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Second Request for Documents and Answers to BWL 26Feb14

Second Request for Documents and Answers to BWL 26Feb14

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Second Request for Documents and Answers to BWL 26Feb14
Second Request for Documents and Answers to BWL 26Feb14

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Published by: LansingStateJournal on Mar 04, 2014
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06/22/2015

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CRT Second Request for Documents and Answers to BWL.

Please note that the requests below includes our original request, the BWL responses are bolded and in blue ink, and the CRT Second Requests are bolded and in black ink. Preparedness, Plans and Reports 1. The Community Review Team has copies of the following plans: The Lansing Board of Water & Light Emergency Action Plan dated October 28, 2013 http://www.lbwl.com/uploadedFiles/MainSite/Content/Home/BWL_Em ergency_Action_Plan.pdf The Lansing Board of Water & Light Emergency Procedures Manual http://www.lbwl.com/uploadedFiles/MainSite/Content/Home/BWL_Em ergency_Procedures_Manual.pdf Please provide of all other operations plans, emergency operations plans, manuals, memoranda or other documents on emergency procedures, crisis communications plans, other than the above two documents, that were in effect at the time of the December 21 2013 ice storm. Please attach copies of all such plans, manuals or other such documents which have been drafted or revised since the December 2013 ice storm. Plans enclosed: • Lansing Board of Water and Light Transmission Operations Plan and Emergency Operations Plan (Transmission Operation Plan (TOP)). See Attachment 1-1..
Note: For security purposes, portions of the plans were redacted to protect information about the BWL ‘s system and customer information.

Lansing Board of Water and Light Emergency Operations Plan (EOP). See Attachment 1-2.
Note: For security purposes, portions of the plans were redacted to protect information about the BWL ‘s system and customer information.

Electric Transmission & Distribution Plan Restoration Procedures (Distribution Plan).

1

See Attachment 1-3.
Note: For security purposes, portions of the plans were redacted to protect information about the BWL ‘s system and customer information.

Supporting documentation is the Best Practices For Storm Responses on U.S. Distribution Systems. This document will provide a measure for the CRT to evaluate the BWL’s response to the ice storm. See Attachment 1-4. The attached “Draft Interim Crisis Communications Plan’ was developed after the December 2013 ice storm and provides a foundation upon which to develop and implement a final crisis communications plan expected by the end of March. This draft crisis plan has already provided guidance and changes in communications protocol, such as frequently alerting our customers to severe weather and the possibility of outages before a storm hits to the news media, social media and BWL website, emphasizing to customers to call the “877” outage line in the event of an outage, and making regular updates during an outage. See attachment 1-5. The attached “Government Contacts” list reflects public officials in the BWL electric service territory, and is now included in all news media email announcements. See attachment 1-6.

Second Request: a) The Transmission Operations Plan refers to Appendix B, LBWL Communications Plan. Please provide that Appendix, or explain in detail why it is privileged. The CRT now has the following plans: (1) Lansing Board of Water & Light Emergency Action Plan dated October 28, 2013 (website); (2) The Lansing Board of Water & Light Emergency Procedures Manual, but only the Order of Restoration Section (Document Request and website); (3) Lansing Board of Water and Light Transmission Operations Plan and Emergency Operations Plan (Transmission Operation Plan (TOP)(Att 1-1); (4) Lansing Board of Water and Light Emergency Operations Plan (EOP)(Att 1-2); and finally, 2

b)

(5) The Response to Question 2 below refers to a “Distribution Plan was used to restore the system.” BWL, by its previous response, has indicated that all of the above plans were “in effect” on 22 December 2013. (a) Which of the above plans, if any, was utilized by the BWL Staff between 22 December 2013 and 3 January 2014 ? For each plan in effect and in use, please indicate the following: (i) (ii) Who was the lead person for training on the plan, prior to 22 December 2013? Who was the lead BWL official for deployment and use of the plan on and after 22 December 2013? On what dates was each plan put into use and on what dates was each plan used between 22 December 2013 and 3 January 2014? For each plan, please indicate which directorates or section within BWL implemented and used or followed the plan on and after 22 December 2013 ?

(b)

(iii)

(iv)

2.

Please provide a detailed description on the technology and plans used by the BWL to ascertain the extent of an outage or interruption in service. a. What was the timeline for survey crews to assess the geographic area comprising the BWL customer base? Please provide a copy of the timeline. Technology used to ascertain outage information 1. Energy Management System (EMS/SCADA)

The EMS was used to monitor what circuits were opened and what was happening in our transmission and distribution system. We also use the EMS to open and close circuit breakers as needed during the switching/restoration process. 3

2.

