Report on the Lansing Board of

Water and Light’s Response to the
December 2013 Ice Storm




May 5, 2014






Community Review Team


2
Table of Contents

Executive Summary……………..……..……………………………………………….Page 3

I. Introduction………………………………..…………………………………………..Page 9

II. Planning……………………………………………………………………………....Page 20

III. Response and Restoration……………………………………….…………….Page 42

IV. Recovery and Mitigation…………….………………………………….…......Page 53

Appendix A-CRT Members and Staff…….………..………………….………..Page 76

Appendix B-CRT Mission Statement……………………………….…………..Page 78

Appendix C-Community Concerns…………………………………..…………..Page 79

Appendix D-Materials Acquired from BWL……………………….…………Page 96

Appendix E-Transcript of March 10, 2014 Public Hearing…….……….Page 99

Appendix F-Reference Materials………………………….………………….….Page 141
3
Executive Summary
CRT Report on BWL Performance
May 5, 2014
I. The Community Review Team consisted of volunteers, selected by its Chair.
All are longstanding community leaders and Board of Water and Light (BWL)
customers. The mission of the Community Review Team (CRT) was to
conduct an independent, objective and transparent review of the BWL's
planning, preparation, response and recovery prior to, during and after this
devastating storm event. Our goal was to evaluate the strengths and
weaknesses of BWL's performance in order to enhance the BWL's capacity to
respond more effectively to their customer's needs and to recover more
quickly during future storm events. The CRT goal was to determine if the
BWL met industry best practices and, if not, to make recommendations to do
so.

II. The BWL is a municipal utility, owned by the people of the City of Lansing,
that provides electric utility services to residential, commercial and industrial
customers in Lansing, East Lansing, and the Townships of Delta and Windsor
in Eaton County and of Dewitt and Watertown, in Clinton County, and Delhi,
Meridian, Lansing, and Alaiedon
1
in Ingham County. Given adequate fuel
sources, the BWL can provide sufficient electric power for its customer base,
without the need to purchase power. In the Lansing area, BWL is responsible
for the provision, and for the protection, of water and energy, two of the three
most important sectors of critical infrastructure.

III. Planning and Preparation

a) BWL has not embraced the strategic contingency-planning mindset
necessary to assure the uninterrupted provision of these essential services.

b) The National Incident Management System is a recognized best practice
for all critical infrastructure owners, including publicly-owned electrical
utilities, but the BWL has not adopted the NIMS system.

c) BWL does not have a comprehensive Emergency Operations Plan, just an
Emergency Action Plan detailed for certain events. The BWL planning

1
Alaledon 1ownshlp and Lhe ClLy enLered lnLo a Þ.A. 423 AgreemenL ln 1998, coverlng Lhe land on whlch !ackson
naLlonal Llfe lnsurance ls slLuaLed.
4
efforts were disjointed. The EAP and other plans need to be replaced by a
more comprehensive plan that includes tools for better situational
awareness, and specific plans for response and recovery.

d) BWL does not have Emergency Manager. BWL did not have a distinct
Emergency Operations Center; during electric power outages of any
duration it continues to run operations from their BESOC.

e) There was a failure of communication between the City and the BWL and a
total lack of communication between the BWL and the other local
governments, representing the BWL customer service area. Assumptions
were made on the transfer of information, rather than the reliance on
established, tested lines of communication. The CRT discussions with city
and county emergency managers suggest that regional planning activity is
not organized and coordinated in advance of emergency events, but
instead, relies on the experience of the participants and their pre-existing
relationships.

f) Emergency Operations Plans must be coordinated before an emergency
event or incident, to provide time for training all personnel on the plan
and for exercising the plan.

g) BWL lacked a communications annex for an Emergency Operations Plan,
as well. BWL did not have available the information required due to the
failure of the OMS and the lack of capacity for customer calls. These
deficiencies substantially reduced their level of situational awareness and
lead to the transmission of information that did not meet the needs of
customers and to their inability to determine how they might best respond
to the circumstances.

h) BWL was neither communicating nor coordinating with the Lansing EOC
after December 24, 2013, and many of the other Emergency Operations
Centers were not open, which contributed to the confusion, lack of
accurate information, and uncertainty experienced by municipal leaders
and citizens.

i) The CRT believes that an integrated regional EOP is vitally needed. If a
regional EOP, which includes a regional EOC, was operating during the
recent event, it would have facilitated the coordination of services between
first responders and with other governmental leaders.




3
IV. Response and Restoration

a) The confluence of three policies, all under the BWL control, contributed to
the length of the outage: the failure to follow the BWL vegetation
management policy, the lack of trained damage assessors, or “spotters” to
immediately be deployed, and the non-availability of the Outage
Management System were significant causes of the length of the outage.

b) The identification and assessment of the location and cause of outages in
the primary distribution system was a substantial cause of the length of
time for restoration. There were an insufficient number of Spotters,
particularly “A” Spotters. The CRT must emphasize the importance of
having sufficient numbers of trained staff including spotters, repair and
central command sufficient to handle emergencies of this size.

c) BWL concedes that they did not have sufficient mutual aid agreements in
place, and has taken steps to address this deficiency.

d) BWL entered the winter storm season with an OMS system known to be
unreliable. The malfunctioning OMS was a critical but missing element in
the response and restoration. They discarded the previous system too
quickly. The system failed during the December outage and had no backup
system. They accepted assurances that OMS was fully operational without
fully testing the system. No back-up system or redundancy was apparently
even considered, much less implemented.

e) BWL had to discard the OMS by the second or third day of the outage, and
then compile damage assessments and prioritize restoration activities,
using an Excel spreadsheet.

f) If the OMS had been fully operational, then power restoration would have
been completed at least two days earlier, AND BWL could have more
accurately advised the public of areas for restoration and date of power
restoration for each circuit.

g) The CRT experience in obtaining records from the BWL was replete with
instances where records were not forthcoming. There are a variety of
reasons: (1) the BWL senior leadership does not preserve its emails,
pursuant to its record retention policy which requires disposal
immediately after use; (2) BWL adheres to a policy of non-distribution of
any records it deems “sensitive information”; and (3) since there is no
institutionalized system for communications during emergency events
with the municipal governments which represent its customer service
area, neither is there a protocol for preserving the records of those
communications.

6
V. Recovery and Mitigation
a) Vegetation management is essential to reducing storm-induced outages in
the secondary distribution system. The failure to follow their vegetation
management schedule was a key-contributing factor to the magnitude of
the downed lines.
b) BWL is implementing changes to their vegetation management policy,
including stricter adherence to the five-year schedule, auditing the
performance of its contracted tree-trimmers, and contracting with an
additional company.

c) BWL reliability is dependent upon the proper maintenance and
management of electrical distribution system. The BWL rate of
replacement is below the rate of replacement based on the expected life of
the components.

d) A significant portion of the live downed lines were service drops from the
distribution system to customer buildings or damage to distribution lines
as a result of service drops being pulled down. The use of service drops
that “unplug” from the distribution line when weighted down would
reduce the number of customer masts damaged or pulled down by
customer service lines. This solution should be evaluated immediately as it
would seem to be more cost-effective and operationally-sound than other
solutions, such as “owning” the customer service line through the meter
box.

e) The BWL should undertake a value engineering analysis of its entire
primary distribution system, with the intent to calculate the optimum
extent and topology of the primary distribution grid, and the optimum
design of each segment of its primary distribution grid. This analysis
should consider all aspects of distribution grid performance, but
particularly should include strong consideration of its effects on outage
extent and time to service restoration in major storm events.

f) Protection of the secondary distribution system requires more than just
vegetation management. Repairs to the secondary distribution system are
relatively easily and quickly done, once the faults are discovered and
localized. Discovery and localization can be difficult however. The BWL
currently depends on customers to notify them when the customer has lost
power.

g) The CRT believes that the greatest feasible acceleration of repairs to the
secondary distribution system will come from the installation of “smart
meters” that are able to signal the BWL when they lose power and when
power is restored, so that the Board will have an instantaneous and
comprehensive view of outages in its system.
7

h) BWL lacked a comprehensive system to identify all at-risk customers,
including those with medical needs and seniors, who may have greater
need for electrical power and a greater inability to re-locate or make
alternative arrangements during the outage.
i) The CRT believes that that the governmental leaders in the BWL customer
service area should create a Community Resilience Planning Coalition
which would take a broad approach to building community level resilience
to extreme events by participating in the drafting of a regional emergency
response plan, that would include community organizations’ input on
issues, promote strategies for engaging and organizing the community at
multiple levels and provide a platform for regional sharing of lessons
learned; connecting people, ideas, and resources; and engaging
policymakers and community members in an ongoing conversation about
resilience.
j) Include regional resiliency, including energy self-reliance, as a strategic
goal, and explore the potential for “islanding” to protect the local electrical
grid, with BWL taking the lead in creating an innovative, strategic
solution.
k) The BWL Board, although appointed in a manner similar to other City
boards, is not an advisory board. Rather, the City Charter granted the
Board “full and exclusive management” over essential services. The Board
needs to assert greater control over the short-term agenda, annual
objectives, current and emerging issues, and strategic direction of the
BWL.
l) The BWL Board has the authority to appoint a standing committee that
would be a liaison with local communities that hold franchises for services
from the BWL. We strongly believe that the Board Chair should appoint a
standing committee to be a Liaison Committee to Local Units of
Government who hold franchises or agreements for services from the
BWL.
m) The Board lacks the mechanisms to assure that they engage in structured,
ongoing and organized dialogue with the other municipal governments
which represent its customer base. This dialogue is vital, both for the
economic health and the security of the region. While a Local Government
Liaison can, and should, be instituted immediately, the long-term
assurance of the regional economic health as well as the health and safety
of its residents compels consideration of the concept of representation on
8
the Board itself for the local governments which comprise the customer
service area.
n) The Board should hire an "operational auditor" to conduct annual
performance audits of the BWL operations and planning efforts.
o) The BWL should establish a Customer Ombudsman, Chief Customer
Officer or expand the duties of the Director of Governmental Affairs and
Customer Relations, reportable directly to the General Manager.
p) The positions of Strategic Planning, Information Technology, and
Operations should be directly reporting to the General Manager.
q) Consider revision of the 54 Recommendations, using the SMART analysis
to include specific metrics, including the tasks to be performed, the
directorate or section within BWL charged with performance and the time
need for accomplishment. Require staff reports monthly to the Board of
Commissioners on specific actions that have been taken on all of the 54
recommendations made in the Ice Storm Outage Report and that the BWL
post those reports on its website for the next 18-24 months.
9
Report of the Community Review Team
on the Lansing Board of Water and Light’s
Response to the December 2013 Ice Storm
Released May 5, 2014

I. Introduction
On December 21, 2013 a catastrophic ice storm struck the Lansing, Michigan region,
causing more than 34,000 electric customers of the Lansing Board of Water and Light
(BWL) to experience a long-term power outage. Many BWL customers lacked electrical
power for an extended period of time, some reportedly for over 10 days. This problem
was exacerbated by a number of factors including the holiday season, the short days of
daylight, and the freezing temperatures. As the outage continued the BWL had to revise
its estimates on the scope of the outage, on the date when BWL crews would address
neighborhood or individual outages, and on the date for power restoration to the entire
customer base. Public frustration
2
over the inability to either seek or provide
information with the BWL, as it lacked a functioning Outage Management System and
sufficient number of damage assessors and customer service representatives, turned to
deep concern over the safety of family members and neighbors as the outage period
lengthened without a known date for restoration, and to anger over the unavailability of
senior leadership. As the public’s concerns continued after the restoration of power, the
Mayor of Lansing determined that an independent investigation of the BWL response
and restoration was needed.
December 2013 Ice Storm Timeline
December 21
st
: The National Weather Service warns of ice storm bringing
approximately .5 inch of ice. The storm hits the Lansing, Michigan area during the
afternoon.
3



2
Þubllc frusLraLlon and anger was dlrecLed only aL Lhe 8WL leadershlp. 1he publlc repeaLedly pralsed Lhe efforLs by
Lhe 8WL llne crews. 1he C81 also expresses Lhelr graLlLude and admlraLlon for Lhe dedlcaLed work of Lhe 8WL llne
crews, ouLslde llne crews, and oLher 8WL employees LhaL worked dlllgenLly Lo resLore power durlng exLreme
condlLlons over Lhe holldays.
3
New 5cole llopolots lce 5totm uooqet, Lanslng SLaLe !ournal, (uec. 21, 2013) Avallable aL
hLLp://www.lanslngsLaLe[ournal.com/arLlcle/20131221/nLWS01/312210017/new-scale-plnpolnLs-lce-sLorm-
danger, SLeven 8. 8eed and LllzabeLh Wolfe, 1lmellne: Þleclng 1ogeLher key ueLalls from lce SLorm, 8WL's
8esponse, Lanslng SLaLe !ournal (Mar. 1, 2014) Avallable aL
hLLp://www.lanslngsLaLe[ournal.com/lnLeracLlve/arLlcle/A3/20140301/nLWS01/140228003?ncllck_check=1.
10
December 22
nd
: At 6 a.m., BWL reports 19,000 customers are without power. Later
that day, about 200 lines are reported down and 25,000 customers are without power.
By 7 p.m., the totals are at 300 downed lines and 34,800 outages. Delta Township
declares a state of emergency.
4


December 23
rd
: BWL reports more than 400 downed lines. At 9 p.m., outages total
19,000. BWL spokesman Steve Serkaian tells the Lansing State Journal that there are
“‘sufficient resources in the field’ to restore power. ‘All hands are on deck and we asked
people to give up their holiday in order to restore power,’ he says.” General Manager
Peter Lark travels to New York for a vacation. Meridian Township declares a state of
emergency.
5
BWL releases a statement at approximately 4 p.m., instructing customers
not to contact the utility to report outages “unless you believe your situation is unique”
and that BWL “is aware of its outage areas.”
6


December 24
th
: At 4 pm, 12,000 customers remain without power.
7
By late that
evening, BWL reports that 7,500 customer outages remain.
8


December 25
th
: BWL reports that 5,700 customers remain without power. BWL
General Manager Peter Lark returns to Lansing.
9


December 26
th
: The BWL reports at 8 a.m. that they are down to 4,400 households
without power. The City of East Lansing reports, “They continue to have many crew
members out working on remaining major circuits and will then be focusing on smaller
pockets where power outages still exist.”
10
BWL General Manager Peter Lark tells

4
Meegan Polland, lce 5totm koocks Oot lowet, uowos 1tees lo loosloq Ateo, MLlve, (uec. 22, 2013) avallable aL
hLLp://www.mllve.com/lanslng-news/lndex.ssf/2013/12/lce_sLorm_knocks_ouL_power_dow.hLml, SLeven 8. 8eed
and LllzabeLh Wolfe, 1lmelloe. llecloq 1oqetbet key uetolls ftom lce 5totm, uec. 22, 8wl´s kespoose, Lanslng SLaLe
!ournal, (Mar. 1, 2014) Avallable aL
hLLp://www.lanslngsLaLe[ournal.com/lnLeracLlve/arLlcle/A3/20140301/nLWS01/140228003?ncllck_check=1.
3
SLeven 8. 8eed and LllzabeLh Wolfe, 1lmelloe. llecloq 1oqetbet key uetolls ftom lce 5totm, uec. 2J, 8wl´s
kespoose, Lanslng SLaLe !ournal, (Mar. 1, 2014) Avallable aL
hLLp://www.lanslngsLaLe[ournal.com/lnLeracLlve/arLlcle/A3/20140301/nLWS01/140228003?ncllck_check=1.
6
8wl. 1o kepott uowoeJ lloes & Ootoqes, news 1en, WlLx, (uec. 23, 2013) Avallable aL
hLLp://www.wllx.com/home/headllnes/8WL-1o-8eporL-uowned-Llnes--CuLages-237066261.hLml.
7
8randon Powell, loosloq 8ootJ of wotet & llqbt Ootoqes uowo to 12,000, MLlve, (uec. 24, 2013) Avallable aL
hLLp://www.mllve.com/lanslng-news/lndex.ssf/2013/12/lanslng_board_of_waLer_llghL_o.hLml.
8
lJ. (ºupdaLe: 8y laLe ChrlsLmas Lve, Lhe 8WL had resLored power Lo all buL 7,300 of lLs cusLomers.")
9
SLeven 8. 8eed and LllzabeLh Wolfe, 1lmelloe. llecloq 1oqetbet key uetolls ftom lce 5totm, uec. 25, 8wl´s
kespoose, Lanslng SLaLe !ournal, (Mar. 1, 2014) Avallable aL
hLLp://www.lanslngsLaLe[ournal.com/lnLeracLlve/arLlcle/A3/20140301/nLWS01/140228003?ncllck_check=1.
10
ClLy of LasL Lanslng, lce 5totm upJote ftom tbe clty of íost loosloq 12/26/1J (uec. 26, 2013) Avallable aL
http://www.cityofeastlansing.com/Home/Departments/Communications/MediaRoom/articleType/Artic
leView/articleId/1709/Ice-Storm-Update-from-the-City-of-East-Lansing-122613/.
11
reporters he cannot predict when power will be restored fully. An East Lansing resident
creates an outage map and posts it to BWL's Facebook page. At 10 p.m., BWL says 3,000
customers are without power.
11


December 27
th
: 3,000 BWL customers were still without power.
12
Eaton and Clinton
Counties declare emergencies. Ingham County officials report that they do not intend to
declare a state of emergency.
13


December 28
th
: At 8 p.m., BWL says outages have grown to 4,500
14
, the increase
reportedly caused by “thawing trees and additional outages being reported.”
15
BWL
Customers rally at an East Lansing school to protest BWL’s performance. Customers
demand restoration of power at a Lansing news conference with Mayor Virg Bernero.
16


December 29
th
: At 5 p.m., BWL lists 3,193 customers lack power on 333 streets and
asks those without power to contact BWL. According to the Lansing State Journal, later
that evening, BWL Spokesman Steve Serkaian texts Lansing Mayor Virg Bernero’s chief
of staff, saying “100 new streets have been reported by customers without power.”
17


December 30
th
: At 9 p.m., BWL reports 700 outages, plus 400 "single-service-
reconnection requests" involving customers who need to repair their connections. BWL

11
SLeven 8. 8eed and LllzabeLh Wolfe, 1lmelloe. llecloq 1oqetbet key uetolls ftom lce 5totm, uec. 25, 8wl´s
kespoose, Lanslng SLaLe !ournal, (Mar. 1, 2014) Avallable aL
hLLp://www.lanslngsLaLe[ournal.com/lnLeracLlve/arLlcle/A3/20140301/nLWS01/140228003?ncllck_check=1.
12
nlck ÞerreaulL, 8wl kespooJs to lce 5totm ltosttotloos, WLnS (uec. 27, 2013) Avallable aL
hLLp://www.wlns.com/sLory/24317333/bwl-responds-Lo-lce-sLorm-frusLraLlons.
13
cllotoo, íotoo, uelto 1wp., MetlJloo 1wp. ueclote ímetqeocles, Lanslng SLaLe !ournal, (uec. 27, 2013) avallable aL
hLLp://www.lanslngsLaLe[ournal.com/vlewarL/20131227/nLWS01/312270029/CllnLon-LaLon-uelLa-1wp-Merldlan-
1wp-declare-emergencles
14
SLeven 8. 8eed and LllzabeLh Wolfe, 1lmelloe. llecloq 1oqetbet key uetolls ftom lce 5totm, uec. 28, 8wl´s
kespoose, Lanslng SLaLe !ournal (Mar. 1, 2014) Avallable aL
hLLp://www.lanslngsLaLe[ournal.com/lnLeracLlve/arLlcle/A3/20140301/nLWS01/140228003?ncllck_check=1.
13
Llndsay vanPulle, Aoqet, ftosttotloo bolls ovet os powet ootoqes cootlooe lo loosloq Ateo, Lanslng SLaLe !ournal
(uec. 29, 2013) Avallable aL hLLp://www.lanslngsLaLe[ournal.com/vlewarL/20131228/nLWS01/312280016/Anger-
frusLraLlon-bolls-over-power-ouLages-conLlnue-Lanslng-area.
16
lJ.
17
SLeven 8. 8eed and LllzabeLh Wolfe, 1lmelloe. llecloq 1oqetbet key uetolls ftom lce 5totm, uec. 29, 8wl´s
kespoose, Lanslng SLaLe !ournal, (Mar. 1, 2014) Avallable aL
hLLp://www.lanslngsLaLe[ournal.com/lnLeracLlve/arLlcle/A3/20140301/nLWS01/140228003?ncllck_check=1.
12
projects power restoration to all customers except single-service reconnections by 11:59
p.m. Dec. 31.
18


December 31
st
: BWL reports that 200 customers are without power at 7 p.m.
19


January 1
st
: BWL reports that all power has been restored at 10 a.m.
20


Community Review Team (CRT)
Cooley Law Professor and retired Brigadier General Michael McDaniel was appointed by
Mayor Lansing Virg Bernero on January 8, 2014 to chair the Community Review Team
(CRT).
The investigation and report would be conducted by a team consisting of citizen
representatives from across the BWL service territory and subject matter experts in key
disciplines. Mayor Bernero gave CRT Chair McDaniel the discretion to appoint the
members of the CRT. The CRT chair began by putting out a call for resumes and letters
of interest, which was answered by eighty-five citizens. On January 20, 2014, CRT Chair
Michael McDaniel released the names of the ten appointed individuals who would serve
on the community review team. McDaniel also selected an all-volunteer executive staff.
See Appendix A. All appointed members of the team are BWL customers, and selections
were based on the applicants’ independence, geographic distribution and expertise.
Those who were not selected were invited to participate actively in the CRT review by
attending public hearings or sending suggestions.
The Mayor and the CRT Chair jointly developed the mission for the CRT. The CRT
released a mission statement in January 2014, prior to beginning the review. See
Appendix B. The CRT’s mission was to conduct an independent, objective and
transparent review of the BWL’s planning, preparation, response and recovery prior to,
during and after the devastating December 2013 ice storm. Further, the CRT would
evaluate the strengths and weaknesses of BWL’s performance in order to enhance
BWL’s capacity to respond more effectively to its customer’s needs and to recover more
quickly during future storms. Ultimately, the CRT’s goal was to release a written report

18
lblJ. SLeven 8. 8eed and LllzabeLh Wolfe, 1lmelloe. llecloq 1oqetbet key uetolls ftom lce 5totm, uec. J0, 8wl´s
kespoose, Lanslng SLaLe !ournal, (Mar. 1, 2014) Avallable aL
hLLp://www.lanslngsLaLe[ournal.com/lnLeracLlve/arLlcle/A3/20140301/nLWS01/140228003?ncllck_check=1.
19
lblJ.SLeven 8. 8eed and LllzabeLh Wolfe, 1lmelloe. llecloq 1oqetbet key uetolls ftom lce 5totm, uec. J1, 8wl´s
kespoose, Lanslng SLaLe !ournal, (Mar. 1, 2014) Avallable aL
hLLp://www.lanslngsLaLe[ournal.com/lnLeracLlve/arLlcle/A3/20140301/nLWS01/140228003?ncllck_check=1.
20
SLeven 8. 8eed and LllzabeLh Wolfe, 1lmelloe. llecloq 1oqetbet key uetolls ftom lce 5totm, Ioo. 1, 8wl´s
kespoose, Lanslng SLaLe !ournal, (Mar. 1, 2014) Avallable aL
hLLp://www.lanslngsLaLe[ournal.com/lnLeracLlve/arLlcle/A3/20140301/nLWS01/140228003?ncllck_check=1.

13
sharing its findings and recommendations. The CRT would make this report available to
the Mayor, City Council, the city’s regional partners within the BWL service territory
and the public at large. The report would also be shared with Michigan Public Service
Commission (MPSC) for review.
The CRT conducted public hearings on the evenings of February 6
th
, 7
th
and 8
th
of 2014
to address customer concerns and take suggestions from citizens. The hearings were
located in three BWL service areas: East Lansing, Lansing, and Delta Township. Each
hearing allowed citizens to express concerns to the CRT orally or to submit written
comments. The CRT continued to accept written comments by e-mail throughout the
process of the review. The CRT also created a Facebook page and an email address to
communicate with the public. CRT questionnaires were distributed to the public
through groups such as neighborhood associations. The CRT also reviewed the
transcripts of the public hearings conducted by the BWL. See Appendix C for a summary
of citizens’ concerns, received either by email or at the CRT public hearings.
Working with a representative from the BWL, the CRT submitted two “requests for
documents” to the BWL. The BWL responded with thousands of pages of documents,
which the CRT reviewed extensively with the assistance of subject matter experts. The
CRT also reviewed and analyzed the BWL’s internal report on the December 2013
storm, released on February 19, 2014. Materials received from BWL are listed at
Appendix D. On March 10, 2014, the CRT questioned BWL top executives
21
during a
five-hour hearing. See Appendix E. The CRT also interviewed city employees and
subject matter experts. After the information-gathering was completed, the CRT began
compiling its findings into recommendations by focusing on three areas of BWL
performance surrounding the December 2013 ice storm: planning and preparation,
response and restoration, and recovery and mitigation. The form of this report tracks
those three performance areas.
Board of Water and Light
The Board of Water and Light is a unique entity within the Charter of the City of Lansing
(City). The BWL, unlike all other City advisory boards, commissions or committees,
“shall exercise administrative, executive, and policy-making authority over the

21
1he C81 lnLervlewed Lhe Ceneral Manager,ÞeLer Lark, AsslsLanL Ceneral Manager, Susan uevon, ulrecLor of
CommunlcaLlons, SLeve Serkalan, ulrecLorof lnformaLlon 1echnology, nlck 8urwell, ulrecLor of LlecLrlc
1ransmlsslon and ulsLrlbuLlon,uave 8olan, and Lhe Manager of LlecLrlc SysLems CperaLlons, Lynn McklnsLry. 1he
C81 ofLen refers Lo 8WL ºsenlor leadershlp" ln Lhls reporL. 1haL Lerm ls lnLended Lo encompass only Lhe Ceneral
Manager, AsslsLanL Ceneral Manager and Lhose dlrecLors wlLh sLraLeglc level declslon-maklng auLhorlLy,
14
operation” of City owned utilities assigned to it.
22
Accordingly, the City has granted “full
and exclusive management of the water, heat, steam and electric services…” to the BWL
with the stated duty to provide those services “in a manner consistent with the best
practices.
23

Although created, funded and owned by the City, the services provided by the BWL
extend, mostly by franchise agreement
24
, to the provision of electrical power to the City
of East Lansing, the Townships of Delta and Windsor in Eaton County and of Dewitt and
Watertown, in Clinton County, and Delhi, Meridian, Lansing, and Alaiedon
25
in Ingham
County.
The BWL is the 32
nd
largest publicly owned utility in the United States serving electrical
customers, according to the American Public Power Association,
26
with just over 96,000
ultimate customers served. BWL is well regarded nationally for meeting reliability
standards set by the American Public Power Association, receiving a grade of 100% on
the Reliable Public Power Provider standards.
27
More importantly, BWL has
demonstrated strategic vision in two other vital areas: the diversification of sources of
power and the generation of sufficient electrical power to assure its ability to meet
customer demand.
In July 2013, BWL began operating its co-generation plant; this natural gas-fired
electric generating plant emits 50% less greenhouse emissions than a coal fired plant,
and will cut sulfur dioxide and mercury emissions by 99% and nitrogen oxide emissions

22
Sec 3-108.1, ClLy of Lanslng ClLy CharLer, as amnd 2012.
hLLp://www.lanslngml.gov/medla/vlew/Lanslng_ClLy_CharLer/3906
23
Sec 3.201, ClLy CharLer.
24
1here ls llLLle slmllarlLy beLween Lhe varlous franchlse agreemenLs, save LhaL all were execuLed beLween 1986-
1988, for a perlod of 30 years, and none appear Lo be excluslve agreemenLs. Cnly four requlre Lhe paymenL of a
franchlse fee by 8WL Lo Lhe Lownshlp.
23
Alaledon 1ownshlp and Lhe ClLy enLered lnLo a Þ.A. 423 AgreemenL ln 1998, coverlng Lhe land on whlch !ackson
naLlonal Llfe lnsurance ls slLuaLed.
26
Amerlcan Þubllc Þower AssoclaLlon, 2013-2014 Annual ulrecLory & SLaLlsLlcal reporL, www.ÞubllcÞower.org. lL
should be noLed LhaL Lhe slze of Lhe cusLomer base for publlc uLlllLles ln Lhe 1op 100 ranges from over 1.4 mllllon
cusLomers for ÞuerLo 8lco and Lhe ClLy of Los Angeles Lo [usL over 30,000 cusLomers for Lhe LwenLy munlclpallLles
aL Lhe end of Lhe llsL.
27
8WL Þress 8elease, 23 March 2014, loosloq 8wl to kecelve 1op Notloool kecoqoltloo fot kelloble ílecttlc
Opetotloos hLLp://www.lbwl.com/AbouL-Lhe-8WL/news/Lanslng-8WL-Lo-8ecelve-1op-naLlonal-8ecognlLlon-for-
8ellable-LlecLrlc-CperaLlons/
13
by 85%. The design and development of this energy-efficient generation plant and
headquarters resulted in BWL receiving gold certification from the Leadership in Energy
and Environmental Design, the first utility in Michigan to receive this award. BWL also
has contracted with Granger Waste Disposal since 1992 for waste to energy electrical
power
28
.
BWL has the capacity to generate locally all the electrical power needed by its
customers. BWL has the capacity to generate 440 MW of energy; it provides
approximately 2,200,000 MWh of electricity each year, which equates to approximately
250 MW of energy on average and a peak demand of 500 MW. BWL purchases 11 MW
of power from Granger (waste to energy) and purchases approximately 1.7 MW of
hydro-electricity under a purchase power contract. BWL also has capacity and energy
entitlement to 150 MW from the Belle River generating facility in St. Clair County and
has a small solar array. BWL can truly supply “hometown power” to its customers. This
is of enormous potential strategic importance. BWL is almost wholly self-reliant for
power; it can generate all the electrical power its customers require. If BWL can
maintain this strategic advantage, rather than have to purchase power off the market, as
do most publicly-owned utilities, it will not only assure the region’s energy self-
sufficiency, but will also assure the energy security of the region.
Storm Frequency and Intensity
The ice storm in December 2013 is reported to have caused a higher percentage of
customer outages than any previous storm affecting the BWL. (Lansing Board of Water
and Light also claims it is higher than for any utility in Michigan, but comparisons to
utilities with larger territories are not appropriate for some purposes because a storm
event is less likely to affect a large fraction of customers in a larger territory.) The ice
storm, however, was not the sole cause of the outage and certainly not of the length of
the outage. The confluence of three policies, all under the BWL control, contributed to
the length of the outage: the failure to follow the BWL vegetation management policy,
the lack of trained damage assessors, or “spotters” to immediately be deployed, and the
non-availability of the Outage Management System were significant causes of the length
of the outage.
Lansing Board of Water and Light, and others, may take the view that this was an
exceptional event and evaluate grid hardening measures and restoration capacity on
that basis. While it is likely that this storm had greater consequences than are likely to

28
hLLp://www.grangerneL.com/energy/pro[ecLs.php?l=mw Cranger supplles 8WL wlLh approxlmaLely 70,000 Lo
73,000 MWP each year.

16
recur with great frequency, we must not be guided solely by our past experience as to
storm frequency or to building a resilient system.
A recent report
29
shows that the level of power outages in the United States due to
weather has been increasing significantly in recent years as illustrated in the following
graph.

