STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE

Transcription

1 STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE STAFF REVIEW OF PSEG LONG ISLAND EMERGENCY PLAN APRIL 2014

2 Table of Contents 1.0 EXECUTIVE SUMMARY INTRODUCTION Emergency Plan Filing Requirements Public Comments Department of Public Service Staff s Review Process ONGOING INITIATIVES Outage Management System Upgrades Interactive Voice Response System Upgrade Flooding Restoration Procedure Streamlined Emergency Plan Emergency Response Organization COMMUNICATIONS Contact Center Background Findings Life Support Equipment and Special Needs Customers Background Findings Recommendation OPERATIONS Damage Assessment Background Findings Recommendations Estimated Time of Restoration Background Findings Recommendation Coordination with Telecommunications Providers and Gas Utilities Background Findings Recommendations Down Wires Background Findings INTERMEDIATE UPDATES Dry Ice Media Contact Advanced Planning and Preparation CONCLUSION APPENDIX 2

3 1.0 EXECUTIVE SUMMARY On February 3, 2014 PSEG Long Island, LLC (PSEG LI or Service Provider), in accordance with the LIPA Reform Act, submitted an emergency response plan (Plan) to the New York Department of Public Service (Department or DPS) for review and recommendation. The Plan was published in the State Register and made available for public for review. The public was provided the opportunity to provide written and oral comments, and in accordance with the LIPA Reform Act, the Long Island Power Authority (LIPA or Authority) and PSEG LI conducted one public hearing in Nassau County and one in Suffolk County. The Authority and Service Provider provided copies of written comments and hearing transcripts to the Department for its consideration in reviewing the Plan. The Department, in this Report, provides recommendations based upon its analysis of the Plan and review of the public comments received. This Report summarizes Department Staff s (Staff) review of PSEG LI s Plan as required by the LIPA Reform Act. It highlights key areas that were appropriately addressed in the Plan; includes Staff s recommendations for communications and operations; describes PSEG LI s ongoing initiatives that are not fully addressed in the Plan; and discusses intermediate updates provided to Staff during the course of its review. Overall, Staff found the Plan to be both comprehensive and sufficiently detailed. Staff is encouraged by PSEG LI s commitment to continuous improvement in its emergency response processes as illustrated by several initiatives already under way. The lack of a modern and fully automated Outage Management System (OMS) that meets industry standards can have serious implications to a utility s overall response to emergency events. It precludes the proper communication of restoration information to customers and government officials. The Computer Assisted Restoration of Electric Service (CARES) outage management system (OMS) that is currently being used by PSEG LI is a mainframe based, COBOL language, legacy program that is approximately 25 years old and lacks many features required to manage large scale events. PSEG LI clearly recognized the immediate need to address replacement of the existing OMS early on in the transition to its role as Service Provider. While Staff notes that PSEG LI expects to begin roll out of its new OMS system later this summer, full implementation will take place in stages over an extended period 3

4 of time most likely years it is imperative that as the process moves towards full functionality the requisite process changes be integrated into the Plan. Staff examined procedures with respect to key areas of PSEG LI s Plan including communications and coordination between PSEG LI and other utilities; procedures for addressing down wires; flood restoration protocols; identification of critical facilities or infrastructure; development and communication of estimated times of restoration; communications with local officials; communications with customers, including life support equipment and special needs customers; communications with the media; training and drills; potential use of National Guard resources; and, PSEG LI s emergency restoration organization s structure. Of these key areas, Staff highlights the Plan s procedure on communicating with customers through its contact center and its procedure on dealing with down wires as areas that are appropriately addressed. Areas of the Plan such as communications with Life Support Equipment (LSE) and Special Needs customers; damage assessment; estimated time of restoration; and coordination with telecommunications and gas utilities require improvement and Staff has made appropriate recommendations in this regard. The recommendations are intended to align PSEG LI with industry wide best practices. Staff participated in numerous meetings, engaged in conference calls and exchanged several s with PSEG LI. Interactions with PSEG LI were productive and PSEG LI was receptive to Staff s comments and suggestions regarding the Plan. During these meetings PSEG LI outlined various ongoing initiatives that will have a significant impact on future Plans. In addition to the new OMS an improved Interactive Voice Response system will be placed in service at the Customer Contact Center; inspection and certification procedures during flooding events will be developed and finalized; the current Plan will undergo extensive streamlining; and improvements will be made to its Emergency Response Organization (ERO). Emergency response plans must be considered dynamic and fluid documents, subject to continual review and update. Plan maintenance, through evaluation of events, exercises, and changing circumstances, is necessary to identify plan deficiencies. To the extent that PSEG LI s Plan will continue to evolve given the initiatives currently underway, Staff emphasizes PSEG LI s obligation to revise the Plan throughout the year to reflect significant and material changes to its emergency response processes and submit such revisions to Staff for review prior to formal incorporation into the Plan. Future improvements to the Plan will reflect PSEG LI s 4