Outage Management System (OMS),

The OMS system is used to receive outage calls, wire down reports, and any other trouble reported by customers. Initially, we used the OMS to track field reports for reported wires down. When the spotter crews would call in to report what was found, the operator would add notes describing where the wire down was located and what was needed to make repairs. Plan used to ascertain outage data 1. No transmission line outages occurred as a result of the December 2013 ice storm. The Distribution Plan was used to restore the system. As stated in the Best Practices for Storm Response on U.S. Utilities, The BWL Distribution Plan calls for the use of Spotter crews to assess the system damage. The Spotter crew reports were used to dispatch the crews. The best practices document was developed by consortium of North American utilities and General Electric known as Distribution Systems Testing Application, and Research (DSTAR). b. Please provide the outage estimates for each day from December 22, 2013 through January 3, 2014, specifying the daily customer outage levels and the cumulative number of customers restored. See attachment 2-B c. What is the method for allocating crews to outage areas once the extent of the outage has been determined? See page 1 of the Distribution Plan (Attachment 1-3). d. What system of prioritizing outage areas for restoration is used by BWL? Please provide a copy, IF contained in any manual or source other than the Emergency Procedures Manual, referenced above (see Item 1). See page 1 of the Distribution Plan (Attachment 1-3). e. Please provide maps of outage locations, by day, if available. Maps of outages not available by day.

4

f. Please quantify how BWL learned of outages (either in raw counts or percentages) between different methods like computerized monitoring, phone calls, utility patrols, city patrols, etc. 1. Actual Breaker trips observed in the EMS/SCADAactual customer counts on the breakers could be obtained via OMS (approx. 30%)

2.

Spotter Reports from the field indicating wires down — BESOC operators attempted to manually calculate customers out using OMS to get customer count on each transformer affected by the wire down and then totaling that number. (approx. 60%) Crews reporting work being done in the field-A crew working on an area may isolate a smaller area to get a larger number back sooner. Smaller outages would result from this, sometimes the crew could determine how many customers were still out, otherwise the BESOC operator would use the same method as above to determine customers remaining out. (approx. 1- 2%) Phone Call/Email/Facebook/SeeClickFix-Calls from BWL customer service, management, Commissioners, City Counsel, EOC, and customers reporting they are still out. These were calls that came in during the last days of the restoration. (approx. 8-9%)

3.

4.

Second Request: The Response to Question 2(a) above, in discussing the Outage Management System, references receipt of outage information from Spotter Crews. a) Please provide copies of all notes prepared by BESOC operators, based on information received through the OMS or other means, from Spotter Crews. Please provide all information or data received from customers’ “outage calls, wire down reports, and any other trouble” and explain how such customer information on outages was used by BWL.

b)

5

c)

Please provide copies of all Spotter Reports prepared by the spotters, whether digital or hard copy, between 21 December 2013 and 3 January 2014. Please provide copies of whatever reports were created by the EMS/SCADA of breaker trips referenced in Respo0nse #2.f-1 above or otherwise created by the Outage Management System. Please explain the relationship between the EMS and the OMS, that is, how the systems are designed to assure they work complementary to each other. Please provide all contractual documents relating to the purchase and integration of the OMS system, including between the BWL and GE and any other companies or contractors who worked on the system implementation or integration. Attachment 2-b contains a compilation described as “Circuit Restorations Schedule”. i. ii. Indicate by whom and when this “Circuit Restorations Schedule” was created. Please provide a BWL Customer Map or other map or document clearly demarking the location, including by nearest street address, of all the circuits listed in the “Circuit Restorations Schedule”.

d)

e)

f)

g)

h)

Response 2-f provides percentages for the mechanisms of reporting outages. Please provide a raw count for each of the four categories contained therein. Please provide the raw count of outage reports received in Response 2-f(4) between Phone Call, Email, Facebook, and SeeClickFix. Please provide the raw count of outages responses received by telephone or email from each of the following sources: management, Commissioners, City Council, EOC, and BWL customers.

3.

How did the BWL receive notification of live downed wires? a. Please provide copies of all logs of communications on downed wires, live or unknown, including calls from 911 Operations Desks, the public, and any other source. 6

1. 2.

Downed wire reports came in through OMS — See Attachment 2-B. Phone calls to BESOC from 911, public, customer service, etc. were taken by the dispatchers and dispatched to a cut and run crew via BWL radio (sparking, arching, burning),

b. What method was used by BWL to track response to reports of live, downed wires? 1. Field reports identifying wires down were taken via BWL radio by the second operator (who was dispatching the spotter crews).

2.