The report attributes this increase to both aging grid infrastructure and increasing
storm intensity associated with global climate change. It also notes that:

The Lansing Board of Water and Light must plan as though recent storm frequency and
intensity is normal or even that these types of events will continue to increase.
As our nation’s approach to disaster and emergency planning has matured, there is a
growing belief in the community that catastrophes in the US have intensified in their
effects, as our society has evolved into a complex system of systems which are “highly
connected, optimized and cost-efficient”.
30
Because our systems, including the electrical

29
(kenward, Alyson and 8a[a, uroo[. 2014. 8lockoot. íxtteme weotbet, cllmote cbooqe ooJ lowet Ootoqes.
Avallable aL hLLp://asseLs.cllmaLecenLral.org/pdfs/ÞowerCuLages.pdf
30
Lewls, 1ed C. 8ok´s 5ooJ llle, 5ttoteqles fot o cotosttopblc wotlJ. Aglle Þress, 2011.
17
transmission and distribution systems are built to be low-cost and efficient, rather than
resilient and secure, they are more brittle, and prone to failure.
The Cumulative Nature of Storm Impact
Some public expectations and some BWL analyses tend to look at grid hardening
measures or storm response practices as though they only affect the customers directly
affected by the avoided fault or accelerated repair. This is incorrect and the BWL should
approach its analyses with care on this point. Whether repairs are done by a single or
multiple crews, repairs after a storm are still done more-or-less serially – repairing one
fault, then on to the next, and the next, etc.. This means that avoiding a fault through
grid hardening or accelerating a repair has the effect of shortening the time to power
restoration for all subsequent repairs.
BWL policy, appropriately, dictates that the sequence of repairs in a major outage is to
first restore power to critical facilities, then secure down lines, then repair faults in the
primary distribution system roughly in order of the number of customers affected, then
repair faults in the secondary distribution system roughly in order of the number of
customers affected. Consequently, grid hardening or accelerated restoration practices
that address critical facilities and secure down lines as a priority benefit all other
customers; grid hardening or accelerated restoration practices that reduce repair time
for the primary distribution system benefit most customers; and grid hardening or
accelerated restoration practices that reduce repair time for the second distribution
system effectively benefit most customers affected by secondary distribution system
faults.
Best Practices
The BWL is charged, by City Charter as follows: “The board shall be responsible to the
Mayor and the City Council for the provision of these services in a manner consistent
with the best practices
31
.” As noted in the Mission Statement, the CRT was therefore
tasked with evaluating the BWL response to the ice storm against Best Practices in the
electric utility industry. The CRT has researched and reviewed a number of After Action
Reports published by other utilities, state governors or public utility regulators, which
focus on electrical outages caused by ice or snow storms.
For example, New Hampshire suffered a severe ice storm, resulting in a lengthy outage
of electrical power in December 2008. As a result, the state conducted a similar,
although broader investigation, into the response by all utilities in the state. The report

31
ClLy CharLer 3-201
18
of that investigation identified the following “best practices”, which the CRT has used as
a partial template
32
:
Planning and Preparedness:
1) The utility bases their emergency operations on the concept of the national
incident management system.
2) The utility has a dedicated emergency operations organization and
facilities.
3) At the first indication of a storm, the utility pre-positions its restoration
workforce which includes damage assessors and crews. The initial damage
assessments begin as soon as possible after a storm has passed and the
damage assessments are used to develop initial restoration time estimates.
4) The utility never underestimates the potential damage of a forecasted
storm.
5) The utility has a comprehensive emergency operations plan in place to
communicate with public officials and emergency response agencies. The
plan is distributed to all employees, who are trained in their roles in all
contingencies, and the plan is exercised annually. The plan includes an
integrated annex to assure it opens communications early and maintains
constant communications throughout the storm or event.
6) The utility extensively uses "non-traditional" employee resources,
including cross-training of current employees and retirees.
7) The utility has pre-staged materials which may include such things as
storm trucks or storm boxes.
Response and Restoration:
8) The utility determines the global estimated restoration times and
disseminates that information both within 24 to 48 hours.

32
nLl LlecLrlc Þower Lnglneerlng, 8est ltoctlces fot ílecttlc utllltles, Þage vll-12. 1he oLher sources of 8esL
ÞracLlces whlch were relled upon by Lhe C81 are lncluded ln Appendlx l.



19
9) The utility has a restoration strategy that targets the restoration of power to
the greatest number of customers in the shortest amount of time.
10) The utility does not limit requests for supplemental crews to the local mutual
aid groups and other local utilities.
11) The utility strives to make sure that all communications are correct and
consistent.
12) The utility implements lessons learned in a timely manner. Implementation
plans that include specific tasks and scheduled completion dates are
developed and tracked.
Mitigation, System Protection and Design:
13) The utility includes 50-year return values for wind and ice loading in their
load cases for designing all line structures.
14) The utility commonly uses automatic distribution line high-speed source
transfer schemes.
15) The utility replaces its traditional electro-mechanical relays with
microprocessor-based protective relays.
16) The utility installs electronically controlled single and three phase reclosers
where appropriate in order to improve system reliability.
17) The utility has an effective outage management system (OMS) that works
even during major outage events.
18) The utility strives for regular inspection of its entire distribution system on a
two-year cycle utilizing a combination of circuit inspection, tree trimming
inspection and pole ground line inspection.
19) Where practical, the utility uses the wire zone-border zone electric ROW
vegetation management practice on sub-transmission lines.
20) The utility utilizes a four-year vegetation management cycle for clearing trees
around power lines.
20
II. Planning and Preparation
System resilience
Critical Infrastructure is defined as the systems or assets without which our society
cannot function. Discussions of critical infrastructure classify them according to the
functions or services that are essential to our health, safety and welfare. While by
definition, they are all “critical,” the three sectors of Critical Infrastructure that are the
most essential, as all other systems of Critical Infrastructure are dependent upon them,
are water, information technology and energy. In the Lansing area then, BWL is
responsible for two of the three most essential sectors of Critical Infrastructure. Despite
its role as the sole provider of essential sectors of Critical Infrastructure, the BWL’s
activities suggest that the importance of its role in the assurance of the regional health
safety and welfare was not fully understood. There are a number of key principles to the
assurance of critical infrastructure
33
, but the most important principle is not assuring
the physical security of the infrastructure, but assuring its resiliency
34
. Resilience results
from a sustained commitment to four factors: Robustness, the ability to continue
operating or stay standing in the face of disaster; Resourcefulness, skillfully managing a
disaster once it unfolds; Rapid Recovery, the capacity to get things back to normal as
quickly as possible after a disaster; and Learning lessons, having the means to absorb
the new lessons that can be drawn from a catastrophe.


33
1hose prlnclples are ÞroLecLlon, 8eslllency, lnLerdependencles, Þreparlng for response and mlLlgaLlon, locuslng
on prevenLlon and deLecLlon, LvaluaLlng lnfrasLrucLure for: CrlLlcallLy(or 8lsk), vulnerablllLy and 1hreaL, and Lhen
developlng a formal rlsk mlLlgaLlon sLraLegy.
34
See llynn, S. Amerlca Lhe 8eslllenL: uefylng 1errorlsm and MlLlgaLlng naLural ulsasLers. lorelgn Affalrs, 87 (2),
2-8 (2008). Many wrlLers lnclude 8edundancy ln Lhe llsL of prlnclples, buL llynn lncludes 8edundancy wlLh ln
8obusLness.
8obusLness
• ueslgnlng sLrucLures sLrong enough Lo Lake a foreseeable hlL
- lnvesLlng ln and malnLalnlng elemenLs of crlLlcal lnfrasLrucLure, so LhaL Lhey can wlLhsLand low-
probablllLy, hlgh-consequence evenLs.
8esourcefulness
- ldenLlfylng opLlons
- ÞrlorlLlzlng whaL should be done Lo conLrol damage and Lo begln mlLlgaLlng lL
- CommunlcaLlng declslons Lo Lhe people who wlll lmplemenL Lhem
- Þrovldlng adequaLe resources Lo emergency responders, Lhe naLlonal Cuard, Amerlcan 8ed Cross,
publlc healLh offlclals
8apld 8ecovery
- Carefully drafLed conLlngency plans
- CompeLenL emergency operaLlons
- Means Lo geL Lhe rlghL people and resources Lo Lhe rlghL places
- 1ralnlng auxlllary flrsL responders prlor Lo evenL
- Pavlng buslness emergency neLworks ln place
Learnlng lessons
- 8ebulldlng homes on floodplalns or falllng Lo resolve lnLeroperable communlcaLlons lssues ls foollsh
- Þeople musL be wllllng Lo make pracLlcal changes
21
“Lifeline systems are interdependent, primarily by virtue of physical proximity and
operational interaction
35
.” When a utility is offline and power is disrupted, there is a
cascading effect throughout the community. All other systems of critical infrastructure
rely upon those three systems: water, IT and communications and energy. If electricity
is lost for a significant period (usually defined as over 36 hours), then other key
resources, such as water and wastewater treatment facilities, banks, hospitals and
medical facilities, nursing homes, and other services vital to the community and
industries vital to the region’s economy are also offline.
The BWL seems to have underestimated the potential impact of these cascading effects
to other resources. There is little apparent recognition of the dependency of other
systems of critical infrastructure on electrical power, or of the interdependencies across
key sectors and systems of infrastructure. One must recognize the consequences of the
cascading effects across systems and sectors of infrastructure vital to the region. Absent
this recognition, there can be no comprehension of the need for regional preparedness
and planning for major incidents.
All other critical systems and facilities depend on electric power to provide services
essential to public health, safety and welfare. The list includes those facilities needed by
the utility or authorities to carry out response and restoration activities, and includes
key BWL facilities, hospitals, emergency response centers and public safety buildings,
water supply and sewage treatment, and similar facilities whose continued operation is
essential. Some facilities that were critical for the restoration of electrical service after
the storm housed the elderly or disabled or were ultimately used as warming or
community assistance facilities after this storm did not have standby generation
equipment. Some critical facilities lost power during the December 2013 ice storm and
required restoration work that, by definition, delayed work on service restoration to all
other customers (albeit for only a few hours).
Standby generation is less reliable and often less economically advantageous than the
use of combined heat and power or other nearly continuous on-site generation. Indeed,
the United States Department of Health and Human Services is currently in the rule-
making process to require hospitals receiving Medicare and Medicaid funding to
evaluate the use of combined heat and power for this reason. We note that such use of
combined heat and power at critical facilities throughout the community might also aid
the Board in meeting its power generation capacity requirements.



33
C'8ourke, 1.u., CrlLlcal lnfrasLrucLure, lnLerdependencles, and 8eslllence 2007.
22
Findings:
1) In the Lansing area, BWL is responsible for the provision, and for the
protection, of water and energy, two of the three most important sectors of
critical infrastructure
36
.
2) BWL has not embraced the necessary strategic contingency-planning mindset
for these essential services.
3) BWL appropriately first focused its restoration efforts on those critical
systems and facilities vital to public, health safety and welfare.
4) The Order of Restoration used by the BWL was outdated and did not include
all critical facilities.
The CRT recommends that the BWL:
1) Working jointly with local emergency planners and municipal
governments, update the inventory of critical facilities, as part of a Regional
Emergency Operations Plan.
2) Assist all units of government representing its customer base with
identifying Special Needs Facilities for power restoration efforts, including
assisted care facilities, elder care facilities, water and sewer plants, food
warehouses, Capital City airport and key industry.
3) Undertake a program of technical assistance to critical facilities in its
service area to determine the feasibility and net benefits of implementing a
micro-grid at each such facility, using combined heat and power or renewable
generation and storage.
4) Explore various options to participate financially in implementing micro
grids at critical facilities where they are feasible and beneficial, including
power purchase agreements, joint ventures, and Board ownership.




36
1he focus of Lhe C81 sLudy was Lhe 8WL elecLrlc sysLem, noL Lhe waLer and sLeam sysLems, buL Lhe CaplLal
8eglon's rellance on 8WL Lo provlde Lhese essenLlal resources, upon whlch all oLher sysLems of crlLlcal
lnfrasLrucLure depend, requlres emphasls.
23
National Incident Management System Implementation & Training
The National Incident Management System (NIMS) is a comprehensive, systematic
approach to incident management which grew out of the Incident Command System
developed by the Fire Community for inter-agency firefighting decades ago and, post-
9/11, has been adopted by all levels of government. NIMS provides a unified approach to
incident management, creates standard command and management structures, and
emphasizes preparedness and mutual aid. The Federal Emergency Management Agency
(FEMA) and the Office of Infrastructure Preparedness, in the U.S. department of
Homeland Security, have consistently encouraged all owners and operators of privately-
owned critical infrastructure to adopt NIMS and to train their staff in its application.
Public Works and water and power utilities have long been considered an essential
discipline in Emergency Management. FEMA has even designed a customized version of
the ICS course, Introduction to ICS for the Public Works community
37
. The National
Response Framework
38
, the broad national outline for coordinated response to all
disasters between all levels of government details the interrelationship with essential
sectors of critical infrastructure in some of the 15 Annexes to the Framework, detailing
the requisite Emergency Support Functions (ESFs). Annex 12, known as ESF 12- Energy
Annex
39
, describes the roles of FEMA and other federal, state and local officials to assist
the owners and operators of utilities during a Stafford Act event. To be able to
appropriately function and communicate during an emergency, the utility owners and
operators must be trained in the National Incident Management System.
NIMS compliance is a prerequisite for eligibility for Federal Preparedness Awards under
Homeland Security Presidential Directive (HSPD)-5, Managing Domestic Incidents.
Personnel must attend training based on their ICS role
40
.
Most utilities, including public-owned utilities, are cognizant of this requirement and
have incorporated it into their emergency planning and training regimens. The APPA
newsletter, for example, promoted NIMS implementation (while objecting to the NIMS

37
lS-100.ÞW8: lnLroducLlon Lo Lhe lncldenL Command SysLem (lCS 100) for Þubllc Works,
hLLp://Lralnlng.fema.gov/LMlWeb/lS/courseCvervlew.aspx?code=lS-100.pwb
38
hLLp://www.fema.gov/medla-llbrary/asseLs/documenLs/32230?ld=7371
39
hLLp://www.fema.gov/medla-llbrary-daLa/20130726-1921-23043-4796/flnal_esf_12_energy_20130301_r1.pdf

40
See, hLLp://www.fema.gov/emergency/nlms m prevlous sLorms or ouLages
24
Integration Center’s proposal for credentialing line workers as cumbersome given
mutual aid agreements), as far back as 2007
41
.
The APPA endorses required NIMS training for key personnel
42
. Given the need to
cross-train employees to assure that BWL has a depth to its roster, has experienced
employees that can be transferred to emergency duties as contingencies demand, and
the need to coordinate response and restoration efforts with government EM officials
from the city, state and other governments in its customer service area, NIMS training is
vital to all BWL staff.
Findings:
1) NIMS is a recognized best practice for all critical infrastructure owners,
including publicly-owned electrical utilities.
2) BWL has not adopted the NIMS system.
3) The BWL had several Emergency Plans, but did not have a coordinated
Emergency Plan. In response to CRT questions, the BWL indicated that
training did not occur with all personnel involved, in the same training
program, at the same time.
The CRT recommends that the BWL:
Recognize its role to assist Regional, City and Township Emergency Management in
disaster response by implementing all of the following:

41
AÞÞA Þubllc Þower Magazlne , november-uecember 2007,
hLLp://www.publlcpower.org/Medla/magazlne/ArLlcleueLall.cfm?lLemnumber=20431 "As lLMA pushes
Lhe nlMS program on Lo sLaLe, local and Lrlbal governmenLs, Loplcs such as credenLlallng of workers wlll
be an lssue," sald Mlke Pyland, vlce presldenL, englneerlng servlces, for Lhe Amerlcan Þubllc Þower
AssoclaLlon."Sooner or laLer, publlc power uLlllLy employees wlll be affecLed. Cf speclflc concern Lo
AÞÞA members ls LhaL Lhey fall under Lhe nlMS seL-up, whlle lCus and co-ops do noL."
42
lrom Lhe same arLlcle on Lhe AÞÞA webslLe, 'CredenLlallng coursework-1he proposed nlMS guldellnes call for
equlpmenL operaLors Lo compleLe prescrlbed Lralnlng reglmens for Lhe ºlncldenL Command SysLem." 1he course
descrlbes Lhe hlsLory, feaLures, prlnclples and organlzaLlon of Lhe lncldenL Command SysLem and explalns Lhe
relaLlonshlp beLween lCS and Lhe nlMS. CLher recommended Lralnlng addresses slngle resources and lnlLlal acLlon
lncldenLs. lL ls deslgned Lo Lell supervlsory personnel how Lo operaLe efflclenLly durlng a homeland securlLy
lncldenL. A Lhlrd Lralnlng course (nlMS-700: naLlonal lncldenL ManagemenL SysLem lnLroducLlon) explalns Lhe
purpose, prlnclples, key componenLs and beneflLs of nlMS. lL also explalns when lL ls approprlaLe Lo lnsLlLuLe an
area command, when lL ls approprlaLe Lo lnsLlLuLe a mulLl-agency coordlnaLlon sysLem, Lhe beneflLs of uslng a [olnL
lnformaLlon sysLem for publlc lnformaLlon, how nlMS resources are managed, and advanLages of common
communlcaLlon and lnformaLlon managemenL sysLems."
23
a) During any event where the City EOC is activated, including during major
widespread outages, a trained and experienced BWL Liaison Officer must be
deployed to the City EOC.
b) Participate in all EM exercises sponsored by any units of government
representing its customer base
c) Assure that all operations employees receive basic NIMS training, at a
minimum the two introductory courses: FEMA IS-700, NIMS An
Introduction; IS-100.PW-B, Introduction to the Incident Command System
(ICS 100) for Public Works; that all first-line supervisors take those courses,
plus ICS-200, Basic ICS; that all senior management officials take those 3
courses, plus ICS-400, Advanced ICS.
d) 2) Participate in After-Action Reviews with all units of government
representing its customer base, not just post-exercise, but after every major
outage, disaster and emergency
e) Develop and maintain good working relationships with the first-responder
community for all units of government representing its customer base
Contingency Planning, Training and Exercises
The hearing on 10 March 2014 with BWL officials left the impression that its leadership
had not yet recognized the need for the integration of planning for the likelihood of a
catastrophic or extreme weather event into its overall strategic planning. Despite the
daily reports of extreme weather, and the warnings to utility operators of the potential
impacts of climate change, the BWL leadership seemed to discount the possibility that
BWL could confront an event ever resulting in greater than the 40% customer outage
experienced last December. The BWL electric operations chief commented during the 5-
hour interview with senior leadership that because BWL had never experienced an
outage of greater than 20%, they assumed that that was the upper limit for which they
should prepare. Similarly, the General Manager declared at the 10 March hearing “no
utility has ever been hit with a storm of these dimensions.” To the contrary, however,
utilities, like emergency planners for government agencies and other sectors of critical
infrastructure, are routinely criticized for the lack of imaginative planning
43
, for the

43
WlLL 8eporL, pp 13-14: º[ConnecLlcuL LlghL and Þower] underesLlmaLed ln lLs plannlng Lhe poLenLlal scale of a
worsL-case power ouLage evenL. 1hls underesLlmaLe had rlpple effecLs Lhrough CL&Þ's plannlng for personnel,
equlpmenL and coordlnaLlon needs." CL&Þ had planned for a worsL-case scenarlo ln whlch 100,000 cusLomers losL
power, only one-elghLh of Lhose acLually affecLed by Lhe nor'easLer. ln facL, 70 percent, 810, 000 of 1,2 mllllon
cusLomers suffered a power ouLage. 1he reporL had conceded LhaL such a sLorm had noL occurred ln 23 years, aL
Lhe Llme Lhe plan was lmplemenLed, buL sLlll faulLed CL&Þ for merely Lelllng lLs emergency crews Lo be on call
26
inability to envision potential natural or man-made actions that can degrade or destroy
their continuing operations.
The North American Electric Reliability Corporation (NERC) and the U.S. Department
of Energy (DOE) partnered in July of 2009 on an effort to address High-Impact, Low-
Frequency risks to the North American bulk power system
44
. As stated in the report,
“Examples of these events include a pandemic illness, coordinated cyber, physical, or
blended attack on the system, extreme solar weather, and the high-altitude detonation
of a nuclear weapon. While some of these events have never occurred and the
probability of future occurrence and impact is difficult to measure, government and
industry are working to evaluate and, where necessary, enhance current planning and
operating practices to address these risks in a systematic and comprehensive fashion”.
In addition the risk assessments conducted by States in the identification of critical
infrastructure were asked by the DHS to use a “worst case scenario” to conduct this
assessment.
The focus of emergency management planning, then, is to “imagine the unlikely” and
then prepare for it
45
. A common catch-phrase of emergency planners is to “Prepare for
the worst, and everything else is a lesser included contingency.”
The BWL, in response to requests from the CRT, provided a number of different
emergency plans
46
. At the March 10, 2014, hearing, BWL indicated that its 2014
Emergency Action Plan (EAP) was the plan implemented during the ice storm. This plan

lnsLead of havlng Lhem walL aL predeLermlned locaLlons. As a resulL lL was harder Lo moblllze Lhem when Lhe
effecLs Lurned ouL Lo be far worse Lhan Lhey anLlclpaLed desplLe warnlngs from Lhe nWS uslng Lerms such as
"hlsLorlc" and "caLasLrophlc" prlor Lo Lhe sLorm.
44
hLLp://www.nerc.com/pa/Cl/8esources/uocumenLs/PlLl_8eporL.pdf
43
1he 9/11 Commlsslon declared LhaL Lhe naLlon's lack of preparaLlon for domesLlc LerrorlsL aLLacks were due Lo a
ºfallure of lmaglnaLlon", and Lhe llLeraLure on emergency plannlng has slnce focused on Lhe need Lo lmaglne Lhe
worsL case scenarlo. See for example, Ovetcomloq follote of lmoqlootloo lo ctlsls moooqemeot. 1be complex
oJoptlve system, M! 8olLon, C8 SLolcls , 1he lnnovaLlon !ournal: 1he Þubllc SecLor lnnovaLlon !ournal, volume
13(3), 2008, arLlcle 4 (2008), McConnell, A. and urennan, L. (2006). 1he Mlsslon lmposslble? Þlannlng and
Þreparlng for Crlsls. !ournal of ConLlngencles and Crlsls ManagemenL, 14: 39-70. dol: 10.1111/[.1468-
3973.2006.00482.x, MarLln, L., & Slmon, S. (2008). A formula for dlsasLer: 1he ueparLmenL of Pomeland SecurlLy's
vlrLual onLology. Space and ÞollLy, 12(3), 281-296.
46
1he 2014 Lanslng 8oard of WaLer & LlghL Lmergency AcLlon Þlan daLed CcLober 28, 2013 (Lhls ls Lhe plan ln use
durlng Lhe uecember 2013 ouLage, accordlng Lo LesLlmony), 1he Lanslng 8oard of WaLer & LlghL Lmergency
Þrocedures Manual, 1he Lanslng 8oard of WaLer and LlghL 1ransmlsslon CperaLlons Þlan and Lmergency
CperaLlons Þlan (1ransmlsslon CperaLlon Þlan (1CÞ))., and Lhe Lanslng 8oard of WaLer and LlghL Lmergency
CperaLlons Þlan (LCÞ).
27
was an update to the July 2012 EAP. The Electrical Transmission and Distribution also
relied on a separate, pre-existing “Order of Restoration” which, although part of an
earlier plan, remained in use. The 2o14 EAP has an effective date of December 1, 2013. It
was produced by the Risk Management Department. There was some confusion at the
hearing of the definition of a “catastrophe” which would trigger the deployment of the
plan
47
.

Although it is an update of a pre-existing plan, we have substantial concerns, including:

a) The existence of multiple plans can lead to operational disconnects during an
event, as staff will need to verify that they are following the proper plan,

b) There was no company-wide system for planning, plans were developed on an
ad hoc basis,

c) There was not sufficient time to train staff on the EAP,

d) There appeared to be conflicting directions in the multiple plans, and

e) There was not clear direction on the “trigger” for deployment of the plan.

The CRT discussions with city and county emergency managers suggested that regional
planning activity is not organized and coordinated in advance of emergency events, but
instead, relies on the experience of the participants and their pre-existing relationships.
While that experience was evident during the ice storm response, there are some
difficulties with this approach. First, experience works only so far as that event, or a
similar event has been encountered and overcome. A properly trained EM cadre,
working for a common and comprehensive Emergency Operations Plan, will adapt to
the contingency confronted. Second, as noted elsewhere herein, when the entire EM
system is reliant on a pre-existing relationship for the trusted flow of information, that
relationship becomes a chokepoint in the information stream. Third, there is no
government entity that encompasses the entire BWL customer service area, which
stretches across three counties.

Continuity of Operations
Continuity of Operations Planning (or Business Continuity Planning in the private
sector) is the concept of strategic-level planning to assure that government departments
and essential services, whether privately-owned or public, are able to continue operation
of their essential functions under a broad range of circumstances including all-hazard
emergencies as well as natural, man-made, and technological threats and national
security emergencies
48
. Thus, emergency plan developers include continuity of

47
See, generally, pp 3-9, March 10, 2014 publlc hearlng, App.L.
48
hLLp://www.fema.gov/conLlnulLy-operaLlons
28
operations either within the plan, as an annex to the plan, or as an integrated
accompanying plan. Strategic planners for the agency or business must work closely
with all departments of senior leadership to develop a Business Impact Analysis, a
detailed assessment of the possible consequences of disruption of an essential function
and collects information needed to develop recovery strategies to quickly resume
operations. The business continuity plan is designed to assure sustained operation of the
agency or business essential functions. It is a collection of resources, procedures, and
information that is developed, tested, and held in readiness for a major disruption of
operations. Business Continuity Planning helps prepare the agency or business to
maintain mission-critical operations after any emergency or disaster. Some important
aspects of a business continuity plan include:
a) Identification of essential services;
b) Thorough risk assessment;
c) Plans for evacuation of personnel from affected work sites;
d) Designation of alternative locations for senior management and key staff;
e) Selection of alternative sources of key supplies, materials and resources and
contingency contracts to assure their availability; and
f) True IT operations back up.
Findings:
1) The BWL planning efforts were disjointed. The EAP and other plans need to
be replaced by a more comprehensive plan that includes tools for better
situational awareness, and specific plans for response and recovery.
2) There was not a concerted response effort or coordinated communications
between the BWL and the City, and none between BWL and the local
governments which represent the rest of their consumer base. The CRT
discussions with city and county emergency managers suggest that regional
planning activity is not organized and coordinated in advance of emergency
events, but instead, relies on the experience of the participants and their pre-
existing relationships. While that experience was evident during the ice storm
response, there are some difficulties with this approach. Experience works
only so far as that event or a similar event has been encountered and
overcome.
3) There was an over reliance on pre-existing personal relationships between
personnel at BWL with the City and elsewhere.
29
4) Emergency Operations Plans must be coordinated before an emergency event
or incident, to provide time for training all personnel on the plan and
exercising the plan.
5) The BWL lacks a Business Continuity Plan, although some necessary aspects,
such as evacuation of personnel, are contained in the 2014 Emergency Action
Plan.
The CRT recommends that the BWL:
1) Consolidate its multiple emergency response plans within the City and
Regional plan, (see below) and then test that plan by scheduling a full staff
coordinated “table top” exercise
49
at a minimum of every 12 months.

2) BWL Staff and upper management should participate in the exercises and
receive training on these plans and regular refresher training. BWL staff with
emergency responsibilities should be required to have training on these plans
and their role and responsibilities and the role and responsibilities of others
that will be involved with any emergency response.
3) Together with the communities in the greater Lansing area (not just the BWL
service area), undertake a regional planning effort to be better prepared and
coordinated and assure that emergency communication protocols are agreed
to and followed. The mayors and township supervisors of our communities
must lead and encourage this effort and provide the necessary resources. This
planning effort
50
should be done in coordination with the State Police
EMHSD District 1 Coordinator.
4) Include Business Continuity Planning in its development of a comprehensive
Emergency Operations Plan.
Inter-agency Communications and Emergency Operations Center
At the CRT public hearing on 10 March 2014, the BWL was questioned on the use of an
Emergency Operations Center and on the communications between the BWL and the
City EOC. The BWL suggested to the CRT that they did not need an EOC , as the current
operations center, known as the BESOC, provided sufficient capability to manage

49
1hls recommendaLlon for a LableLop exerclse on lLs LCÞ, ls separaLe from Lhe recommendaLlon Lo annually
parLlclpaLe ln a reglonal full scale exerclse.
30
1he Mlchlgan Þubllc Servlce Commlsslon has developed a Local Lnergy Assurance Þlan LemplaLe and occaslonally
has held workshops whlch could be anoLher resource.
30
operations during the outage. BWL advised that, in any event, there was not a need for
EOC activation.
The primary role of an EOC is to provide strategic direction and support for the actual
response organizations. An equally important role is to coordinate the response, so that
all entities are working cohesively and coherently to address the multiple nuanced issues
that will arise in an event. The EOC acts as the center of gravity for senior level decision-
making and thus, links horizontally to other municipal governments and vertically to
higher-order government agencies. The EOC assures that the senior officials all have the
same set of data, the “common operating picture” so that when decisions are made, each
senior official, whether with that government agency or a linked government, will know
and understand the basis for the decision. When the senior officials are in the EOC, then
the decisions are emanating to the public and others from a common location. Because
of the potential impact on the personnel and equipment needed for daily governmental
services, during an event, the coordination or reconfiguration of day-to-day (i.e.,
‘normal’) services to the remainder of the affected municipality, state, is commonly
accomplished through the EOC. Similarly, since senior-level decision-making is
facilitated through the EOC to assure, among other reasons, that the public, like the
government officials, are all receiving the same information and at the same time,
emergency public information is coordinated and disseminated through the EOC.

An EOC is vital to assure that a number of capabilities are present and shared between
all participating agencies and units of government. Those capabilities include:

1) Assurance that EOC internal operations are organized and based on NIMS/ICS
concepts and principles.

2) Provision of a Common Operating Picture (and, usually, a more sophisticated
communication system) and greater communications reach to key officials.

3) Use of dedicated software and other tools (CAD, GIS, WebEOC) to assure the
preservation of information, data and communications for further analysis.

4) Provides a platform for contingency decision-making, horizontally, and often
vertically, by the inclusion of senior and key agency or organization members
– officials that have the jurisdiction or authority to speak on behalf of their
municipality, agency or corporation to other orders of government and
participants and that have the political, legal, or financial authority to commit
extraordinary funds and resources. Other participants include those with
needed subject-matter expertise or resources.

31
5) Missions that should be coordinated through the EOC include:
- Damage assessment, consequence analysis, interdependencies impacts
and situational awareness to support decision-making and resource
allocations for response and recovery
- Coordination with member communities for Emergency Response
- Communications with elected or appointed officials
- Warming Centers coordination
- Health and Safety Checks on residents
Medical, weather or other alerts to the cities and townships.

The BWL advised that they followed their Emergency Action Plan. That plan includes a
process for the activation of the “Command and Communications Center’, providing
that, “[i]n a catastrophic event, the Unified Command Team, charged with managing the
BWL’s emergency response, will determine whether or not the situation warrants
activation of the CCC.”
BWL published its Crisis Communications Plan in March 2014, in response to criticisms
of its inability to communicate with the public during the ice storm and outage. The
stated purpose of that plan is to assure a “constant and consistent line of reliable
information” from the BWL “to its customers.” That plan lists the members of its “Crisis
Communications Command Team” as the General Manager, Assistant General Manager,
the Director of Communications and the Director of Governmental and Community
Services.”
The Unified Command Team and the Crisis Communications Team identify differing
personnel for crisis leadership. It seems apparent that the Emergency Action Plan and
the Crisis Communications Plan were developed and drafted independently of each
other, with no consideration for the potential overlap in planning, processes, and
personnel. This is only one example of why comprehensive unified plans are needed.
Of greater concern, the March 2014 Crisis Communications Plan, although expressly
detailing the forms of response for specific contingencies, does not reference any
emergency operations plan nor does it connect with any city or regional plan.
As detailed elsewhere herein, the CRT received thousands of pages of documents from
the BWL in response to their requests. Despite asking repeatedly, BWL has apparently
not preserved any records from the BESOC nor elsewhere in Electrical Operations, on
its actions in response to the ice storm nor in the restoration process. No
documentation equals no lessons learned. There apparently was no organization-wide
32
process for retention of key documents for subsequent analysis to determine what
worked and what did not. In answer to a question about the lack of organization-wide
exercises, BWL pointed out that every event is an exercise, that they had a windstorm in
November 2013, which downed 3000 lines and that there were “lessons learned’ from
that event. Yet, there is apparently no documentation of any of the steps taken, nor of
the overall process used, to recover from the worst outage ever to affect the BWL
customer area.
CRT Planning and Response Working Group members met with City of Lansing
Emergency Management (EM) and Fire Department personnel. The City EM personnel
detailed their efforts to open and maintain the City Emergency Operations Center and to
assure a common operating picture for City leaders. The City EOC was in operation from
December 21 through January 3. It remained in operation to coordinate the response to
the heavy snowfall that would occur later that week. The state EOC was partially
activated on January 5, 2014
51
. The City willingly provided the CRT with copies of the
City EOC records, emails with the BWL, and CAD maps created during the outage,
based on a verbal promise from the CRT Chair to Chief Trent Atkins that we would not
distribute them.
There is a substantial discrepancy between the accounts provided by the BWL Senior
Leadership and the City Emergency Management Office, describing the flow and volume
of communications between the BWL and the City during the ice storm and restoration
efforts between December 21, 2013 and January 3, 2014.
The BWL advised the CRT, both at the March 10th public hearing and again during an
April 10th tour of the BESOC, that BWL Operations officials called in to the City EOC,
every day, for the EOC conference calls. The BWL also advised that they had a
representative in the EOC during the outage.
In contrast, Lansing EM stated to the CRT Working Group that the BWL stopped
communicating with the city on or about Day 3 or Day 4 of the outage. Further, that
there was not a BWL representative in the EOC until 30 December. As noted, BWL was
asked to explain the discrepancy on April 10, 2014, and suggested that their “phone
presence” continued throughout. Yet, the communications log from the EOC indicates
that many calls to the BESOC went unanswered or unreturned. The City EOC hosted 1- 3
conference calls each day, staring on December 22, 2013 and ending on January 3, 2014.
BWL was fully engaged with the City on 22-23 December. From the 0800 hrs
conference call on December 24
th
through the 0800 hrs conference call on December

31
hLLp://www.mlchlgan.gov/documenLs/snyder/Þ8_140103_weaLher_brleflng_p_m__updaLe_443899_7.pdf

33
29
th
, however, there was no participation from BWL; the log indicating, “Invited. No one
on call.” As noted below, the EOC communications log indicates that there was sporadic
communication from BWL between December 23
rd
and 28
th
, 2013.
Lxcerpted from C|ty LCC Commun|cat|ons Log

34
Further, the emails provided by the City EM only evidence email communications between the
EOC and BWL for the period from December 26
th
through January 3
rd
, and almost all concern
the routing of reports of outages from other sources to the BWL and their acknowledgment by
BWL. There are no emails between the BWL and the EOC prior to December 26
th
. The BWL
did not have a representative stationed in the EOC until December 30
th
and never had a
representative in the EOC with operational expertise or decision-making authority, other than
when the General Manager or other officials visited during the first two days of the outage.
Note: The CRT strongly asserts that this failure of communications cannot be attributed to
the Director of Electric Systems Operations. Electric Operations in the BESOC was
attempting to conduct restoration and emergency operations with the tools used during
normal operations. The lack of a cohesive and comprehensive emergency operations plan
included the lack of a system for scalable management staffing. Emergency operations
substantially increase the duties of the Operations section, including the need for contingency
scenario planning and implementation, recordkeeping and communications. Utility power
restoration, like many disaster responses, requires an influx of personnel to restore services.
The deployment of spotters, linemen and tree crews through Mutual Assistance Agreements
and contingency contracts necessitates an increased management capability for direction
and coordination. With 3 times the workforce on the ground than normal operation, to be
efficiently directed according to the order of restoration and evolving exigencies, required
management staffing that had not been planned for nor exercised prior to the outage. The
plan must therefore anticipate scalable management operations for the significantly
increased workforce and the increased duties of BWL management.

