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The Commonwealth of Massachusetts Fase of Repreataioes Hate House, Boston C2188. 1054 December 2, 2011 ‘Ann Berwick, Chair “Massachusets Department of Pubic Utilities (One South Station Boston, MA 02110 Re: DPLU.11-119, Public Comment Regarding Uilty Response to October 29, 2011 Snow Stomm Dear Chairwoman Berwick: ‘We write in reaction to public utilities’ repeatedly inadequate emergency preparedness and insuiient storm response, as exhibited by the sustained electric servve losses that impacted more ‘than 1 millon residents following Tropical Storm Irene and over 800,000 residents afer the October 29, 2011 Nor easter. “These extended power outages not only created a signifeant sk o public safety but als inficd sufstantal nancial loss oa residents and businesses inthe Caramel. While we recognize that both Tropical Storm Irene and the October soowsiorm cased signifieant damage tiles” inasuctre within the sor period of two months, in some circumstances, we believe the damage could have been prevented by adequate routine maintenance and mitigated by ample preston prepared. Additionally, public utes, particularly National Grid, have repeatedly filed 10 communicate ‘effectively with customers and government officials reading estimated times of restoration (ETR). ‘National Grid attempted to improve communications after Irene by appointing community nisons; however, efforts ding the Oetober snowstorm were sil ar fram exemplary {tis imperative that public utliies are held accountable for reliable eletric service, particularly as they possess the technological capabilities to minimize extended power losses. Following Tropical Storm Irene, NSTAR restored service 10 97% ofthe 500,000 Massachusetts customers within 3 days, ‘while National Grid lft customers in the dazk for more than a week during both Irene and the October storm. Generally, we believe the length and numberof these outages were exacerbated by poor routine ‘aintenance, inappropriate pre-sorm preparations en inadequate technology. Although National Grid purports an annual expenditure of $23M for vegetation management as ‘evidence of appropriate regular maintenance, this does not prove that ratepayer dollars used for tree= ‘timming ae being spent wisely or well. In fact, even cursory observations reveal that tree branches faze encroaching and often growing between power lines, endangering the public during heavy snowfalls and strong winds. Tree maintenance adjacent to utilities" power Tins is essential for ‘ensuring publi safety, as wel as reliable inastructure and service and thus, should bea priority. In addton to infasructure maintenance, public utes needs to implement bette preparations in ncipaton of leve! 5 eatastrophic events with high regional impact. For example, National Grid fled o pln forthe forecasted sepona impacts of Tropical Stor ee and the October Nor east As a result he uty was ewie found without an adequate number of owvoPstae crews when ‘rally all Nrtheastem erews were commited to restoring regional damage. We understand that National Grid waited until ae the sion and the inital damage assessment was completed which sccording to President Marey Reed takes between 48-72 hours—before enlisting the resources om Sites outside of the Nonheast. Prior to forecasted extraordinary regional eves, all tities need to ensure contractors and other utes across North America are alteady prepared to assist with immediate damage mitigation and service restoration. And while National Grid's use of community linsons during the October Nov'caster was definitely an improvement over the disorganization displayed following Tropical Storm Irene, utes’ repeated simigele to convey information ina timely manner to both municipalities and customers highlights the need for improved alternative methods for post-storm information exchange. Ms. Reed articulated in her storm response leter that communication is hindered by the electric infrastructures lack of sophistication and the subsequent inability of National Gri to determine te extent of system damage without customer reporting. Furthermore, she explained that predicting the estimated times of restoration (ETRs) “is more an art han a science.” In the 21% century, an age of advanced technology and instant communication, this is both surprising and concerning. Petheps we must require National Grid and its counterputs to invest in the technology required to take precise intemal readings of system-wide damage. The widespread impact of these two level 5 storms, ‘coupled with the forecasted dramatically changing weather pattems, highlight the need for rapid «development of smart meter technology that would filial quicker post-storm darnage assessments. ‘The DPU should encourage and assist withthe implementation of these advancements and strive to move past the pilot phase of smart meter integration Aaditionally, we recommend the DPU consider requiring ulities to have a centralized database for ‘ffcient realtime communication between a uty company and the municipalities it serves. This will enable municipal oficas to track reparied system damage, outage, safety hazards, and TR ilies should ensure that these company databases are acoesible 10 mobile erevs as well ax ‘municipal officials, even when electric and cell service has ceased. This innovation would diminish the lag time in communications between municipalities, work crews, and restoration management teams, allowing all stakeholders to have immediate access to information as it becomes availabe. Further, public utilities need to broaden the avaiable lines of communication between customers and ‘custome support, from updating central websites tobe smart phone friendly, oemplaying more radio and satelite communication in areas where cel service is dawn during catastrophic storms, ‘Thank you for investigating the causes behind the extensive electc service outages that let over 300,000 public utility customers in the dark twice within two months, ‘The customers and ‘municipalities served by public utlites like National Grid deserve an explanation forthe sustained safety risks and financial losses resulting from these lengthy power outages. 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