This operator would add notes to the wire down order in OMS describing what was found and what needed to be done. The operator would assign a “digger” or other abnormal crew type to the order as a way of tracking which wire down calls had already been worked. Realizing we could not use the OMS to make the conductor cuts, we began the manual process of marking the identified wire downs on the circuit prints. From this point on, the OMS was no longer being updated as the operators had put a manual process in place. When we started assigning spotters directly with crews, the spotters patrolled the circuits ahead of the crew to locate any other wires down. As the crew worked on the identified wires down. The crews; working with the spotters, would address each of the wires down as they made their way through the circuit. After the restoration was completed (1-1-14), we started using OMS again to dispatch wires down.

3.

4.

5.

4.

Is BWL required to submit an Electric Disturbance Events (OE-417) Report to the U.S. Department of Energy? If BWL has done so, please attach a copy.

7

1.

The BWL’s Transmission Plan covers the circumstances that require the submittal of the DOE OE-417 report (See Appendix H in Attachment 1-2). The Transmission Plan atso, states what events require reporting the North American Reliability Council (NERC). No event during the December 2013 ice storm required the submittal of the OE-417 Report or a NERC notification. a. b. Loss of BWL customers did not exceed 50,000. Load lost from storm damage did not exceed 200 MWs.

2.

3.

Second Request: BWL’s answer above references the following: “BWL’s Transmission Plan covers the circumstances that require the submittal of the DOE OE-417 report (See Appendix H in Attachment 1-2).” None of the Appendices to the Emergency Operations Plan were provided. Please provide them. 5. Please provide the number of downed wires each day and the number restored each day, by day, for the period from December 22, 2013 through January 3, 2014. We understand that new downed wires would cause this number to change somewhat each day, so please include the day that BWL learned of each downed wire. See Attachment 5-1. Second Request: 6. The Community Review Team has access to:
http://www.lbwl.com/uploadedFiles/MainSite/Content/Outage/Restoration_Process _Presentation.pdf.

To assure that we have complete information, please provide an organizational chart for all supervisory personnel at BWL. Please provide an organizational chart for all supervisory personnel tasked with response, recovery and restoration of power from the outages of December 21, 2013 through January 3, 2014. If there is not a distinct organizational chart for supervisory personnel during emergency operations, then please provide a 8

list of all supervisory personnel tasked with emergency operations, including name, title and position description. See Attachment 6-1. a. Please advise the days and hours of operation of the BWL Emergency Operations Center. 1. The BWL Electric Operations Center (aka. BESOC) is staffed and is operational 24 hours per day, all days of the year.

b. Please provide the names, titles and position descriptions of all persons staffing the BWL Emergency Operations Center between December 21, 2013 and January 3, 2014. 1. 2. 3. 4. Dave Bolan — Director, Electric T&D Lynn McKinstry—Manager, Electric System Operations Brian Sebolt—Supervisor, Electric System Operations Transmission and Distribution Supervisors (a.k.a Dispatcher) a. b. c. d. e. 5. 6. 7. 8. Paul Lange Martin Pennington Shane Butler Shawn McBryde Jay Dudley

Elizabeth Hernandez — Analyst, Electric System Integrity Sue Heiler—Field Services Support Pat Terry — Field Services Support Christine Obert—Field Services Support

9

c. The emergency procedures manual refers to a daily critique meeting at 6oopm each day. Please provide copies of the minutes or notes from each of those meetings. For the duration of the restoration process, beginning on December 22nd through January 4th meetings (conference calls) were held at 0700, 1300, and 1900 daily. The purpose of each meeting was to ensure that each Department was communicating their efforts with other Departments involved in the restoration process with the overall goal of having an efficient coordinated effort of restoring our customers’ services as quickly as possible. Each meeting followed the agenda below.
• • • • • • • • • • • •

Safety Reminder Number of Customer outages Outage restoration time update Wire downs restoration update

Storm Assessment Information Crewing requirements Spotter requirements Material and equipment issues Supplemental Resources Contractor or outside electrician issues Mutual Assistance requests Maintenance orders from storm work (Work manaqement • Next Day work assignments/schedule Note: Minutes/notes were not taken during the meetings.

Each meeting was represented by the following Departments System integrity Primary Metering/Electric Test Group Electricians/Spotters Primary Metering/Electric Test Group Engineering • System Operations (Operations Center) Tree Trimming

10

• • • •

Electric Transmission and Distribution Traffic Construction Services Purchasing/Warehouse Customer Service Safety Records Management Communications

Second Request: a) Was it the practice of BWL to issue an internal Emergency Response Call list each week? If so, did it include a list of upper management/executives that were available for that week? What is the highest level of upper management chain of command included in that list? Response above states that BWL held conference calls, three times daily, for the duration of the restoration process, but that no minutes or notes were taken during the meetings.

b)

1.