Findings:
1) Despite the recent weather events, there is a lack of urgency of the need for
integration with the city EOC and with the regional community.
2) The CRT believes that an integrated regional EOP is vitally needed. If a regional
EOP, which includes a regional EOC, was operating during the recent event, it
would have facilitated the coordination of services with first responders in
conducting well-checks and other services, and reduced the frustration of out-
county and other governmental leaders who were unable to get accurate
information, from BWL.
3) As discussed above, BWL does not have a comprehensive Emergency Operations
Plan, just an Emergency Action Plan detailed for certain events. BWL does not
have Emergency Manager. BWL did not have a distinct Emergency Operations
Center; during electric power outages of any duration it continues to run
operations from their BESOC.
4) BWL Emergency Operations are not coordinated with the City of Lansing, nor
with any other municipal government that represents its customer base.

33
The CRT recommends that the BWL:
1) Develop a comprehensive EOP, in coordination with the City EM officials, that is
an Annex to the City EOP, consistent with MCL 30.410 (1) (a)
2) Working jointly with the City of Lansing and other regional governments, develop
a regional EOP which includes a process for siting, supporting and sustaining a
regional EOC.
3) Develop, in coordination with the governments representing its customer base,
an Energy Annex to a Regional Emergency Operations Plan.
4) Collaborate with Lansing Emergency Management, Lansing Police Department's
Neighborhood Watch, Lansing Neighborhood Council, East Lansing
neighborhood associations and similar groups in all townships in the
development of a program supporting block level emergency response plans.
This effort would build upon the well-developed social infrastructure of Lansing's
186 organized neighborhood groups and prepare them to play an important role
in planning for, responding to, and recovering from extreme weather events.
BWL Crisis Communications
Extensive public comments were received by both the BWL and the CRT on the lack of
communications with BWL, both the inability of its customers to report downed lines,
discussed in the section on the Outage Management System, and on the lack of current, and
detailed information on the restoration efforts. The lack of knowledge of expected restoration
has an effect increasing geometrically, as it continued for some customers to the fifth, sixth,
seventh, eighth, ninth and tenth date without power, coupled with the BWL public statements
of 90% restoration. Those remaining customers felt overlooked and forgotten by the utility, as
they coped without power and heat for the holidays, discarded spoiled food, imposed on
families or neighbors and, in cases where they were able to find rooms at local hotels, returned
daily to their homes, to determine of power had been restored.
As noted in the Introduction, BWL did issue press releases three times per day, but the
information was limited to providing the number of customers without power and in most
releases, also provided the number of downed lines. Later releases added the location of line
crews and the expected location of line crews. The BWL spokesperson also had press
conferences twice daily. BWL senior officials acknowledged that they had no crisis
communications plan in place to manage messages to customers and other audiences. BWL
focused on their communications failings in their Outage Report: 19 of 54 recommendations
discuss “Customer Communications” and 9 additional recommendations discuss “External
Communications”. BWL commissioned an outside consultant to develop a Crisis
Communications Plan. A plan was issued in March 2014.
36
Findings:
1) BWL efforts were not sufficient to communicate needed information to a
community of the size of Capital region;
2) BWL did not have available the information required due to the failure of the
OMS and the lack of capacity for customer calls.
3) These deficiencies substantially reduced their level of situational awareness. The
lack of situational awareness and the lack of a coherent communications plan or
annex, lead to the transmission of information that did not meet the needs of
customers and the resultant inability of its customers to determine how they
might best respond to the circumstances. While there was daily communications,
the issue was that the quality and content of these communications was not
resulting in the messaging that the public and emergency managers needed.
4) BWL must create a long-term strategic communications plan to rebuild its trust
with its customers and community.
The CRT recommends that the BWL:
1) Create a robust social media presence for its customers – this work is already
underway internally, but must become a priority for its communications
operations, as consumers are primarily using digital communication tools to
learn about outages and other service issues.
2) Require all communications staff and senior leadership to undergo certified
NIMS communications training in order to understand best communications
practices during crisis situations, with associated training events and tabletop
exercises to ensure coordination of communications functions with regional
governments.
3) Further refine the March 2014 plan. The plan must contain greater detail on how
to address the need for timely and accurate information; customer information
must be consistently explained in a way that effectively meets customer
expectations; and the plan must assure the provision of information sufficient to
allow the public to make informed decisions on how they may best respond.
There is a considerable body of studies on this subject that should be drawn upon
in the development of such a plan. Once this plan is completed the BWL
management and employees must be trained on, periodically exercise, and follow
the plan.
4) The crisis communications plan must be an annex to the Emergency Operations
Plan and should be guided by a qualified communications professional certified
through the NIMS protocols.
37
City Emergency Planning & the Collaborative Planning Process
The Michigan Emergency Management Act, MCL 30.409 (2), emphasizes the need for a
coordinated, but locally developed and initiated plan of emergency response, naming the
mayor or his designee as the City Emergency Management Coordinator, pursuant to a process
to be detailed in the city charter.

The City Charter provides a broad foundation of authority to the mayor and city council to act
during emergencies and disasters: "[t]he City shall take such action, and adopt such
ordinances, as shall be necessary to provide for the public peace and health and for the safety
of persons and property within the City
52
." The Charter also provides the City Council power
to enact time-limited emergency ordinances
53
. The Lansing City Charter says "the Mayor shall
be a conservator of the peace. The Mayor may exercise within the City the powers
conferred upon sheriffs to suppress disorder and enforce the laws of the State and the
ordinances and regulations of the City.
54
"
Pursuant to Charter section 3-310, the City enacted the Lansing Emergency Management
Ordinance, Chapter 234, which sets forth a scheme for developing a coordinated city-wide plan
for response to emergencies or disasters, akin to the process created by the Legislature in the
Michigan Emergency Management Act, which it expressly references. The city ordinance
envisions that the Mayor, through his designee, the Emergency Management Director, shall
develop both a comprehensive plan and an ongoing program to “provide for the mitigation,
preparedness, response and recovery from natural and human-made disasters.” More than
that, of course, the city ordinance cloaks the Mayor with increased, albeit temporary, authority
as the guarantor of public health safety and welfare within the City
55
.
The Emergency Management Ordinance expressly expands the powers of the Mayor during an
emergency, to include the authority to “ Relieve City employees of normal duties and
temporarily reassign them to other duties” This requirement is quite common in legislative

32
SecLlon 3-310, ClLy CharLer.
33
SecLlon 3-308, ClLy CharLer
34
SecLlon 4-102.1. 1he language ln Lhe Lanslng ClLy CharLer ls noL as expanslve as LhaL ln oLhers. 1he ClLy CharLer
of SouLhfleld, for example, provldes LhaL Lhe mayor "ln emergencles, have Lhe powers conferred by law upon
sherlffs Lo prevenL dlsorder, ptesetve tbe pobllc peoce ooJ beoltb, ooJ ptovlJe fot tbe sofety of petsoos ooJ
ptopetty."(Lmphasls added). noLe, however, LhaL powers Lhe sLaLe leglslaLure granLs Lo Lhe offlce of sherlff are
qulLe exLenslve. 1he Mlchlgan Sherlffs AssoclaLlon webslLe conLalns a monograph by reLlred kalamazoo CounLy
Sherlff 1om Ldmonds whlch llsLs 30 sLaLuLorlly-prescrlbed duLles of Lhe Sherlff and noLes addlLlonal common law
powers. See hLLps://www.mlchlgansherlff.com/pdfs/1he°20Cfflce°20of°20Sherlff°20by°20Ldmonds.pdf
33
See, Lhe duLles prescrlbed for Lhe execuLlve branch of Lhe ClLy, parLlcularly secLlons 234.03 and 234.07.
38
delegations of temporary, emergency authority to the executive branch and the need is
obvious: the contingencies arising during disasters or emergencies frequently demand greater
deployment of personnel for temporary duties, including those duties commonly fulfilled by
fewer employees, such as clearing roads and streets and those uncommon duties, including
clearing storm debris or emplacing sandbags. Further, such events often require streamlined
command and control systems within a government, to assure a rapid, agile and flexible
response to the crisis.
While the BWL is a creation of the City Charter, its employees, unlike the General Manager,
and although fulfilling a vital public function, are not considered municipal employees.
During the ice storm, the BWL employees acted independently from the City of Lansing
command structure and sometimes without communication or coordination. It is a truism that
strong disaster response requires strong partnerships. There was no evidence of such a
partnership between the BWL and the City EM during the ice storm outage. When questioned
about communications with other governments, BWL advised that they assumed that their
discussions with the City EOC would be passed on to the other units of government.
Both the City and BWL personnel spoke positively of the personal relationships they have with
officials in the other organization and some suggested that those relationships assured
sufficient communications during the outage. And the City EOC staff also stated they had
relationships and communications with some of the other communities’ emergency personnel
during the December outage. The same assertion was made concerning emergency operations
plans, that while there had been no coordination of emergency operations prior to
implementation, the personal relationships would assure that the mutual trust between
experienced operators would assure that a solution could be identified, agreed upon, and
executed, timely.
Such an assertion, however, is contrary to facts determined during the investigation, and to
expected protocols and best practices in the Emergency Management discipline. An over-
reliance on personal relationships creates its own chokepoint to information flow. When that
communication link between individuals, say between an electrical distribution operator in the
BWL BESOC and a first responder in the City EOC is interrupted (by shift change, fatigue,
injury, overwhelmed by other duties, etc.) then the link between agencies is lost. Further, no
formal communication plan had been established for information flow during emergency
events between the Lansing City EOC and other communities’ emergency personnel, other
than the City of East Lansing.
During emergencies, there must be a clear and clean command structure. This need is directly
stated in the Michigan Emergency Management Act which provides that the state Director of
Emergency Management “shall assume complete command” of the emergency operations,
39
including by employees of other state agencies, when expressly directed by the Governor
56
. The
Act also provides the Governor with temporary authority to commandeer private property, as
needed and subject to proper compensation.
57
Within that spectrum of emergency authorities,
could reside the ability of the Mayor to direct the employees of the BWL during an event.
Findings:
1) As discussed above, there is critical need for a regional EOC, or minimally, a plan
to ensure a coordinated response for emergencies and disasters across
governmental boundaries.
2) There was a failure of communication between the City and the BWL and a total
lack of communication between the BWL and the other local governments which
represent the BWL customer service area. Assumptions were made on the
transfer of information, rather than the reliance on established, tested lines of
communication.
3) Municipal and township first responders and officials and BWL employees were
often engaged in redundant tasks, or tasks that could have been more efficiently
performed by other EM officials or responders within the region, such as the City
EOC designing outage maps of traffic lights, multiple warming centers and
information centers, the disorganized exchange of outage information by emails.
4) BWL was neither communicating nor coordinating with Lansing EOC after
December 24, 2013, and many of the other Emergency Operations Centers were
not open contributed to the confusion, lack of accurate information, and
uncertainty experienced by municipal leaders and citizens.

The CRT recommends that the City:
1) Consider amendment of the City Charter to clarify the powers of the Mayor and
to provide the Mayor executive authority over the BWL during disasters or
emergencies

2) Emergency Management Director, working with all other member communities,
including Ingham, Clinton and Eaton Counties, create a regional emergency
operations plan (EOP).


36
MCL.30.407(1).
37
MCL 30.403(1)(d).
40
3) Work with BWL Operations and Senior Leadership to integrate their BESOC and
Crisis Command Center, using the NIMS framework, with the City EOC.

4) Consider fully integrating BWL employees into the City EM structure.

5) Recommend appropriate emergency management training for BWL leadership,
including Commissioners, on how best to build in resilience and ensure full
response capability to storms that are increasing in severity and frequency.

6) Sponsor or encourage a full scale training exercise, involving emergency
management staff of all units of government and BWL in the tri-county region, to
take place annually.

Emergency Declarations
Neither Ingham County, nor the Cities of Lansing or East Lansing, declared an emergency
during the ice storm or outage. Eaton and Clinton Counties declared emergencies on 27
December. Shiawassee County, immediately to the north of the BWL customer area, declared a
state of emergency, almost immediately after the storm hit.
58
. In April 2014, the Governor
issued separate emergency declarations for Marquette County, and for Newaygo and Osceola
Counties, to permit state resources to assist the counties in recovering from the effects of the
harsh winter
59
. Although the Michigan Legislature recently appropriated monies for ice storm
clean-up.
60
, without the pre-requisite of a gubernatorial declaration, that eventuality was
unknown in December.
While, in the public’s perception, the need for state or federal resources is the prompt for an
emergency declaration, the judicious pro-active use of the declaration is an essential tool for
municipal governments. An emergency was declared by the State and the City, less than one
week later, in anticipation of the heavy snowstorm
61
. A similar anticipatory declaration would
have provided the Mayor with the authority to deploy city employees as needed, including to
assure full door-to-door, health and welfare checks of the neighborhoods, and to assist in
damage assessments and debris-clearing.
While Lansing is used as the example, this recommendation applies to all county, city and
township governments within the BWL customer service area. The ability to do so, in response

38
hLLp://www.abc12.com/sLory/24284184/shlawassee-counLy-ls-ln-a-sLaLe-of-emergency
39
hLLp://www.mlchlgan.gov/snyder/0,4668,7-277-37377_37637-326671--,00.hLml
60
hLLp://www.ml.gov/documenLs/msp/l8_-_13-06_-_SupplemenLal_-_04.22.2014_434323_7.pdf
61
hLLp://www.lanslngml.gov/medla/vlew/mayordeclaressnowemergecy/6226

41
to an extended outage, presumes that BWL is consistently and fully communicating with the
affected governments, through a jointly developed communications plan, or as an Annex to the
proposed Regional Emergency Operations Plan.
The CRT Recommends:
That all units of government within or partially within the BWL customer service area review
their emergency operations plans to include a process for assessing the need for an anticipatory
emergency declaration.
42
III. Response and Restoration
BWL Storm Response
The BWL leadership advised that they tracked reports of the approach of the ice storm. There
was resistance to CRT suggestions at the March 10
th
hearing for pre-positioning equipment or
personnel. BWL leadership suggested that without knowing the extent of the storm, or
geographic area of greatest damage, then it would not have been cost effective to pre-position
equipment.
The goal of storm damage prediction, however, is to forecast the amount of damage a storm
will produce, the resources required for restoration and the approximate time to restore
service; it is an essential part of the storm management process, providing triggers for levels of
storm center activation and crew mobilization
62
.
It should be noted that the MPSC staff report on DTE and Consumers Energy found that
Consumers Energy did not have significant mutual aid crews working on the first two full days
of the storm restoration. In contrast, DTE started monitoring the ice storm on December 17
th

and held preparatory storm strategy discussions on December 18
th
. And on December 19
th

DTE made the decision to secure out-of-state resources and have them on site before the storm
occurred, notified their employees of the impending storm, put local contract crews on standby
for line work and vegetation management on call, and ramped up all DTE Electric storm
support crew. DTE Electric’s preplanning was advantageous as they had 317 line crews
working to restore service on the first day of the storm restoration
63
. The duty of the damage
assessors, or “spotters” is to patrol the rights of way to identify trouble spots, evaluate the
extent of the damage, and develop initial estimates of resources needed for restoration
64
. Best
practices call for the spotters to be pre-positioned or at least staged prior to the storm hitting
the area, for the spotters to be well- familiar with the system and the geographic area, and to be
well-trained in damage assessment
65
.
A review of published after-action reports support the BWL contention that the period of time
needed to assess the storm damage, to survey all the lines, record and tally the number of
equipment damaged (broken poles, spans of wire down, damaged transformers, etc.), and the
location of the damage and then to return file that information at the BESOC where it must be
prioritized against the current crew locations, equipment availability and the Order of

62
See 8LS1 Þ8AC1lCLS lC8 S1C8M 8LSÞCnSL Cn u.S. ulS18l8u1lCn S?S1LMS, sopto noLe 13.
63
MÞSC SLaff reporL uecember 2013 lce SLorm, pg 13.
64
lJ.
63
lJ. Also, coooectlcot Octobet 2011 5oowstotm lowet kestototloo kepott, WlLL AssoclaLes, uecember 1, 2011, p.21.
43
restoration, prior to dispatching crews to perform the repairs, was the greatest bottleneck in
the restoration process.
But industry and BWL recognition of the problem does not excuse it, as the Best Practices
compiled by utilities with similar storm-caused outages in the last few years attest. The BWL
had only 18 spotter crews available on December 22
nd
, rising to 23 crews on December 27
th
.
More telling, the need for spotter crews never diminished, as spotter crews, in similar
numbers, were deployed throughout the time period of restoration, save for individual
breaks.
66
BWL has identified some specific steps
67
to address the “spotter bottleneck.” In the
2011 Connecticut outage, reviewers suggest that it would have been prudent to pay standby fees
to out-of-state crews, given the lack of local mutual aid assistance available due to the size of
the storm and the lengthy delay in restoration caused by the non-availability of sufficient
spotters. Pre-staging spotters can be cost-effective by reducing the overall cost of repairs and
the amount of time electricity is out if there is significant damage. Connecticut Light and Power
Company is an order of magnitude larger than BWL, with almost one million customers and is
investor-owned.
BWL concedes that it lacked sufficient linemen internally to address the scope of the
restoration. BWL, due to its relatively small size, always planned to rely on Mutual Aid
Agreements (MAA), primarily through the Michigan Municipal Electric Association. This
proved an insufficient pool of assistance crews, however. On December 22
nd
, BWL reports that
it had 20 line and tree crews available. From December 29
th
-31
st
, they deployed 54 line and tree
crews. The documents received from BWL and its Internal Outage Report describe the
scramble to identify the number of crews needed, to locate the crews and to execute
contingency agreements (both for spotters and line crews). In response to the CRT second
request for information the BWL reported that several mutual aid agreements were executed
during the restoration and they initiated a RFP for additional mutual aid agreements following
the December 13, 2013 storm. Contracts and billing statements for mutual aid agreements
during the storm were provided to the CRT and reveal that there was substantial cost for
external aid during that period. It is difficult to determine if the cost for those external services
provided by entities that did not have mutual aid agreements prior to the storm were more
than if the BWL had had pre-existing agreements. But it is clear that following the storm the
BWL is increasing the number of mutual aid agreements it has.
As noted above, BWL conceded to the CRT that a functioning OMS would have likely reduced
the outage by 2 days. This admission, coupled with their acknowledgement that they did not
have sufficient spotters to ascertain the extent of the lines down, tends to confirm that BWL

66
8WL uecember 2013 lce SLorm CuLage 8eporL, p33.
67
lLems 10-14, 8WL lce SLorm CuLage 8eporL (addlng spoLLers and llne crews (addresslng Lhe boLLleneck) and Lralnlng for
spoLLers, developlng common reporLlng forms & poLenLlally conLracLlng wlLh elecLrlc servlce flrms for damage assessmenL).
44
lacked awareness of the scope of the problem and explains in part why their initial response
was not as robust, efficient or quick as it should have been had they known the full extent of the
damage. This lack of situational awareness then caused unduly optimistic early reports to the
media and to local emergency managers that they had the situation under control and further
resources or actions were not needed. For example, the BWL media release that said
customers should only report down lines and not power outages further hampered their
situational awareness. While BWL may have known the number of customers without power,
they did not know the extent of the downed lines, which increased the time needed to restore
power to the circuits and then the time needed to repair feeder lines and then individual
customer lines. While this problem is partly traceable to the subsequent weather, which
knocked down additional lines, it was directly and largely caused by lack of sufficient number
of spotters at the onset of the storm and the loss of the OMS.
The lack of good information to quantify the full scope and potential duration of the restoration
and recovery led to decisions that tempered the response effort. In an energy emergency, the
quality of the initial assessment phase is critical to the response and recovery effort. It is wiser
to plan, and be prepared, for the worst-case, and then stand down, than to under-prepare and
have to mobilize late, prolonging the recovery efforts.
During the public hearings held by the CRT, there were several questions involving how many
BWL employees were required for a crew repairing downed power lines and whether a BWL
employee had to accompany outside contracted repair crews. The CRT has reviewed the
current collective bargaining agreement (effective 11.01.2012 – 10.31.2016) between the BWL
and the International Brotherhood of Electrical Workers, AFL-CIO local 352. Article XI of that
Agreement address safety and establishes a Safety Committee to Joint Safety Committee
comprised of equal numbers of Employer and Union representatives to develop safety rules.
Article XI, Section 9 of the Collective Bargaining Agreement provides in part:
“Only as a reflection of a custom in the electric utility industry to express specifically in a
collective bargaining agreement, as well as in the “Safety Rules”, and the understanding of the
parties to the particular Agreement on this aspect of electric utility work- the parties hereto
agree that two (2) or more employees, qualified in the judgment of the immediate supervisor of
the job, shall work together whenever wires or equipment are energized at more than 500 volts
to ground or, in the judgment of the supervisor of the job, wiring is congested or unusual
exposure is involved. ---- To accommodate working one person primary, exceptions to the
language in the preceding paragraph may be made for specific situations. Such specific
situations must be approved by the Joint Safety Committee, ratified by those persons currently
holding the classification of Line worker and must be in keeping with industry practices.
Specific situations shall become part of the Board of Water and Light “Safety Manual” and
appear under a heading “Rules for one person in primary”. Two person line crews shall be
made up of two Bargaining Unit journey workers or a qualified apprentice.”
43
In discussions with BWL staff, the CRT was told that it is a requirement that one BWL
electrical utility worker accompany any line crews providing line maintenance under a mutual
aid agreement. It was stated that this requirement is for safety reasons to ensure that repairs
and restoration of service is in compliance with the BWL standards, i.e., to ensure that when a
BWL employee has to maintain that line or connection in the future she/he is ensured that it
meets BWL standards. BWL noted that the three-man crew requirement only applied to
primary, not secondary, lines, and that the BWL supervisor could supervise more than one line
crew in an area. There was discussion, based on citizen and outside expert suggestions, that the
requirement for three-man crews unduly delayed the restoration period. While the timeline
suggests that BWL should have called in crews sooner and should have had more contingency
agreements executed and ready, there is not sufficient evidence to conclude that the size of the
crews was a factor.
Findings:
1) There were an insufficient number of Spotters, particularly “A” Spotters. The
CRT must emphasize the importance of having sufficient numbers of trained staff
(spotters, repair and central command) sufficient to handle emergencies of this
size and that they do mock trainings with all staff involved more frequently than
once a year and provide refresher training to staff spotters on a regular basis.
2) BWL concedes that they did not have sufficient mutual aid agreements in place,
and has taken steps to address this deficiency. But while there may have been
sufficient linemen, by the end of outage period, there does not appear to be
similar Agreements for Spotters, even though that is an acknowledged "choke
point".
3) BWL has hired three additional linemen, according to its Outage report.
The CRT recommends that the BWL:
1) Given that insufficient spotters for damage assessment was a serious problem in
the December outage, identify the types of spotters necessary and currently
lacking.
2) Include the acquisition of qualified primary distribution system spotters in its
mutual aid agreements and extraordinary assistance contracts. Since repair crews
are fundamentally more expensive than spotters, we believe that repair crews
should be the restoration bottleneck rather than spotters.
3) Identify specific personnel for spotter duty and training for deployment in
emergencies. This function should be mandatory, not voluntary on the part of the
employee, as it appears to be now. Training should also be mandatory and held,
minimally, once per year.
46
4) That the two person line crew requirement and the requirement that a BWL
employee accompany the outside contracted line crew are reasonable to ensure
safety of BWL employees.
Outage Management System
The BWL determined that it needed a new Outage Management System (OMS) in 2010. The
OMS is designed to model outage status in the field in order to aid in managing operations by
predicting the cause of a cluster of outages and giving estimated restoration times. This system
allows data about outages to be submitted directly to the OMS via customer telephone calls.
The BWL received two bids, from General Electric and CGI, and selected the bid from GE.
BWL began implementation of the OMS in early 2013, despite the fact that the purchase
agreement was signed in late 2011. After considerable delays and missed deadlines, the OMS
was installed and operational by February 2013. Bugs had become evident by May 2013,
requiring further servicing by GE. The OMS was not operational again until November 2013,
just weeks before the December ice storm. A storm in November 2013 revealed some
additional issues with the OMS, including repeat calls from the same customer being reported
as a wider outage and problems with “conductor cuts”. These issues were reported to GE, but
fixes were not put into place before the December 2013 ice storm.
Note: There are gaps in the information provided the CRT on implementation of the OMS,
including why a system contracted in late 2011 was not installed until February 2013. The
CRT heard, but was not able to confirm, that the installation in early 2013 was done only
after BWL threatened to withhold payment to GE after multiple missed deadlines. Further,
we were told that installation was done too quickly, that defects surfaced in May, and again
in November 2013, and that the fixes contracted for these defects were still not completed in
December 2013 when the ice storm occurred.
The link between the call center and the OMS was tested prior to the ice storm, but was never
tested under the load experienced during the outage. Alarms designed to alert the BWL if
either the call center stopped sending data or if the OMS stopped receiving it were not tripped.
During the outage, data from thousands of customer calls was not sent from the call center to
the OMS.
Besides its inability to process the sheer volume of data received from customer calls, emails
and data inputted by BWL CSRs, the OMS had another flaw: it could not account for the
“conductor cuts.” Conductor cuts are intentional cuts of power lines in the field made to close
in a circuit to restore power. The OMS was not able to recognize that the intentional cuts had
continued loss of power and reported that the entire circuit was restored. As a result,
customers calling in December to report power outages in the areas serviced by the
intentionally cut lines were told incorrectly that their power had been restored.
47
This disconnective flaw in systems between the operations process used by the restoration
crews and the information system created by the IT department and its contractors made an
organized, considered plan of restoration impossible. Because the OMS was detracting from
the operators’ ability to accurately track the scope of the outage, the BWL Electrical Operations
decided to discontinue its use. The decision to “pull the plug” on use of the OMS was made on
either December 22
nd
or 23
rd
of 2013. All data, whether from customers or BWL employees, on
location or causes of outages, that had been entered in the first two days of the outage was thus
inaccessible by Operations, and had to be re-created. When the conductor cut issue with the
OMS system was fixed and the OMS was re-started five days later, the data on OMS was lost in
the re-start.
Without the OMS, and without a backup system, Electrical Operations had to resort to an ad
hoc paper system, which Operations candidly and repeatedly described as either “organized
chaos” or “chaos”: the Spotters had to manually enter their findings on a paper report and
drive those reports to the BESOC, where the reports would then have to be analyzed and then
compiled into an order of restoration according to the pre-existing priority system, not as
chronologically received or based on the size of the outage. The work orders to the line crews
were then created and documented on paper and the crews dispatched via 800 Mhz radio. But,
when the crews had finished at a location, the record of completion had to then be manually
created as well. A stand-alone laptop in the BESOC was used to create an Excel spreadsheet
containing this data.
BWL asserted to the CRT that if the OMS System had been operating fully in December 2013, it
would not have significantly accelerated restoration. This statement seems to contradict other
statements made by BWL officials. We were told that the OMS failed to accurately report the
number of downed lines early on, and that this, in part, is why too few damage assessment
teams were dispatched. Once dispatched, they were unable to communicate directly from the
field to the OMS, which resulted in delays getting line crews out, etc. etc. The malfunctioning
OMS was a critical, missing, element in the response and restoration actions of the BWL.
Certainly the most common but often the most expensive form of resiliency is to maintain a
redundant system. BWL was specifically questioned why they did not maintain their pre-
existing outage management system until the new General Electric OMS system was fully
functional. Their reply was that it would be time-consuming and potentially confusing to enter
the data twice- first to the OMS and then to the pre-existing system. While the CRT concedes
that the maintenance of two systems is labor-intensive, certainly there is a spectrum of
solutions between redundant full systems and an ad hoc paper system. Maintaining the pre-
existing system during 2012-2013, given the known recurring problems with the OMS, would
have been worth the expense in labor costs. At a minimum, the OMS, which had a number of
patches applied during implementation, could have had a separate backup data storage
installed, so that even if they used the OMS exclusively, there would have been redundant data
storage.
48
Summary of CRT Findings
BWL entered the winter storm season with an OMS system known to be unreliable. The
malfunctioning OMS was a critical but missing element in the response and restoration. BWL
was overly dependent on the OMS system, even prior to final testing. They discarded the
previous system too quickly. OMS lacks redundancy. The system failed during the December
outage and had no backup system. The system could fail during next the outage for different
reasons. (BWL acknowledged lack of power to REO Town HQ, while OMS is apparently located
elsewhere, the point is that localized power failures can occur; IT systems can be hacked or
disrupted, etc). They accepted assurances that OMS was fully operational without fully testing
the system. No back-up system or redundancy was apparently even considered, much less
implemented. If the OMS had been fully operational, then power restoration would have been
completed at least two days earlier, AND BWL could have more accurately advised the public
of areas for restoration and date of power restoration for each circuit.
The CRT Recommends that the BWL:
1) Integrate the OMS into an Emergency Operations Plan (EOP) which is tested to
its maximum capacity
68
., both to assure system functionality and to assure
integration with restoration operations, on a semi- annual (6 months) basis. Staff
noted that because they had not experienced an outage of more than 20,000
customers, they assumed that was the maximum ever likely. As noted above,
recent reports indicate that storm frequency and intensity are on the rise. Since
the outage, the now apparently functional OMS has been tested for loss of power
to 35,000 households—still fewer than lost power in the December outage.
Therefore, the system must be tested to its maximum capability
2) Remedy the lack of redundancy in their OMS System by (1) devising an
alternative system and (2) including the potential loss of OMS as a contingency
in EOP. The OMS failed during the December outage and had no backup system.
3) The IT Department shall report OMS implementation and maintenance and
redundant system development to the Board of Commissioners at least monthly.
Further, the Commissioners should carefully review the history of the selection,

68
lLem 23 (8WL lce SLorm CuLage 8eporL, p. 43) only calls for ºperlodlc sLress LesLs". 1he CMS needs Lo be LesLed regularly
wlLh maxlmum capaclLy demands, lncludlng coordlnaLlon wlLh lv8 & 877 sysLems (CuLage 8eporL, pg 49) & call cenLer sLaff.
lurLher, lL needs Lo be LesLed ln slmulaLed emergency exerclses wlLh all sLaff parLlclpaLlng. As dlscussed elsewhere hereln,
Lhere ls a lack of coordlnaLed, uLlllLy-wlde Lralnlng for emergency evenLs and a lack of senlor-leadershlp emphasls on
Lralnlng and readlness.

49
installation, and performance of the GE OMS system to determine if further
action is required.
4) A contingency retainer agreement with a third-party answering service must be
executed. This is consistent with the BWL changing its corporate philosophy to
one that plans for, recognizes, and addresses all potential contingencies.
69

Recordkeeping

The CRT experience in obtaining records from the BWL was replete with instances where
records were not forthcoming, in some cases, ever. There are a variety of reasons: (1) the BWL
senior leadership does not preserve its emails; (2) BWL adheres to a policy of non-distribution
of any records it deems “sensitive information”; and (3) since there is no institutionalized
system for communications during emergency events with the municipal governments which
represent its customer service area, neither is there a protocol for preserving the records of
those communications.

While the BWL produced more than 4,000 pages of email printouts, including many duplicate
email chains, the response was accompanied by a caveat that 20,000 pages of emails (a
particularly large number considering the claim that senior leadership does not maintain its
emails) had to be reviewed to be culled of material that the BWL considered sensitive of
confidential.

The “Records Retention Policy and Records Retention and Disposal Schedule” received from
the BWL asserts that it is their corporate policy to “only retain records during the period of
immediate use” and then, unless required by law to be retained, are sent for disposal. While
their policy undoubtedly adheres closely to applicable state law, it also makes meaningful abter
action analysis impossible.

The BWL is a publicly-owned utility and thus, the owners of the utility have a right to expect a
full review by its representatives, subject to narrow statutory exceptions. Without any record of
its actions, the public and its representatives have no means to independently confirm or
validate the actions of the BWL.