5 identification of best practices, lessons learned, and Staff s recommendations will continue to be reflected in subsequent versions of the Plan which are required to be filed annually with the Department. 5

6 2.0 INTRODUCTION 2.1 Emergency Plan Filing Requirements On January 1, 2014 PSEG LI formally assumed responsibility for the management, operation and maintenance of LIPA s electric transmission and distribution assets in accordance with the terms of the Amended and Restated Operations Services Agreement (OSA) dated December 31, The LIPA Reform Act, in part, directed PSEG LI, as the service provider, to submit on or before February 3, 2014 an emergency response plan to the Department for review and recommendation and to file a Notice of Public Comment with the Secretary of State to be published in the State Register. The LIPA Reform Act required LIPA and PSEG LI to make the plan available to the public for review and the opportunity to provide written and oral comments, with written comments to be provided by March 14, LIPA and PSEG LI were also directed to conduct at least one public hearing in Nassau County and at least one in Suffolk County. The Authority and Service Provider are also required to provide copies of all written comments and hearing transcripts to the Department for its consideration in reviewing the Plan. The Department is required to provide its recommendations to the LIPA Board of Trustees not later than April 15, 2014 based upon its analysis of the Plan and review of the public comments received. The Plan must be made final not later than June 2, Public Comments Pursuant to the LIPA Reform Act, two public hearings were conducted on March 13, The first public hearing took place in Suffolk County and the second public hearing took place in Nassau County. Staff attended both public hearings. No oral comments were offered at either public hearing. Written comments were accepted through and including March 14, 2014, the expiration of the comment period. Written comments were received from the Towns of Hempstead, North Hempstead, Brookhaven and Oyster Bay and will be addressed in the Flooding Restoration Procedure section of this document. 2.3 Department of Public Service Staff s Review Process During the course of its review of the Plan, Staff was guided by the provisions of the Public Service Law (PSL) 66(21)(a) as amended by The LIPA Reform Act, New York Code, 6

7 Rules and Regulations Part 105 (16 NYCRR Part 105), and recommendations made by the Moreland Commission on Utility Storm Preparation and Response. An emphasis was also placed on the work done or identified in Case 13-E (August Order) for consistency with emergency response management throughout the State to establish industry-wide best practices in such areas as flooding preparation and response, safety concerns with down wires, and coordination with other utilities. Both the PSL and 16 NYCRR Part 105 establishes the steps to be taken in anticipation of major emergency events. They also define roles and responsibilities of personnel for each activity, contain strategic contact information in the event the plan is activated, and set forth communication protocols with customers and other outside stakeholders in the event the emergency plan is activated. The New York Investor-owned utilities (IOUs) and LIPA s response to Hurricanes Irene and Sandy served as the impetus for a more comprehensive review and approval process of emergency response plans in New York State. Governor Cuomo established by Executive Order 2 the Moreland Commission on Utility Storm Preparedness (Moreland Commission) on November 12, The Moreland Commission was directed to review the preparation, response, and management of the IOUs to a number of severe weather events. Upon receipt of the Moreland Commission s Interim Report, Governor Cuomo proposed legislation (LIPA Reform ACT) that strengthened the Public Service Commission s (PSC) regulatory role over the IOUs, and expanded the oversight role of the Department to include LIPA and its service provider, PSEG LI. In its Final Report the Moreland Commission concluded that improvements were needed to better prepare the New York utilities to respond to the growing threat of catastrophic weather events. To that end, the Moreland Commission made several recommendations that were tailored to address areas of weakness uncovered during its investigation. Further, the Moreland Commission acknowledged the need to put forth recommendations targeted at specific utilities and made recommendations to establish industrywide best practices in such areas as flooding preparation and response; safety concerns with down wires; and, coordination with other utilities. 1 2 Case 13-E-0198, In the Matter of 2013 Electric Emergency Plan Review, Order Approving Electric Emergency Plans. Issued August 16, (August Order) Executive Order 73. 7