For each of the following individuals, please provide any notes, handwritten, digital or other format, any emails generated, and any work orders, other orders or directions issued, relating to the outage restoration process, between 20 December 2013 and 3 January, 2014: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. Dave Bolan Lynn McKinstry Brian Sebolt Paul Lange Martin Pennington Shane Butler Shawn McBryde Jay Dudley Elizabeth Hernandez Sue Heiler Pat Terry 11

12.

Christine Obert

2.

For each of the following subject areas, please provide ALL documents generated, and indicate the date created and the author: • • • • • • • • • • • • Number of Customer outages Outage restoration time update Wire downs restoration update Storm Assessment Information Crewing requirements Spotter requirements Material and equipment issues Supplemental Resources Contractor or outside electrician issues Mutual Assistance requests Maintenance orders from storm work (Work management) Next Day work assignments/schedule

Media and public communication 7. Please provide copes of the BWL reports to the media each day on the outage levels and the time estimates by which BWL expected to have power restored. See attachment 7-2. Also, describe the extent to which social media and the BWL website were used to notify or advise customers, including frequency of updates, and the personnel responsible for updating the website, or social media. Please include: 12

During the December ice storm outage, 36 outage news updates were sent from 6 am, Sunday, Dec. 22, 2013, through 10 a.m. Wednesday, Jan. 1, 2014, an average o three per day. These outage news updates, designed to communicate to BWL customers and the public at large, were sent from a range of eay morning, mid-day, late afternoon and late evening. The outage news updates were sent and posted simultaneously to: • • • • • Lansing news media (and later to statewide and national media outlets) via email BWL Website Social Media-BWL Facebook and Twitter sites, and SeeClickFix Lansing governmental officials BWL employee-wide and Board of Commissioners

In addition, hundreds of individual Facebook and SeeClickFix responses were posted, including private messaging, responding to comments and more than 200 Tweets. The outage news updates attempted to be responsive to customer concerns, providing the following information: • Outage number • Downed wire safety warning • Number of crews in the field • Intersection areas where line crews were working to repair circuits (plus next in line) • Known outage streets with appeal to customers not on the Street list to respond • Customer walk-in centers throughout the community • Mast repair customer responsibility and Meter Dept. extended hours for customer convenience The BWL made three restoration projections: • On December 23, we announced that a “substantial portion” of BWL customers would have power by the end of Christmas Day.” Result — 90% of outage service territory was restored. • Before the weekend of Dec. 28, we projected that fewer than 1,000 customers would be without power by the end of the weekend. And by Monday, Dec. 30, 1,100 remained without power Shortly thereafter, we projected full restoration of power by the stroke of midnight on New Year’s Eve night, Tuesday, Dec. 31. With the exception 13

approximately 10 customers connected to a pole being repair, and hundreds of single service reconnections due to mast damage which were previously disclosed, at 10a.m. on New Year’s Day, Wednesday, Jan. 1, the BWL reported that power was restored to its electric service territory. Prior to the December ice storm outage, the BWL crisis communications culture was reactive rather than proactive. That now has changed to a more proactive crisis communications strategy, both in advance of severe weather hitting and during an outage crisis. Since ice storm outage restoration, we’ve had a number of severe winter weather events, and ve separate outage events ranging from 100 to 7,400 customer outages. In all of the severe weather events, we posted at least two days prior to the forecasted weather, warning customers about the impending storm and directing them to call the BWL 877 outage line if they lost power. We also continuously posted updates, cold weather safety tips, and City of Lansing updates. During the outages, we acknowledged the time the outage began, the number of outages, the cause of the outage, the geographic area of the outage that can be found on the outage map, projected time of restoration, full restoration all clear, and apologized for any customer inconvenience caused by the outage. These communications improvements have been noted on Facebook and Twitter with positive comments by our customers. The BWL has retained the local communications firm of Martin Waymire to help develop the draft interim crisis communications plan into a permanent plan by end of March based on an examination of best practices across the utility industry. Martin Waymire can also assist during emergencies if needed. We’ve also hired a social media specialist, a newly created position (start date Feb. 17). The social media specialist will help develop strategies on how to best communicate with our customers over all social media channels. a. the number and identity of media contacts which occurred, See attachment 7-1. b. the date and time of each media contact, 14

See attachment 7-2. c. and the names, titles and position descriptions of each individuals that served as spokespersons for BWL. General Manager J. Peter Lark and Communications Director Stephen Serkaian served as spokespersons for the BWL, They held daily news briefings in the field providing restoration updates, and responded to dozens of interview requests and information from local, state and national news media, including local talk radio interviews. (No contact logs were kept of these interviews.) Serkaian was assisted on updating social media sites, such as Facebook, Twitter and SeeClickFix, by Rebecca Rostar, Development & Account Review Specialist, and Maxwell Bollinger, Intern, Public Relations & Community Relations. A number of Information Technology staff members assisted in posting advisories to the BWL website. Second Request: a. b. Who decided to advise the public not to report outages, but only downed lines. (see email Outage Update of 12/23 at 400p)? Please provide any and all existing electronic communications from the following BWL executives from Dec. 1, 2013 to January 10, 2014, either (1) internally, (2) with BWL Commissioners, or (3) to any city or township official or representative in the BWL service area: a. J. Peter Lark, General Manager b. Susan Devon, Assistant General Manager c. Steve Serkaian, Communications Director d. Dave Bolan, Director of Operations e. Lynn McKinistry, Manager of Electrical Systems f. Mike Collins, Manager, Enterprise Risk Management

15

8.