As an example: the CRT received a summarized chart of the BWL’s Order of Circuit
Restoration in response to its first request for documents and answers along with copies of
press releases listing the street intersections that crews were working on each day. In order to

69
8WL was speclflcally quesLloned why Lhey dld noL malnLaln Lhelr pre-exlsLlng ouLage managemenL sysLem unLll Lhe new
Ceneral elecLrlc CMS sysLem was fully funcLlonal. 1helr reply was LhaL lL would be Llme-consumlng and poLenLlally
confuslng Lo enLer Lhe daLa Lwlce- flrsL Lo Lhe CMS and Lhen Lo Lhe pre-exlsLlng sysLem. Whlle Lhe C81 concedes LhaL Lhe
malnLenance of Lwo sysLems ls labor-lnLenslve, cerLalnly Lhere ls a specLrum of soluLlons beLween redundanL full sysLems
and an ad hoc paper sysLem. MalnLalnlng Lhe pre-exlsLlng sysLem durlng 2012-2013, glven Lhe known recurrlng problems
wlLh Lhe CMS, would have been worLh Lhe expense ln labor cosLs. AL a mlnlmum, Lhe sysLem, whlch had a number of
paLches applled durlng lmplemenLaLlon, could have had a separaLe backup daLa sLorage lnsLalled, so LhaL even lf Lhey used
Lhe CMS excluslvely, Lhere would have been redundanL daLa sLorage.
30
compare the Order of Restoration to the actual restoral process, the CRT requested a list of
each circuit and a map demarcating the location, by nearest street address, of all circuits listed
in the “Circuit Restorations Schedule” but was told that information was considered sensitive
and could not be reviewed
70
. The BWL relied on the North American Electric Reliability
Corporation (NERC) guidelines in its refusal
71
. The NERC Guidelines, however, clearly
envision that the utility will have developed a policy or plan for the handing and labeling of
sensitive documents. The CRT expressly requested, in its Second Request for Documents, the
“BWL Policy on classification of plans and other documents
72
.” None was ever received, leading
to the conclusion that none existed. The CRT could not independently determine whether the
Circuit Restorations Schedule had been followed.

The industry has spent some time and energy on the issue of restoration planning. The
February 1, 2012 edition of TD World contains the results of a survey of 250 utility
professionals. A key finding was the interest in automating their restoration planning and
action processes. This effort is more amenable to large utilities with the available initial and
continuing funding than smaller utilities
73
. Other independent surveys, studies, or consulting
reports have produced various recommendations for restoration best practices
74
. This
publication contains a reasonably comprehensive explanation of the actions, technical and
administrative, necessary to prepare for and effectively respond to a large outage, including
management and mobility of emergency resources and emergency staff before and during the
crisis; damage assessment; crew deployment; external and internal communications; and a
process to ramp-down during recovery after restoral.

Thus, even internal “restoration plans” must include mobilization or deployment sequences or
be little more than technical guidance for the field and line engineers or lists of personnel and
entities to contact.

The information, which should be maintained during a power restoration, which also should be
maintained for post-restoration documentation:


1hose guldellnes broadly deflne ºsenslLlve lnformaLlon" as any daLa or lnformaLlon whlch could be used Lo LargeL elecLrlc
secLor crlLlcal lnfrasLrucLure, damage faclllLles, dlsrupL operaLlons or LargeL lndlvlduals. 1he guldellne conLlnues, however
and asks a serles of four quesLlons for Lhe uLlllLy Lo analyse wheLher Lhe daLe or lnformaLlon should be consldered
ºsenslLlve." 1he only quesLlon whlch could apply ls Lhe query, ºCould someone lnLenL on causlng harm [Lo faclllLles] use Lhe
lnformaLlon Lo hls or her advanLage?" Agaln, a quesLlon so broadly wrlLLen as Lo lnclude any poLenLlal operaLlonal
lnformaLlon.
71

72
See 8equesL #3, C81 Second 8equesL for uocumenLs and Answers Lo 8WL.
73
1ransmlsslon and ulsLrlbuLlon World Magazlne (1&u World), lebruary 1, 2012
74
8LS1 Þ8AC1lCLS lC8 S1C8M 8LSÞCnSL Cn u.S. ulS18l8u1lCn S?S1LMS, by Lavelle A. lreeman - CL Lnergy/uS1A8 ,
Cregory !. SLano - Wlsconsln Þubllc Servlce CorporaLlon and MarLln L. Cordon - lndependenL ConsulLanL , presenLed aL Lhe
2010 ulsLrlbu1ech, March 23rd, 2010, 1ampa, lL
31
1. Lists of personnel hours used in restoration,
2. Components and equipment used in restoration actions,
3. Substation Components, e.g., transformers, from company storage used for restoration,
4. Substation Components, obtained or borrowed from other utilities,
5. The sequence of restoration actions
6. The assignment of restoration actions to individual field and line engineer units
including specialized equipment used,
7. The sequence of restoration achievements, i.e., records of service areas restored to full
connectivity and customers reconnected.
8. Logistics/staging/housing actions performed to maintain response personnel and
equipment.



The CRT recommends that the BWL:

1) Maintain and retain all information developed during restoration operations,
including all forms of communications. Retaining this information will assist
post restoration analysis, enhance institutional retention and uses of valid
lessons learned, and improve the technical competencies of field engineers and
technicians, as well as assuring operations or restoration manager’s decision
making processes are more clearly understood by future key personnel.

2) Information to be retained should include:

a. A full log of the operations/restoration center input (phone calls, emails,
radio messages, etc.), including identification of individuals sending and
receiving, during the event.
b. A full log of output, as in #1 above.

c. Set of maps, optimally GIS, depicting the stages of the event, including at
least, the initial outage area and affected components and customer zones,
and stages of restoration sufficient to recreate the series of restoration
actions leading to full restoration.

d. Full log of personnel engaged in restoration activities.

e. Full log of components and equipment used. This, optimally, would
differentiate between components initially/originally identified for the
restoration and those identified during the event based on discovery of event
damage.

f. Log of field engineer actions; optimally with enough specificity to
distinguish technical actions vs. administrative actions.

g. Log of physical access entries, either IAW or similar to NERC CIP standards
for Physical Access to BES sites.

32
h. Log of all connections to the local control systems during the restoration,
including full hardware/software descriptions and each connecting devices
security certificate.

i. Log of interactions with partner utilities, Independent/Regional Systems
Operators (ISO/RSO), private, state and federal regulatory organizations,
state utility commissions, state governing personnel, federal entity
personnel supporting restoration activities, as well as other personnel or
organization interactions relevant to the restoration or an understanding of
their role or influence on the restoration activities.

3) Retain this documentation in a form that enables efficient use, recall, and reuse,
and in a format that is compatible with performing the same series of retention
actions for future events; i.e., not a ‘one time” storage, but with future use and
comparison in mind
75
.

73
LlsL complled for Lhe C81 by Mr. L. uanlel MaLhls , a reLlred experL from Lhe Mlsslon Assurance ulvlslon, naval Surface
Warfare CenLer, uahlgren, vlrglnla.
33
IV. Recovery and Mitigation
Tree and Vegetation Management
BWL contracts with an out-of-state tree management service, Wright Tree Service. A
substantial proportion of the comments received from the public centered on the lack of tree-
trimming in their neighborhood or criticized the efforts of the contracted service. The prior
system of vegetation management had significant flaws
76
, most of which have been
acknowledged by BWL. BWL has committed
77
to contracting with additional companies for
tree-trimming, to closer supervision of its contractors, to adherence to a five-year schedule of
tree-trimming, and to increasing the budget for that purpose.
The vegetation management efforts by BWL and by the City of Lansing or East Lansing are not
coordinated.
In Lansing, the City Operations and Maintenance Department is responsible for maintenance
of all city-owned trees. This responsibility includes all trees in public parks and the Groesbeck
Golf Course, but most notably on the tree lawns or parkways on the city streets. The BWL is
responsible for maintaining the vegetation in its Rights of Way (RoW). In the City of Lansing,
approximately 50% of the RoWs for residential service run through the tree lawns along the
streets. Both the City and the BWL, then, have responsibility for vegetation management in the
same areas. This lack of coordination has led to past instances when the City of Lansing and
the BWL Contractor are trimming in the same neighborhood at the same time. It is possible
then, the Lansing resident, through his taxes and rates, is paying two municipal entities to trim
the same tree on the same day.
The City of East Lansing Department of Public Works manages tree trimming and tree
removal, but also contracts with a third party, Ayles Tree Service, to do the vast majority of the
work. The City of East Lansing reported very favorably on Ayles Tree Service for response
time, service and cost. It was noted that the BWL has not and does not coordinate with the
City of East Lansing as the City has very different needs than the BWL. The City only trims the

76
ln lLs responses Lo Lhe C81, Lhe 8WL produced several vegeLaLlon ManagemenL plans, whlch varlously descrlbed a Lhree,
flve, and seven year roLaLlon for Lrlmmlng ln lLs cusLomer area. When asked abouL Lhe dlscrepancles, Lhe 8WL explalned
LhaL whaL sLarLed ouL as a Lhree year cycle became a flve year cycle when lL was deLermlned as malnLenance was
performed LhaL Lhe enLlre servlce area could noL be compleLed wlLhln Lhree years, whlch Lurned lnLo a seven year cycle
when lL became obvlous LhaL Lhe malnLenance could noL be compleLed on Lhe flve-year Llme Lable. 8WL also acknowledged
LhaL many clLlzens have prevlously complalned abouL Lhe loss of Lhelr Lrees from a rlgorous Lree-Lrlmmlng program, whlch
ln Lhe pasL caused 8WL Lo leave ln place many branches or Lrees whlch overhang power llnes.
77
8WL lnLernal 8eporL, 8ecommendaLlon 7: º1he 8WL wlll sLrlcLly adhere Lo a 3 year Lrlmmlng cycle and ls ln Lhe process of
modlfylng lLs Lree Lrlmmlng sLandards and procedures Lo remove all branches locaLed above dlsLrlbuLlon llnes and beLLer
proLecL lLs llnes durlng a ma[or sLorm."
34
public trees located in the City rights of way or in public parks. In a number of locations,
especially neighborhoods, the power line rights of way are located in rear yards along property
lines. The City of East Lansing also noted that when BWL needs to trim trees in East Lansing,
the BWL or their contractor usually notifies the City and advises of the locations where they
will be completing trimming or removal work. The City ensures that the BWL or their
contractor notifies the affected property owners. Many times, depending on the tree work
scope, the City will issue a press release to advise its residents of the work location and of the
BWL contacts.
Findings:

1) Vegetation management is essential to reducing storm-induced outages in the
secondary distribution system. The failure to follow their vegetation management
schedule was a key-contributing factor to the magnitude of the downed lines.

2) Many homeowners have resisted more aggressive vegetation management, and
many tree-related outages were caused by trees outside of the utility right of way.
These trees would not have been addressed during typical vegetation
management practices and have been shown to greatly affect the reliability of the
distribution system.

3) More consistent vegetation management and distribution system maintenance
over the years would have reduced the total number of outages and downed lines.
Michigan’s diverse landscape of vegetation, however, makes a one size fits all
cycle length ineffective in some areas, as shown by the BWL’s shifting vegetation
management cycle target. Effort must be taken to account for vegetation
prevalence when creating the maintenance plan.
78


4) When problem vegetation is identified outside of the utility right of way, efforts
should be taken to communicate to the customer the dangers of the hazard. The
communication should be documented.

5) While some lists of Best Practices have recommended a four-year cycle of
vegetation management, adherence to the promised five-year cycle coupled with
the recommendations below, should be sufficient.


The CRT recommends that the BWL:

1) Contract with, or otherwise fund, the City of Lansing Operations and
Maintenance Division to do all tree trimming for BWL in those areas (treelawns
and adjacent to city parks and golf courses) where the City is already engaged in
vegetation management.

78
MÞSC SLaff vegeLaLlon ManagemenL 8ecommendaLlons: hLLp://eflle.mpsc.sLaLe.ml.us/eflle/docs/17342/0032.pdf
33
2) Evaluate its 5-year schedule to determine whether vegetation management needs
to be even more aggressive. Based on the Board’s representation that it has been
close to a five-year cycle for vegetation management, however, it is doubtful that
shortening that cycle will provide much benefit. Rather, based on both public
comments and comments from the BWL, focus should be placed on a strong and
effective quality assurance program. Adjustments to the vegetation management
standards must be made, especially with respect to the removal of dead trees or
trees in poor condition.
3) Perform an 100% audit of all lines annually to ensure both that the BWL can stay
on track in its vegetation cycle and that sections that may require immediate
attention are not neglected.
4) Explore collaboration with other entities doing tree-trimming (City of East
Lansing, Townships, Consumers Energy, DTE) in order to increase efficiencies.
Grid Asset Management

Lansing Board of Water and Light’s electricity distribution system includes a large number and
a substantial variety of components. The management of those assets is a critical activity that
affects the reliability of the BWL’s distribution grid. According to BWL staff, the current budget
for distribution grid maintenance is based on historical expenditures. Based on data presented
in the BWL’s report on the outage, however, the rate at which various components are replaced
in a typical recent year appears to be well below the rate of replacement consistent with the
expected life of those components. For example, it appears that distribution lines are being
replaced at a rate consistent with a 120-year average life, which is unreasonably long. Our
experience is that organizational decision-making about whether equipment conditions
warrant replacement is strongly shaped by the relative paucity or generosity of the
maintenance budget. Our recommendations for grid hardening and improvements in the
BWL’s ability to repair its distribution system after storm damage can be implemented at the
appropriate pace if supported by an asset life-cycle based budget rather than historical
expenditures that may not match even routine maintenance needs.
The CRT also notes that some grid maintenance or modernization activities can be done more
cheaply or with less cumulative impact on adjacent properties if done in coordination with
municipal infrastructure work.
Findings:
1) BWL reliability is dependent upon the proper maintenance and management of
electrical distribution system.
2) The BWL rate of replacement is below the rate of replacement based on the expected
life of the components.


36
The CRT Recommends that the BWL:
1) Budget for distribution system maintenance based on regular replacement of
each and every component at its engineering-based life-length and continue to
recalculate its grid maintenance budget on that basis in all future budgets.
2) Implement a procedure that actual replacement of most grid assets will be
condition-based, or because distinctly better technology is available and warrants
replacement of equipment that is not yet at end of life.
3) Establish a process of long-term scheduling and annual work coordination in
conjunction with each of its host communities.

Critical Facilities

Securing Downed Lines

Approximately 400 lines broke during the December 2013 ice storm. Most of the restoration
work during the first two to three days appears to have been securing downed lines.

The number of downed lines that must be secured can be reduced through general grid
hardening, which we address below. This section focuses on accelerating the process of
securing downed lines so that energized lines are not a risk to public safety.
The CRT believes that, upon investigation, the BWL will find that use of modern distribution
circuit interrupters that can automatically detect, isolate, and report on line breaks, arcing
currents, and other circuit safety problems will be warranted at key locations in the primary
distribution system and perhaps at the origin of each distribution feeder line. We further think
it likely that remotely operated breakers/reclosers are warranted on the down-current side at
each branch point in the secondary distribution grid and perhaps at selected other locations in
longer feeder lines. We anticipate that systematic comprehensive deployment of circuit
interrupters will enable the BWL to effectively turn off power to all downed line locations very
quickly and without using valuable spotter time to guard down lines and line crew time to
perform line cuts upstream of downed lines.

A significant portion of live downed lines are service drops from the distribution system to
customer buildings or damage to distribution lines as a result of service drops being pulled
down. It is possible to reduce this problem, accelerate the repair of service drops, and reduce
the problem of damage to customer masts by using service drops that “unplug” from the
distribution line when weighted down. The Electric Power Research Institute has completed a
demonstration project using a product that combines service drop breakaway with overload
protection, which may be the preferred product category for an effort like we recommend. The
cost of breakaway service drop devices is small, so the BWL can minimize the cost of installing
breakaway service drops by concentrating on strategies that minimize labor costs, but the BWL
should undertake a benefit-cost analysis as to whether some more aggressive plan for the
installation of breakaway service drops might be worthwhile.



37
Findings:

1) A significant portion of the live downed lines were service drops from the
distribution system to customer buildings or damage to distribution lines as a
result of service drops being pulled down.

2) The use of service drops that “unplug” from the distribution line when weighted
down would reduce the number of customer masts damaged or pulled down by
customer service lines.

The CRT recommends that the BWL:

1) Undertake a value engineering analysis of the potential deployment of automatic
circuit interrupters in its distribution grid and implement them accordingly.

2) Adopt the practice of installing breakaway service drops whenever it installs or
repairs a service drop or performs major maintenance on the distribution line to
which a service drop is connected.

3) Perform a benefit cost analysis to determine whether a proactive effort to install
breakaway service drops is warranted.

Hardening the Primary Distribution System

The primary distribution system is addressed separately because faults in the primary system
affect large numbers of customers and require greater skill to repair. In the December 2013 ice
storm, repairs to the primary distribution system took from the second to the sixth day of the
outage, and the repairs to the primary distribution system effectively restored service to a
substantial share of the Board’s customers.

There are a variety of options to reduce the extent of damage to the primary distribution
system that will result from damaging storms. These include, but are not limited to:

• More frequent or severe vegetation management
• Adding additional laterals and circuit management equipment to enable more power
rerouting around faults
• Using wire that can sustain higher loads
• Using ice-phobic wire
• Using stronger pole-top configurations
• Using taller poles to stay clear of shorter vegetation
• Shorter spacing between poles
• Relocating lines to less-vegetated places
• Undergrounding

Each of these practices has costs and benefits that vary with location and conditions. Neither
the CRT nor the BWL are currently in a position to evaluate the best options in each location of
38
the BWL’s grid. We simply note that the current design of the grid is a result of historical
decisions when reliability expectations, weather, and technological options were different than
they are today and therefore should not be assumed to be optimally designed for current or
future conditions.

In performing this value engineering analysis and in implementing grid improvements and
maintenance practices, the BWL should be cognizant of opportunities to reduce costs (or
improve results) through collaboration with host communities. For example, it will be
significantly cheaper to place a line underground if conduit and vaults for this purpose are
constructed in conjunction with municipal street, water, or sewer projects than if the work is
done entirely by BWL as a separate activity.

Finding:

BWL was engaged in repairs to the primary distribution system from the second to the sixth
day of the outage, which effectively restored service to a substantial share of the Board’s
customers.

The CRT recommends that the BWL:

1) Undertake a value engineering analysis of its entire primary distribution system,
with the intent to calculate the optimum extent and topology of the primary
distribution grid, and the optimum design of each segment of its primary
distribution grid. This analysis should consider all aspects of distribution grid
performance, but particularly should include strong consideration of its effects on
outage extent and time to service restoration in major storm events.

2) When performing value engineering of the primary distribution grid and in
implementing any hardening of the primary distribution grid, the BWL should
examine opportunities to reduce costs (or improve results) through collaboration
with host communities.

Accelerating Repairs to the Primary Distribution System

Based on representations from the BWL, we believe that it currently has sensors in place
which allow it to automatically detect outages in the primary distribution system. As
discussed above, BWL staff advised that the process to repair the primary distribution
system following the ice storm was rate-limited by the ability of spotters to patrol and
localize the line breaks causing the outages rather than by the ability of repair crews to
make the necessary repairs. The Board should seek methods to accelerate primary
distribution system fault localization and identification.

Finding:

The identification and assessment of the location and cause of outages in the primary
distribution system was a substantial cause of the length of time for restoration.


39
The CRT recommends that the BWL:

1) Examine options to add additional sensors to the primary distribution system so
as to localize faults much more quickly. Sensors are not particularly expensive
and use of increased numbers of them may well be warranted.

2) Harden the Secondary Distribution System
a) Breaks and other faults in the secondary distribution system affect fewer
customers per fault and are easier to repair than are faults in the primary
distribution system. Thus, while we encourage the Board to undertake some
hardening of the secondary distribution system, the CRT believes the Board
should focus its grid maintenance and upgrade investments on the primary
distribution system for the next few years.

b) Vegetation management is a key to reducing storm-induced outages in the
secondary distribution system as it currently exists. Accepting BWL’s
representation that it will “strictly adhere” to a five-year cycle for vegetation
management, the CRT believes that shortening that cycle further will not
provide much further benefit. Rather, based on both public and BWL staff
comments we believe that the Board should focus on a strong and effective
quality assurance program for its vegetation management and consider
making some adjustments in its vegetation management standards, especially
with respect to the removal of dead trees or trees in poor condition. See the
vegetation management section for further analysis of these issues.

c) Once the value engineering analysis of the primary distribution system is
completed, the BWL could begin using internal staff to undertake a
substation-by-substation analysis of the secondary distribution lines fed from
each substation and optimize the configuration of that portion of the
secondary distribution grid. The order in which this analysis is done should
begin with those portions of the secondary distribution grid suffering the
greatest outage experience in recent storms and proceed toward those with
apparently less risk. As these lines run through neighborhoods, and options to
improve the secondary distribution system will require collective decisions
about vegetation management, line relocation, undergrounding, and the like,
that the BWL is not necessarily institutionally empowered to make on its own,
we recommend that this planning be done jointly with the local government
and engage the affected neighborhood.

Finding:

Protection of the secondary distribution system requires more than just vegetation
management.





60
The CRT recommends that the BWL:

Direct its staff to work with local units of government to determine optimal strategies to
harden the secondary distribution system, proceeding substation-by-substation in the order
of susceptibility to storm damage as determined by experience in recent storms.

Accelerating Repairs to the Secondary Distribution System

Repairs to the secondary distribution system are relatively easily and quickly done, once the
faults are discovered and localized. Discovery and localization can be difficult however. The
BWL currently depends on customers to notify them when the customer has lost power.
Despite the remediation of the OMS, in a large storm event it may still be difficult for the
BWL to manage the volume of customer reports. Further, there may be multiple faults
preventing power delivery to a given customer and the BWL may repair the fault that is
furthest up-current from the customer and believe in error that the customer’s service is
restored. We therefore conclude that the greatest feasible acceleration of repairs to the
secondary distribution system will come from the installation of “smart meters” that are
able to signal the BWL when they lose power and when power is restored, so that the Board
will have an instantaneous and comprehensive view of outages in its system.
The CRT was advised that the BWL currently has plans to begin piloting smart meter
technology in the summer of 2014. We encourage the BWL to proceed with all deliberate
speed to adopt and deploy smart meters throughout its system so as to obtain accelerated
service restoration in its secondary distribution system as well as other benefits.

Smart metering implementation is consistent with industry best practices and with the
plans of the Michigan investor-owned utilities:

• DTE has installed approximately 1.2 million Advanced Metering Infrastructure (AMI)
meters which represents about 65% of their residential customer base of approximately
1.9 million.
• Consumers Energy has installed approximately 227,000 AMI meters which represents
about 9% of their residential customer base of approximately 2.49 million.

Each company forecasts complete installment of AMI meters over their entire residential
customer base within the next few years
79
.

The benefits of Smart Grid technology is discussed in the MPSC Staff report on the December
2013 Ice Storm response by Consumers Energy and DTE. It noted that a Department of
Energy report on initial results from Smart Grid Investment Grants to utilities for installation
of distribution automation devices as a means to: 1) Reduce the frequency of both momentary
and sustained outages, 2) reduce the duration of outages and, 3) reduce the operations and
maintenance costs associated with outage management.


79
uaLa recelved from conversaLlon wlLh MÞSC sLaff.
61
The BWL indicated in its Ice Storm Outage Report that it is moving forward with a project to
implement smart grid and smart meter technology which will allow it to identify individual
customer outages.

In the interim, until the BWL can use smart meters for outage and restoration detection, we
recommend the Board focus on increasing the corps of qualified spotters at its disposal for
inspecting and localizing faults in secondary lines.

We also note that the use of breakaway service drops as discussed above will reduce or
eliminate the problem of service drop breaks causing breakers to open in the secondary lines,
which will mitigate some secondary outages and outage repair times.

Findings:

1) The greatest issue with repairs to the secondary distribution system is the
discovery and localization of the faults.

2) Smart meter technology would provide BWL with an instantaneous and
comprehensive view of outages in its system by signaling when a customer has
lost power and when power is restored.

3) The use of smart meters will be of great benefit in assisting BWL in the
identification of pocket outages or those residences which are awaiting mast
replacement.

The CRT recommends that the BWL:

1) Proceed as quickly as is consistent with good practice to deploy smart meters and
integrate them to its outage management system to accelerate the identification
and repair of the secondary distribution system after storm damage.

2) In the interim, ensure that it has an adequate core of spotters for restoration of
the secondary distribution system following a storm.

3) Deploy smart meters first to those residences located on lateral circuits.

Other Customer Issues
Masts and Pocket Outages
Many of the strongest criticisms were voiced by those citizens who resided on short lateral
circuits or had lost power when their service line was disconnected from the service mast
disconnecting from their residence. The prevailing question was: Does the BWL have a plan to
address pocket outage identification, esp. prior to installation of smart metering? It would
seem that if BWL had known where the pocket outages were located, they could have
addressed them more timely, given that they said they had sufficient work crews.
62
Statements made at the March 10 hearing seemed to confirm the customers’ concern that the
BWL did not seem to include the individual outages as either a pocket outage or in their totals
when addressing restoration. Many of those individual households that were without power
were awaiting independent contract electricians. This three-step process, requiring that
customers find an electrician on their own (even from a list provided by the board) after the
secondary distribution system is repaired, was a source of huge frustration and anger in
December. The anger was still evident at the public hearings in January and February.
Customers’ anger was exacerbated by the delay caused by having to locate the electrician,
repair the mast, and then await full restoration in the system, freeing up a BWL to come
restore their individual power and by the reports of price gouging by contractors
80

Findings:
1) An innovative solution to this issue will substantially assist the BWL in regaining
public trust and confidence.
2) As noted above, the use of service drops that “unplug” from the distribution line
when weighted down would reduce the number of customer masts damaged or
pulled down by customer service lines.
3) The use of service drops may be a more efficient solution, both in terms of cost
and operations, than owning the system, including the mast, through to the
meter box.
The CRT recommends that the BWL:
1) Consider plans to own the system, including the mast, through to their meter
box, as part of its benefit cost analysis to determine whether a proactive effort to
install breakaway service drops is warranted.
2) Consider plans to install breakaway service drops first to those customers on
lateral circuits or to special needs customers.
Medical Needs & Senior Citizens
The public expressed great concern to the CRT at public hearings and in emails concerning the
lack of the knowledge by BWL on the location of their elderly customers and those with
medical needs. Citizens also expressed concerns over communicating with seniors during an
emergency as many of them may not have access to social media or the use of a cell phone data
plan. Many citizens with medical issues expressed frustration over the lack of communication
during the storm. While, by law, Michigan utilities must assure priority for the continuation of

80
ClLlzens advlsed LhaL Lhe prlce for servlce masL resLoraLlon ranged from $300.00 Lo $1800.00.
63
power to those with medical needs,
81
there is not a similar legal requirement for its seniors.
BWL leadership affirmed that it had two different programs, Medical Alert and Senior Shutoff
Protection, during the March 10 hearing. (App. E.) BWL conceded that the programs were not
identical in either the requirements for participation or in the information provided to
customers about the programs. Neither the elderly nor those with medical needs receive
priority for restoration of services. In fact, BWL officials indicated that those on the priority list
may not have been reached until December 28th or 29th, several days into the storm. The
location of the residences of the elderly and those with medical needs was not wholly known by
the BWL. To obtain locations for the elderly in Lansing and East Lansing, Lansing EM received
data from Tri-County Office on Aging, plotted that on a CAD map, and provided that to the
CERT teams performing health and welfare checks and to first responders. Citizens also made
recommendations, including using voter registration lists or partnering with Sparrow Hospital
or local organizations such as “Meals-on-Wheels” to determine the locations of senior citizens.
Findings:
1) BWL lacked a comprehensive system to identify all at-risk customers, including
those with medical needs and seniors, who may have greater need for electrical
power and a greater inability to re-locate or make alternative arrangements
during the outage.
2) BWL lacked an mechanism to communicate to the EM officials throughout its
customer base, the locations of seniors and medical needs customers that were
without power.
3) The items in the BWL Ice Storm Outage Report on this issue ,
82
lack specificity.
BWL must update its critical & public safety lists and work with local officials for
awareness of seniors and other vulnerable populations, work with local
organizations to maintain warming and cooling centers, work with local
neighborhood groups and non-governmental relief organizations and empower
neighborhoods to react to emergencies.
The CRT recommends that the BWL:
1) Develop through voluntary customer participation, and maintain, a list of all
elderly customers and those with medical needs.

81
Mlchlgan Þubllc Servlce Commlsslon, Consumer SLandards and 8llllng ÞracLlces for LlecLrlc and Cas 8esldenLlal Servlce,
ÞarL 9, 8ule 47 Avallable aL hLLp://mlchlgan.gov/documenLs/mpsc/lACall011408_221482_7.pdf.

82
Items 44, 47, 48, 54 (pgs. 68 & 69)
64
2) Communicate daily with all EOCs to coordinate with emergency response
personnel in all municipalities to ensure the safety of vulnerable citizens during
an outage or other emergency event. Communication should be for the duration
of a storm event.
3) As part of the integrated Regional EOP, provide the regional EOC (or all EOCs or
EMs for all governments within its customer service area, if no regional EOC is
created) with up-to-date information of the location of its at-risk customers.
4) Revise items 44, 47, 48, 54 of the outage report. There must be a coordinated
effort between BWL and local government emergency personnel and community
groups to assure clear communication and coordination of efforts to protect at-
risk customers when an emergency arises.
Community Resilience and Preparation
This report has already discussed the need for system resiliency and the need for the BWL to
change its philosophy from viewing restoration of power as its main effort during an event to
recognition of the role of guarantor of the resiliency of the electrical power for the community.
The CRT strongly asserts that the Tri-County region must also focus on community resiliency
83

to emergency and other events. A community can be broadly defined as “an entity that has
geographic boundaries and shared fate”
84
. Certainly that is a fitting definition here, where the
community of BWL users awaited restoration of power.
Community resilience as used herein is focused on creating the organizational behavior for
disaster management, as both a set of capacities for addressing the disaster and as an overall
strategy of engagement to assure early and effective disaster readiness and response.
85
Further,

83
8ussell ShorLo, now to 1blok llke tbe uotcb lo o lost-5ooJy wotlJ, new ?ork 1lmes Magazlne 9 Aprll 2014: 8eslllency ºls
lnLended as a nonpollLlcally charged way of geLLlng aL lssues underlylng cllmaLe change: Lhe need Lo rebulld ln ways LhaL
Lake ecology, economy, lnfrasLrucLure and weaLher uncerLalnLy lnLo accounL. Much of Lhe credlL for Lhe change ln Lhlnklng
has Lo go Lo Purrlcane Sandy lLself, whlch hlL ln one of Lhe rlchesL, mosL populous parLs of Lhe counLry and also Lhe cenLer
of Amerlcan medla. And lL came afLer a serles of caLasLrophlc evenLs - Purrlcane kaLrlna and oLher sLorms, buL also 9/11
and Lhe banklng crlsls of 2008 and Lhe subsequenL global economlc downLurn - whlch, Laken LogeLher, seemed Lo solldlfy
Lhe feellng of llvlng ln an age of chronlc uncerLalnLy". http:]]www.nyt|mes.com]2014]04]13]magaz|ne]how-to-th|nk-||ke-
the-dutch-|n-a-post-sandy-wor|d.htm|?hpw&rref=magaz|ne&_r=1

84
norrls, eL al., commoolty kesllleoce os o Metopbot, 1beoty, 5et of copocltles,
ooJ 5ttoteqy fot ulsostet keoJloess, Am ! CommunlLy Þsychol (2008) 41:127-130, 128.
83
ld., 133-141.
63
both the three February public hearings held by the CRT and the three held January 15
th
-17
th
by
the BWL were replete with testimonial examples of neighbors helping neighbors. This
communal engagement and assistance needs to be harnessed, energized and organized prior to
events, however. Despite the overuse of the term, there is synergy in partnering disparate
public and private resources into a communal plan for response to events. The many benefits
include ownership and engagement and the release of governmental resources for other
emergency response tasks. Space and time constraints prohibit the CRT from identifying all
regional assets that should be utilized in developing community resilience. The Red Cross has a
lengthy record of this service and was active in deploying warming facilities and shelters,
coordinated through the City EOC. The Capital Area United Way involvement with 211 is a
valuable link with support organizations. The Tri County Office on the Aging was active in the
City EOC, as well: they identified the locations of their clients for the Cities of Lansing and East
Lansing, which were mapped on a CAD map in the EOC which was then used by police and fire
for health and welfare checks. The City of Lansing also deployed its CERT
86
teams on the first
two days of the outage, both for damage assessment and for health and welfare checks.
As an example, though, of the expansion of community involvement, the Lansing Police
Department's Neighborhood Watch has historically helped organize block groups and train
block captains in promoting safe neighborhoods. This effort could conceivably operate out of
that office or out of Emergency Management. The City/LPD/Emergency Management and the
Power of WE (which already operates both an AmeriCorps and a VISTA program) could
collaborate in the organization of a regional community resilience program. These organizers
could assist in pulling together residents to create block plans, e.g., helping to organize initial
block meetings, creating block level parcel maps with pertinent information (household names,
children, pets, resources such as generators, shut-ins, etc.,), helping blocks to identify
neighbors responsible for critical functions (communications, well-checks on vulnerable
neighbors, basic needs), and more. A well-planned and coordinated response at every level--
households/blocks to municipalities/regions will go a long way toward reducing the confusion
and helplessness that characterized the December 2013 outage. Conceivably, there may be
grant funds through FEMA, the Michigan Public Service Commission, or from the Corporation
for National and Community Service to acquire VISTA volunteers to serve as 'organizers'.
Similarly, the two cities and many of the townships are endowed with well-organized
neighborhood associations. For example, Lansing has the Neighborhood Watch Coordinator
and the Coordinator of Lansing Neighborhood Council, each of whom have communications
links to 187 and 36 leaders of organized neighborhood watches and neighborhood associations,
respectively. Further, two large neighborhood listservs (over 2200 households, each) are

86
1he CommunlLy Lmergency 8esponse 1eam (CL81) Þrogram ls a lLMA-sponsored program whlch Lralns volunLeers ln
baslc dlsasLer response skllls, lncludlng flre safeLy, llghL search and rescue, Leam organlzaLlon, and dlsasLer medlcal
operaLlons. Mlchlgan as a sLaLe has one of Lhe hlghesL raLes of parLlclpaLlon ln Lhe program.
66
maintained by Allen Neighborhood Center ("Active Neighboring News") and South Lansing
Community Development Association ("South Lansing Update".) The Regional Community
Resilience Coalition would assure that the Regional Emergency Plan, which includes all
communities served by the BWL, has an emergency communications plan/listserv which
includes all of the neighborhood associations and community groups throughout the BWL
customer region.
Energy Self-reliance and Islanding
A related concept of resilience was referenced in the Introduction. The economic strategic
importance to the Lansing region of BWL is self-reliant for power, that is, if it has the capability
to generate all the electrical power its customers may require (assuming sufficient supply of
fuel). This concept of temporary isolation, or “islanding” is the opposite of contemporary
network theory, which holds that the more inter-connected that BWL is to the Grid, the more
opportunities to assure the availability of purchased power, should a portion of the grid be
blocked. The seminal text on networked critical infrastructure, in its analysis of the national
electrical power grid, observes that the greatest vulnerabilities in the network exist “in the
middle, that is, in the transmission and distribution layer of the power grid. Faults occur and
propagate throughout major portions of the country, because of critical links, insufficient
distribution capacity, and cascade failures.
87

Certainly the BWL must maintain the ability to spot-purchase power, in its mission to afford its
customers the most affordable power possible. But, the capacity for islanding, to separate the
BWL customer area from the rest of the grid, should protect the customer area from the
“effects of percolation on networks.
88
Islanding is being explored by the Department of Defense
for certain military bases roughly the same size as the Lansing area. The strategy is that, rather
than try to prevent the worst-case contingency through rigid physical and IT security, we
deliberately plan for its occurrence, by re-architecting the transmission and distribution system
to those bases. Islanding then protects one section of the grid from “contaminating” other
sections. BWL operations would need the capability to re-configure the system to shut off
access to outside power, when certain threats, such as viruses, geomagnetic disturbances or
grid overload are apparent.
In addition to increasing BWL resilience, this approach may mitigate future reductions in
electric power generation due to the ongoing shutdown of coal fired prime power plants and
reduction of nuclear generation capacity. Consideration may also be needed to ensure that
existing and future control systems are capable of and programmed to rapidly island the BWL

87
ctltlcol loftosttoctote ltotectloo lo nomelooJ 5ecotlty. uefeoJloq o NetwotkeJ Notloo, Lewls, 1ed C.,ed, !ohn Wlley and
Sons 2006/
88
8ok´s 5ooJ llle, sopto, aL pp183-186.
67
service area from surrounding transmission connectivity
89
. These system alterations can be
achieved by including internal islanding in future distribution repair, upgrades, and
modernization planning.
The CRT recommends that the City, BWL, and other area local governments:
1) Create a Community Resilience Planning Coalition which would take a broad
approach to building community level resilience to extreme events by:
a. Participating in the drafting of a regional emergency response plan, that
would include community organizations’ input on issues including a
coordinated crisis communications plan and procedures to ensure a
coordinated, efficient response to hazards across jurisdictions;
b. Providing a forum for consideration of new risk reducing technologies and
design in the built environment;
c. Promoting strategies for engaging and organizing the community at
multiple levels (household, block, neighborhood, shelters and non-profits,
businesses, jurisdiction) to identify vulnerabilities, mitigate risk and better
prepare for response and recovery from extreme events, and
d. Providing a platform for regional sharing of lessons learned; connecting
people, ideas, and resources; and engaging policymakers and community
members in an ongoing conversation about resilience.
2) Include regional resiliency, including energy self-reliance, as a strategic goal, and
3) Explore the potential for “islanding” to protect the local electrical grid, with BWL
taking the lead in creating an innovative, strategic solution.
Governance Issues
While this section and its recommendations may seem, at first, outside the mission of the CRT,
it was specifically tasked to consider issues in mitigation. Mitigation are the actions and
changes which are implemented now – before the next disaster – to lessen its impact and
improve restoration times. The CRT members have all held appointed or elected office at
senior management or leadership and/or held positions on boards entrusted with strategic and
financial decision-making authority. The CRT believes that mitigation requires consideration
and re-alignment of the roles and relationships of the Board and the BWL and within the BWL
senior leadership. The BWL needs to regain the confidence and trust of its customers.