8 PSEG LI formally filed its Plan with the Department on February 3, Prior to this filing, Staff held several meetings with PSEG LI to discuss statutory requirements and clearly define expectations for the February filing. Staff s comprehensive review of the Plan included the operations, communications, and logistics components of PSEG LI s Plan. Staff examined procedures with respect to key areas including communications and coordination between PSEG LI and other utilities; procedures for addressing down wires; flooding protocols; identification of critical facilities or infrastructure; development and communication of estimated times of restoration (ETRs); communications with local officials; communications with customers, including life support equipment and special needs customers; communications with the media; training and drills; potential use of National Guard resources; and, PSEG LI s emergency restoration organization s structure. In order to develop a thorough understanding of PSEG LI s emergency response philosophy, Staff requested that PSEG LI provide additional information regarding its emergency management, operations, and communications procedures. In response, PSEG LI submitted supplemental documentation which was also considered in the course of Staff s review. In accordance with the LIPA Reform Act, this report details Staff s analysis of the PSEG LI Plan and provides specific recommendations to LIPA and PSEG LI to further improve the Plan. 3.0 ONGOING INITIATIVES During various meetings, PSEG LI has indicated that it expects to make changes in the ways it responds to emergency events over the remainder of this calendar year and that its emergency response plan would be revised accordingly to reflect any material changes to its current practices. These changes include the implementation of a new Outage Management System (OMS); improvements to its Interactive Voice Response (IVR) system in its Contact Center 3 ; streamlining and reformatting the current Plan; and strengthening its Emergency Response Organization (ERO). 3.1 Outage Management System Upgrades Efforts are currently underway to develop and introduce a new OMS for PSEG LI. Building on a successful implementation at Public Service Electric and Gas Company (PSE&G) in New Jersey, the project involves the implementation of CGI's PragmaLINE (CGI) outage 3 Contact Center is a term used by PSEG LI and is synonymous with Call Center. 8

9 management solution. This system will replace the existing legacy Computer Assisted Restoration of Electric System (CARES) OMS which, while still functional, operates off an older mainframe platform and does not allow for all of the functionality available in the newer CGI system. Once completed, its implementation is expected to improve outage response and restoration, overall operational performance, and customer satisfaction. Roll out of the new OMS is expected to begin in the summer of Development and implementation of a complex outage management system can span multiple years and often involves extensive procedural and training reforms. During the transition period, both the CARES and CGI systems will be used in parallel until such time as full functionality with the new system has been achieved. Therefore, in the interim, PSEG LI should look to simple and inexpensive ways to improve and maximize the functions of its current OMS. Staff is cognizant that changes relative to the CGI system will evolve as will the modifications to PSEG LI s emergency response procedures; however, PSEG LI is cautioned to ensure that the Plan reflects the most current procedures and training associated with the implementation of the CGI system as the roll out progresses. 3.2 Interactive Voice Response System Upgrade PSEG LI s current IVR system is being replaced this year with the Nuance Natural Language IVR system as a means to improve the overall customer experience. The legacy system does not use natural language recognition technology. The ability to quickly and efficiently navigate the new IVR system will allow customers to quickly and efficiently navigate the IVR and provide real time outage update information are proven drivers for customer satisfaction, which is one of the highest priorities for PSEG LI. The IVR system upgrade will provide the ability for customers to schedule a callback at his or her convenience when a representative becomes available; provide customers with outage restoration updates; and, include an enhanced screen pop that provides a Contact Center representative with more detailed information about where a customer left off in the IVR system. The new IVR system, to be implemented in the third quarter of 2014, will offer customers who prefer to communicate with PSEG LI through electronic technologies a broader offering of options that are readily available and easy to navigate. 9

10 3.3 Flooding Restoration Procedure PSEG LI is working with municipalities to derive a coordinated process for dealing with flooding events. At present, the Plan identifies the responsibilities and actions of PSEG LI and municipalities during a flooding event. The Plan states in addition to its own assessment, PSEG LI will rely upon the direction of the municipality to identify locations to de-energize and restore service. Opposing comments regarding this procedure were received from the Supervisors of the Towns of Hempstead, North Hempstead, Oyster Bay, and Brookhaven (Supervisors). The comments received are the basis for ongoing collaboration to revise PSEG LI s flooding restoration procedures. In their comments, the Supervisors requested that PSEG LI withdraw any practice involving municipality involvement in the de-energizing and restoration processes. The Supervisors further state that the townships do not have electricians, and restoring electrical service through hiring and training electricians and inspectors is beyond the scope and capacity of their expertise. The Supervisor of Brookhaven requests that PSEG LI hold meetings in each county served by LIPA before adopting a new emergency plan. The Supervisors of Hempstead and Oyster Bay states the Towns involvement, as stated in the Plan, would only increase delays, add an unnecessary bureaucratic layer, and add entities to the blame chain in the restoration process. The Hempstead Supervisor recommends that PSEG LI have a workable plan with clearly defined roles and also that the townships are provided an opportunity to hear directly from PSEG LI how it will carry out the proposed inspection process revision. The Supervisor from Hempstead also suggests that customers would be better served by a utility that familiarized itself with local geographic characteristics rather than allowing large numbers of counties, towns, villages, police and fire departments play a role in electric service restoration. PSEG LI responded in a letter sent to all Long Island Town Supervisors along with the Nassau and Suffolk County Village Officials Association. The letter states that PSEG LI has examined the LIPA tariffs and has offered a revised inspection and certification process to be incorporated into its Plan. PSEG LI states that it will conduct the initial assessment to determine if an electric inspection certification must be obtained by customers prior to electric service being restored thereby removing municipality involvement in this process. PSEG LI further proposes to provide on its website and through other appropriate mechanisms, useful information 10

