can%-c Ms. Sandra Squire Executive Secretary Public Service Commission of West Virginia 201 Brooks Street PO Box 812 Charleston, WV JLM : dml

Transcription

1 AhP4 25 9,oi;3 Pri& KAEt SEC BXa3 A FirstEnergy Company John L. Munsch Attorney 800 Cabin Hill Dr. Greensburg, PA Telephone: Fax: January 14,2013 VIA FEDEX OVERNIGHT Ms. Sandra Squire Executive Secretary Public Service Commission of West Virginia 201 Brooks Street PO Box 812 Charleston, WV Re: Fall Run Community v. Monongahela Power Company; Case No E-C Dear Ms. Squire: Enclosed for filing please find an original and twelve (12) copies of Monongahela Power Company s Answer and Motion to Dismiss in the above-referenced matter. A copy has been served upon Complainant by First Class US. Mail. Sincerely, 7 can%-c John L. Munsch Attorney WV State Bar No JLM : dml Enclosures cc: Certificate of Service

2 THE PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON CASE NO E-C FALL RUN COMMUNITY Complainant V. MONONGAHELA POWER COMPANY Defendant ANSWER AND MOTION TO DISMISS ANSWER Monongahela Power Company ( Mon Power or Company ) submits an Answer and Motion to Dismiss in response to the above-captioned Complaint of Fall Run Community, ( Complainant ) in this proceeding and on information and belief says: 1. Monongahela Power denies that it has violated the provisions of West Virginia Code Chapter 24, the Commission Rules for the Government of Electric Utilities or its own rules and regulations. 2. The Complainant contends that the Company s restoration activities describing the outages at the Fall Run Community near Ireland, West Virginia, is inadequate. Specifically, the customers are concerned about the power line leading up to their community being restored

3 first, and then the service to their community being restored at a later date. The group of customers refers to two major storms in the June 29 derecho event and the October 29 Hurricane Sandy event. The June derecho event began on the evening of June 29 and the restoration effort continued through the first two weeks of July. During these two weeks, the Company also experienced multiple additional high wind events which interrupted additional customers, The storm, in terms of overall outages, was the largest in Mon Power history. The customers state that their outage lasted six days. It is important to note that on day six of the storm, Mon Power s restoration effort was in full force and, in addition to restoring the distribution line serving the customers, Mon Power was also continuing to work on restoring elements of its transmission system as well as large customer blocks. The Hurricane Sandy event began on the evening of October 29, and, like the derecho, caused massive and widespread damage to Mon Power s system. In addition, because of the snow and tree conditions affecting the roads, including some major roadways, there were areas that were inaccessible to Mon Power workers and other emergency workers for multiple days following the initial storm. The customers mention that they were out of electric service for eight days, The Company s restoration effort, which was hampered not only by travel and accessibility conditions, but also by the sheer number of damaged poles and ines, continued until November 16. Mon Power follows the FirstEnergy storm restoration process, which is intended to ensure safety, and to restore customers as quickly as possible. Power was knocked out to large numbers of residential customers as well as hospitals, police and fire departments, water pumping stations, schools, and other important public facilities. -2-

4 When an outage is widespread, restoring power to all affected customers at the same time is not possible. Generally, service crews first must restore transmission and substation facilities, as they supply power for local distribution systems. Next, the Company gives priority to hospitals, critical care and life support facilities, communications facilities, and emergency response agencies. After that, crews work to restore power as quickly as possible to the remaining customers. Customers may wonder why crews drive past their homes instead of stopping to restore power. Especially early in a storm s aftermath, Company linemen often are responding to hazardous situations or high-priority damage locations. In the early phases of storm restoration, the Company s primary focus is to find areas with electrical hazards - such as downed (and potentially energized) wires and related electrical equipment - and make them safe. At such times, linemen focus on isolating these hazards. The Company understands customers frustration when they see Company or mutual assistance vehicles and line workers in their area during a storm restoration effort, and then see them leave without completely restoring power. The restoration effort must follow an orderly process to restore service to customers as safely and quickly as possible. A copy of the outage event history for the customers is attached as Exhibit 1. A copy of the reliability record for the customer s circuit is attached as Exhibit 2. MOTION TO DISMISS The Commission maintains an ongoing general proceeding to investigate the storm restoration activities in West Virginia. The proceeding is docketed at Case No E-T-W- GI. Each of the electric utilities operating in the state is a respondent to the proceeding, The -3-

5 GI. Each of the electric utilities operating in the state is a respondent to the proceeding. The Complainants instant complaint concerns general storm restoration activities and procedures and is best considered in the context of the generic proceeding. Other general complaints involving storm restoration activities have been dismissed as stand-alone proceedings and consolidated in the general proceeding. See Stalnaker v. Monongahela Power Company, Case No E-C (Consolidation Order issued October 1, 2012). The Commission held public comment hearings on November 15,2012, in Charleston, West Virginia, and on November 19,2012, in Clarksburg, West Virginia. Commenters were invited to address the Hurricane Sandy restoration as well as the derecho restoration. Monongahela Power requests, therefore, that the present proceeding be dismissed and filed with the general proceeding at Docket No E-T-W-GI WHEREFORE, Monongahela Power Company respectfully requests that the Public Service Commission grant Mon Power s Motion to Dismiss the Complaint of Fall Run Community. Respectfully submitted, MONONGAHELA POWER COMPANY Date: January 14, Cabin Hill Drive Greensburg, PA

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7 Substation - Circuit Month -Yr CI CMI SAID1 SAlFl CAlDl HEATERS - #4 HEATERS Dec HEATERS - #4 HEATERS Dec HEATERS - #4 HEATERS Dec-IO HEATERS - #4 HEATERS Dec HEATERS - #4 HEATERS Dec EXHIBIT 2

8 Re: Case No E-C VERIFICATION STATE OF MARYLAND, COUNTY OF AUEGM, TO'%": April E. McKenzie, Advanced Business Analyst, Compliance, Monongahela Power, being duly sworn, says that the facts and allegations therein wn(ained arc true, exccpt so fa as they are thmh statcd to be on information, and that, so fm as they are therei~ stated to be on information, she believes them to be true. Taken, sworn to and subscribed before me this fi day of January, MY commission expires: 3" 6-73, 201 b

9 , J Re: Case No E-C CERTIFICATE OF SERVICE I hereby certify that on this 1 4'h day of January, 201 3, a copy of the foregoing Answer and Motion to Dismiss was sent by U.S. Mail, First Class, to: Fall Run Community James Roe, et a1 16 Lowther Holw. Ireland, WV Staff Attorney Public Service Commission of West Virginia 201 Brooks Street PO Box 812 Charleston, WV John L. Munsch