89
lnLervlew wlLh L, uanlel MaLhls.
68
Governance, accountability and communication with its customers are critical components of
building that trust and confidence in the BWL operations.
Board of Commissioners’ Oversight
The Board of Commissioners is created by City Charter. The Board of Commissioners only has
3 employees (the General Manager, Corporate Secretary and an internal auditor
90
). The Board
needs to effect control over the BWL strategy and policies and assure meaningful review of its
actions. The Board has authority and responsibility to conduct annual audits. The Board
should also institute performance audits of the BWL. Performance audits as commonly used in
state government are designed to determine whether an agency is achieving the objectives
established by the Legislature and whether it is managing its resources in an effective,
economical, and efficient manner. These audits focus on programs and issues that are of
particular interest to legislators and the public and make recommendations to improve agency
operations. Program evaluations assess a program's effectiveness and evaluate whether desired
outcomes are being achieved. The concept is easily adaptable to the Board’s needs.
Performance or operational audits are needed to provide assurance to the City and its
customers that the BWL is well positioned for the future.
In many instances, it appears that the BWL Board agenda is driven by the BWL senior
leadership, rather than the Board. The timing and content of the BWL Storm Outage Response
seem to reflect that. Monthly updates at discretion of BWL Leadership are not enough. In the
corporate world, annual meetings are held which not only provide updates to stakeholders on
corporate activities, but provide a platform for debate on annual objectives, current and
emerging issues, and strategic direction. A board-driven annual meeting, open to all BWL
customers, might challenge some of the insularity of the organization's leadership, and provide
a forum for discussion of important issues and approaches.
The CRT observes that the Board might benefit from training on, and utilization of the Carver
Policy Governance Model
91
or a similar system of organizational governance. The BWL Board
of Commissioners could seek the expertise of a trained facilitator of the Model to integrate the
model into its practices. Implementing these principles would allow the Board of

90
Sec 3-202.1, ClLy CharLer.
91
1he Carver Þollcy Covernance Model ls a sysLem of organlzaLlonal governance. 1he Len prlnclples of Lhe Model are
deslgned Lo clarlfy lnLeracLlons beLween Lhe governlng board and managemenL wlLhln an organlzaLlon. JOHN CARVER, The
Policy Governance Model, The Authoritative Website for the Carver Policy Governance Model,
http://www.carvergovernance.com/mo http://www.carvergovernance.com/model.htm del.htm. The Policy Governance Model
empowers a governing board to focus on large issues, to “delegate with clarity,” to control management “without meddling,”
and to “rigorously evaluate the accomplishments of the organization.”

69
Commissioners to take on a more proactive role without overstepping its purpose. Using the
Model would allow the Board of Commissioners to effectively govern the correction of the
issues that became apparent throughout the preparation, response and recovery from the
December 2013 ice storm. Using this Model would create clear responsibilities and
accountability between management and the Board of Commissioners, including clear
expectations for the organization as a whole and ensure that all responsibilities are assigned,
eliminating double-delegation or failure to delegate. The Model would require the Board of
Commissioners to specifically identify the level of reporting the Board of Commissioners
expects from BWL management, how management will be evaluated, how frequently
management should report.
The CRT observed that communication by the Board with local governments that have
franchises or agreements with BWL, does not appear to be a structured, ongoing organized
dialogue. The BWL should immediately create the means for priority contact with the elected
and appointed officials within the jurisdictions that they serve. BWL Rules of Procedure, Rule
9.4, permit the Board Chair to appoint Standing Committees and Ad Hoc Committees. Note
also that Sec. 5-102.11 of the Lansing City Charter states: “An ordinance creating a board,
commission and committee may set forth a different size for the body or a different length of
term for the members than required in this section if the Council finds that the change is
appropriate.”
The BWL Board has the authority to appoint a standing committee that would be a liaison with
local communities that hold franchises for services from the BWL. We strongly believe that the
Board Chair should appoint a standing committee to be a Liaison Committee to Local Units of
Government who hold franchises or agreements for services from the BWL. Each standing
committee is required to have 4 members, so each of these 4 committee members should
liaison with one or more of the 8 units of government that have franchises.
Recommendation:
The CRT recommends the Board establish a local government franchise liaison standing
committee and request that the respective local governments identify and assign a specific
person to be the liaison from that community with the Board. The scope of this liaison
function should be broader than just emergency management; it should encompass all matters
relating to services and relationships between the communities and BWL.
The BWL should immediately develop by-laws for the local government liaison committee
which assure: priority contact with the elected and appointed officials within the jurisdictions;
that its structure is revisited on a regular schedule to identify any concerns with the
effectiveness of communications at this level; that the notification and communications
mechanism to the local officials for any such future events receive the highest priority, with
ample follow up to assure communication, as well as assessment of response times to restore
service; and that the Operations Management System is discussed with the members and with
70
officials of the jurisdictions served by the BWL, so there is familiarity with how the BWL uses
that system and what the expectations are for its effective use in future events.
The CRT would observe that there has been substantial discussion, in the city councils for
Lansing and East Lansing, the townships, public hearings and elsewhere, that the City of
Lansing should expand the Board of Commissioners to include membership from outside the
City. It is not clear, however, if the authority currently exists to, by ordinance, expand
membership. And it is not certain whether the City Council could expand membership to
include individuals who do not reside in the City of Lansing. It would appear that a potential
amendment of the City Charter would provide some method of Board representation from
outside the City of Lansing.
The CRT does support the concept that there should be regional representation on the BWL
Board. We also observe, however, that the BWL is an asset wholly owned by the City of
Lansing. The issue is not simply a matter of the numbers of BWL customers that reside outside
the BWL service area. Rather it is the recognition of the vital and integral role that locally-
produced and distributed electricity and water services play in the region’s security and
economy which compels the conclusion that there must be a mechanism for robust regional
input.
Findings:
1) The BWL Board, although appointed in a manner similar to other City boards, is
not an advisory board. Rather, the City Charter granted the Board “full and
exclusive management” over essential services. The Board needs to assert greater
control over the short-term agenda, annual objectives, current and emerging
issues, and strategic direction of the BWL.
2) The Board should take immediate, affirmative steps to effect this change,
beginning with training in Carver or a similar management tool.
3) The Board lacks the mechanism to assure that they engage in structured, ongoing
and organized dialogue with the other municipal governments which represent
its customer base. This dialogue is vital, both for the economic health and the
security of the region.
4) While a Local Government Liaison can, and should, be instituted immediately,
the long-term assurance of the regional economic health as well as the health and
safety of its residents compels consideration of representation on the Board itself
for the local governments which comprise the customer service area.


71
The CRT recommends that the Board of the BWL and the City:
1) Hire an "operational auditor" to conduct annual performance audits of the BWL
operations and planning;
2) Establish a standing committee for review of, and contract with outside expertise
for, an annual operational audit.
3) Institute a training process for all board members in Carver or other Policy
Governance Model. Implement and use the model and continue the training on
an ongoing basis.
4) Request the City to consider provision to the BWL Board of expense
reimbursement and/or some minor stipend for attendance.
5) Create a Local Government Liaison Committee of Board members and local
government representatives from remaining governments, which will meet
quarterly to review service-related issues and to recommend changes,
improvements, and innovations AND the Board must institute a clear process for
plenary and due consideration and action on the Committee’s recommendations;
6) Request an opinion from the Lansing City attorney to clarify whether an
ordinance or City Charter amendment could establish an expanded Board to
include non-Lansing residents, to represent the municipalities within the BWL
customer area.
7) Urge the involved governments, the City of Lansing and the City of East Lansing
and all townships with residents within the BWL customer area to meet and
discuss the concept of representation on the BWL Board. These discussions must
focus on the need for regionally developed and implemented plans for emergency
response and for resiliency.
8) Create and drive the system for implementation of the Internal Report and the
CRT Report.
9) Recommend to the City a "Best Practice" for recruiting new board members. Not
only those that may represent certain areas that they serve, but recruit to needs of
expertise, including, as examples only, an engineering background, business
background or security background.
Recommendations from the MPSC Staff report
The MPSC staff report notes various rules and regulations which set standards for utilities
which are regulated by the MPSC. Those rules generally are used to ensure utilities maintain
their operating and distribution systems in such a manner as to be prepared for events like the
December 2013 storm. Examples cited in the MPSC staff report include:
72
1) Setting a vegetation management schedule and budget & complying with it (pgs.
23-26 of MPSC staff report)
2) Customer call answer time – rule 460.724 (pg 29 of MSPC staff report)
3) Community outreach activities (no rule – but see comparison pg 32 of MPSC staff
report)
4) Blockage time of customer ability to report outage – (reference to rule at pgs. 32-
33 of MPSC staff report)
5) Service quality credits (rule 461.744-746, pg 34 of MSPC staff report)
6) Time limits for relief of non-utility personnel guarding downed power lines
7) (Rule 460.723, pg 37 of MPSC staff report) sets time limits for non-utility
employees (i.e. police /fire personnel) guarding a downed wire. & adequate
number of persons certified to perform wire down duty during high volume event
(pg 38 of MPSC staff report).
The CRT recommends that the Board of the BWL:
Review the standards for comparable utilities (both privately owned utilities regulated by
public regulatory bodies like the MPSC, and Municipal Utilities) and consider establishing
clear standards for BWL upon which to base its operations and budgets to ensure adequate
preparation, response and restoration of service for future emergency events .
BWL Senior Leadership
Strategic planning, innovation and change. The BWL does not seem to embrace any utility-
wide strategic planning focus, from the top- down, as a corporate value. "Best Practices" are
mandated by city charter for BWL, but seem to be defined as meeting the industry median. The
CRT was left asking: Are there strategic planning sessions by Board and senior leadership on
an annual basis? Is innovation by employees encouraged, recognized and rewarded?
Senior leadership insularity. Within the current organizational structure there are only two
positions that directly report to the General Manager - the Assistant General Manager and the
Director of Communications. As an example, the impact of the lack of a functioning OMS for
over two years, while IT and the vendor struggled to assure functionality, may have been
lessened if a CIO was directly engaged in this issue. At minimum, Strategic Planning,
Information Technology, and Operations should be directly reporting to the General
Manager. The BWL structure and culture make reform difficult, if not impossible, from within.
Accountability of BWL to customers. The current corporate culture seems to replicate an
investor-owned utility rather than a municipal utility. For example, there is no meaningful
mechanism for citizens to propose change or innovations to the Board or to the BWL. The CRT
73
heard citizens complain that the Agenda has 5 minutes for Public Comment, but no real system
for public engagement. While the BWL has a Director of Governmental Affairs and Community
Relations, that portfolio should be expanded. Other publicly-owned utilities have a senior-level
position for customer relations, such as a customer ombudsman or “Chief Customer Officer.
92

This position should also directly report to the General Manager.
Implementation of Outage Report. Too many of the recommendations within the report are
aspirational goals rather than concrete recommendations
93
. The BWL should refine the 54
recommendations contained in their report into what would be a more actionable plan by
reframing their recommendations into to “SMART” Goals which are: Specific, Measurable,
Attainable/Actionable, Realistic/Relevant, and Timely
Once goals are established, it is important to:
i. Develop actionable recommendations to meet each goal
ii. Identify financing mechanisms
iii. Establish evaluation and measurement criteria
BWL should be accountable to their Board and customers by reporting at least quarterly
progress to meeting these goals until such time as they have all been met. But if the goals are
too loosely framed, then accomplishment of the goals can be declared by BWL, without real
and needed change being effected. While the CRT has received the BWL Updates, it remains
concerned that, because of the general language used in many of the original
recommendations, it is facile to denote the goals as “completed.” The recommendations should
provide for the time line under which it is expected that this will be achieved. If there are
changes to the goals and the time line for their implementation they should be explained and
the goal and time line revised as needed. Items 10-14 in the first BWL staff update on Ice

92
!LA - !acksonvllle, llorlda's munlclpally owned elecLrlc, waLer and wasLewaLer uLlllLy, for example, creaLed a poslLlon wlLh
overslghL over all lnLeracLlons beLween Lhe uLlllLy and lLs cusLomers, Lo assure ºcusLomer loyalLy by ensurlng !LA cusLomers
have a poslLlve experlence Lhrough each of Lhe mllllons of lnLeracLlons LhaL occur annually.
hLLps://www.[ea.com/AbouL_us/8oard_and_ManagemenL/Senlor_Leadershlp_1eam.aspx

93
See 8ecommendaLlons 2,4,10,14,13,20,21,24,30,32,36,37,39,43,44,43,48,49,30,31,& 34, whlch use amblguous verbs such
as ºwlll conslder", ºwlll evaluaLe", ºwlll lnvesLlgaLe", ºwlll revlew", ºworklng Lo lmprove", ºwlll focus Lhelr efforLs" ºwlll
provlde lnformaLlon" and ºwlll be more proacLlve". CerLalnly, Lhe C81 acknowledges LhaL lL has on occaslon used slmllar
language hereln. 1he dlfference ls LhaL Lhe C81 ls charged wlLh maklng recommendaLlons whlch musL leave Lhe 8WL, 8oard,
ClLy, and oLher governmenL offlclals Lhe laLlLude Lo deLermlne Lhe mosL approprlaLe means of lmplemenLaLlon. 1he 8WL,
however, musL Lake clear and speclflc sLeps Lo prevenL slmllar evenLs and Lo convlnce Lhelr cusLomers LhaL Lhey have done
so.
74
Storm Outage Report refer to steps they are taking to address the “bottleneck” that occurred
when they lacked trained spotters and damage assessment personnel. But these still lack
sufficient specificity. The customer will still ask: “What are they going to do and when it will be
done
94
?” Until the customer believes that these questions have been answered, it will not have
regained trust and confidence in the BWL.
The CRT recommends that the BWL:
1) Establish a Customer Ombudsman, Chief Customer Officer or expand the duties
of the Director of Governmental Affairs and Customer Relations, directly
reportable to the General Manager.
2) Restructure its organizational chart so that the positions of Strategic Planning,
Information Technology, and Operations direct reporting to the General
Manager.
3) Hold an Annual Meeting of Stakeholders, with explicit invitations and
opportunities for public debate on innovation and strategy.
4) Implement a utility-wide quality assurance plan. The testimony on vegetation
management (that they looked at bills submitted by contractor monthly, and only
now are adding a competitor and checking performance after trimming) suggests
the lack of a comprehensive quality assurance plan.
5) Consider revision of the 54 Recommendations, using the SMART analysis to
include specific metrics, including the tasks to be performed, the directorate or
section within BWL charged with performance and the time need for
accomplishment.
6) Require staff reports monthly to the Board of Commissioners on specific actions
that have been taken on all of the 54 recommendations made in the Ice Storm
Outage Report and that the BWL post those reports on its website for the next 18-
24 months.



94
1hose lnclude Lhe followlng 8esponse lLems conLalned ln lLs lce SLorm CuLage 8eporL: lLems 2,3,4,3, 7, 8,
9,10,11,12,13,14,20,21,32,33,36,37,38,39,40,43,44,43,32 and 33. (See 02/18/14 CommlLLee of Whole 8oard
meeLlng.)

73




Closing Remarks
The CRT has worked diligently to assure that we have conducted a thorough and fair review of
the facts. We have attempted to at least note and address every issue raised by the members of
our community. Our mission was to be independent, objective and transparent as
we listened to community concerns, interviewed the BWL senior officials, BWL operations
staff, City EM and other staff, discussed the issues with subject matter experts and amongst
ourselves, and reviewed plans and documents.
Our goal was to assess the facts and then to develop and recommend best practices for the City,
the region and BWL. We do not reach conclusions on individual performances, although some
urged us to do so. Quite simply, that is the role of the City, Board, and other government
officials.
We recognize again the hard and diligent work of the BWL line crews and other BWL workers
who worked to restore power and assure the safety of our community. We have offered the
recommendations contained in this report to help assure that the BWL is better prepared to
more rapidly respond to future power outages and to urge future investments that will result in
a more resilient electric infrastructure for our region.
The December outage revealed the fact that the Lansing BWL, our innovative, well-regarded,
and award-winning utility, had a serious blind spot. That blind spot was the failure of BWL
leadership to grasp the threat posed by increasingly powerful and frequent weather events, its
role in the security and well-being of the community and to take appropriate steps to mitigate
potentially disastrous impacts. The BWL's lack of comprehensive preparation was mirrored
throughout the region, with a patchwork of emergency plans and uncoordinated responses in
many jurisdictions served by BWL.

In presenting our findings and recommendations, the CRT hopes that we will all learn from the
December storms, and that local leaders, including and especially those responsible for our
critical infrastructure, will together move resolutely to do what is necessary to ensure that the
next major threat is met with a well-planned and practiced, coordinated, and effective
response."

76




77
Appendix A

Community Review Team Members and Staff

The Community Review Team consists of the following volunteers listed by location within the
BWL service territory:

City of East Lansing

Michael McDaniel: Cooley Law School professor, former homeland security advisor for the
state of Michigan and former Deputy Assistant Secretary of Defense for Homeland Defense,
retired Michigan National Guard Brigadier General, CRT chair;

Beverly Baten: Former member of the East Lansing City Council from 1997 to 2008; and

Douglas Jester: Former East Lansing Mayor and City Council member. Jester currently
serves a principal with 5 Lakes Energy LLC, a policy consulting firm focused on clean and
alternative energy.

Meridian Township

Jerry Richards: Former Chief Executive Officer of Meridian Township. Richards currently
works for the Mannik & Smith Group, an engineering and environmental services firm with
offices in Lansing.

Delta Township

Darnell Earley: Emergency Manager, City of Flint; former city manager for the cities of
Saginaw and Flint; and

Bill Long: Former Chairperson of the Michigan Public Service Commission and former
Director of the Michigan Department of Labor.

City of Lansing

Larry Bass: President and CEO of Friedland Industries, Inc., a Lansing-based waste
management and recycling company; Chair Emeritus, Sparrow Health Systems;

Patricia Spitzley: Deputy Redevelopment Manager for RACER Trust, a national organization
specializing in property rehabilitation and outreach in automotive industry communities in 14
states; and

Joan Nelson: Director of the Allen Neighborhood Center on Lansing's East Side and 40-year
resident of Lansing.

CRT Chair McDaniel also appointed the following all-volunteer executive staff:
78

Mark Burton: An attorney with over a decade of experience managing advocacy and
legislative projects in Michigan, serves as the chief of McDaniel’s executive staff;

TJ Bucholz: Former communications executive for Governors John Engler and Jennifer
Granholm and current senior director of public affairs for Lambert, Edwards & Associates – a
statewide public relations firm, advises CRT chair McDaniel on communications best practices
and serves as chief spokesperson for the CRT;

Jeff Pillon: Emergency management coordinator for Energy Sector in the Department of
Energy, Labor and Economic Growth during the 2003 blackout, advises McDaniel on utility
and emergency response and recovery and mitigation of future vulnerabilities;

Rhonda Grant: President and Chief Executive Officer of the Grant Consulting Group, a
government relations firm with locations in Lansing and Washington, D.C., serves as legislative
advisor.

The following students, alumni and staff from the Thomas M. Cooley Law School provided
invaluable assistance in the research and drafting of the two Requests for Answers and
Documents, the review of the thousands of pages of received documents, and in researching
this report:

Heather Spielmaker
Rebecca Stephen
Katherine Mortensen
James Vitrano
Kathleen Lawrence
Tara Chambers

The Chair would especially commend the assistance provided by Rebecca Stephens and Kate
Mortensen who also volunteered their time in the drafting of the report over the last two weeks
of April 2014.



79
Appendix B
CRT Mission Statement
Community Review Team
Brigadier General (ret) Michael C. H. McDaniel, Chair
On December 21, 2013 a catastrophic ice storm struck the Lansing MI region, causing more
than 34,000 electric customers of the Lansing Board of Water and Light (BWL) to experience a
long-term power outage. The BWL is a municipal utility, owned by the people of the City of
Lansing, that provides electric utility services to residential, commercial and industrial
customers in Lansing, East Lansing, and the townships of Delhi, Delta and Meridian.
The mission of the Community Review Team (CRT) is to conduct an independent, objective
and transparent review of the BWL's planning, preparation, response and recovery prior to,
during and after this devastating storm event. Our goal will be to evaluate the strengths and
weaknesses of BWL's performance in order to enhance the BWL's capacity to respond more
effectively to their customer's needs and to recover more quickly during future storm events.
Under the Lansing City Charter, the BWL is governed, administered and operated as a
separate, independent agency, not as part of Lansing's city government. However, Article
2 Section 5201 of the Charter provides that the BWL "shall be responsible to the Mayor and
the City Council for the provision of these services in a manner consistent with the best
practices." Our work, therefore, will be directed toward developing a series of findings and
specific recommendations for ensuring that the BWL meets or exceeds utility industry best
practices in the planning, preparation, response and recovery from any future large scale
power outages.
Consistent with this mandate, and in accord with our charge from Mayor Bernero, the CRT will
include citizen representatives from across the BWL service territory, as well as subject matter
experts in key disciplines. We will deliver our written report to the Mayor and the City Council
within ninety days and will share our findings and recommendations with the city's regional
partners within the BWL service territory and the public at large.
Our final report will also be submitted to the Michigan Public Service Commission (MPSC) for
their review.



80
Appendix C
Community Concerns
• What Have We Learned About East Lansing's Situation Since the BWL Outage? A
Report to East Lansing's City Council and Citizens. Dreger, Alice, PhD. Rep. N.p.,
22 Jan. 2014. Web.

Board of Water and Light Hearing, Jan. 15, 2014
Hannah Community Center
Concerns Raised by Citizens (compiled from hearing transcript)
• BWL did not have a plan for the ice storm or other emergencies
• Establish warming stations much more quickly
• BWL Lacks emergency and disaster planning
• East Lansing lacks local advocacy/leadership
• Communication to public/within BWL a problem
• Citizen asks, "How did BWL get themselves in this situation in the first place?"
• Better preparation needed- storm was predicted
• East Lansing has no representation on BWL board
• Did not appear to be enough teams working
• Failed and deferred line maintenance, obsolete equipment played a large role
• Concern for pets of those who need to leave homes due to outage
• Encounters with customer service/linemen- willing to do anything they can.
Management should take same attitude
• All BWL and local government personnel should know what their emergency roles
are, where to go
• Do not want "hometown power co."- we want cutting edge, fastest, best power
company
• Implement disaster preparedness and recovery plan
• Neighborhood with buried lines didn't lose power
• Recommends better critical infrastructure planning in communities
• Keep climate change in mind- storms like this will keep happening
• Utilize neighborhood associations/nonprofit community/neighbor-to-neighbor
communication
• BWL should use "Smart Meters"
• Systems such as "Turn on your porch light to show you have power" should be
implemented before a disaster
• Creation of microgrids that help isolate emergency services from the rest of the grid
81
• Need outage map system, possibly with a way for customers to update
• Consider environmental impact of any changes made in response to ice storm
• Implement medical priority list
• Live downed wire in neighborhood, no BWL or 911 response
• Implement emergency drills and communication plan
• BWL representative did not show up to police chief's emergency operations center as
planned
• Establish system of repair priorities, backup set of procedures for use of private
contractors
• EL produced own outage maps because BWL was losing outage reports
• Use voter registration list or Meals-on-Wheels list to keep senior/low income
registry
• Public safety threatened in many ways during outages
• Customer service believed resident had power when they didn't
• Once the trucks arrived, it took them only 45 minutes to restore power
• Concerns about citizens on oxygen 24/7
• Safety issues during outage- food poisoning, fires, downed wires, etc.
• Citizen showed BWL worker around neighborhood to find outages
• Went to Hannah Center "information center" during outage, took 2.5 hours to get
information
• BWL needs "Boots on the ground" to communicate
• No transparency in BWL business model
• Use public libraries as community centers, make sure they have power first
• Welfare checks occurred too late- several days into outage
• Be prepared for situation where website and Facebook, cell phone data connections
don't work
• Concerns about 100+ year old houses in East Lansing's historic neighborhoods
• Need registry and plan in place for disabled/mentally disabled Welfare checks
need to start right away













82
Board of Water and Light Hearing, Jan. 16, 2014
Delta Township Hall

Concerns raised by citizens (compiled from hearing transcript)

• Citizen without Comcast (phone and internet) as well- no way to communicate with
BWL
• Hotel in Delta Township had heat but no lights, Fire chief forced guests to evacuate.
At that time, people had to travel as far as Coldwater for lodging.
• Citizen told mast repair was "his problem" by BWL workers
• Customer told by BWL workers "We are servicing large groups of homes first, you
will be last"
• Tree trimming occurred in past few years but apparently did not work
• Need point-person for local units of government
• Citizens not notified about masts
• Received phone call on Jan. 2 stating that water rates would increase. Insulting that
BWL can't respond to customers’ needs but can find phone number to notify of rate
increase.
• Citizens Told by BWL customer service they "weren't a priority"
• Need BWL cell phone app which works on phone data plan to report outages, etc.
• Private electricians are charged a fine if they interfere with BWL equipment,
therefore they may not be able to restore electricity to a home
• Create list of local electric contractors to deal with masts quickly
• Lansing State Journal and Councilwoman Carol Wood were most reliable source of
information, not BWL
• Citizen was marked as having power when power had not been restored
• Need to look at restoration priority schedule
• BWL online information is too hard to locate
• BWL customer service was closed on Saturday during this crisis
• Citizen made homeowner's insurance claim for mast- taken care of within 12 hours,
even with the weather
• Concerns about pets during outage when kennels are full, pet-friendly hotels full
• Communication inconsistencies- from "don't call us" to "report your outages"
• Citizen called WILX and Carol Wood and power was taken care of immediately.
• BWL should be providing safety information about burst pipes, carbon monoxide,
food safety on their website
• Need a priority restoration list, for example, stoplights on Saginaw Highway should
be a top priority
• Citizen had 14 calls ignored or disconnected
• Citizen encountered "mailbox full" message when calling BWL
83
Board of Water and Light Hearing, Jan. 17, 2014
REO Town Depot

Concerns raised by Citizens (compiled from hearing transcript)

• Concerns about elderly and disabled
• Tree trimming should happen more often than every 4-5 years. It is an expensive
process, but nothing compared to what this outage cost.
• Concerns about preparedness for something larger such as a terrorist attack
• Implement a "risk oversight committee"
• Citizen went to BWL to ask about location and date of meeting- representative "did
not know what she was talking about"
• Implement rule that all managers must be on hand for 72 hours after an emergency
hits
• Citizen moved to new building "this week", put on hold for an hour to set up
electricity
• Examine how larger cities deal with an emergency like this
• Suggestion that lines be buried like MSU- unscathed by storm
• Several thank line crews for sacrificing holiday
• Consider soliciting the help of churches and other community-oriented institutions
• Where were the Mayor and Governor?
• Citizen took photo of tree service workers in his back yard, work ineffective.
• Open schools that have generators in them
• Citizens disconnected from phone calls to BWL
• Citizen with live downed line, tree branches on top of it for 10 days. Reported it every
day, told it wasn't a priority because she had power.
• When BWL arrived, it took 15, 30, 45 minutes to correct problems and restore power
• Citizen had a tree tagged on November 14, tree was never trimmed.
• East Lansing and Delta Twp. need representation
• Use neighborhood associations as network
• 25 year resident has noticed that since Wright tree service took over, the service has
suffered.
• Banks have disaster recovery plans and are tested annually- BWL should be held to
this standard
• Implement outage maps like several other cities
• Citizen threatens lawsuit
• Concerned that customers are paying two people to do the same job per the City
Council presentation (Lark and Serkaian).
84
CRT Hearing East Lansing, Feb. 7, 2014
Hannah Community Center

Concerns Raised by Citizens (recorded by CRT support staff)

• Engineer- recommends tree trimming
• Citizens report areas with buried lines- both did and did not lose power
• Should have been watching weather and prepared days before storm
• Lack of communication about mast repair
• Emergency Plan should include more open hours for customer service
• Use MSU as a model (buried lines)
• Consider sharing tree trimming with public works
• Suggestion that residents bury masts personally
• Trees tagged but never trimmed
• Historically, BWL had generators to loan out to medical needs list.
• Councilwoman Carol Wood- 2003 outage had much better communication between
BWL and city officials
• Do not give false information to the public- no information is preferred over
incorrect information
• Former BWL employee- GM was less involved in emergency, utilized metermen in
emergencies, called water department for assistance
• If citizens leave their home, no way of knowing when they can return
• Consider announcing areas that are being worked on or still don't have power on TV
or radio
• Burying power lines too expensive
• Concerns about Lark deleting e-mails
• Policies requiring 3 men in a crew and 1 BWL worker to outside crew are inefficient
• City council needs to work with BWL Board of Commissioners to form
intergovernmental committee to represent all areas of BWL service and bring
concerns to BWL
• BWL should start a generator campaign- buy in bulk and offer to citizens at low
price, could restore trust
• CRT Hearing Lansing, Thursday, February 8, 2014 7:00 PM Pattengill Middle School
• Clearly no emergency plan in place
• Concerns raised by Citizens (recorded by CRT support staff)
• What is rationale behind policy requiring BWL worker with each crew?
• Communication issues- BWL phone message. First it says don't call in outages, then
"turn on your porch light"
• BWL did not learn from 2003 outage
83
CRT Hearing Lansing, Thursday, Feb. 8, 2014
Pattengill Middle School
Concerns raised by citizens (recorded by CRT support staff)
• Communication issues- BWL phone message. First it says don't call in
outages, then "turn on your porch light"
• Councilwoman read several e-mails from constituents: citizens did not see
BWL trucks for days, citizens unable to move to a hotel due to pets.
• BWL did not learn from 2003 outage and subsequent report
• Did BWL have disaster recovery plan?
• Length of outage and lack of proper information from BWL egregious
• When BWL arrived, took only a few minutes to connect customer's power
• Restoration priority appeared to be "on the fly" BWL worker joked with
customer "power will be on next year" and drove away
• Outage reporting system needs to be something other than phone- text, tweet,
etc. These show evidence of the report, phone calls do not if they do not go
through.
• Better government communication with BWL during 2003 outage
• BWL website was not current through outages.
• Neighborhood lost power for eight days, this is longer than even the most
prepared have planned for.
• Concerning how outage number fluctuated wildly
• BWL needs an employee "phone tree" to reach person with proper authority
to make decisions in emergency
• Need tree trimming plan
• Are emergency drills happening with local emergency groups
• Concerns about vulnerable populations
• Why didn't BWL phone systems work?