11 such as electrical contractor lists, required certification forms, and general guidance on the overall inspection process to be followed to assist customers. Staff acknowledges that collaboration with the Towns and Villages to develop a final inspection and certification process is ongoing. Although the Emergency Response Plan addresses flood restoration procedures, any revision made to these procedure must be made to the satisfaction of Staff and reflect the concerns of public officials. To that end, Staff will continue to monitor this effort over the next several weeks, providing input that will ensure the appropriate procedures are in place and memorialized in the Plan put in place on June 2, When revising the flood restoration procedures, PSEG LI should consider separate processes for handling small scale flooding events and large scale flooding events. In doing this, it would need to define what would be considered a large scale event. Customer restoration should focus on allowing speedy restoration and coordination with gas companies. The Plan should also clarify, where appropriate, the different procedures required for flooding in areas served by an underground systems. The Plan should also address recommendations of the Moreland Commission regarding training related to de-energization and re-energization procedures with municipalities; and incorporation of a coherent, uniform policy for streamlining the re-energization of flooded customer equipment. 3.4 Streamlined Emergency Plan PSEG LI has informed Staff that the Plan that goes into effect in June 2014 is an interim or bridge Plan for PSEG LI has indicated that in addition to updating its plans to include its new OMS and IVR system discussed above, it will also extensively rewrite and reorganize the Plan to be more in line with the IOUs emergency response plans. Staff is in agreement that the present Plan is unwieldy and cumbersome to navigate, and is encouraged by PSEG LI s commitment to condense and simplify this document. The current Plan consists of an introduction, multiple procedures referred to as Emergency Restoration Implementation Procedures (ERIPs) for operations and communications, and the Logistics Support Emergency Procedures (LSEPs). The Plan provides many detailed instructions on PSEG LI s approach to emergency response which provides a person new or unfamiliar with an emergency response role valuable insight on the actions required, programs to use, and supplemental procedures to review. In recognition of PSEG LI s goal to overhaul its Plan for the December 15, 2014 filing, Staff highlights some areas below that PSEG LI can consider when making this change. 11

12 The Plan is voluminous - consisting of approximately 2,000 pages. PSEG LI should review all the information currently in the Plan for need, and streamline the information to minimize duplication, allow users to quickly locate information, and to reduce document management problems when edits and updates are required. The ERIPs and LSEPs originated from different documents as is evident by the differences in formatting and level of detail presented in each. There are inconsistencies regarding the type of information (i.e., definitions, checklist, instructions, etc.) and order in which the information is presented in the Plan procedures. The emergency activities and information in the communications section of the Plan are organized by a person s title; while operations and logistics organize information by task. By way of example, PSEG LI can look to several sections in the Plan to serve as models for the consideration in streamlining the Plan. ERIP has a definition section to explain the terms unique to this procedure; a storm position section that explains in one concise area a person s overall role and responsibility by title; recommended staffing level depending on the level of response needed; and provides pertinent contact information. ERIP adequately presents the training and drill information discussed under Part 105.4(b)(4) and includes a description of each drill and training, outlines how drills and training will be managed, and provides a schedule for when each drill will be conducted. Lastly, the Communications ERIP - Assignments and Responsibilities procedure under ERIP 2.0 provides the name, contact information, and assigned physical locations for key titles in the emergency organization. 3.5 Emergency Response Organization PSEG LI is the only major NY utility that has not fully implemented an Incident Command System (ICS) structure; however, PSEG LI has indicated that internal discussions are ongoing and the move to an ICS structure will occur in the near future. An ICS structure is an organizational tool that establishes command, control, and coordination of an emergency response regardless of size and complexity of an incident. According to Federal Emergency Management Agency, ICS establishes common processes for planning and managing resources; is used by all levels of government (federal, state, tribal and local) as well as by many nongovernmental organizations and the private sector; and is applicable across disciplines. It is typically structured to facilitate activities in five major functional areas: Command, Operations, Planning, Logistics and Finance/Administration. All of the functional areas may or may not be used based on the incident needs. 12

13 PSEG LI has revealed to Staff interim changes it plans to make to its emergency organization charts to be more in line with an ICS structure. Upon review of the revised organization charts Staff found that PSEG LI has better aligned the communications and logistics leads to show that they report up to the Incident Commander. The revised charts clearly differentiate who reports to the Operations & Survey Control System Coordinator versus the Crew Control System Coordinator. The revised charts also reduced the areas where a person is responsible for more than seven individuals. Staff concurs with these changes as an interim solution pending full implementation of the ICS structure. 13