Does the BWL have a defined outage reporting center or system? a. How many customer calls were received by the BWL each day between December 21, 2013 and January 3, 2014? See attachment 8-1. b. Are customer calls handled by an automated outage reporting system, or are they handled by personnel? Customer outage calls are handled by both; customers may contact the outage reporting system directly by dialing 877-295-5001 or by selecting the specific prompt for outage reporting when calling into our local line (517702-6006). Customers may also opt to speak with a customer service representative during normal business hours and report an outage. c. If handled by personnel, please advise of the number of personnel fully or partially tasked to received calls from customers for each day from December 21, 2013 through January 3, 2014? See attachment 8-2. d. If available, how many customer walk-ins to BWL offices took place during those dates? The amount of walk-in customers served was not tracked. e. How was the substance of those calls, ie, downed live wires, outage areas, etc., transmitted to emergency operations? All conditions mentioned were entered into the (Outage Management System).

9.

How were decisions on outage restoration priorities transmitted to the public? What methods were used to advise the public on the outage levels and projected restoration? Please describe all communication methods used to advise the public, besides the media, answered in Question #7 above. Communications provided to the media, as responded to in question #7 above, was posted on our website, Facebook and Twitter pages. In addition, information was provided to individual customers as available through the customer call center and the customer walk-in centers. 16

Resource Levels and Capabilities 10. Please provide the number of BWL and other Crews (split out) and the number of BWL and other personnel the BWL had working on restoration in the field each day until restoration was completed. That is, please provide the names and position description for each BWL employee and each utility worker gained by contract or mutual assistance working on power restoration or other outage issues from December 21 through January 3, 2014. a. For each employee, provide their daily work logs if available. See Attachments 10-1, 10-2, 10-3, 10-4, 10-5, 10-6, and 107. b. If no work logs are available, please detail the number of hours worked, the outage areas addressed by city or township and street number and the assignments completed. N/A Second Request: a) The documents provided are missing the lineman sheets for December 27, 28, 29, & 30. Please provide those sheets or explain their absence. The computerized sheets of the lineman timesheets attached at 10-5 are missing all even-numbered pages. Please provide the missing even-numbered pages. The individuals listed in the time sheet s are inconsistent with the list of BWL employees in 10-1. Please explain the discrepancy. The lineman time sheets provided do not add up to a 24 hour day. Please explain the discrepancy. The documents provided include total assistance costs for Traverse City at 10-6 and for Asplundh at 10-7. Please provide the total assistance costs for all public and private companies, under contract or mutual aid, and include the specific costs for each crew, including an hourly rate, per diem and a separate entry for overtime and for each vehicle or other equipment provided. 17

b)

c)

d) e)

f)

What was the total workforce of BWL, as of 22 December 2013? How many employees were on vacation or leave between 23 -27 December, 2013? What process or policy was in place to recall then during an emergency or major outage? How many employees were recalled from vacation or leave from 23-27 December, 2013?

11.

What mutual aid agreements did BWL have in place as of 21 December 2013? See Attachments 11-1 and 11-2. a. What mutual aid agreements are in place as of today’s date? See Attachments 11-1, 11-2, 11-3, and 11-4. b. Please list the utilities and companies with which agreements have been entered for both prior to and after 21 December 2013 and attach copies of the mutual aid agreements. c. For all mutual aid agreements in effect either now or as of December 21, 2013, please provide a copy of the agreement. See Attachments 11-1, 11-2, 11-3, and 11-4. d. If any mutual aid agreements were in effect in December 2013 that are not now in effect, please list those as well. N/A e. Please provide a copy of any document that expressly identifies when requests for mutual aid are to be sent out (e.g., if at any point it appears that service won't be restored within 48 hours)? See Attachment 1-3 (Distribution Plan- See Page 1).

12.