86
CRT Hearing Delta Township, Friday, Feb.9, 2014
Delta Township Hall
Concerns raised by Citizens (recorded by CRT support staff)
• Vulnerable populations- seniors, disabled
• Resident could not get in touch with BWL weeks after the ice storm about
another matter (tripping hazard in parking lot).
• Citizen in Neighborhood that was tree trimmed in September 2012 by Wright
Tree Service, still lost power in December.
• Televised information is not helpful if there is no power
• Delta township needs representation
• Senior/Disabled Registry
• Alternate housing unavailable- hotels without power
• Use rate increases for changes that will help in the future (i.e. smart meters)
• Criminal activity increases without power
• Communicate with all communities on BWL service
• Generators prone to theft
• Run emergency drills like fire/ems
• BWL workers failed to notify phone/cable co. that repairs affected service
• Bury power lines
• Failure to notify residents about masts
• Allow public works to assist
• Loss of faith in management
• Appoint contact person for township (Consumers has one)
• "Never saw a BWL worker"
• Make sure unnecessary union restrictions can be lifted in emergency
• Non-BWL worker told resident that Lansing poles need to be replaced
• Suggestion that BWL have a policy in place to put pressure on them, such as
promising to reimburse customers after a certain time of outage (i.e. 72
hours). This would act as an incentive for BWL to call in more crews rather
than pay 40,000 customers expenses.
• Delta township officials very available, but had no information from BWL
• More warming stations
• Radio is the best way to reach all populations
• BWL should be communicating with Township officials, not the other way
around.
• Delivered handwritten note to BWL location, no one in facility
87
• Communicate about which streets/areas have power so people can find hotels,
coffee shops
• Collecting $25 reimbursement very cumbersome
• Suggestion that Communities join together and communicate, organize.
• No response to e-mails to BWL
• Reimburse citizens for losses/expenses
• Have to keep driving by their house to check if power is restored

88
Concerns Submitted by CRT Questionnaire
Concerns Location
Citizen comfortable with a wood stove but
unable to leave the house, someone must
watch over generator/stove East Lansing
Biggest frustration is no communication
from BWL, no idea when power would come
back on, no idea if they received messages
about outages. Lansing
Tree trimming inadequate Lansing
Communication from BWL poor Lansing
Need plan for emergency, especially during
holiday Lansing
Need communication to residents outside of
telephone lines East Lansing
Medical Priority List is necessary,
recommends collaborating with other local
organizations such as: Tri-County Office on
Aging,
the Ingham County Health Department,
neighborhood schools, neighborhood
associations, or other local groups. This kind
of collaboration could be the hallmark of a
"Home Town Power
Company." Unknown
Would like to know that total dollar amount
that the BWL spent on this outage, including
salaries of all employees, overtime, meals,
equipment, outside companies' time, etc. Unknown
Does not believe BWL IT department when
they say they can't retrieve Lark's emails East Lansing
"I live in a city with infrastructure-outages
like this should not happen." East Lansing
"BWL can never restore our faith in them." East Lansing
9 1/2 days after outage there were still live
wires across street. East Lansing
Called BWL daily, no confirmation. East Lansing
Moved to a hotel after a few days, did not
learn that their home was repaired until
going to Hannah Center East Lansing
89
Need warming centers East Lansing
Director at Hannah Center had not been
informed of downed wires, had not heard
from BWL (Dec. 22). East Lansing
Two Transformers near home blew, handled
by ELFD and police (not BWL) East Lansing
Would like the option to choose power
source East Lansing
Would like East Lansing to have
representation East Lansing
BWL should expect massive outages to occur
and plan to cope East Lansing
BWL should rehearse on a yearly basis for
expansive emergency outages East Lansing
Consider power/facility sharing with MSU East Lansing
Phone and web coverage needed on outages East Lansing
Ongoing real-time outage map that could
possibly accept public web input East Lansing
Rethink BWL circuits as portrayed in circuit
maps East Lansing
MSU was unaffected, and therefore should
be considered as a warming center. Lansing
Lack of outage management system- former
system allowed BWL employees to track
outages to the nearest transformer. Lansing
When did BWL develop the emergency
response plan that was posted a few days
after the outage? East Lansing
Citizens had surgery during outage-
devastating experience, forced to recover in
a hotel East Lansing
BWL should pay for their mistakes East Lansing
Citizens should have another option for
power utility. East Lansing
90
East Lansing citizens pay high taxes, expect
decent service. East Lansing
Electricity is a life or death matter for some
people. East Lansing
Appalling that there were only 3 line crews
during the storm. East Lansing
BWL should be taken over by larger
company with oversight by State of
Michigan. East Lansing
All customers need representation within
BWL East Lansing
Should establish customer-owned co-op
utility East Lansing
Received orange tag (call BWL to arrange a
contractor). Phone number on tag was not in
service. East Lansing
Inspect individual homes sooner to assist
owners in making local repairs East Lansing
Provide online status reports East Lansing
Hire as many contractors as possible, keep a
database of contractors East Lansing
Called BWL after 5 days without power,
BWL stated they had no reports of an outage
in that area. East Lansing
BWL needs agreements with other electricity
companies to help in crisis and improve
communication Unknown
BWL knew that 877 number was not
working. Should have checked throughout
the storm and reset. Unknown
BWL not prepared for substantial
loss/catastrophe. Has only prepared for 20%
outage. Should plan for 50% or more, for
disasters such as solar flare, EMP
disruption, internet outages. Unknown
91
BWL stated that there was a major failure
with its Outage Management System (OMS).
Yet they claimed that the OMS failure, which
led to confusion as to which lines did and
did not have power, in no way hampered
their efforts to identify outages and restore
power. This claim appears to be
contradictory. Unknown
BWL has yet to address their external
communication issues in their report or
meetings. East Lansing
Could not reach BWL by phone. East Lansing
Stopped by BWL office, Customer Service
Representative could not give any specific
information. East Lansing
Improve tree trimming efforts- plan for new
growth and monitor tree trimming crews East Lansing
Have enough crews to restore lines or
arrangements with other utilities to do so. East Lansing
BWL website useless- "its not rocket
science" to provide updates through a
website. East Lansing
Facebook provided updates, but this is not
the best option East Lansing
BWL restoration projections incorrect East Lansing
All information communicated and results
seen were due to persistence of
neighbors/local officials East Lansing
Need emergency plan/preparedness East Lansing
Management may be able to run the
organization remotely for routine purposes,
but this was not routine (NYC trip) East Lansing
Called BWL 8 times before getting through East Lansing
Waited at Hannah Center info station for
two hours, told his street had power when it
didn't, told restoration of his area would be
last priority East Lansing
Saw no BWL trucks until Dec 31 East Lansing
92
East Lansing needs representation East Lansing
Need emergency plan with priority system,
especially for medical needs, disabilities, etc. East Lansing
Clear and public plan available for disasters East Lansing
Received mailbox full/busy signal at BWL
phone number East Lansing
Better tree trimming efforts East Lansing
Equipment upgrades East Lansing
Have never experienced such a long power
outage (age 60 and 70) East Lansing
Independence Village in East Lansing: shut
down facility due to lack of power. East Lansing
Keep up-to-date maps of the lines East Lansing
Have agreements with other power
companies Unknown
Individual paid to maintain his own trees,
did not lose power. Had many coworkers
who had no power for seven days while their
coworkers with consumers did.
Recommends replacing management. Asks,
"What did they do with emergency
funding?" East Lansing
Live wire hanging down in the street for
days, road never blocked or closed. Reported
several times, no action taken for several
days, cars driving beneath it. Recommends
online outage map, more phone lines,
communications officer. Citizen is fearful
that "communication" will be only
improvement. BWL needs to be significantly
staffed and trained for this type of
emergency, more linemen, more mutual
assistance agreements. BWL needs to admit
to their significant failures. East Lansing
93
Request that the CRT Report address the
following: CRT report should make plain to
all of us how BWL is governed. BWL has a
habit of saying it is “owned by its
customers,” but it appears … owned by the
City of Lansing. ….Please research and
explain…. the governance structure, and
how the governance structure can be
changed so that more of the customers have
political power over the running of BWL.
CRT report should clarify what types of
payments are being made to the City of
Lansing annually…. legal or regulatory basis
these payments are being made, how they
are calculated, and especially how they
(presumably negatively) impact the ability of
BWL to appropriately create and maintain
infrastructure and personnel. …BWL’s
claim…that every line crew had to have a
BWL representative with them, which
allegedly limited the number of crews that
could be deployed. You should speak to the
rumor that it was union rules that caused
delay of additional crew deployment. Do all
utility companies require this kind of
company representative to be with line
crews during a massive disaster? … East Lansing
94
.... why some municipalities and not others
in the BWL service area opted to declare a
State of Emergency. It should include an
examination of what costs, harms, and
benefits ensued from decisions to either
declare or not declare a State of Emergency.
…CRT report should tell us in detail how
upper management did or did not manage
various aspects of the crisis, including but
not limited to invocation of any emergency
plans, decisions to hire additional crews,
and so forth. The report should also explain
the roles in this emergency of the General
Manager and of other specific upper
administrators.
93
….specific details of the previous OMS and
the current OMS, including the specific
differences from before-and-after meant to
alleviate the problems during the outages
and information about how the current OMS
has or has not been field tested. We also
want to know details such as the name of the
technology company that created the new
OMS, the name of the software (so that we
can independently research its reliability),
and the cost of the new OMS. CRT report
should explain exactly how BWL utilized the
list it has of customers with special medical
needs. …..explain whether any changes will
be occurring in the management of
customers with special medical needs. CRT
report should examine the question of
whether BWL is too small to be a utility…
whether the size of BWL means that it is
simply too vulnerable to manage
catastrophic assault to the grid by a natural
disaster or terrorist attack. If it is possible to
be as small as BWL and still perform well by
virtue of cooperative agreements that can be
used during major outages, then that should
be explained in detail.
96

…. why inadequate mutual aid agreements
were in place when the outage began. …
what mutual aid agreements have started
and stopped when, which exist now, what
they entail, what costs are involved, and so
forth. …timeline of what happened when
during the outage, including exactly when
linemen and customer service rep numbers
of personnel went up or down, what
triggered when the increases or decreases in
those numbers, when upper management
was meeting, when Mr. Lark was working
from New York City, when and how BWL
personnel were meeting with the Lansing
EOC or other public safety personnel of
affected municipalities, when certain
municipalities declared States of
Emergency, when various press releases
were put out, when counts of numbers of
remaining outages were made and how they
were made, and so forth. I believe it is worth
including on this timeline the public outcries
that occurred via the Glencairn school
protest (disclosure: I helped to organize
that) and the subsequent press conference,
as it appears that many actions started to
finally occur after those public outcries. (If
this is the case, it is worth the public
knowing that this is what it takes to get
action.) CRT report should provide details
about what additional costs have been
incurred because of the outage, not only in
terms of new materials and subcontractors
required because of the outage, but also
costs incurred by virtue of the substantial
PR campaign that BWL has felt it necessary
to launch.
We want to know how much of BWL’s
money has been spent on advertisements
apologizing, on community forums, on the
cost of your contracted PR firm, and so
forth. Provide an accounting of all of these
costs.
97
Appendix D
Materials Acquired from BWL
• 2012 Union Contract. 16 Feb. 2014. 164 pages.

• 2nd Request Answers and Attachments to CRT. 7 March 2014. 1582 pages.

• Asplundh Construction Corp. Storm Assistance Agreement. Response to 1st CRT
Request. 13 Feb. 2014.

• Best Practices for Storm Response. Response to 1st CRT Request. 13 Feb. 2014.

• BWL Board January 2014 Resolution requiring public forums. 11 March 2014. 2
pages.

• BWL Board March Committee of the Whole Agenda. 11 March 2014. 2 pages

• BWL Crisis Communication Plan dated March 2014. 11 March 2014. 12 pages.

• BWL Dec 2013 Ice Storm Outage Report, Appendix containing transcripts of the
January 15, 16, and 17 2014 public meetings, and Notes Released 2-18-14.Web. 19
Feb. 2014. 333 pages. (LBWL Website)

• BWL Emergency Procedures Manual; provided within response to 1st CRT
Request. 13 Feb. 2014. 21 pages. (LBWL Website)

• BWL Second Update: Storm Outage Response Improvement, Steps 1-54. 21
March 2014. 2 pages.

• Bylaws and Governing Structure. 2nd Request Answers and Attachments to CRT.
7 March 2014.

• Consumers Energy Mutual Aid Agreement. Response to 1st CRT Request. 13 Feb.
2014.

• Draft Interim Crisis Communications Plan. Response to 1st CRT Request. 13 Feb.
2014.

• Emails from and between key staff. 2nd Request Answers and Attachments to
CRT. 7 March 2014. 3505 pages.

• Emergency Operations Plan November 2012. Response to 1st CRT Request. 13
Feb. 2014.
98

• Franchise agreements. 2nd Request Answers and Attachments to CRT. 7 March
2014.

• Government contact names and email addresses. Response to 1st CRT Request.
13 Feb. 2014.

• Graphs of BWL Phone System Usage. Response to 1st CRT Request. 13 Feb. 2014.

• Hydaker-Wheatlake Co Emergency and Non-Emergency Contract Agreements.
Response to 1st CRT Request. 13 Feb. 2014.

• Invoices for outsourced line crews. Response to 1st CRT Request. 13 Feb. 2014.

• Kent Power Emergency Storm Assistance Contract. Response to 1st CRT Request.
13 Feb. 2014.

• Lansing Board of Water & Light Emergency Action Plan.Web. (dated 2014
effective 12/1/13)(LBWL Website) 6 Feb. 2014. 42 pages.

• LBWL Facebook Page and Comments.Web. 11 Feb. 2014. 78 pages.

• List of circuits down, restoration dates, and customers affected. Response to 1st
CRT Request. 13 Feb. 2014.

• List of downed wire reports. Response to 1st CRT Request. 13 Feb. 2014.

• List of FEMA Mutual Aid Agreement Participants. Response to 1st CRT Request.
13 Feb. 2014.

• List of media contacts and email addresses. Response to 1st CRT Request. 13 Feb.
2014.

• List of Mutual Aid Contracts. Response to 1st CRT Request. 13 Feb. 2014.

• Mlive Freedom of Information Act Response. Web. 18 Feb. 2014. 66 pages.
(Mlive.comWebsite)

• MMEA Mutual Aid Agreement Response to 1st CRT Request. 13 Feb. 2014.

• Non-Record Material Retention Policy. 11 March 2014. 2 pages.

• Order of Restoration Response to 1st CRT Request. 13 Feb. 2014.
99

• Organization Chart Response to 1st CRT Request. 13 Feb. 2014.

• Record Retention Schedule and Policy. 11 March 2014. 70 pages.

• Reliability Presentation. Web. 6 Feb. 2014. 21 pages. (LBWL Website)

• Response to 1st CRT Request. 13 Feb. 2014. 717 pages.

• Restoration Process Presentation. Web. 7 January 2014. 29 pages. (LBWL
Website)

• Rules and Regulations for steam, chilled water, and water service. 2nd Request
Answers and Attachments to CRT. 7 March 2014.

• Rules of Procedure for BWL. 2nd Request Answers and Attachments to CRT. 7
March 2014.

• Safety Manual. 2nd Request Answers and Attachments to CRT. 7 March 2014.

• Second Update: Storm Outage Response Improvement Steps 1-54. Received 11
March 2014.

• Section of City Charter. 2nd Request Answers and Attachments to CRT. 7 March
2014.

• Steve Serkaian Press Releases. Response to 1st CRT Request. 13 Feb. 2014.

• Timesheets for line crews. Response to 1st CRT Request. 13 Feb. 2014.

• Transcripts from January 7 and February 18 Board of Commissioners Meetings.
2nd Request Answers and Attachments to CRT. 7 March 2014.

• Transmission and Distribution Restoration Procedures. Response to 1st CRT
Request. 13 Feb. 2014.

• Transmission Operating Plans Response to 1st CRT Request. 13 Feb. 2014

• "Vegetation Management Policy and Standards."Web. 28 Jan. 2014. (LBWL
Website)
100

Appendix E

Transcript of March 10, 2014 Public Hearing

March 10, 2014 Meeting
7:58 AM

McDaniel: identifies team, sitting, general questions, last until 1pm, not
looking for individual answers, just general. If directed, will be indicated,
otherwise corporate wide, just state who is answering. Asked for a
videographer who is not here, if they show, put them in corner by Citypulse
Three kinds of questions: planning, response, recovery & mitigation.
Darnell Early will ask Response, Doug Jester will ask Recovery &
Mitigation, but anyone can and should do follow up questions.

McDaniel to Lark: Senior Leader Communications, during first 4 days of
the event (Sun 22
nd
being the first, 22
nd
through 25
th
where majority
restoration occurred), who was making the decisions on any strategic
determination as to what areas would be restored and the order they would
be restored:
Lark: All those decisions would be devolved to Lynn McKinstry, in charge of
that group, who reports to Dave Bolan, who reports to Sue who reports to
Lark. As to order of restoration (deferring to Dave and Lynn), Lynn would
have made those decisions. Lynn confirmed correct.

McDaniel: Preface to major question asked many times: What were you
thinking going to NYC on 23-25?
Lark: When it comes to restorations and outages, not foreign to BWL.
Since the outage of Dec 23, 4 or 5 outages. In the 7 years Lark’s been here,
there’s been 100 outages, maybe more. As GM, work on restoration doesn’t
begin on day of restoration but years early, forming a crack team that
knows what they’re doing. I am blessed to have that. Lynn, Dave, and Sue.
Sue right hand person. What was I thinking? On the first day this
happened, texts started coming in at 11 pm Dec 21, but I went to sleep until
awakened at 4 am in the morning hearing things land on the roof and major
crashes all over the place. I went to look at my house and saw problems,
saw arcing in the distance, saw the big storm and would have been in
contact with someone like Sue, Lynn, or Dave. On that first day, my first
move was to get regular clothes on at 5 am and get down to Lansing, which
101
is what I did. Unfortunately, our HQ was out of power at that time and for
most of the first day. That group (Sue, Lynn, or Dave.) would have gotten
together that first day. I remember the first thing I did after doing a brief
assessment with that group was to contact the Mayor, I went to his house,
we examined what was going on and concluded, more his decision than
mine, that a press conference was in order. Before the press conference,
met with those 3 and SXS. Cannot remember who else was consulted. Very
in depth talks about what was going on, had a press conference at 1 or 3 pm,
met with the same people described at the press conference. At that point,
was of the view the best people on the ground were making decisions and
was leaning toward going to NY but wasn’t sure or not, and Mon 23 went to
NY. Indicated to all that was a mistake. In retrospect that was a mistake.
Do over, wouldn’t do it. Do not think the restoration was compromised in
any way by my absence. The group knew he was in NY and everyone had
cell phones. Worked with Ms. Devon for 11 years, she knows when to get
Peter and when not to. Worked for 7 years at BWL to make sure that if had
a heart attack that the place would run well without him. Complete
confidence in Sue to make decisions in his absence, even though she knows
when to call Peter in his absence. While in NY, got emails CC’ed on, texts,
the like. In constant communication, out to dinner, eating dinner and not
in communication, but cell phone was operable. Throughout time in NYC,
best possible personnel on the ground, they would say absence would not
affect one wit the restoration, but if I did it again I wouldn’t do that. When
I left, the team said 300 lines down, 500 lines down, turns down we had
2400 lines down which we just couldn’t’ have known at that point. Given
2400 pages of information. This should detail our problems with the OMS.
While I was aware the OMS was not fully in place or up to snuff, if I was
aware we had conductor cut problems, I wouldn’t have gone, but at the time
no knowledge of conductor cut problems.

McDaniel: Do you recall what updates you did receive in NY?
L: No.
M: Did you decide to cut the vacation short?
L: Yes, was going to take 1 extra day. Monitoring the situation pretty
closely. Received 50 emails or texts. Things seemed to be proceeding along
the way hoped until Christmas Day. On Xmas, Lark woke up and decided it
would be better to be in Lansing than in NY, so had wife get him a flight
that left 10:50 am, so Peter was back in MI on Xmas day. Directly went into
the field to continue to working at the BWL until 9:30 pm and stopped at
Subway and got a ham and cheese sub.
102

M: Were any of the costs associated with the early departure/return to
Lansing on the bLW:
L: No costs were in any way on the BWL.

Larry: What is a conductor cut?
Lark: The problem with the conductor cuts to us, giving credit to Sue, I
knew people were having trouble getting into our system when I left, but
afterward I heard 250k calls into 877 number and 50k into other number.
Contributed confusion to overwhelming of the system. But at some point
either when in NY or when came back, talking to Sue, we started to think
What’s going on? Why don’t customers have accurate information? Sue
researched and saw a conductor cut problem with the OMS. The first thing
you want to do is bring back the major circuits. The general said we got a
lot of people back in 4 days, excellent on our part. They call it “closing in
the circuits”, the circuits open and no one on that circuit has power. We
want to bring that circuit back. There are many tentacles coming off the
circuit, there might be 100 lines and 50 might be down and 50 might not.
So the line crew would cut those lines before the circuit could be opened
again. Conductor is another word for line. We would cut the lines and tack
them up on a utility pole out of the way. Cut enough to bring the circuits
back up. The problem was, the OMS would read that the entire circuit was
back, every customer was back, but wasn’t reading the tentacles that had
been cut, they were not back. This wasn’t a problem with restoration. We
had done this for years without the OMS fine. We had a large windstorm in
November. But it wasn’t getting back to customer service. So the CSR
would say oh we don’t see you as being down, you’re up.

Patricia: You went to Virg. Did you call any other leaders?
Lark: No.
P: Were there any more communications w/ Virg regarding follow up for
that day?
L: Not about followup, but Lark did call Virg but doesn’t remember if talked
to him or left a VM. Larry Bass, gonna check conductor cut stuff out with
Lynn & Dave.

Lynn: Conductor cut function in OMS is modelling function, not tracking
other than to model it. A conductor cut in the OMS is not physically
turning off the line, just helping to model what’s going on in the field.

103
McDaniel: Generally about plans. We have a bunch of different plans.
Emergency Plan, Emergency Procedures Material, Transmission Plan
(TOP), earlier emergency operation plan, distribution plan, primary plan.
Want to make sure have the right document to refer to. The older one that
was also on the website was the one being followed.

Dave confirmed.

McDaniel: Looks like the document we have is part of a larger doc called an
Emergency Procedures Manual, but we don’t have an entire older EPM.
Dave: This was replaced with an Emergency Action Plan, but the old one
was what was used for the restoration plan, not as an appendice. The EAP
was in effect, but the order of restoration from the old plan was in use
because the new EAP didn’t have an order of restoration.

McDaniel: What training was done on the EAP?

Sue: It’s updated periodically, so periodically we go to the Lansing
operations center and go through with the city what they do in an
emergency, and if an emergency comes up, they contact us and we start
working with the EOC.

McD: How often is periodically?

Sue: When we first updated the plan in 2011 or 2012, we all, all of upper
management went over for training, recently did it again. February and
March, rolling training, not for everyone at once. Still ongoing. Can only
take 15 people at once to do the training.

Bill Long: On page 6 of that plan, talks about employee responsibilities in
item C, talks about drills for each department. Can you explain, does the
BWL conduct a training where you bring in, can you describe?

Sue: We do, but the interaction with the EOC was separate. In every one of
our locations, we do periodic training, safety meetings monthly, safety
walkthroughs monthly, every department conducts their own trainings
where safety operations are concerned.

104
Bill: Have to have multiple communications working together. Is there a
training where there is a mock emergency where everyone is activated and
trained?

Sue: We do, more recently for water emergency action plan, where we do
tabletop exercise and go through an event to make sure everyone knows
what we’re doing.

Dave: On the EOP plan, we have annual if not biannual training on that,
which encompasses training on communications up and down the line.

Bill: But are CSRs included?

Lynn: I don’t think they are. The plan tells all the departments that they
are responsible for their own drills. We do a lot of drills in Electric, not
only for outages, but also for fires, evacuations, EOP is a guide for each
department to grow on.

Bill: How is it monitored?

Lynn: We are going to expand on that. We usually have a mock storm drill
annually, but if we have an event we count that as our drill. We had a storm
in November, so we consider that our drill since we exercised the drill.

Dave: So the November draft you have was the process of the plan being
updated in response to the November storm/drill.

Jester: Did the power outage in the HQ hurt restoration?
Lark: Probably.
Sue: Call center was at Haco, which has emergency backup generation, so
call center was able to take calls.
Lark: But we were impacted somehow?
Sue: The website was down at headquarters. Everything else was powered
and operational.
Lark: There are pumping stations for water that weren’t all up and
operational on that first day. We have about 120 wells, and some were
affected by the outage.
Lynn: We lost one of our circuit at the call center, but we had the other and
the backup.

103
Jester: EAP with the Lansing EOC. When was it invoked?
Sue: That’s just one part of it. The EOC contacted us on the 21
st
indicating
they were preparing for the approaching ice storm and followed the
procedures calling folks who need to know, they had already been planning
but that was just one more step in the information flow.
Jester: How long did they operate in emergency mode?
Sue: I don’t know. The entire time we had outages maybe.
Lark: That press conference the first day was at the EOC early on that first
day.

Bill: Catastrophic event determination. Activation of the Command
Unification Center? What criteria is used to determine catastrophic event?
Sue: With respect to that section of EOP, determination that we don’t have
normal communications and need a place for all upper management to
come together to the command and control center. We did not activate that
because we did not have a situation where we did not have communications
available.

McDaniel: The lack of comms is a trigger for a catastrophic event or a need
for the EOC?
Sue: The need to bring everyone together into a controlled area.
Catastrophic event means communications are down. Otherwise, we can
work separately and communicate via radios and telephones.

Bill: Unclear on the process of determining whether the City of Lansing –
McDaniel interrupts for later.
Bill: Regarding BWL operations, you did not pull everyone together in a
unified command center?
Sue: We did not. It was an electrical outage and the folks working on the
restoration were already working in the restoration area with all the
communications they needed. No need for a separate area.

Joan: After the November outage, there were some improvements and
changes made, particularly relating to spotters. What were those changes?
Lynn: Clarification of roles, how to call them in, and how to categorize
them. There are so many people and so much going on that we might need
to restructure, get better training, better pool of people to pull from, maybe
increase that.
Joan; Went from understanding that 300 lines down to 500 to 2400, part
fault of OMS, but was it also a function of an inadequate damage
106
assessment process? In best practices, comment is made that the tone of
the restoration and recovery is set by the initial damage assessment and
getting arms around scope of catastrophe. Can you talk about damage
assessment? How many people were on and how soon?
Lark: OMS had nothing to do with damage assessment. Damage
assessment is typical bottleneck. Safety of customers and people. No utility
has ever been hit with a storm of these dimensions. All of our footprint was
affected. We have 1200 miles of distribution, and that has to be walked,
people have to go out and look at it to determine how many lines are down.
Lynn: OMS was working well for wire down reports, but the storm just kept
growing and growing. Day 1, 100 down, day 2, 300 down, the longer ice
stayed on the trees, the more lines that came down.
Pat: It wasn’t the storm that grew. The storm was a set event.
Lynn: When we say storm we’re talking outages. It was the outages that
grew.
Dave: We had 31 spotters on Day 1. When best practice storm preparation
based on historical storm experiences. Our historical storm experience was
20k out due to an ice storm, and we brought in 6 mutual aid crews in our
plan to deploy. This was much larger than what we ever dealt with before.
We based our spotters on that 21 storm outage. One of the lessons is that
yes we need more spotters. They need to be a journeyperson engineer.
Looking at bringing in contracting firms to help us our.
Lark: Don’t mean to say the storm kept growing, on day 2 winds picked up.
On that first day we had a number of limbs that fell, but on Monday,
Tuesday, wed, each day more limbs came down.
Dave: DTE experienced the same kind of events.

McDaniel: Still stuck on the EAP. Went into effect on Dec 1, but no
training until Feb 2014. So there wouldn’t have been any training on the
new plan as of the storm?
Sue: Yes, but it was just an updated plan for name changes, telephone
number changes. No procedures were changed. Just updated for
new/updated info regarding contacts.
M: How do we assure that all pertinent employees have reviewed and are
familiar with the updated plan?
Sue: Enterprise Risk Management group is responsible for updating the
plan, when that’s done it is sent out to every single individual at the BWL
who should read and be aware of the changes. There is no follow up to ask
if people did it.

107
Beverly Baten: Conversation with head of 911, had a dropped call from 911.
If you exchange info with BWL, all the calls coming in would have helped
911 out calling for emergency, and 911 said there is no exchange with the
BWL. Is that a possibility?
Lark: I don’t know that is the case though it sounds like it. Yes, we are
overhauling our entire system so we can talk to everyone.
Lynn: We get wire down reports and constant calls from 911 in a formerly
unlisted number.
Q: New in EL to have to call. Good idea to share

Bill: Response says will consolidate the plans. When will that be?
Dave: 6 months is the target.
Bill: In the meantime?
Dave: The documents is still there, but for convenience rather than have
separate ones to pull, put them all in one so it is easier to use. It’s not that
they aren’t there.
McDaniel: Including the new Communications plan?
Dave: Yes. We’re looking at an Emergency Response Plan as Sue indicated.
Larger utilities have been asked to do that. We’re building the backbone of
that right now. Looked at a couple on the internet and see how that can
work for us so we can build something very similar on a wide scale. Will
take time to do because it involves everyone.
McDaniel: That isn’t uncommon. Every state agency builds their section
and then it is put together into a common approach. Not an uncommon
approach.
Nick: When the plan is sent out, Sue makes sure you follow it through with
your guys.

McDaniel: How often do we do a full-scale, BWL exercise of some sort,
whether it is electrical outage or some other emergency event, meaning
anything from tornado to active shooters. How often is a BWL wide, not
just department, event?
Sue: I don’t think we have done that.
Lark: We have not done that, although we would have done that in other
areas such as water. The electric area not so much. Not saying this is
sufficient, having had this event, we will be doing exactly what your
question suggests. But I can’t emphasize enough that in a way we’ve done
them, but not as tests. We had 3,000 lines down in November due to a
wind storm. Those are lessons learned. In 2008 we had that tornado that
took our a cooling tower in the Moore’s park area. There were sustained
108
outages that involved the GM all the way down the the bottom. That’s not
to suggest we shouldn’t do them or aren’t remiss in not doing it, but we
don’t have a comfort level with that level of storm. It’s not as if we hadn’t
been through those, and that’s a good point. We will be doing a sort of
table top analysis in the future with respect to electrical. It is one of our
recommendations.
Dave: For our distribution plan. We can easily incorporate what Peter’s
suggesting as well.
McDaniel: Which will become part of the ERP I hope.
Dave: Yes, but how it fits in I can’t say at this time.