14 4.0 COMMUNICATIONS 4.1 Contact Center Background Prior to, during, and after an electric outage event, consumers look to their utility s contact center for guidance regarding safety concerns (e.g. down wires), ETRs, identification of electric outages, description of restoration efforts, and availability and distribution locations for dry ice. Emergency response plan includes information relative to contact center staffing, and responding to and management of high call volumes. The August Order requires utilities to have procedures that clearly identify the methodology to determine contact center representative staffing levels, include contact center performance objectives and goals, and identify the triggers and parameters for the activation and use of third party vendor assistance in handling increased call volumes. The intention of the August Order is to ensure that the utility contact centers remain prepared at all times to assist customers, through advanced preparations and planning, to control the call volume, call handling time, and improve overall customer experience when contacting the utility during an emergency Findings The Plan reflects that PSEG LI is committed to providing good customer service to the ratepayers and other stakeholders. For example, the Contact Center Director is responsible for the efficient operation of the Contact Center staff in order to achieve an answer rate of over 80 percent of calls within 90 seconds. The Plan further specifies performance objectives and goals including triggers used to support High Volume Call Assistance utilization and staffing decisions: Achieve Service Level of 90% answered within 90 seconds; Achieve Average Speed of Answer of less than 70 seconds; and Achieve Abandonment Rate of less than 5.00%. These statistics each show that PSEG LI has set high standards for performance which should ultimately benefit customers who are reaching out to its Contact Center representatives for assistance during electric outage events. 14

15 4.2 Life Support Equipment and Special Needs Customers Background An LSE customer is a customer or a resident of a customer s premises who requires electrically operated machinery to sustain basic life functions. 4 Utility emergency plans should state the procedures for contacting LSE customers within 24 hours of an emergency event and the policies for responding to these customers needs for electric service to sustain basic life functions. Special needs customers are another category of customers who require additional assistance. These customers include the elderly, the vision-impaired, the hearing and speechimpaired, the mobility-impaired and human service agencies representing these special needs customers. Special needs customers also include those customers for whom a documented medical emergency exists. For a customer to be designated a special needs customer based on a medical emergency, the utility is notified in writing by a medical doctor or a qualified official of the local board of health of the medical emergency or the reason why the absence of utility service would aggravate the medical emergency Findings Currently, PSEG LI has identified approximately 6,000 LSE and approximately 41,000 special needs customers within the LIPA service territory. PSEG LI s Plan includes a procedure for contacting LSE customers within 24 hours of an emergency event. PSEG LI has adequately identified the procedures that it will utilize to establish and maintain contact with LSE and Special Needs customers prior to, during, and after an emergency event. Moreover, PSEG LI s Plan does a good job of outlining the procedures that address instances when the utility is unable to reach an LSE or Special Needs customer at any time prior to or daily during an event. These procedures include the use of alternative methods of contacting LSE customers, such as field visits, in the instances where customary communication means have failed. Lastly, PSEG LI s Plan also includes its policies for handling inquiries and requests for assistance from LSE, special needs customers, and human service agencies representing these customers. Absent from the Plan, however, are procedures for and details of PSEG LI s plans to conduct general outreach to and education of LSE and Special Needs customers throughout the year. The August Order clearly states the need to establish outreach procedures and provide 4 5 Part 105.4(b)(9). Title 16 of the NYCRR Part 11.5(a)(3). 15

16 educational materials to LSE and Special Needs customers that clearly define utility and customer responsibilities during emergency events Recommendation Include procedures in the Plan detailing outreach and education to LSE and Special Needs customers throughout the year. 16

17 5.0 OPERATIONS 5.1 Damage Assessment Background One of the first steps to restoring electric service is an assessment of the damage sustained by the electric system. When damage assessment is done timely and comprehensively, it improves the use of resources and reduces electric restoration time. Accurate damage assessment plays a significant role in setting restoration priorities, efficient crew assignments, protection of equipment, rapid restoration to critical facilities, and issuance of accurate ETRs. Damage assessment information can be obtained through intelligent instrumentation of the system and/or field observations and testing. For emergencies such as system-wide outages, preliminary damage assessment is required for planning and communication purposes. The emergency plans should include procedures for mobilizing resources in order to survey system damage and describe the method for communicating with surveyors. For severe emergencies requiring damage assessments, emergency response plans should describe the methods for making broad scale preliminary assessment by rapid survey of damaged areas within 24 hours, and within 48 hours, make more detailed estimates of system damage; describe how damage reports will be integrated with other sources, such as customer call-ins to make an assessment of system damage Findings Overall, PSEG LI has a sound approach to damage assessment. Initial damage predictions take into account historic data from previous storms, actual and forecasted weather, current level of electrical demand compared to historical demand, and partial completion of system-wide surveys. Restoration times and resource needs are refined as more survey data is collected. 7 For the transmission system, survey teams patrolling in vehicles and/or helicopters are assigned a circuit according to priority. 8 For the distribution system, survey teams can be dispatched from the substation supplying electric service to the area to be assessed. 9 Consistent with most utility procedures, the surveyors are instructed to first survey the unfused portion of Part 105.4(b)(7). ERIP ERIP ERIP and ERIP