From what utilities or other companies were the outside personnel requested? a. From what utilities or companies were the outside personnel received? See Attachment 10-1 and 12-A b. Who (name, title and position description) made the decision to call for outside personnel? 18

Pat Hanes, Manager of Transmission and Distribution c. When (all instances) were the personnel requested? See attachment 10-1. d. What was the response time, for each request? Approximately with in a day of the request crews were able to respond. Second Request: The chart found at 12-1 in the BWL Answers & Attachments is inconsistent with the chart at 10-1. a) The BWL compilation at 12-1 indicates that Mutual Aid crews arrived on 12/23. The Chart on 10-1 indicates that the Mutual Aid crews first arrived on 12/22. Please explain the inconsistency. The compilation of all mutual aid agreements totals 47 agreements between BWL and other companies, including the Michigan Municipal Electric Association Agreement, Consumers and the FEMA Mutual Aid agreement. Chart 12-1 provides that 21 companies were contacted to seek mutual aid. Please explain in detail why the other 26 companies were not contacted. c) Chart 12-1 refers to “all other Thumb Area utilities.” Please provide the names and contact person for every Thumb Area utility who was contacted but declined on 27 December. Charts 12-1 and 10-1 provide that Hydeker-Wheatlake had a 3-man crew respond on 12/22 or 12/23 and then 18 crewmembers on 12/29. There is no contract provided between Hydeker-Wheatlake and the BWL until 10 January. Was the delay in Hydeker providing the 18 additional crew members the need for BWL to conduct an RFP process or to otherwise negotiate a contract? Please explain. Please explain the delay in crews arriving for not just Hydeker, but also from Asplundh and Kent Power.

b)

d)

e)

19

f)

Has the BWL developed a form or template contingency contract for private contractors as needed to support an outage response? Does it have policies implemented for contracting with private contractors in the event of major outages? If so, when were they developed? Were they used during then outage from 22 December to 3 January 2014? Action Item # 16 of the BWL Outage Report refers to new Mutual Aid Agreements. Please provide copies of the Mutual Aid Agreements the BWL has with: a. b. American Power Association FEMA

g)

13.

What were the methods of communication between BWL and the city and state governments? 1. BWL’s Manager, Electric System Operations participated in the City of Lansing EOC conference calls several times daily. A member of the EOC contacted the BWL to advise they were holding several calls per day (0800, 1400, and at 2000).

Please provide copies of all communications between BWL staff or leadership and the city of Lansing, other customer cities and the state of Michigan that addressed any of the following: a. b. c. d. e. the number of customers without power, steps being taken to address the outage, estimates of power restoration, any concerns for or discussions of customer health and safety, and please provide a detailed list of all measures taken to ascertain the location of all senior citizens and residents with medical needs or devices requiring electrical power.

There were no minutes taken during these meetings, updates were given during each calls. The information varied depending on the how the conversation went each time. Basic information that was consistently discussed:

Estimated number of customers out 20

Wires down for the first few days, as numbers grew we stopped counting exact numbers as they were very large Number of crews working Areas we were working in Approximate number of customers to be restored that day Updates on restorations for critical customers After a few days into the storm, locations that were out were added so EOC could arrange for wellness checks After a few days into the storm we were also giving the EOC streets that were out within the city I do not recall the exact day that calls started coming in from Delta Twp., but it was somewhere around Jan 1st. Lynn McKinstry took several calls in the late morning requesting areas in Delta Twp that were still without power. Those locations were given as requested. See attachment 13-1. Also, see 36 outage news updates sent to City of Lansing officials provided in attachment 7-2. Second Request: a) Who made, and when was the decision made, to advise the public not to report outages, but only downed lines. See Attachment 13-1, email of Steve Serkaian to Carole Wood, of Monday December 23, referencing information posted on SeeClickFix, “The Board of Water and Light is aware of its outage areas. Please do not call to report a power outage…” Do the emails provided at Attachments 7-2 and 13-1 equal all the emails sent to City or Township officials, the public, the media or to BWL customers from 12/22 through 1/3/14 ? If not, please provide all other emails from BWL.

b)

c)

21

Recovery and Mitigation 14. Has BWL compared their expected restoration and response capabilities with other, previous outages? a. Has BWL compared their expected restoration and response capabilities with other publicly owned utilities experiencing similar ice storms or other naturally-caused outages? The BWL has not compared its expected restoration and response capabilities exclusively with other publicly owned utilities experiencing similar ice storms or naturally occurring events. The impact of severe and damaging storms depend on an electric utility’s transmission and distribution typology, construction and maintenance practices, service territory geography, type of storm, the weather following the storm, and other factors. As a result, the storm impacts tend to be unique, which makes it difficult to compare one utility’s response capability with another utility’s. However, some ice storms have similar characteristics. Ice storms result in a large number of individual outages because falling branches and trees take down individual services, secondary distribution lines, single and three phase primary lines, and can even damage high voltage transmission lines. These storms typically occur during the year when daylight hours are at a minimum and temperatures are below freezing, so crews must protect themselves from exposure. They may be accompanied by snow storms that further hinder restoration efforts. Trees and branches weakened by the storm continue to break days after the storm has passed, sometimes damaging the same circuit multiple times during the restoration. The Michigan Public Service Commission defines a catastrophic storm as one that results in 10% or more of a utility’s customers losing service or for which a unit of government has declared a state of emergency. Using the percentage of customers losing service as a metric of storm damage, the BWL has compiled a list of other utilities that have experience severe ice or winter storms with an impact similar to the ice storms impact on the BWL.