McDaniel: Struggling with the definition of a catastrophic event. At least
two different instances the MPSC refers to a catastrophic event being a 10%
outage. Reference to 2003 blackout, separate different type, having 25%
outage in 2003. Want to make sure we’re using the same definitions.
When we’re talking about that catastrophic event, what is the trigger %?
Lynn: Where we reference the MPSC & catastrophic event, that is more for
reliability reporting. That’s where that 10% comes from.
M: Is there a % outage considered catastrophic?
Lark: It’s [D & Lynn] area, but susceptible to a number of different
definitions. After this event, we had an outage of 7200 people in Lansing,
and if it had been 10k it would have been “catastrophic” per MPSC. But it’s
not catastrophic to us – it was just a circuit failure and when the circuit is
restored everyone would come up. In February, we had 2300 event that
was far more catastrophic in my mind. In 2003, it didn’t affect BWL badly
but it took out all 2m Consumers customers. There was nothing they could
do. All outages are important to us and we will rush to try to fix it.
M: So what is catastrophic?
Dave: In 2003, we lost a whole system but were out in 21 hours. It’s not the
customers out, it was the sustained outage. The loss of major equipment
that you can’t replace. Loss of transformers, etc. The loss of those facilities
would be catastrophic. Those lines on a distribution system were
unfortunate but we could get them up in a week, and not as catastrophic.
Jester: So it’s the expected duration of the outage. Your folks have to deal
with it, but the rest of the community also needs to respond. There’s a hole
in how the plans are triggered and the effects on the community. What
does the BWL think and how it related to interaction with the community?
McDaniel: If it wasn’t a catastrophic event, the lack of the trigger to EOC,
there was no lack of communication ability.
109
Pat: Looking at the restoration procedure, unified command to keep in
contact internally and in contact with media, CSR, and other folk. You may
have been in communication internally, but what about those external
contacts? That is also a reason to form the unified command team.
Sue: That would be SXS’s job. He was in constant contact with the media,
so there was no need for it. I was involved with customer service and was
in constant contact with the CSRs.
Pat: But contact with local gov’ts isn’t a reason to open the EOC?
Sue: Correct.
Doug: SXS responsibility to let local gov’ts know?
Lark: All external stakeholders would go to SXS, as well as Calvin on the
governmental team. We did not have a crisis communication plan. Had we
had a CCP, we wouldn’t have had the issues Pat worried about. Media came
to the BWL almost instantly. But we could do better with neighborhood
communications, red cross, city and township officials, we could have done
better. SXS and Calvin Jones could have done that. We have an active CCP
now, just reviewed the documents draft for a permanent plan.

SXS: Prior to the ice storm outage, my list of press releases went to city of
Lansing officials, during ice storm, in touch with gov’t officials who reached
out to him, but after the storm expanded press releases to more gov’t
officials in service territory, and an expanded community relations list.
Now all communications go to an expanded list.

Darnell: Contacting local gov’t officials. As uninformed as the customers.
One of our tasks is to follow up on the feedback we have received. Can we
be walked through the process to keep local gov’t informed?
Lark: Everyone in Lansing was contacted, and that is what has brought
acrimony from those areas outside of Lansing that were not. Not saying we
did good enough job in Lansing either. But Carol Wood and the Mayor
knew what was going on. When we found out about the inconsistent
statements we were giving customers, those created a situation where we
were giving incorrect info to customers. After that, we tried to get as much
accurate info as possible onto website, facebook, twitter.
SXS: During course of ice storm, set out 36 outage update reports, about 3 a
day reflecting the best information known at that time to communicate to
the community through the news media. Put on the website and pushed it
through social media. My responsibility as communications director are for
internal and external communications. Prior to ice storm, that was just to
news media. In between, we gave dozens of news interviews, over the
110
phone, in the field, trying to create a narrative of how we were restoring
power. We hoped that these news updates would reach the community,
including officials.

Jerry: Any effort to contact cities to help gather information about where
outages were, and how extensive?
Lynn: We are in contact with the Lansing EOC a lot. Not a documented,
written procedure, but when they activate they call us. I was involved 3x a
day with the Lansing EOC, which was also acting on behalf of EL, maybe
not right away. But our contact to police and fire was through Lansing
EOC, giving status reports, what was still out. Toward the end, giving them
streets so they could do well checks. As soon as they activate, we include
them in.
Lark: To expand, did we call Mayor Triplett, etc. We presumed that the
Lansing EOC was in contact with the other local gov’t entities. The fire
chief for Lansing is also fire chief for East Lansing, so we assumed info was
disseminated. We don’t have to be under assumption before, because now
every update is going out to every unit. I assumed they were getting that
info.
Jerry: We need two-way communication and a plan for everyone to
seamlessly work together, practiced in tabletop so there is communication.
You have folks in the field, but there are police all over. They know where
streetlights are down or out. Not clear what you actually have w/in
operations which circuits are up and which are not and distribution live is
actually coordinated? I was under impression that emergency management
system was tied in, but now said it’s only a model. What system is working
that says what is up and running, and was it working then?
Lark: Lynn is best person to answer, but we do have an operations center,
the location shouldn’t be public, hopefully we didn’t disclosed, it is in
downtown Lansing and there is a backup. It worked entirely throughout
the outage. Big board on a computer that shows us where the circuits are
and what is up and what is down. Our grid is getting smarter. As that gets
smarter, we can get down even below the circuits. Once the smart grid is in
place, we ill know if the house is on or off. Working on for years, but not
there yet.
Lynn: We have an EMS that monitors all substations and circuits. There is
one substation excluded b/c small. We know when we have outages and
dips. We don’t know wire downs, but we have a close monitor of our entire
distribution system. Tie in with OMS, we do want the two systems to talk to
each other, so when a breaker opens, we see it on EMS and it can feed into
111
OMS. The OMS is not meant to ever tell you automatically when a wire is
down, but we have eyes in the field on everything.

Beverly: I was out of power for 9 days, had power restored Dec 31. One side
of street had power, the other did not. The city knew that power was out
and left a notice, but the customers themselves weren’t told. Whatever they
were doing for emergency wasn’t filtering very quickly. By the time they
came on the 30
th
, was kind of late, but interesting that they knew where the
outage was.
Lynn: We were trying to share information on where pocketed outages
were. We had spotters in the field and as we found the pockets we were
tracking those. And were passing info as much as we could.
Beverly: When we came to check the house, drove around looking for BWL
trucks, but had a hard time finding them. With 12 houses, I understand you
had bigger outages elsewhere.
McDaniel: Hold for later until after EMS and order of restoration first.

McDaniel: Control center itself. Also BESOC?
Lynn: Yes.
McDaniel: I have a sense from operations side that you don’t need within
BWL an EOC because the BESOC is 24/7?
Dave: Yes, that is our emergency operations.
McD: The day to day is also your emergency?
Dave: It is.
McD: There are some ways that would make sense, there is the big board,
the large scale computer system EMS, can you explain the difference b/w
what is tracked in EMS v OMS?
Lynn: The EMS is actually tracking and monitoring real time system
operations, system voltages, etc. The OMS is purely a way to track outages
in a more organized fashion have a handle on the outages. What areas are
out, how many, etc. Tool used to manage operations.
McD: How to harmonize the two systems? Lines down fed into the OMS,
how to compare against EMS?
Lynn: Hopefully soon the OMS and EMS will talk to each other, so if
something in the EMS happens, a breaker opens, then it goes into the OMS
even before calls start coming in. The OMS groups calls that come in and
predict what is out. It will predict where outages are. Helps track quicker
where critical customers are and where largest outages are.

Jester: Some outage systems integrate with forecast management. Do you?
112
Lynn: Yes, our OMS does have estimated restore time in it to estimate on
the field, we do have the ability to give restoration times. The default time
is based on past history. We can change it to be more realistic based on
response from guys in the field.
Jester: How accurate were those estimates?
Lynn: We did not have good estimates at all. It was not performing as it
should.
Jester: What was the problem?
Lynn: Not a problem with estimated modules themselves, but that the OMS
was abandoned as soon as the conductor cut issue was figured out.
Jester: How much less efficient did going to manual?
Lynn: We call it organized chaos. Didn’t hurt response time. We have good
guys who can put info in. It may have been more confusing, more time
consuming, and needed more bodies, but didn’t expand response time.
Lark: But at the very end, an operating OMS might have saved us some
time.
Dave: Marginal
Lark: The singletons or the onesies. We could have known there are 10,
and not only addressed 3 of them and come back later. Had no effect on
basic restoration, but that last bit it might have been.
Dave: When it comes down to the customer service restorations.

Lynn: I made the decision to abandon the OMS a day and a half or two days
into it. We had a work -around, we had been using the work -around. But
with the amount of wires we had down, we needed to find another way. At
the beginning, all the wire downs reported were going into the OMS, and
we were dispatching to all to get a feel. When we realized we couldn’t keep
up with it and modeling wouldn’t work, we gave crews circuit prints and
asked spotters to mark up the prints and those went into an excel
spreadsheet. We were able to determine pocket outages from that point.

Bill: Back to broader communication process. One of the responses was
that safety list would be updated and restoration plan will be shared with
officials. The restoration plan lists foster case and other community places.
What is BWL responsibilities when communicating with those community
centers and what is the local gov’t’s responsibility? From Delta Twp, so as
you look at the plans, how to identify these local officials to be
communicated to? Where does BWL responsibility end?
Lark: We have updated our lists so every local official we can find will get
material from us from now on.
113
Bill: Is it clear what their responsibility is? If those people aren’t there, who
is responsible?
Lark: We do have a list of those people who are medically infirm such that
they would need help if there was an outage. That’s what we are working
through. Whose responsibility is it to help them? It’s our responsibility to
get that info to the local entity. But we must do updating because we ask
customers to tell us if they are in that position, mainly through customer
connections newsletter in the monthly mail, but not everyone reads. How
do we get to them? Once we have a list, we have to think through HPPA
concerns. How much medical information of a customer is private and
shouldn’t’ go out? It’s an example of how we want to reach out and get the
info to the cities, but we want to make it legally. We have to be aggressive
in getting the info from the customers, and need to get permission to then
pass the info along to the city. Working through that right now. There are
many other things like that.
Sue: We couldn’t automatically give a medical list to any official because of
privacy concerns. The medical alert list is really to alert the BWL not to
shut off the power for nonpayment. Notice that they have life supporting
equipment. Do let the people know that this does not put them higher on
restoration and that they must go elsewhere and are responsible for
themselves. But we are very interested if local gov’t want to work with us
on that, but we need to make sure that the customers are in agreement.
Beverly: You have Medical Alert form and Senior Shutoff Protection in
connection. There is nothing about shutoff for medical. It sounds like
there are two groups.
Sue: There might be overlap. The Medical Alert is for them to inform us
that should you become into a situation where unable to pay the bill, need
to know if life is endangered if power is shut off. Do have senior citizen
protect plan, too. Different group, but there is crossover.

McDaniel: Are you a gov’t official, Lark?
Lark: I can’t speak dispositively, but I would consider myself a gov’t official.
McD: So Sue, you are not using the medical alert list to prioritize response?
Sue: We inform them that it does not give them higher priority, but it is
part of the OMS system, so when it gets down to onesies and twosies, then
people are aware of the medical alerts.
McD: When did you get to onesies twosies?
Dave: End of the weekend, 28
th
or 29
th
.

114
Larry: HPPA. I would suggest to contact Sparrow and ask Sparrow to help.
No one with more familiarity than they do. Risk management, someone
will know rules and bologna and red tape. About notifying gov’t. Gov’t is
putting BWL between gov’t and customers. Realize that gov’t is a customer,
but 70-80% is not gov’t. In the era of social media and notifications and
cell phones and emails, I do work all over the world on my cell phone. How
is it that you can’t notify customers directly?
SXS: The gov’t officials are being contacted by constituents.
Larry: There just seems to be a layer between gov’t and customers.
Darnel: I had asked about the relationship b/w the BWL and the
municipalities they serve. By own volition, did not reach out well enough.
Needs to be addressed.
Larry: That’s important, but more important to communicate with
customer base.
McDaniel: They are both important. Let’s talk about customers first.
Joan: Communications w/ customers was confounded by a lack of OMS
functions. In the area of preparation, can we ask about OMS reference to
problems in May.
McD: Hold off on OMS for now.
Larry: Sparrow will probably be happy to help, they have vast knowledge.
Sue: We do have HPPA trained officials.
Larry: Healthcare usually deals with it more than others. Getting back
to…seems…gov’t has to be notified, counties, whoever has to be notified.
But in the day of social media and being able to do business sin NY, how
can we better communicate with constituency, customer base, not just
gov’t, directly.
Lark: In this storm, we didn’t do a good job communicating w/ customers
b/c did not have info b/c of OMS. We did a heck of an effort in getting info
out on facebook, in media, twitter, etc. Would have been better had people
could have called and gotten a restoration time. People want to call and
talk. We can’t talk when we have 300,000 calls in a day. But there has to
be some sort of voice recognition system that says “Yes, we Know you’re
out”, gives info, and allows them to call back for status updates. These
things are being worked on and things are in place and have worked
successfully throughout the last four or five outages after the ice storm. We
have an outage map that will be debuted March 11 at community meeting
for board. Did not have the info then, but we did a lot of announcing to
people. Not enough to satisfy all customers. Have since fixed OMS and
been stress tested. March 9 we got final results on stress tests.
113
Larry: Not criticizing lack of info, more to do with not having gov’t in the
middle of it.
Doug: Doug & Jerry have been asking gov’t questions not to be most
informed, but because gov’t needs to know to prepare a response. When
you know, you prepare differently.
Larry: But the customer with a pacemaker should know before the mayor of
EL.
Lark: That’s were we’re going. They will be able to have that very shortly.
Sue: One of the biggest concerns was the lack of an outage map. They want
to look at it. Assuming that, we will debut tomorrow to our board a new
interactive outage mapping system up and running right now that will allow
customers to get in, see their area, and know whether they are an outage
area or not. The second phase requires more secure site, but will allow
customers to get in and look at their house. Shouldn’t be available to just
anyone b/c security issues. Connected to OMS, will give restoration times,
will be default time of 24 hours and as soon as an outage, crew will go out
and estimate time, which will replace default. Customers will be able to
look and know.
Lark: What about phone customers who don’t have a computer?
Sue: Customers call 877 number to report an outage. Everyone wanted to
talk to a human and that is what overwhelmed the system. We had 250k
the first day come through system, 112k through call center. Cannot staff
for 112k calls. The 877 number should take those calls, people can report
outages, but the call processor wasn’t working, so wasn’t going from 877 to
OMS system, which gave conflicting info if up or not. Alarms on both sides
so if either 877 number or OMS gets jammed, alarms on both sides. All call
center folks are now focused on answering VM, email, Facebook, anything
coming in on those areas and getting that into OMS. Market going to 877,
ordered magnets to stick by phones so people don’t go to call center.
Lark: Since the storm, what info does the customer get when they call 877?
Sue: If they call in, in the early part of the outage, it will tell them to call
back and get a restoration time. They can call back and hear the default,
but eventually it will be restored.
Nick: On a system level, there will be a best-guess default for the whole
system. After feedback from crews is put in, they then get for their house.
Pat: For the 70% I agree, that’s the #1 priority. But my parents are 83. If
he answers a text, I will turn purple. Those social media things. When you
talk about facebook, I was on facebook, I know what was there. Most
people don’t want to talk to someone – they just want to hear we’re working
on it, this is the status. We need to hear some information. Most people
116
know it was stressful. We’d prefer a recording to a busy signal or dead air
or stressed CSR. The communication can be on local gov’t so dad can call
mayor’s office. Social media is extremely important, but there must be a
mechanism in place to get info out to people w/o internet, w/o text
messaging. Try to implement policies to reach the majority of the folk.
Must be a coordinated effort. Local gov’t needs to be informed to get that
smaller percentage that can’t.
Lark: Not relying on the one system. Our system should be up and running.
We’ve had 4-5 hours where there has been good response. When they leave
facebook message, we can then reach out and confirm. It isn’t just the
internet stuff, not just the phone stuff, some people also want to hear the
radio. The radio is something we’ll use for protracted outages and any
other means we can come up with. There’s no one size fits all.
Bev: Restoration priorities listed, public safety is first priority, then group
of others. Is there a privilege list? Saw an op-ed at CityPulse? Gov’t calling
in and getting a response.
Lark: There is no privilege list. People are brought back based on
documentation we have. The idea might have come from the fact that at
some point it was clear that no one was getting good information from the
BWL. Carol emailed Lark a lot, saying: these people don’t have power.
Incumbent on Lark when she or anyone called Lark to get that information
to the T&D people and tell them if you don’t already have this address, here
it is, not “and put it on today”. Tried to keep track of those and tried to get
back. Everyone who emailed Lark got the same treatment. There was no
exception for the BWL Commissioners. What did the article say?
Bev: That a commissioner called in, shared emails with Lark about being
out on Dec 29
th
, and 45 minutes way said a spotter was on the way.
Lark: I would have passed on the address and then been told when
someone is going out. I try to get back to the commissioners, Carol Wood,
or any other human with info as quickly as I can.
Dave: There might have been someone in the area already.

McDaniel: General public safety dictate public officials have, look at order
of restoration priorities. Going back to BESOC, did BWL have direct
communication b/w BESOC and LEOC?
D&Lynn: Yes, 3 times a day.
Dave: We fit under their umbrella, we don’t drive them.
McD: Were they sitting in the EOC?
Dave: Not everyday, but Christine was there.
117
Lynn: CSR was there. Assigned to operations during the storm to work as a
liaison b/w us and the EOC. Whenever they asked a Q about a specific area,
or whatever they want, sent her down with a computer who then could ask
BWL. That is what EOC requested. No ability to make any decisions.
McD: What info did you give Christine to ask the city on BWL behalf?
Lynn: None. We talked on conference calls and if any special had the
numbers directly to call.
McD: Did use the conduit for scope of remaining outages?
Lynn: Was discussed during conference calls. Rep was there at their
request. Number of wire downs, quit counting after a few days there were
so many, areas of restoration, what was restored, what would be overnight,
how many crews, next plans, restoration efforts.

McD: SXS had 3x a day media releases. Were these based on the same
info?
Lynn: SXS info was an hour before the EOC meetings. The internal BWL
meeting was an hour before EOC meetings. The next hour, have the same
info passed to EOC.
McD: Is BESOC scaleable? Is there surge capacity?
Dave: To a certain extent. Doubling or tripling the size?
McD: Yes, is there a B team?
Dave: Yes, they are 24/7.
McD: External stakeholder, not a BWL employee?
Dave: No, it’s a confidential area because access to all critical assets. NERC
requirement. They could use it to affect bulk power system.
McD: I mean from other communities, local gov’t officials, fire, police, and
emergency management?
Lynn: Yes, they could come in for a meeting. There wasn’t a need for them
to come in. We would hold conference calls or go down to them.
Lark: At BESOC, there is a closed area that NERC requires people are not
admitted. There are other areas in BESOC that people can go. NERC
requirements prevent terrorists from taking out specific circuits. Everyone
there has to be NERC certified.
McD: No officials in BESOC?
Dave: Only one I saw was Mayor Virg.

McD: What would you do with that info if we had a new address?
Dave: Ask the operator if it was in, if they had a crew or spotter dispatched.
If yes, relay back. If not, report it.
Pat: But you abandoned the OMS? How then?
118
Dave: The issue is time. Going forward, were putting in the single ones.
Has a spotter crew or who been dispatched to the address.
Pat: Not clear when said OMS, how to address outside scope of OMS.
Lynn: When we abandoned the OMS, we kept everything on paper prints.
When we got calls, we’d compare address to identified wires down or
outages, and could say whether a crew was on it or not.
Lark: In a perfect world, could have told everyone to call 877. But they
were getting incorrect information, so that’s why Lark tried to pass along
the info he was given personally.
Bill: Had it functioned normally, could liaisoned with…? But didn’t. No
way to know whether communication was going to other units of gov’t other
than Lansing.
Lark: Assumed that once it went to Lansing it would move on. But now we
will have a liaison appointed to other units of gov’t.
Joan: Info is important, but more so what you do with it. What about other
EOCs? You assumed LEOC was spreading info. But there are County
EOCS, etc. What about them?
Dave: Were the activated?
Lynn: Only been involved with Lansing EOC, don’t know about any others.
It’s on them on their end, we don’t know otherwise.
Lark: My number is not a secret, and most gov’t officials can figure out how
to get Lark.
Joan: Coordination in a regional event to have a regional EOC?
Lynn: It would make sense.
McD: What info was given on the 3x LEOC conference calls?
Lynn: Where crews, how many, weird issues, materials (we didn’t), and
they would pass on what the city was doing per tree removals, etc. If we
had a wire down that they needed clear to proceed, we’d discuss that.
Jerry: What was communicated to Lansing? Lansing wasn’t interested in
everyone else. How would they pass along what they didn’t know?
Lynn: Systemwide blanket still out, not Lansing specific. One day did talk
to Delta few days in a row asking about what was out in Delta toward the
end.
McD: How were they described?
Lynn: NE/SW boundaries of major streets, vague info that way, amount of
customers in that area.
McD: Any discussion of related issues w/ medical alert, 2 other issues
coordination of warning centers, health and safety checks. Was any of that
discussed?
119
Lynn: Some about locations of warning centers, Lynn didn’t document, also
about health checks further into the outage asking streets still out and then
they were making determination on safety checks, probably started after
the 28
th
. Not immediate. That information was requested.
Pat: Mayor was in LEOC?
Dave: He was in BESOC.
Pat: How did he come to be in there?
Lark: Don’t recall the day it was, might have been first day?
Dave: It was.
Lark: Sunday morning before the news conference. Picked him up at 6-7
am at his house. Had to drive Jeep on curb to get down there. Wanted to
get down there to check. Don’t think Mayor had an agenda at that time. It
was the first day, just checking how things were going.
McD: Liaison at EOC was linking back how?
Lynn: Was calling BESOC, not Lynn directly. Clericals were talking to each
other. Sue was managing the spreadsheet so people would have something
to give back.
McD: Decision to ditch OMS & use Excel was on 2
nd
day. Go through how
to document.
Lynn: At the very beginning, call would give address, say wire
down/outage, and would compare to spreadsheet or circuit prints and see if
already identified. There was a stack of work to see if they were in there,
stack of next work orders could tell that. Whoever answered the phone
would have to look through a list of sheets to see what was going on.

McD: Commented that at some point discarded trying to ascertain the
number of lines down.
Lynn: When first started, the wire downs poured in. Every conference call,
it was more and more and eventually overwhelming. Spotters were
reporting more and more. Just a count wasn’t giving great information,
were trying to focus on locked out circuits to try to lock down outages and
problem areas. Didn’t count wires down b/c increasing so quickly. Lynn
made this decision very early on.
SXS: Last media update on 23
rd
at 4 that reflected 500 wires down. All
subsequent media updates from the 23
rd
on talk about hundreds of wires
down with a focus on safety. Palpable fear that there’d be serious injury or
death from wires down.
McD: Do you have something that documents the decision?
Lynn: We were still tracking and investigating the wires down, but just not
reporting them because it was just so big.
120
McD: The only way you can track are the media advisories?
Lynn: Yes
McD: But then it was asked for the public to stop reporting down lines?

McD: Emergency?
Lark: Can’t say how that went, to my knowledge, no emergency. May have
been the very first day. Was not asked for a recommendation. Did not
suggest to Mayor that an emergency should be called.

Darnell: Protocols that one might expect to be in place were not. Think
impt to look at service at 30,000 ft look and a ground level look for the
individuals with the personal needs. But clear that the area needs to
recommend to be looked at clearly going forward. Know what it means
when the residents try to find out and you are just as uninformed as they
are. The communication must go forward not just with Lansing but with
other municipalities. All must know what is going on to govern.

McD: Order of restoration. When last updated?
Dave: 2005.
McD: How far down the list did we go?
Dave: Priorities all the way. We went to mobilization level 1. Went to mob
1 & 2.
Dave: Saw this on the radar that Monday before the storm, saw on
projected ice storms. Monitored that through 19
th
morning generation
meeting, bring in operations, generating people to roll if it was to occur,
making sure we understood our roles with the November storm fresh on
our minds, though we understood how to restore the system. On the Friday
20
th
, work management meeting, discussed again, T&D person was
instructed to look at MAA and make sure contact info was up to date, that
spotter crew coordinators were informed and the spotter list was up to date.
Followed the storm through the 21
st
and that night Pat Hanes, T&D
manager called in MAA crews from 6 cities.
McD: Crew is 2?
Dave: Initial crews are 3 except for ESWs, some 2 person crews, some were
3.
McD: Seemed that primary lines had a 3 person crew that would either be
all BWL employees or 1 BWL & 2 outside crew.
Dave: One birddog with potential to serve crews of 3 person.
McD: 1 BWL supervisor/birddog supervising more than one MAA of 3-
people?
121
Dave: Yes
McD: How far apart were the crews geographically?
Dave: Not eyes on everyone, could be a couple streets, could be a mild.
Some birddogs had 1, some had 2.
Pat: Response says birddog with each crew team.
Dave: It is different, it’s just a clarification, birddogs could be watching
multiple crews. Some birddogs were watching 1 crew, but some were
watching multiple crews.
Doug: Restoration process has some phases. Person calls in or you
otherwise know there’s an outage, that triggers someone to look at the line.
Dave: That is part of it, you look at the lines down, then there are spotter
reports, but once you have that info you go after the energized down line
first, then the public service stuff like REO town and hospitals.
Doug: To clarify, someone goes to look at a line and see if its down or
broken. That goes into a work order system and a line crew goes later?
Dave: Outage management system. It goes into the spreadsheet.
Doug: When a line crew makes a repair, what are the steps to restoration?
Dave: First they will cut and clear the line. Once that has been done or is
being done, another process looks at all the major circuits that are out and
that is where they are. Just because lines were cut and cleared, doesn’t
mean a crew is on its way to restore. If there is no down line, restoration
happens when line is energized. Can only bring back one circuit at a time.
Don’t close in multiple breakers at the same time.
Doug: Are there other big roles in the restoration work?
Dave: Spotters do the assessing and bring it to the BESOC, BESOC develops
a work plan including maps, materials, etc. Goes into a stack that is
dispatched based on priority.
Doug: At different times, each of those stages could be the choke point.
Dave: The spotters were the choke point.
Doug: At some point, you would have had a pile of work for line crews to
do.
Dave: We kept up with the work that was done. The spotter crews weren’t
bringing back the reports fast enough until we got until the services around
the 28
th
.
Lark: That was the bottleneck.
Dave: That’s not uncommon for this type of process. That is a normal
process. Knowing we have the limits on the qualified people, we’ll bring in
firms that will specialize in that.
122
Bill: Are there some slots for spotters with not technical skills, while others
must have technical skills? Some could just identify that there are down
lines, while others determine what is needed?
Dave: The quality of spotters varies and it impacts the reports. Some
spotter reports come back incomplete and that slows down the process, If
they can’t identify a bad transformer or pole.
Bill: But there is a category of spotter that could be there, present
Dave: C Spotters.
Bill: You brought some in for training anyway. Has that been a volunteer
effort and/or are you going to be able to say “we need X amount of people
who can understand that level spotter and you will be called in” v who
shows up.
Dave: Voluntary v. Mandatory. In the past, the electrician (hourly
employees) have a financial incentive. But this storm was so much bigger
than in the past that we went through the level of employees that we had
trained. Are we going through the organization to recruit individuals?
Yeah, we will discuss making those mandatory for storms. But when we
pull electricians out of the plant, we will have the power plant without
maintenance. And that might be valuable for reliability of the system.
Bill: And retirees?
Lark: And retirees.
Bill: Could you mandate some employees, have more people to draw on in
an unusual system like this.
Lark: Do we have different sorts of spotters? Yes. Assessor types, As, Bs,
Cs.
Dave: A, B, C spotter. A spotter is a journeyperson qualified in the field. B
is safety to watch A in case something happens. C spotter goes out after the
situation has been assessed to stand there and protect down line. We have
plenty of those. We don’t have enough A spotters and that’s what slows us
down.
Doug: A spotters not part of Mutual aid?
Dave: No.
McD: Did we have A spotters prepositioned?
Lynn: Can’t get them in the field because we can’t predict what lines go
down.
McD: Were they staged?
Dave: They were told to be in Sunday morning, but they were not there
sitting there. We had 31 total spotters. 14 A spotters on Sunday. Went up
to 18, all BWL employees.
123
McD: Ipad or electronic form to use. Was that lost when the OMS was shut
down requiring them to use written doc?
Dave: That’s an enhancement to come, they never had that.
McD: They were using written docs?
Dave: Yes.
McD: Part of the bottleneck?
Dave: Yes. Part of our recommendation to get that. The contractor has a
PDA type Ipad.
McD: Is that contract in place now?
Dave: Talked on Friday, working on T&C.
Bill: Do the MAA require cost relative to just having the contracts in place
to be willing and able?
Dave: Everybody wants their services at the same time, have to be on the
button to call them in ASAP. Must establish ability to call in an option, put
down a retainer. Must negotiate.
Lark: When came in 2007, no MAA; since then, worked out with CE &
municipalities, subsequently others after the storm that provides for
compensation. Already been two possible ice storms and the pins and
needles we’re on. Had we not entered into agreements in advance to make
sure we have people available on standby, not so much with MMEA, not so
much with CE, but with contractors you have to pay to have them on
standby.
Bill: Or you’ll pay more when you need them later:
Lark: Not just pay more; they won’t be there. Generally there are
contractors, but supply and demand. This storm was unusual and they
weren’t there.
Bill: Looking at the ramping up of crews. 22
nd
- 26
th
had 20 crews. Then 27
had 34, 28 had 35, 29 had 54, ramped up.
Dave: That includes tree trimming, too.
Bill: What was it? You brought line crews in but not a higher number in the
first few days.
Dave: The trigger for the increase was the spotter reports. Basically you
size your crews after the assessment.
Bill: So those crews were available if you could use them.
Dave: If we brought them in with the spotter bottleneck, they would have
sat there with nothing to do and just been an added expense. The first
phase of the restoration is the primary circuits. Toward the end you break
into laterals and house services so your crewing services with mushroom
even though the lines down is lower because they are more spread out.
124
Bev: Going back to Dec 21. The EL police dept had weather spotters. When
they see the weather is changing, they will call public works and do a ride
along in EL to see what is going on in preparation for what will happen the
next day. Using regional resources and having that contact will be a natural
response, they are there already. The night of Dec 21, I had guests who left
at midnight and we knew then that we were in trouble. I had a fear of
people driving, knowing police are out there anyway, you could have had
that contact to use the resources at hand.
Dave: We knew the weather was bad, that’s why we activated the plan on
Dec 21
st
. The police were helpful in identifying lines down, the 911
dispatchers.

Break

McD: We have 2 hours and 4-5 topics to cover. Turn to Darnell for
Response issues starting with areas not yet covered.

Darnell: The public and the committee must have answers to help
understand response. Crucial in terms of communication and outreach.
Collective bargaining as it relates to the response broadly. Are there any
provisions in the CBA that allow the LBWL to suspend collective bargaining
rules during incidents like the ice storm? What in the CBA are provisions
that were impediments or things to be enhanced?
Lark: I don’t think the CBA in one way or another hampered
communications or restorations efforts. Can we suspend in an emergency?
Unsure, but think we can suspend CBA. Here, were less interested in
suspending CBA and working the plan we had, nothing to gain from
suspending CBA. We know system better than anyone. When working on
primary circuits, we want our people working on it for safety reasons.
Darnell: What about people who volunteered to help but were turned away?
Lark: Unfamiliar with that situation. Is anyone aware that people offered to
help and were turned away? No. Not everyone at the BWL is a union
employee, maybe 60-40. Many people worked the storm who were not
union employees.
Pat: Are lineworkers?
Lark: Are all union members.
Darnell: Never in conflict with CBA to deliver or identify crews?
Dave: All crews brought in were IBEW crews so it was not an issue.
Jerry: What about work rules? Memorandum of Understanding, rumors,
any work rules that inhibited or slowed down contract for other employees?
123
Lark: No, mainly it was safety. Any rules abided by that to an outsider
looked to slow things down were safety rules we abide by. In a dangerous
business, electricity, water, T&D, Generation, steam, chilled water, safety is
paramount and job one.
Dave: There were no work rules that impeded us.
Pat: Birddog?
Dave: That is across the utility industry. Could we just turn loose a bunch
of crews on the system? It would put it at jeopardy because we might not
be familiar with something that is wired up differently, there is that
exposure.
Jerry: Primary, main lines and then the rest of the system. When it got to
the rest of the system, was there BWL employee?
Dave: No, only on primary over 60,000 volts. That’s why we could bring in
so many crews at the end. They were not supervised.
Darnell: The MoU/Work rules didn’t shape the response from precluding
people who wanted to get involved from getting involved?
Dave: Not to my knowledge.
Pat: Primary systems, were the first addressed?
Dave: Wires down, then critical like hospitals, them primary circuits.
Pat: Just BWL workers?
Dave: Outside contractor crews for primary that had BWL escort with
them, the birddogs.
Pat: Were there enough birddogs for those first few days to accompany the
crews who came in through MAA?
Dave: Yes.
McD: The req. to have a 3-member crew work a line, where is it?
Dave: Safety manual discussed in a contract.
McD: Safety committee would write manual, 3-member crew is in the safety
manual, so it is incorporated into the CBA.
Dave: Not part tangentially, just “wills”. 5-1-3.
Jerry : So it’s in there so you’re bound by it.
Dave: Clarified in the safety manual rather than the contract.
Larry: Safety has to be job 1. Assume there are rigid OSHA rules.
Lark: Yes.
Bill: Enough BWL employees to escort for primaries, but if we could
remove spotter bottleneck, it would relate to the number of employees
actually had if you could get out with more force sooner.
Dave: To go full throttle, take all crews, dissolve them, make them birddogs,
and send them out. But we need the information first. This is what we did
as soon as we could, dissolve our own crews to make birddogs.
126
Bev: Simplified Distribution Circuit, looking at how primary and lateral
circuits work. Could put it in newsletter. People are wondering why and
where. Why didn’t I have power until the 31
st
. Educate people on how the
system works. If you give the information to people, they’d be more
understanding. I don’t read it all the time, but I read Consumers Energy
and got useful information. When you give information, people look to
resources.
Lark: Good idea. You’ll see it in Connections.
Darrel: So re: CBA, nothing in there that precluded you from using any
resources presented.
Lark: yes
Sue: Yes.