18 the three phase main distribution system. Transmission and distribution surveyors record the type and location of damage on paper forms. When the first fault is found, transmission surveyors are required to immediately call to report damage; distribution surveyors should return to the substation to report damage. This allows quicker assignment of repair crews to outage jobs and the capability to restore electric service through switching. Surveyors continue to assess the electric system until the entire system has been surveyed or have been instructed to stop. Along with field surveys, damage information is congruently gathered through system sensors and instruments. Still, the Plan should provide guidelines as to how quickly damage assessment should be accomplished. By having requirements to complete broad scale preliminary assessment by rapid survey of damaged areas within 24 hours and a more detailed estimate of system damage based on field surveys in 48 hours, PSEG LI would be in a better position to develop and issue accurate ETRs. Communicating this information to the public also assists with setting appropriate customer and municipal expectations. PSEG LI has informed Staff that it has a pilot program in place that uses tablets to electronically transfer damage assessment information from the field. This is a positive step forward in improving the way that the utility responds to emergency events. Staff finds that this pilot program should be expanded and linked to the OMS. In doing so, surveyors would be able to obtain procedures and system maps from the tablet; the electronic damage assessment form could be designed to minimize common inputting errors, allow the incorporation of field pictures, as well as provide the opportunity to remotely assign work. This will allow for more efficient development of estimated restoration times, better utilization of resources, minimization of human error, and better post emergency analysis Recommendations Include in the Plan a procedure that describes the method PSEG LI will use to make broad scale preliminary assessment by rapid survey of damaged areas within 24 hours, and within 48 hours a more detailed estimate of system damage based on field surveys. Expand the pilot program with the goal of implementing a system-wide electronic tool for capturing damage assessment information from surveyors in the field that can be linked to the Outage Management System. 18

19 5.2 Estimated Time of Restoration Background Communication of ETRs is vital to the public. This critical piece of information allows customers, municipal officials, and emergency personnel to be able to properly plan for the safety of civilians and protection of property. ETRs are only effective when they are accurate and timely issued; therefore, the utilities have procedures in accordance with the ETR Protocols that sets expectations of when ETRs will be available depending on the outage impact of an emergency event. 10 Reporting time frames differ for events expected to last less than or equal to 48 hours and for events expected to last greater than 48 hours. 11 The ETR Protocol breaks down ETRs into three categories: global, regional, and local. Global ETR is the time that majority of the customers within a utility service area will have electric service. Regional ETR relates to restoration times for a section of a utility service area that might be considered by the utility as an operating area, division, or district. The local ETR consist of restoration times by villages and/or townships. All three types of ETRs should be applicable to at least 90% of the affected customers Findings PSEG LI has multiple ways to generate ETRs depending on the amount of system information available and the extent of the emergency event. The Plan also provides sufficiently detailed instructions to guide those unfamiliar with the process used by PSEG LI to generate ETRs. PSEG LI has methods for estimating and refining initial restoration times and storm impact. Pre-storm estimates and initial predictions are based on past storm data from 1990 to present. The projected path and predicted severity of the current storm are also considered. A Estimated Time of Restoration Protocol presented in the August Order discusses the Department s expectation of when information will be available during storms or storm like emergency when more than 5,000 customers are interrupted for more than 30 minutes within a division or more than 20,000 customers interrupted companywide for more than 30 minutes. For outage events expected to last 48 hours or less: notify DPS of event within the first 6 hours, provide DPS with a global ETR, and prepare a statement for press release within the first 12 hours. Establish ETR for each locality affected and make them available to public within the first 18 hours, and consider issuing press release based on condition within first 24 hours. For outage events expected to exceed 48 hours: utility should notify DPS of a multi outage day event within the first 6 hours, prepare press release, and communicate with affected municipal and government official within the first 12 hours. Schedule municipal conference calls within the first 18 hours and notify DPS regarding areas impacted by most damage within the first 24 hours. 19

