Powerline Bushfire Safety Taskforce PO Box 262 Collins Street West VIC 8007 Introduction The VFF welcomes the opportunity to comment on the Powerline Bushfire Safety Taskforce consultation paper. The areas of bushfire safety and electricity distribution/cost are both very important to farmers. The VFF consists of an elected Board of Directors, a member representative General Council to set policy and eight commodity groups representing dairy, grains, livestock, horticulture, chicken meat, pigs, flowers and egg industries. Farmers are elected by their peers to direct each of the commodity groups and are supported by Melbourne-based staff. The VFF is of the opinion that the focus for ongoing safety in electricity deliver has to focus on proper maintenance of the lines and the vegetation surrounding the lines. Any changes in the physical distribution network must be cost effective and not compromise reliability. Also it is extremely important that any future investment into the distribution network (undergrounding, replacement with insulated lines, etc.) must be paid by all users of the network as the entire community benefits from this work. This submission will focus on the three priority issues for the VFF, being electricity reliability, the prices sensitivity of electricity users and distribution of costs. This submission will also address some of the direct issues raised in the consultation paper as they relation to these three issues. Electricity Reliability Issue No.3 To what extent are people prepared to accept a change to the operation of the network so that the likelihood of bushfires from the electricity supply system is reduced significantly, given that hose located towards the end of a powerline may experience a deterioration in the reliability of their electricity on high fire risk days? 1
The VFF is very concerned with electricity reliability. There are many farm businesses that rely on electricity for imperative daily operations. The VFF is very concerned that the consultation paper has a focus on the residential impacts and implications on unreliability, but agriculture related business are numerous and the impact of unreliability can be significant. The consultation paper stated the following: And: Overall, participants agree that they would be able to cope with a 12 hour power outage 1 Recognising that many people are now highly reliant on electricity for pumping water and fuel, for using telephones and the internet, for refrigerating food, and for comfort (air conditioning), the Taskforce has been investigating ways to reduce the number of people that would lose their electricity supply when powerline faults occur. The Taskforce has identified promising ways to reduce the number of customers that lose their electricity supply, however the risk to supply reliability on high fire risk days remains, especially for those located towards the end of a powerline. 2 We are concerned that the taskforce is not taking the impact of electricity loss to farm business seriously enough and focusing on the impact on households. Individuals may be in a better situation to deal with a 24hr black out, but that can be very costly for a farm business. The cost of interrupted service for businesses could be considerably more than just the added cost on the bill due from powerline technology improvements. Loss of electricity can have significant impacts on the operation of a farm business, and quality assurance issues. Electricity is used for vital farm business activities such as irrigation, cold room storage for production, cooling on dairy farms and processing for dairy For example, in regional areas of Victoria, there are over 50 dairy processing facilities, 5000 dairy farms, 40 egg farms and 1000s of livestock producers; all of which rely on electricity as a vital part of their business. Electricity reliability is essential for proper animal welfare, such as cooling chickens both meat and egg production, cooling of pigs and water delivery to troughs. These business can suffer extensive daily losses from a cut power supply. While the suggestion has been made that producers should have back up for critical needs as a power loss at any time would have impact on these and other issues of QA, the cost of back up generation for all small business and farms would be an enormous impost. Also, many businesses have back up generation, but are not designed to carry the load for an extended period of time on for emergencies. An example of the critical nature of electricity generation is the requirement for cooling fans in chicken meat production. If there is a total loss of electricity to a chicken meat barn, the animal losses can begin within ten minutes on a hot day. Electricity reliability is vital. 1 Pg. 10 2 Pg.14 2
Electricity is an essential service, farmers and small business should not have to invest enormous resources by purchasing generators capable of running large cooling/irrigation requirements to cover electricity loss due to issues that could be resolved by other means. Communication Reliability Reliability is communication is essential; where phone and internet rely heavily on electricity. The State warning system is very reliant on this technology to warn residents and to put fire fighting resources in place. It is imperative a reliable system is in place 12 hours without power could place human lives at danger. Research and New technology The consultation paper states that the ability to reduce catastrophic bushfires through changing the electricity operation system is dependent on research being currently undertaken. The consultation paper states, with regard to the fast switch off technology: Automatic switching off the electricity supply system would need to be very fast to substantially reduce the likelihood of a bushfire start. The Taskforce is currently undertaking research to determine how fast is fast enough, but is expecting it may be in the order of 0.1 seconds or less. The Taskforce has also searched the world to find new technologies that are able to detect faults and respond much faster than existing technology used in Victoria. At this stage, the Taskforce considers that some new technologies, such as Ground Fault Neutralisers in non-metropolitan substations and new smart switching devices for SWER powerlines, are promising in their ability to operate fast enough. The Taskforce is continuing to analyse and trial these new technologies. This research should also include the implications for businesses on a less reliable electricity source. Electricity users will need to know to what degree their source of electricity is less reliable. The VFF are particularly concerned with any prospect changes that will have significant reliability impacts, such as the disabling of auto reclosers on SWER lines during the fire danger period, as recommended by the Bushfire Royal Commission. 