 10, 2012, the Office of the Attorney General (“Attorney General”),Department of Energy Resources (“DOER”), and the International Brotherhood of ElectricWorkers Local 455 (“IBEW” orthe “Union”) filed their respective reply briefs with theDepartment. Pursuant to the procedural schedule, Western Massachusetts Electric Company(“WMECO” or the “Company”) files this reply brief.The Attorney General described the October 29 snowstormas a catastrophic eventthat“simultaneously affect[ed] WMECO’s affiliates, other utilities across the state, as well asthose across a region.” Exh. AG-MDC/PJL-1, p.9. In the face of this catastrophe, the menand women of WMECO jumped into action, working diligently and with purpose to safely,efficiently and quickly restore essential services to its customers inwestern Massachusetts.Regardless of the outcome ofthis case, those who responded and left theirownhomes andfamilies in order to fight the devastation caused by the forces of naturemust be lauded andcongratulated for their devotion to duty and service to the public.When regional catastrophic storms occur, it takes time to put back what Mother  Nature has cast asunder. Recent events in the mid-Atlantic states once again demonstrate that
 
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when devastating storms occur, it takes time and patience to fix the damage. In the face ofaregional catastrophe, WMECO and its crews and support personnel swiftlyand safely restored power to its customers. Although WMECO has learned many lessons from this storm, penalties are neither called for nor necessary, and would merely tarnish the diligent effortsthat the Company’s men and women dedicated to serve the public.For thereasons stated below, which supplement the reasons containedin theCompany’s initial brief, the evidenceshowsthat WMECO prepared for,and responded to,thelargest storm in its history (the “October Snowstorm”) consistent withboththe Company’sEmergency Response Plan(“ERP”)and with utility practicethat resulted inan effectiveservice restoration. The penalties urged by the Attorney Generalare inappropriate andunnecessary, and arebased on alleged ERP violations that are withoutmerit and must bedeniedunder the applicable legal standard.In this reply brief, the Company focuses on the arguments set forth by the AttorneyGeneral, DOER, and IBEW in their respective reply briefs. Silence as to any particular matter or point doesnot constitute agreement.
II.ARGUMENTA.
Each of the Attorney General’s arguments for assessing monetary penaltiesagainst WMECO is unsupported and contradictedby the record evidence.The Attorney General seeks to justify her requested penaltiesagainst the Company based on three specific alleged ERP violations.Each of those argumentsis addressedin detail below. In addition, certain more general allegations in her reply brief also merit a response.The Attorney General takes the position that becausesome customersand officialsexpresseddissatisfaction (Attorney General reply brief, pp. 3, 6) and the restoration period lasted for “significant periods of time” (Attorney General reply brief, p. 13), either there must have been

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