20 computerized spreadsheet is used to predict the number of customers out of service during major storms has the ability to and can produce initial days to restoration. The spreadsheet predictions are based on the amount and type of restoration crews, feeder outages, and system information such as number of switches, circuits, and customers served. The spreadsheet provides a rapid and rough computation of restoration information. As the restoration process continues and better field survey data and crew availability is known, ETR estimates continue to be refined and will progress from system level to regional/divisional level to substation level to circuit/neighborhood level. The Plan states, at minimum, ETRs will be provided in accordance to the ETR Protocol. DPS staff finds that this method for generating pre-event and initial ETR is a useful approach. The Plan discusses division level coordination of ETRs for substations in Substation Dispatch Authority (SDA) 12 or Local Control. 13 It states the Group Coordinator shall verify new ETRs, update the ETR in OMS, and ensure that all restored jobs are shown as completed in OMS in a timely fashion. For ETRs on next day planned work, Group Coordinators shall ensure such things as end of day reconciliation of work, establishment of new ETRs for jobs not completed and ones newly scheduled, and determining resources needed is completed timely. The Group Coordinators manually enter ETRs identified for next day scheduled work. On the other hand, the ETR Coordinator monitors work dispatched in OMS, ensures that job level ETRs are provided where possible and that they are accurate, verifies the substation s daily work plan, and validates and updates associated information in various reports while also acting as the technical advisor for the communications liaisons. The PSEG LI Division & Substation Communication Liaisons gather information regarding outages and ETRs, restoration activity, crew locations, and manpower for substations in either SDA or Local Control. These liaisons also organize and update this information in the Division communications website at a minimum of twice daily. Staff finds that the Plan clarifies the roles of all parties responsible for ETRs at the division level; however, there appears to be an overlap on the management of ETRs between the Group and ETR Coordinators. In addition, there appears to be no system in place to fulfill the ETR Protocol request for updated ETR information four times a day during restoration periods exceeding 48 hours Substation Dispatch Authority provides the substation the authority to only dispatch crews to the area served by the substation. ERIP and ERIP

21 The procedure for generating more refined and accurate ETR on a substation level is explained in ERIP The ERIP defines the steps for developing circuit level ETR for multiple customer outages and single customer outages using the Substation Restoration Algorithm (SRA). 14 SRA is used at the substation when it has been placed into either SDA or Local Control through a computer program. SRA requires current and accurate information on the amount, assignment, and type of repair crew; percentage of circuit field surveyed; and repair jobs and its status. As more damage locations are bundled under a job the algorithm can become less accurate. The SRA uses an average repair rate of 2 high voltage jobs per crew per day and 6 low voltage jobs per crew per day. The algorithm can be used to provide revised ETR information as more system information is available. Information used by SRA is manually entered. Overall, Staff finds that the methods discussed above allows for accurate development of ETRs. Nevertheless, the Plan needs to specify whether and when restoration times generated pertain to global, regional, or local ETRs. The Plan discusses generating initial ETRs first and follows by discussing ETRs for jobs and circuits generated at the division or substation level. While these ETRs are the basis for global, regional, and local ETRs and that PSEG LI should continue to generate these ETRs for internal planning and coordination. Yet increased emphasis should be placed on distinguishing when and how global, regional, and local ETRs are derived. Global, regional, and local ETRs are important information, especially for emergency events that result in long outage durations, and should be used to communicate to the public through press releases and other means. These styles of ETRs, along with ETRs on next day planned work that PSEG LI currently perform, are more useful and meaningful to customers and other external entities. Global ETRs are used by IOUs for press releases and take into account projected damage, crew activity, and other pertinent information. As concrete system information is collected, utilities build on global ETR in order to generate regional and local ETRs. 14 The Substation Restoration Algorithm (SRA) is a quantitative tool for PSEG-LI to provide customers with estimated restoration times. This algorithm can only execute once a substation has been placed under Local Control under the jurisdiction of the substation area coordinator. The SRA calculates estimated restoration times based on pending repair orders and damaged patrols (or RP-5 forms). As more damage locations are identified, RP-5 forms are grouped and prioritized into outage pockets. As a result, ETRs provide a more accurate representation of service restoration time. 21

22 It is difficult to judge whether ETRs will be generated in a timely manner by PSEG LI. The Plan states that ETRs will be provided in accordance with the ETR Protocol; however, in order to ensure timely generation of ETRs, PSEG LI should describe in its procedures what actions will be taken, by whom, and when to follow what was outlined in the ETR Protocol. In addition, many of the work required to obtain timely ETRs are manually intensive and begs the question if enough manpower is available to allow for timely ETR during severe emergency events. DPS staff recognizes that LIPA s new OMS would automate many steps and allow for the generation of timely and useful ETRs Recommendation Create a procedure to fulfill the ETR Protocol request for updated ETR information four times a day during restoration periods exceeding 48 hours. Clarify how and when global, regional, and local ETRs are determined to provide ETRs on a more customer minded basis and to be consistent with the ETR Protocol used elsewhere in the State. 5.3 Coordination with Telecommunications Providers and Gas Utilities Background During times of emergency, manpower resources can be limited and job completion might be dependent on prerequisite work to be done by other entities. Telecommunications services are important since it is relied upon by first responders, emergency management personnel, the general public, and electric utilities during an emergency. Previously, communications between the electric utilities and telecommunications providers occurred at the local level and did not allow for more widespread planning during large events. This practice is evolving. In addition, coordination between gas and electric utilities is now viewed as a way to expedite safe restoration of gas and electric service to customers, especially important during winter months when most heating systems will not work without electricity. Therefore, there has been an increased effort to coordinate restoration activities between the industries. To assist with this process, it is essential to have predetermined plans in place on how coordination will take place. The emergency response plan should state the policy and criteria governing conditions under which requests for service restoration aid from other utilities, contractors, government 22