3 3 The VFF commented on the Bushfire Royal Commission recommendations that manually disabling of auto reclosers on SWER lines during the fire danger period was fraught with danger. The Commission has made comment that this would affect around four per cent of consumers. There is agreement that this will cause a drop in reliability of electricity supplies on all days during this six week period. It is reported that the majority of faults, approximately 75 per cent, are transient and self-correct through the reclose function. Disabling the reclose function will mean a significant increase in long power outages for rural customers. Reducing the reliability of rural supplies through disabling of reclosers for a six week period will have potentially significant impacts on human and animal welfare across rural Victoria. These impacts must be considered in deciding how this recommendation might be implemented. 3
Before the adoption of fast switch off technology there will need to be research conducted to determine what the impact will be on reliability. A trial period with willing participants in Victorian conditions is the most appropriate approach to this research. With regard to New, fast Switch off Technology, we would also caution the government in relying on new technology, that is relatively untested, to deliver the fast switch off times to reduce bushfire risk. As we have seen with the metropolitan myki experience, a push to lead the world with untested technology can lead to considerable unforeseen problems. Stand-Alone Supply Issue No. 6 Are customers in sparsely populated areas prepared to be supplied by a stand-alone electricity supply, rather than from the electricity grid and to have the poles and wires removed? The supply of a stand-alone system for electricity must be by consent of the home/business owner. The decision to find it acceptable and conditions /incentive required would have to be determined with the home/business owner. Before a system of stand alone electricity supply is begun extensive research should be conducted in the areas considered to measure willingness of participants. All customers along a powerline must agree and compulsory decommissioning of lines should not be considered. Undergrounding, Insulated Wires and Costs The consultation paper has made it clear that undergrounding of the entire network is not an economically viable exercise and the VFF agrees. There may be cases where undergrounding is the best option in certain areas, but a decision to underground any wires has to be made very carefully as it is clearly a very expensive. The appropriate action, where needed should focus on installing insulated wires as a second option to increased maintenance. For the same investment level, replacing lines with insulated wires cover 4
2.5x the distance of undergrounding. The State needs to make sure there is a strong focus on value and targeted investment when determining the work program around replacing infrastructure. The VFF will not comment on the quantum of funds that should be used on network infrastructure, but as a principle we believe that large scale investment in the network should not happen until tested and proven to deliver quantifiable outcomes. A strong maintenance regime may fix a large number of the problems and that should be the first priority for the network. Issue No. 10 How should the costs of the Taskforce recommended package of measures be distributed The cost of all powerline bushfire mitigation works must be distributed across the entire Victorian network. The purpose of the bushfire risk mitigation is for both protection of life and protection of community assets. There is a clear responsibility for the entire Victorian community to provide protection for community assets and reduce risk to State and National Park land. Increased costs to farmers may not be able to be passed on down the supply chain, therefore farmers would have to absorb these increases. Farmers do not just supply the local market but compete with imported goods and need to supply an increasingly price sensitive export market. An increase to Victorian farmers could see them at a disadvantage in supply the market place. Also, regional Victorians are already disadvantaged compared to their metropolitan counterparts. The 2010 State Parliamentary Inquiry into rural and regional disadvantage found there are many examples of the higher cost for deliver and access of service for rural and regional Victorians. 4 This disadvantage should not be further exacerbated through unfair distribution of network maintenance and bushfire risk reduction costs. Conclusion The State government must not over invest into the distribution network. The appropriate balance between costs associated with bushfire mitigation and safety must be reached. It is estimated that electricity faults is responsible for 4% of bushfires. Given that the estimate of complete undergrounding of powerlines is estimated at over $41.5bn, this is clearly not an option. The appropriate response for the government will be to identify the high priority lines that still represent a significant bushfire risk after a thorough vegetation maintenance regime for insulated wire replacement. 4 2010 Inquiry into the Extent and Nature of Disadvantage and Inequity in Rural and Regional Victoria, Parliament of Victoria, Rural and Regional Committee, Key Recommendation 2 5
The State may consider offering stand-alone generators in remote areas if the home/business owners are willing participants and their service and costs are not adversely effected. Bushfire safety is extremely important, but electricity reliability is also very important for business owners. The financial impact of prolonged lost service to rural business cannot be overlooked. The VFF could not support changes in the way the electricity system is operated if it means there is a decrease in reliability of supply. Finally, the costs associated to any bushfire mitigation through powerline must be borne by all network users. The benefits to risk mitigation are community wide so the cost should be community wide. 6