22

Company/State

Customer Outages (%) 39 29 65 51 61 60 30 10 65 40

Restoration Days 10 9 14 10 14 11 10 10 11 10

JCPL/New Jersey PSEG/New Jersey PSNH/New Hampshire UnitiI/New Hampshire NHEc/New Hampshire NatonaIGrd/NewHampshire Kentucky Utilities/Kentucky Kentucky Power/Kentucky CL&P/Connecticut Toronto/Ontario

This list is not exhaustive, but merely indicative of utility restoration response times and response capabilities. b. Has BWL compared their expected restoration and response capabilities with other Michigan utilities experiencing similar ice storms or other naturally-caused outages? Not directly. However, the BWL calculates the same distribution reliability indices on the same basis as those required to be filed by other Michigan regulated (investor owned) utilities. These calculations include the impact of major storm events. The three indices used are: System Average Interruption Duration Index (SAIDI), which measures the average outage duration for all customers of a utility. Customer Average Interruption Duration Index (CNDI), which measures the average outage duration for those customers who experience an outage. System Average Interruption Frequency Index (SAIFI), which measures the average number of interruptions for each utility customer. A history of the BWL’s, Consumers Energy’s, and the DTE Energy’s performance is shown in attachment 14B.

23

c. For any of the above which were answered in the affirmative, please attach copies of the reports, studies, or papers which contain the comparisons. There are no specific reports, studies or papers which contain the comparisons shown in 14. b, and c. 15. Please provide a copy of the report of the results of the BWL internal review and recommendations. Please describe all additional steps, besides any described in the report of the internal review, that BWL has taken to internally evaluate their operations in planning, response and recovery from the outages of December 22, 2013 through January 3, 2014. The internal storm response report will be made available when completed and ready for release. There are no other reports or internal evaluations available at this time regarding the BWL’s planning, response, and recovery from the storm outages. 16. Please describe all measures in mitigation which BWL has determined are necessary to lessen the likelihood, magnitude, or consequences of another outage of similar length and severity as occurred from December 21, 2013 through January 3, 2014. Measures designed to improve the BWL’s storm response and lessen the likelihood, magnitude, or consequences of another outage similar in length and severity to the ice storm will be included in the internal report. 17. For each of the last three years, please provide all metrics available (e.g., hours spent, number of trees trimmed) for the amount of preventive maintenance work done on lines. a. Using the same metrics, what does BWL forecast for preventive maintenance work in 2014 and 2015? 1. 2. Calendar Year 2014 $3.2 Million anticipated for preventative maintenance. Calendar Year 2015 $3.35 Million budgeted for preventative maintenance.

b. What other projects are planned or under consideration in 2014 and 2015 to increase reliability?

24

1.

Modifications to the LBWL tree trimming standards to eliminate the current overhang trimming practice. Analysis being performed on the current three year trimming cycle to assess increased trimming schedules.

2.

c. What was the cost of these preventative and tree trimming measures over the last 3 years? See Attachment 17-C. Second Request: In Response #17(b), BWL advises that its tree-trimming schedule is now on a three year cycle, as it states that "Analysis being performed on the current three year trimming cycle to assess increased trimming schedules." (emphasis added). No previous BWL statements, however, provide for a three year cycle, but instead state that BWL was utilizing either a five or seven year tree-trimming cycle: BWL December 2013 Ice Storm Outage report, dtd February 18, 2014, Executive Summary, Action Item #7, p.8: “The BWL will strictly adhere to a 5 year trimming cycle…” LBWL Website: "We strive to complete a vegetation maintenance cycle for all communities in our service area every five years in order to provide clearance for power lines." http://www.lbwl.com/vegetation.aspx Accessed 18 February 2014 LBWL "Why Manage Vegetation" Brochure: "The BWL strives to complete routine vegetation maintenance for its entire system of power lines every five years." http://www.lbwl.com/uploadedFiles/MainSite/Content/Community_ Impact/Vegetation/TreeTrimBrochure.pdf Accessed 18 February 2014 LBWL Vegetation Management Practice: "The LBWL strives to maintain approximately a 5-7 year vegetation management I maintenance program cycle" http://www.lbwl.com/uploadedFiles/MainSite/Content/Community_ Impact/Vegetation/Policy.pdf Accessed 18 February 2014