23 agencies or others would be made. 15 Further, the Moreland Commission recommended that utilities formalize coordination with telecommunication and cable providers before and during major events, including the placement of utility and cable personnel within each other s emergency command centers; that cable providers and utilities devise a means to share relevant system information during emergency periods; re-evaluate utility emergency plans in light of the recent storms; and ensure that critical infrastructure lists include critical telecommunication and cable facilities. 16 The August Order states that a section in the emergency response plan should be devoted to communications and coordination with gas and telecommunication companies; including the type of information that will be shared, such as, critical facilities, locations of crews, location of outages, locations of wires down, generator locations, ETRs, crew progress, corporate level, and local level contact information Findings PSEG LI has a good restoration coordination process with Verizon that can be beneficial to developing a coordination procedure for the other telecommunications companies in the LIPA service territory. The Plan states that PSEG LI will coordinate with telecommunication and cable providers, for planning and emergency response; and make every effort to obtain critical facility information from telecommunications, cable, wireless, gas, water, and sewer providers. ERIP and discuss PSEG LI s coordination with other utilities. ERIP effectively covers the coordination of restoration work with Verizon and states the policy and criteria governing conditions under which request for aid would be made. The procedure complies with the Moreland Commission recommendations and the August Order for coordination with Verizon. It includes preset locations to place Verizon personnel (Telco Coordinators). Assigned Verizon and PSEG LI personnel who will facilitate the coordination along with their respective contact information are provided. The Plan designates individuals that are responsible for advising the Telco Coordinator of feeder outages and restoration; assist the Telco Coordinator and crews in clearing LIPA lines interfering with Verizon restoration work; requesting from the Telco Coordinator a list of locations by importance of where LIPA Part 105.4(b)(11). Moreland Commission, On Utility Storm Preparation and Response, June 22, 2013, p. 52. August Order. 23

24 lines are to be cleared of Verizon equipment; agreeing upon the order in which these locations are to be cleared with the Telco Coordinator. They also verify or request the surveying of damage locations for repair crew assignments. PSEG LI and Verizon may combine or co-locate their work resources.!!staff finds that the work agreement between PSEG LI and Verizon allows room for flexibility depending on the type of event, is well thought out, and is a good model that PSEG LI can use to encourage other entities to get agreement on coordinated restoration efforts. Notwithstanding, the Plan should better cover information discussed under the Moreland Commission recommendations and August Order for wireless telecommunication companies, the local gas utility, and other phone and cable companies in LIPA service territory. It should also state the policy and criteria governing conditions under which request for aid and coordination would be made to these entities. An emergency procedure similar to that in place for Verizon should be created for PSEG LI coordination with other telecommunication companies and local gas utility. Coordination with the gas utility is briefly discussed in the Plan where it states that when gas service has been interrupted due to flooding, PSEG LI will coordinate restoration effort with gas utility in the Emergency Operation Centers (EOC). PSEG LI also does not have a list of critical facilities for the gas utility. PSEG LI needs to discuss its use of National Grid gas crews and personnel as contractors and how this would impact its coordination efforts. ERIP covers PSEG LI coordination of restoration work with Cablevision. The revised ERIP sent to Staff in March states that this procedure would also include Time Warner and Verizon FiOS. PSEG LI made a wise decision to base this procedure on the ERIP that discusses PSEG LI coordination with Verizon. However, ERIP still requires additional work. No official agreement has been put into place between PSEG LI and the other telecommunication companies. There is no preset locations shown for Cablevision personnel (CATV Coordinator) to report to, and telecommunication assigned personnel and contact information is not available. PSEG LI should look into creating a procedure that completely covers the coordination efforts with all other telecommunication companies. PSEG LI and Verizon have coordinated efforts for setting utility poles in prior emergency events. This is an excellent way to share manpower resources to expedite restoration. PSEG LI should extend this practice, where feasible, with other telecommunication companies to coordinate manpower resources for such activities as damage assessment to expedite electric 24