Pat: MAA, how many were called upon during the incident?
Dave: At the beginning we had 2, we added 3 more as the process went on.
We really exercised the MMEA one Peter put in place with 31 other
municipalities.
Pat: The spreadsheet that said accept/declined. The people who declined
were in our same boat. Do you have agreements with utilities outside
Michigan so if there is a localized incident we can call on people who aren’t
having these same problems?
Dave: APPA agreement is across the country to 2,000 other utilities. We
have nationwide incident. If a FEMA incident occurs, then that is more,
but that’s a stretch b/c someone has to exercise a FEMA-type action. 1000
national, 31 local, 3 contractors, now it shouldn’t be an issue.
Lark: MMEA dovetailed into APPA. We also got CE and now working on
DTE.
Pat: Can you walk me through the thought process of looking at the
oncoming storm, what steps are taken to access the APPA MAA, not
concerned with the local ones, but what about country wide industry
agreement.
Dave: Actually going on right now b/c of KY. There is a person assigned to
that from APPA who coordinates it nationwide. Would call MMEA first,
say I need 15 crews, locally can get 6, where to get other 9. APPA would
come in.
Pat: Is that what happened?
Dave: We didn’t need that many. When we needed the crews, we had non-
utility contractors who were closer, so we got them in sooner than someone
from out of town.
127
Lark: Lineworkers in general enjoy this kind of work. We sent our
lineworkers to NJ during Sandy. They enjoy this. MMEA like us to call on
them like we like to help. Even CE we work closely with on this. We’d
rather have a CE crew or MMEA crew we work with, but in a large scale
situation we’d tap into the APPA nationwide.
Dave: We had enough between MMEA and Kent, Asplund, etc.
Joan: So you had enough line crews and the bottleneck was with damage
assessment. And you feel now the contracts for more spotters are
sufficient?
Dave: We entered into K last Friday, they told us they have crewing to do it.
Just basic discussion, what do you do, how many people, where are you
located.
Joan: How many you have, who you can use.
Dave: First we have A with skills
Joan: But also C, who will make sure local kid doesn’t step on it. Third way
would be to activate laptops in trucks to talk to OMS.
Dave: Can those laptops be used to transmit to BESOC?
Lynn: FFA (Field Force Automation) being used by some crews, plans to
interface with OMS seamlessly so they could get work orders electronically,
put notes in electronically, give feedback in the field. Save radio traffic and
time, but not speed of restoration b/c will just get calls electronically v over
the radio. Will be less confusion and less them doing outside stuff.
Joan: When will it be active?
Nick: Probably about a year, it is very complex. Not only have to
communicate to own crews, but when you have contract people you need
them to have same functionality.
Bill: If you get that up and BWL employee must be with those crews, and
that BWL crew member can use the laptop, and uniform, sounds possible.
Nick: Two levels. One is communication to cut out paper/radio
communication.
Jerry: Generally bottleneck with damage assessment, but getting down to
lower level, wondering how much bottleneck is at receiving end, b/c so
many people calling in, or is it a combo b/w people in the field.
Lynn: In emergencies, bring in extra dispatchers just to talk to the spotters.
But when tell the spotters the circuits to patrol, the spotter comes into the
BESOC with th info.
Jerry: That sounds chaotic
Pat: She called it organized chaos.
Bill: And then you have to organize it.
Dave: And we have 10 inquiries at any one time.
128
Jerry: But if that could be more organized, it should help make sense of the
chaos, that should be a top priority if that is the bottleneck.
Darnell: To organize and respond with all the resources you have so the
power loss is mitigated by those efforts. When no issues with CBA, it still
took 10-12 days. Where is the focus so we can mitigate the inconveniences
as soon as possible. That’s what I want in an operations plan, something
that says how to identify and deploy resources to mitigate the time the
power is out.
Lark: We have employed measures to mitigate those measures. In addition,
hiring 3 new line people and more dispatchers. We were pretty happy with
the tree trimming, and it estimated if we had trimmed poorer then 70% out
nor 40%. But about being better next time, bottleneck is a point, but we
need to do more tree-trimming. Mother Nature or God just did a lot of it
for us and we have a pretty aggressive plan in place. But since then, we’ve
upped since 5 to 18 crews. We must identify the places with all the trees
and visit them. That’s the number one answer to prevent the next outage
from not taking 10 days. At MPSC, of all the calls taken in 4 year term, 90%
involved tree trimming, half wanted them out, half wanted more trimming.
But now we are really ramping up, so we’re about to get more people
yelling.
Bev: EL?
Lark : oh they are.
Bev: How to identify?
Lark: Wherever there are, for example, in Glencairn or Moore’s Park, you
see a ton of trees.
Lynn: Moore’s River Drive has been trimmed, we are now planning
Glencairn and planning all of East Lansing. We are getting more receptive
to tree-trimming.
Joan: Are you coordinating with city foresters?
Lynn: We do coordinate with Lansing, working on coordinating with EL
and any other areas that have foresters.
Lark: But the foresters might not do line work. There are lot of protocols
and equipment. We will take anyone’s help, but they shouldn’t be around
power lines.
Bill: As you expand tree trimming, obviously will cost more money. Are you
adding more employees or contracting out?
Lynn: Increasing contractors, added a second tree trimming contractor,
and possibly third.
Bill: How do you evaluate the quality of the work?
129
Lynn: Were inspecting monthly as we got bills, now we’re going the next
day to inspect and make sure it is up to standards.
Bill: Report said supervisor can be contacted for the resident to inquire
about tree-trimming, some will be upset and some won’t, but oversight and
monitoring. In forums people claimed trees were marked but not cut.
Lark: Sure it happened, but seems not exactly true. We make a real effort
to give our number out, and wish people would call.
Lynn: We are getting calls from customers and following up on all of them.
Pat: How to follow up? I got a notice in October but don’t know if it was
done. Are there subsequent notices?
Lynn: We don’t leave a subsequent notice, but we might do that now. We
mark them with a dot. We’ll go out to look and see if the tree was trimmed
or not. We can look at records with contractors to see if they did what they
say was done.
Pat: Follow-up would help a lot.
Lynn: Also getting a lot of planning 2 months in advance and people are
complaining shortly after notices, but haven’t been out yet.

Darnel: OMS. What is current status of emergency management system?
Lark: Those things we had problems with are all fixed. Nick, what doesn’t
work? Here’s the OMS. We installed in Feb. Found problems in May.
Problems we thought were fixed by October, but doesn’t mean it can be run.
Professionals have to come document and adjust the system and were
scheduled to come out when the ice storm hit. There were 100 little
questions but 2 big ones. This is not unusual with anything. Nick will talk
about OMS. If there are or not problems talk about how that works. Does
it work right now, as to the problems we had, and two, -- it wasn’t like we
were asleep at the switch on the vendor’s OMS system. Nick worked
diligently with the vendor.
Nick: That system works today. If we had an ice storm today, the system
would response appropriately. I can’t talk about how systems are tested
and put into place. It is complex to model our entire T&D system. The
system will look at two calls, see what they have in common, and estimate
what the issue is. Is it a switch? More info might move it to transformer
and a crew can go right to the transformer. Complex to project upward. If
you use MS, you get patches to fix bugs. This is like that. Report problems
and get them fixed. Some were cosmetic, some were significant (conductor
cuts). In the process, document the problem to GE, wait for fixed, test the
fixes, and put them into production. That’s where they were when this ice
storm hit. GE had fixed issues and they rolled ready to put into production,
130
they were testing, we had approved for them to put it into production, and
then the ice storm hit.

Darnell: Had it been functional at the time how beneficial would it have
been?
Lynn: If we had the ability to make the conductor cuts, we could have for
example had a circuit and modeled the conductor cuts in the OMS and seen
the pocket outages in a neat package, and when we closed the breaker, only
the people who actually came back up would have been visible.
Lark: Would it have shortened the life of the outage?
Dave: The major inconvenience was on the customer not being able to be
told their information. It would have marginally adjusted restoration
times. Reading the DTE report, they had all the gadgets and programs and
vegetation management and construction and annual drills and OMS and
phone systems that didn’t operate without any major issues, smart meters,
adequate crews, and it still took them 8 days to restore 10% of their system.
The technology had a marginal effect. What drives the restoration is the
intensity of the storm and the duration of it.
Darnell: So are we better off?
Dave: It might be 8 days instead of 10 days.
Lark: Our CSRs rely on the OMS to tell people stuff, and that’s what wasn’t
happening. If the OMS had worked, it would have been night and day as far
as getting information to the customers. Marginally on the outside we
could have grouped the pockets better.
Jerry: In Meridian Township, folks were the last ones, and no one knew
they were out. Having the OMS working, would it have pointed these
people out sooner?
Sue: If they had called in.
Jerry: Took less than an hour to fix it and they were back.
Lark: That’s a problem, that people are frustrated that it only takes an hour
to fix it.
Dave: If they were part of the major circuit, that’s the priority.
Pat: Does OMS require the public to call in, or does the OMS have the
capability to find them? People were forgotten. Once you have that
address, will they get left behind?
Lynn: The operator can put an address in, a citizen can call, or if the people
in the field had laptops, customer doesn’t have to call, that’s just one way,
sometimes we think we can get a full restoration and think everyone is back
but someone calls without power. There are times where you think
everyone is restored but you do rely on a callback.
131
Joan: Was there any difficulty adding addresses?
Lynn: Yes. The 877 number interfaces with the OMS. This was an issue we
were aware of with the OMS and knew it was failing before the ice storm.
We implemented a test call at beginning of each shift, but during the storm
we made no test calls. During the storm, a lot of calls were not going in
from 877.
Lark: Didn’t matter regarding the restoration. What you make the
conductor cuts, everyone is closed in, the issue was “well we show you do
have power” because of that.
Pat: But when you stopped OMS, it no longer mattered.
Lark: On the 28
th
, GE did bring the system back and Lynn emptied it out to
start over. What else could she do? The old stuff was in error.
Lynn: So then we put all the cuts into the OMS
Doug: The primary restoration activity is not dependant on you calling.
Once it is down to local lines, they are dependent on you calling. In the
future, smart-meters might address that.
McD: When we’re talking about pocket outage, the OMS won’t know them
based on the circuit sensors based on EMS and OMS or transformers in
yards. You only know based on spotters, smart-meter, or customer call?
Lark: If you lose your power, call in, because we don’t know. When we have
the smart grid, then we will know and no one need call anymore. Starting
July 1 we will begin the smart meter program, but it is very expensive and
will take several years.

Joan: We’ve all weathered failed technology. We have a new system
installed in Feb, failed in May, fixed in Oct, still failed, will be another year,
can’t talk to EMS, is this the right system? When installing something new,
is it customary to have a parallel system working at the same time so if it
failed it was so tragic?
Nick: Everyone has experienced bugs, but maybe not as critical as this
system. The prior, old, archaic system that we were replacing was no longer
supported, so the ability to parallel would have been complex, as well as the
difficulty in inputting information in two systems. We had successfully
gone through multiple storms with the OMS. We didn’t anticipate a storm
where we had 2400 lines down.
Lark: Asked Sue to look at the GE OMS once it works.
Lynn: Conductor cuts weren’t working in November wind storm, but rest
was. We just didn’t have anything of the magnitude of the ice storm. We
had workarounds. It is fixed and has alarms on it. We had been keeping a
close eye on it, it just slipped.
132
Nick: it’s relatively easy to test simulated calls and test volume. This wasn’t
a volume issue, it was just that occasionally the connection b/w the 877
number and the OMS would stall and have to rebooted.
McD: When was the first load test?
Nick: Before production, mid 2012. Don’t think ever try a 250k volume test
before. Prior, peak calls in an hour would be 1600. Goal is to hit 40k in an
hour, though hate to imagine the storm needed for that. Test would be for
10k per hour. Switched from old system to new system on Feb 14, 2013.
There had been a test period before that, but was a straight cut over.
Bev: Can you tell people at the bottom of the list that they are a week out?
Sue: We would not be able to tell customers that. CSRs would not know
that. We are trying to provide outage maps to give broad restoration time
that could be narrowed down. We are working on that right now. We have
the map, but getting down to the individual addresses will take approx. 6
more weeks. Add text messages.
Lark: Return time will still have to be discussed and adjusted.
Jerry: Spreadsheet that info went in. Once the OMS didn’t work, what
other IT support was given to arrange this system or was it all paper?
Lynn: All paper.
Darrel: So IT ability to disseminate information was hampered?
Nick: OMS was the major modeling tool. Once that was out, it became
spreadsheet and people.
Lark: And we tried to get the info out via press conferences. Tried to give
general info on when large block of people would come back, but couldn’t
answer individual questions. This was a group decision, SXS not
responsible. On the first day, rather than like CE that said “7 or 8 days”
BWL tried to estimate when a majority of customers would come back.
Better to say majority by close of business Christmas. May have made a
mistake, but most customers would be back by Christmas. 90% were up,
but if you were in the 10% you were unhappy. When you heard the majority
would be back by Christmas that meant to everyone that you would be back.
Would you rather know 10 days and be up sooner. Then we tried to think
how else to be helpful. We estimated 1000, but if you were in that 1000,
that didn’t help. We took steps and tried to say where our crews were so
people knew where we were, but then people would not see them and get
mad. Then they would give streets, but people would look and not see
trucks and be mad. Tried to be helpful, but it engendered ill will. It was an
attempt to get as much info out as possible while being handcuffed.

133
Darnell: In the report speak to the failure of the OMS and the aggressive
plan to fix that and make sure it works. More proactive and reactive to fix
it to be able to make communications. Recognized shortcoming.
Lark: We believe it is fixed. It is my job as GM to find problems, fix them,
and move forward. We found the problem, fixed it, and moved forward.
McD: The EMS didn’t go down.
Lynn: Correct. But it is just one line, not a map or specifics. We will find
the geographic locations on map.

Doug: Vegetation Management. No unique treatment of ash. Ash tree fall
has been significant problem. Will ash trees be just removed?
Lynn: Anything that looks like a threat to the lines will be removed. We
haven’t been aggressive but will. Issue is with taking down big trees and
nothing to do with the wood and don’t want to leave it. But will start going
after ash trees.
Doug: 1200 miles of line, 700 underground (1900 total) all levels of line.
Lark: Generally the underground is downtown and some suburban
neighborhoods. Just distribution lines, not transmission.
Doug: How frequently do you visit each segment for veg management?
Lynn: Five years.
Doug: 250 miles of line a year? What have you been running?
Lynn: 5-7 cycle. 5 has been the goal, but there was a section not hit, so 1
year behind. Looking to see if we could even move to 3 year cycle.
Doug: QC sounds good. These lines have poles. How many poles?
Lynn: We’ll get back to you.
Doug: What’s the replacement schedule for poles?
Dave: Once every 10-12 years. This falls in line with DTE’s plan.
Doug: Reconductoring (replacing lines)? A report says 10 miles a year.
Sue: We’ll get back to you.
Pat: 5 year cycle. How long does it take to go through cycle.
Lynn: It’s all 5 years. It’s a rolling thing.
Doug: What kind of conductors are you using?
Dave: Aluminum and Copper, triplex, spacer cable
Doug: What’s the state of the system as far as mix of ages and technologies?
Dave: Unsure.
Doug: Were the outages related?
Dave: 75% or more of outages were trees falling on lines, don’t know if type
of line would have helped.
Doug: Hydrophobic coating?
Dave: Round.
134
Doug: If we were to look at all assets in distribution system and put on a
replacement schedule, are we there?
Dave: Hiring a firm for asset management to do an inventory of the system,
at which time can better answer the question.
Doug: So distribution budget isn’t based on asset now?
Dave: It’s based on historical use. We are moving to an asset-based budget
now with this inventory.
Doug: Circuit breakers and fuses. To what extent are they reclosers and
remotely controlled?
Lynn: No switches, but 50ish pole reclosers controlled from control center
or site. All breakers in substations except one can be controlled remotely.
We are phasing out subclosers (?) with reclosers.
Doug: Sometimes there are alternate routes. How much of the customer
base can be rerouted and how much is unique?
Lynn: Almost everything can be rerouted, most downtown customers have
dual feeds, some are one or the other, very few instances if we lost a few
large substations where no all customers could be shifted.
Doug: Primary or also secondary?
Lynn: Everything, including laterals. When there are underground feed,
there is a diff, underground loop, where can be loop fed even when there is
cable failure. Sometimes customers don’t want to pay for loop feed on
installation and they have single feed.
Doug: Sensor meters? Currently not deep sensoring?
Lynn: Loss of fault detectors on overhead primary starting 10 years ago
aggressively. Now putting in some underground loops to help find cable
faults sooner. 30-40% of the system. Intellirupters smart reclosers detect
everything. Those are just starting to put out, 5 or 10 installed, have a lot in
the yard waiting to be installed. Several thousand lateral lines.
Dave: You think these would all help restoration process?
Doug: Safety or restoration. Just thinking about integration with
smartgrid.
Dave: We’re putting major effort into smartgrid starting in July. Moving in
that direction, but don’t have it now.
Bill: What percentage customers do you think will take that expenditure?
How many years?
Lark: Unsure. The manager is not here.
Sue: Four and six years dependent on capital expenditures.
McD: Residential too?
Sue: Yes. We’re in early phases of it. In July we’ll put pilot out to
customers to see how it works for us and for the customers.
133
Lark: There is pushback on smart meters, so we need to roll it out that gives
customers as much control as possible, issues with privacy and health. DTE
is starting and getting pushback. We want to be the best utility in the
country. In many places, BWL is the finest around. Most affordable,
reliable. In smart metering, don’t want to be in the lead. Costs millions so
we want to follow behind so we can see where others make the mistakes
because we can’t afford those mistakes. Thinking-wise we might be ahead,
but we want to watch to make sure we buy the right thing.
Sue: Four is hopeful; six is likely.

Bill: Tree-trimming budget.
Lynn: It has gone up quite a bit.
Bill: Broken out into management, labor, internal & outside, then other
management expenses.
Dave: Not just management, all other expenses beside labor.
Lark: it’s tree-trimming management, the management of trees, not
Management expenses. There was a dip in 2008 or 2009 and then brought
it back up. We were in kind of a recession so we backed down on it briefly.
In 2013, the number is all pre-storm. 2014 will be higher than that. From a
financial point of view as GM, it has been proved that it is an investment
that pays dividends.
Bill: Not free of charge, will cost. But lesson b/c we wanted to keep our
rates down, what’s the balance of looking forward and adding things. How
to prepare and get a balance of cost that customers, owners, rateplayers can
identify and understand to be forward thinking to save money in the long
run.
Lark: Our mission statement wants affordable, reliable, with environmental
stewardship. It’s affordable, and reliability is something we take extremely
seriously. This outage did not make me happy one bit. If you look at the
management over the past 5-10 years, SAIDI and CAIDI numbers and
Safety numbers, the BWL has nothing to be embarrassed about and
outperforms larger competition in the state. Will continue to be affordable,
reliable, and exercise excellent environmental stewardship. It is my job and
team’s job to figure out how to be a lot more reliable, a lot more
communicative, and still beat our mission statement and be affordable.
Underlying it all is a notion of what you want to be: a Cadillac, a chevy, or a
Pinto. Everything costs a little more. Being as nimble and good as we are,
we can be affordable and reliable. I don’t plan on this happening again. I
can’t control a 40% outage Mother nature gives us, but I can fix the
communications.
136

McD: Sue, when considering SmartMeters, compare cost and balance of
underground lines with smartmeters?
Lark: When it comes to underground lines, we are happy to underground
them, but it is the cost to the customer. It isn’t the cureall that everyone
thinks underground is. When you lose power underground, you can’t see it
and have to find it. And they are all served by aboveground. Everyone asks
for underground and we are happy to, but it’s $1m a mile. To underground
to the house, you are still reliable on transformers.
Sue: Is it part of the discussion? No. We’re not discussing it in that
matter. Looking at what it takes to do smartgrid overall for organization.

Doug: To take laterals and put underground, could you do something glike
that?
Dave: Some undergrounds go to downtown, but would be a board decision.
Lark: LCC has requested that and we’re doing that right now.
Doug: Say Glencairn wants their trees and wants to underground. Can
they?
Lark: They as a neighborhood association could investigate that, but it will
be fed by aboveground lines so they will still be dependent on that.
Doug: So it’s a local gov’t decision to do that, likely with special assessment.
McD: Do you have ability to assess?
Lark: Yes
Larry: I have underground, but so many aboveground that I still go out.
Something still hits other lines.
Lark: 2 summers ago, lost city of Lansing when circuit went out. Damage
was in underground between access points. Most customers were auto
thrown to other circuit, but Lark was worried until they could find and fix
the short, the break in the backup circuit was. That’s the problem with
underground, it’s not easy to find where that is.
Doug: Infrastructure coordination. You can’t get a collective decision to
take a lateral or feeder line to get it underground. Even if you could finance
it, which you don’t want to.
Lark: Didn’t say that, but I don’t think I do.
Doug: Your report says you don’t want to. Local gov’ts do major
infrastructure revisions from time to time. For example, the Chesterfield
neighborhood, every sewer, line, and road will be replaced. If they wanted
to underground, would be better to do it now than to have the street dug up
now.
Lark: Yes, would be a good time to look into that.
137
Doug: Is there coordination b/w BWL and municipal Public Works when
stuff like this comes up?
Sue: Not a coordinated effort
Lark: But will be happy to. Any gov’t entity interested can call me.
Doug: Cities, townships do veg management. Efficiencies to be gained by
working together.
Lark: Yes, exploring that right now with Lansing. Not to say won’t do it
with others, but it is being discussed right now. Need certain certifications
to work near lines. Economies of scale there with planning or trimming, or
disposal.

Doug: 8 member board. What committees within the board?
Lark: Whole, finance committees meet regularly, HR and executive
committee, have had ad-hoc committees from time to time. Principal are
HR, executive, finance, and committee of the whole.
Doug: No sewer, no electric supply or topical? All about management of
the business?
Lark: There are occasionally ad-hoc committees the board chair puts in
place.
Doug: Is there an annual review of reliability, response capacity?
Lark: Nothing annual. Generally I recommend topics to the chair, who
adds, strikes, or edits and the chair makes the final list. Committee of the
whole March 11 to review the 54 suggestions and progress on them will be a
topic. There are other timely topics. The board is appointed by the Mayor
with approval of the city council. 4 year terms, staggered.

Doug: The report: some are past, some are definitive “will do” some are
future “will consider”. How did you make?
Lark: New document made for March 11 board meeting, one side lists
actions and blue side is what we did. As GM, I want to make sure that if I
tell the board we’re doing something, it will be done. Don’t see anything on
it we won’t do in short order, and have already taken a big bite at the 54
things.
Pat: Great, is there a move to make it public on website.
Lark: Sue and SXS says yes.
Sue: You asked us to do that.
Lark: Okay, available tomorrow night on the website. Also the Connections
that comes out will have the items, if not the updates.
Larry: OMA?
138
Lark: Yes, always open to OMA. BWL created by a city charter. Governed
by the city charter. Derived all power. We are part of the city.
Larry: Who owns BWL, who has authority over BWL, what about EL, Delta.
Only the citizens of Lansing “own” the BWL?
Lark: Not definitive, owned by city of Lansing, not EL or DT. Not atypical.
Many municipal utilities like Traverse City serve outside Traverse City. As
who operates it, under my reading of the charter, autonomous entity
operated by GM with the approval of the chair and 4 boardmembers. The
board is autonomous and does not report in a way to anyone, but does have
meetings with the city council.
Pat: Can you remove a board member?
Lark: Unsure. Mayor can appoint subject to approval, unsure about
removal.
Pat: Record Retention Policy.
Sue: Didn’t ask for that.
TJ: Yes we did.
Sue: Ok. You can have it.

Doug: [missed the question]
Lark: Return on equity.
Doug: Payment in lieu of taxes?
Lark: Multiplied by 6.1% of revenue. 20-21 million, to 22 million. Will the
summer be hot?
Doug: Where does 6.1% come from?
Lark: Can be any amount. Look at APPA overview of what returns on
equity (pilots?) appropriate amount is, what is average amount across the
country for utilities with >100 revenue, we have 350, average is 6.1. In this
case, kind of above pay grade. Decision is made by board of commissioners
and city council. Did give the board the info that 6.1% is the average
number.
Doug: Has 6.1% of revenue changed?
Lark: Twice. When I arrived, it was 4%. Two years ago, it went up to 5%,
then a year ago it went up to 6.1%.
Bill: 6.1% for a few years?
Lark: 5 year contract
Bill: City charter requires budget by June 1. Is that budget open for public
review?
Lark: Everything is subject to OMA. Some stuff can be closed for
personnel, and we are working on that budget which will be prepared and
filed timely.
139
Bev: What do the towns get if not a return?
Lark: Not money, but give people who don’t live in Lansing one of the
lowest prices for electric service, if not the most reliable, of any of the large
providers in the area.
Bev: But I as a EL resident am subsidizing the city of Lansing?

Doug: Budget is subject to approval by city council?
Lark: All board members have to live in City of Lansing.

McD: Its 13:00, please indulge followup questions.

Pat: Everything new costs money. Logical that it will trickle down the the
ratepayer. Underground lines, community discussions, folks there can’t
afford to think about that. Increased tree trimming, smart meters, are all a
cost…but I want you to come to my yard. I understand the struggle. But
make it known that this will cost money and it will trickle to the ratepayers.

Joan: BWL aspires to excellence, and learning more about challenges in
bottlenecks and OMS, it is a serious thing to watch and correct. Totally
frustrating to suffer without power, but also frustrating for those in charge.

Bill: Was there insurance?
Lark: Not for this. This is not typically insured.
Sue: No, we don’t have insurance on this. Have talked to carriers, but the
cost of carrying this type of insurance is too much for what we might get.
McD: is there a self-insured loss fund?
Sue: Yes, there is something set aside and it is enough to cover losses of this
magnitude.
Bill: So you have to budget to refill it?
Sue: Yes.

Bev: Neighborhood watchdog.
Lark: If you need something, we will come to talk to neighborhood groups.

Darnell: Communications issue might be an easy fix- I regret saying that.
You have recognized that the issue of communication is an issue and might
not be as easily fixed. Public relations contract: where are you with that
and how will it help communications?
Lark: OMS is fixed, will continue to monitor, otherwise we can get no info
out. Then to get it out we need a crisis communication plan. What we had
140
wasn’t effective enough. We hired a firm to give us a preliminary plan, and
now we have a basis for a crisis communication plan that is best in class
throughout the US.
SXS: Very comprehensive, looked at 15 utilities, best practices in a crisis,
and gives a menu to select from both for real time capability and
technologically that mirrors where we’re trending, including an outage
center that uses the outage map launched last week.
Lark: I am 100% confident that we can handle the next 40% outage better.
But we are anxious to see your work. Perhaps there is something in the
2400 pages and 4000 pages of emails that say that there is something more
to do that we have overlooked. We think we’ve uncovered items that will
make us a better utility, but hope we learn something. Hopefully when the
MPSC reviews, it will help make [us] a better utility.

McD: the EOP mentions unified command team, that wasn’t called?
Sue: Correct.
McD: Reference to June 2008 disaster, governor and FEMA declaration.
Was there an after action report by BWL?
Sue: Yes, worked with FEMA to help with restoration costs. Some facilities
were covered by insurance that were hit by the tornado, beyond that we
recovered money from FEMA, 1-1.5m
McD – Will request FEMA amount.
McD – FEMA makes grants available for risk mitigation efforts. Did you
apply after 2008 storm?
Sue: Not aware, do not think so.

McD: When did Doug Wood leave?
Lark: Doug left Friday and the storm hit Saturday night. But the team in
place on Monday were people who were long term, competent people. No
one was taken his place, he ran generation and transmission, and instead
we created a new director of generator before Doug actually left. Dave
moved into that position before Doug left, shadowing Doug.
Dave: November 15 or 16, about 6 weeks shadowing.

Jester: You have an aspiration to be recognized for excellence. Who are you
competing with?
Lark: Different in different areas. To be the best, have to fulfill mission
statement, being affordable. When talk about peers, next closest utility,
rates need to be lower than that. That is the main peer there. Reliability,
other similarly sized large utilities, including the two larger ones in MI.
141
Environmental, you can’t go too far. The only utility to reduce carbon by
20% across the footprint, not many peers. Used to be largest solar array.
Try to be on cutting edge, retired 4 coal units, almost 7, saves 339 tons of
coal. As to peers, all different, but try to keep an eye out. APPA has 2000
utilities; BWL has been a platinum award winner for reliability. Won the
diamond award given to 6 utilities of 2,000, hard to do in an ice storm. But
no one cares, if their power is off. Many people at the BWL are second to
none and do a great job.
McD: And Mr Lark, we will let you have the last word. Thank you, all.

























142

Appendix F

Reference Materials
The following reference materials were relied upon by the CRT, or its subject matter
experts, for guidance and best practices in developing this report. They are included so
that the readers of the report and the BWL can delve more deeply into the sources of the
recommendations included herein and may also be helpful in pointing the way
forward.
• "Army Emergency Management Program." Headquarters Department of the
Army, 20 Sept. 2012. Web.
• Bak's Sand Pile: Strategies for a Catastrophic World. Lewis, T. G. Williams, CA:
AGILE, 2011. Print.
• "City of Buffalo Municipal Electric Utility Energy Emergency Response." N.p.,
n.d. Web.
• "Community Resilience as a Metaphor, Theory, Set of Capacities, and Strategy for
Disaster Readiness." Norris, Fran H., Susan P. Stevens, Betty Pfefferbaum, Karen
F. Wyche, and Rose L. Pfefferbaum. American Journal of Community
Psychology 41.1-2 (2008): 127-50. Print.

• Communication management and trust: their role in building resilience to
“surprises” such as natural disasters, pandemic flu, and terrorism. Longstaff, P.
H., and S. Yang. Ecology and Society 13(1): 3. 2008. Print.

• Connecticut October 2011 Snow Storm Power Restoration Report. Rep.
Washington D.C.: Witt Associates, 2011. Print.
• "Cracks in a Postdisaster Service Delivery Network." Gillespie, David F., and
Susan A. Murty. American Journal of Community Psychology 22.5 (1994): 639-
60. Print.

• Crisis Leadership Now: A Real-world Guide to Preparing for Threats, Disaster,
Sabotage, and Scandal. Barton, Laurence. New York: McGraw-Hill, 2008. Print.

• Critical Infrastructure Protection in Homeland Security: Defending a
Networked Nation. Lewis, T. G. Hoboken, NJ: Wiley-Interscience, 2006. Print.

• Developing and Maintaining State, Territorial, Tribal, and Local Government
Emergency Plans. March, 2009.Web. Department of Homeland Security,
FEMA—promotes a common understanding of the fundamentals of planning and
143
decision making to help emergency planners examine a hazard and produce
integrated, coordinated, and synchronized plans.

• Disaster Resilience: A National Imperative. Washington D.C.: National
Academies, 2012. Print.
• EEI Releases Updated Report: "Before And After The Storm: A
Compilation Of Recent Studies, Programs, And Policies Related To
Storm Hardening And Resiliency" Edison Electric Institute (EEI).
March 2014. Web. The Edison Electric Institute (EEI) was asked by its
members to update its January 2013 report to incorporate newly released studies
on recommendations and best practices with regard to hardening the distribution
infrastructure and creating a more resilient system, especially since the impact of
Superstorm Sandy in the Fall of 2012.

• Hardening and Resiliency: U.S. Energy Industry Response to Recent Hurricanes
Seasons
This report was prepared by the Office of Electricity Delivery and Energy
Reliability, U.S. Department of Energy and examines the efforts industry has
taken, since the 2005 and 2008 hurricane seasons, to harden their assets and/or
implement changes to make their energy systems more resilient.

• Local Government Energy Assurance Planning Energy Assurance Guidelines
Version 2.0 . Public Technology Institute. Dec. 2011. Web.

• Manager's Guide to Contingency Planning for Disasters: Protecting Vital
Facilities and Critical Operations. Myers, Kenneth N., and Kenneth N.
Myers. New York: J. Wiley & Sons, 1999. Print.

• "Michigan Public Service Commission-Staff Report December 2013 Ice Storm."
Electric Operations Section-Operations and Wholesale Markets Division, 10 Mar.
2014. Web.
• National Incident Management System NIMS is a comprehensive, national
approach to incident management. It provides the template for incident
management, regardless of cause, size, location, or complexity and is applicable
at all jurisdictional levels and across functional disciplines

• "New Hampshire December 2008 Ice Storm Assessment Report." NEI Electric
Power Engineering, 28 Oct. 2009. Web.

• Public Crisis Management: How and Why Organizations Work Together to
Solve Society's Most Threatening Problems. San Jose, CA: Writers Club, 2000.
Print.
144
• Report on Transmission Facility Outages During the Northeast Snowstorm of
October 29-30, 2011-Causes and Recommendations.
Federal Energy Regulatory Commission and the North American Electric Reliabil
ity Corporation. Web.

• The Resilience of the Electric Power Delivery System in Response to Terrorism
and Natural Disasters: Summary of a Workshop. Cooke, David W. Washington,
D.C.: National Academies, 2013. Print.

• Utility Security: The New Paradigm. Seger, Karl A. Tulsa, OK: PennWell, 2003.
Print.