25

LBWL T&D Restoration Process Slides, dtd January 15, 2014, slide 4: "We are currently in year 3 of a 7 year trimming cycle." http://www.lbwl.com/uploadedFiles/MainSite/Content/Outage/Resto ration_Process_Presentation.pdf Accessed 18 February 2014 Minutes of the March 25, 2008 Board of Commissioners Meeting: “Update on Tree Trimming. J. Peter Lark, General Manager reported that the Board of Water and Light (BWL) is doing a good job with tree trimming and is at the end of its 5-year cycle." http://www.lbwl.com/uploadedFiles/MainSite/Content/About_the_B WL/BWL_Governance/Minutes_and_Agendas/Minutes/08Mar25min.pdf Accessed 18 February 2014 Please identify the following: 1) 2) 3) 4) 5) 6)
Please specify the length of the tree trimming cycle used f0r each year from 2008 to 2013.

7)

8)

9)

What is the tree trimming cycle to be utilized in 2014? If a decision was reached to shorten the cycle to three years, when was the decision reached to alter the tree trimming cycle from seven or five years, to three years? What factors were assessed to reach the decision to alter the tree trimming cycle from seven or five years, to three years? Who made the decision to alter the tree trimming cycle from seven or five years, to three years? What guides or studies on industry best practices were instrumental in the decision to alter the tree trimming cycle from seven or five years, to three years? Please provide either URL links or hard copies of all guides or studies on industry best practices used, relied upon or referenced by BWL on determination of the appropriate tree trimming cycle. What guides or studies on industry best practices were instrumental in the decision to forego the trimming of trees or branches located above distribution or other lines prior to 18 February 2014? Please provide either URL links or hard copies of all guides or studies on industry best practices used, relied upon or referenced by BWL on determination of the appropriate extent of tree trimming around distribution and other lines. Is the decision to triple the budget for tree-trimming (Response #17-a above) a decision which must be approved by the Board of Commissioners for the BWL? If so, has it been approved? Action item # 8 indicates that contractors will be rewarded based on “past performance” with a larger 26

10) 11) 12)

percentage of the tree-trimming contract. What records of private contractors past performance exist? Please provide them. Has the BWL decided to post an RFP on its tree-trimming contract ? If so, when will that be done? Has the BWL developed a plan for communicating the scope of its 2014 tree-trimming plan to its consumers? Action Item #8, refers to increasing the number of treetrimming crews “temporarily.” What period of time is intended by this statement? Response #17-c indicates a tree—trimming budget of $2,199,242.00 for 1013. Page 29 of the BWL’s February 18th Outage Report indicates a jump of almost one million dollars spent on tree trimming services between 2012 and 2013. Does this increase over 2012 include tree trimming or removal required as part of the 22December, 2013 – 3 January restoration effort?

18.

Is there any repair or restoration from the storm still left to be done, for example, temporary repairs with a permanent repair to be done later?

See Attachment 18-1 (Outstanding storm related repairs as of Feb. 1, 2014. New Requests: 1. For the Agreement between the Board and the IBEW (Agreement), previously provided electronically, dated 1 November 2012, please provide the following explanations: a. The Agreement does not specifically provide a rule that all primary lines be serviced by 3 man crews. See Art 11, Section 9, of the Agreement. Please provide the safety procedure or rule which contains this requirement, expressly including the means by which it became integrated into the Agreement. b. Please provide all safety procedures “published” post -Agreement of 1 November 2012, as a result of the process by the Advisory Safety Committee, as set forth at Art 11, Sec 9, in the Agreement. c. Is there any other reference to the size of a crew other than Art 11, sec 9 of the Agreement (such as in a BWL Safety Manual)? If so, please provide and explain the process by

27

which it became integrated into the Agreement. 2. The CRT has the transcripts of the three public hearings held by BWL on January 15-17, 2014. Please provide the transcripts of Board discussion, staff reports and public comments from the January 6, 2014, and February 18, 2014, BWL Board of Commissioners meetings. Please provide the following documents: a. BWL Policy on classification of plans and other documents b. BWL Policy on Data Retention The CRT has access to the Lansing City Charter available on the City of Lansing website at http://www.lansingmi.gov/media/view/Lansing_City_Ch arter/5906. a. Please provide the rules of procedure required by the Charter in section 5-105.2. b. Please identify, list, and attach all other governing documents for the BWL. c. Please provide the following additional documents: i. ii. BWL Board Bylaws and Governance Structure Franchise agreements between BWL and all municipalities other than city of Lansing Distribution of electrical load by municipality, including, but not limited to: • • % of peak loadsize of distribution network “How much electricity is distributed where”

3.

4.

iii.

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