ny psc report on october 2011 nor'easter response

7/31/2019 NY PSC Report on October 2011 Nor'Easter Response

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ......................................................................................... 1

HURRCANE IRENE AND TROPICAL STORM LEE OUTSTANDING

IMPROVEMENT OPPORTUNITIES ....................................................................... 4

PERFORMANCE ASSESSMENT .............................................................................. 6

Overview .......................................................................................................... 6

Orange and Rockland ..................................................................................... 10

New York State Electric and Gas .................................................................... 15

Central Hudson .............................................................................................. 18

Con Edison ..................................................................................................... 20

CONCLUSION AND RECOMMENDATIONS .......................................................... 22

Attachment 1 Hurricane Irene Recommendations ......................................... 25


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EXECUTIVESUMMARY

On Friday, October 28, 2011, initial weather forecasts indicated that a

Northeaster was in route to our region and it was expected to bring snow to the

Catskills, the Hudson Valley, and the Taconic region of the State.1 A winter storm

warning was issued by the National Weather Service on Saturday, October 29. It

forecast significant amounts of heavy, wet snowup to seven inches in areas along the

Hudson River and up to ten inches in the southeastern portion of the state. The

forecasts predicted widespread power outages as a result of snow accumulations on

foliage-laden tree branches.

Snow began to fall mid-day Saturday and continued through the night. By

Saturday evening, the utility companies had begun to report numerous electric service

interruptions due to heavy snow and wind gusts. This Northeaster was the third major

weather event to hit the region in three months. In some areas, the October storm

caused greater tree damage and power outages than Hurricane Irene and Tropical

Storm Leestorms that occurred in August and September of 2011, respectively. In

total, service to over 400,000 customers was disrupted due to branches and trees

sagging and breaking on utility infrastructure. Overall, this service restoration effort

took eight days to complete.

Following the October storm, Staff investigated the performances of the

Consolidated Edison Company of New York (Con Edison), New York State Electric and

Gas (NYSEG), Central Hudson Gas and Electric (Central Hudson), and Orange and

Rockland Utilities (Orange and Rockland)all of which sustained customer outages that

lasted greater than 72 hours. Staffs investigation also assessed whether the utilitieswere properly prepared for the Northeaster; whether they responded appropriately in

its aftermath; whether they have identified the lessons learned from this storm; and,

whether they are taking all necessary corrective actions. We have also examined the

1New York City was also forecast to be hit by the storm but to a lesser extent than the upstate

regions.


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communications they used to inform customers, the media, and government officials of

the service restoration efforts. Our review of the October snowstorm has found utility

company deficiencies similar to those indentified by our performance review of the

utility company efforts for Hurricane Irene and Tropical Storm Lee. Thus, the

recommendations presented in the Utility Performance Report Following Hurricane

Irene and Tropical Storm Lee likewise pertain to the utility responses to this storm.2

Our investigation generally found (except for Orange and Rockland) that

the utility companies did not have substantial difficulties acquiring the crews they

needed to perform the service restoration work, and they maintained adequate

communications with the public, the media, and public officials via traditional

communication channels; however, the utilities still could do more to take advantage or

alternative communication technologies, such as social media, to communicate with

customers. We did find, however, that NYSEG should have issued some of its estimated

times of restoration (ETRs) sooner than it did in those Divisions that were less affected

by the storm. We also found that NYSEG failed to contact its customers using life

support equipment ahead of the storm. Further, for some Divisions, NYSEG needs to

train additional personnel to serve as wire guards.

With respect to Orange and Rockland, our investigation found that the

utility did not perform well in several respects. Issues that existed with the Companys

Hurricane Irene restoration efforts also existed for this storm. During Hurricane Irene,

Orange and Rockland was able to manage the storms effects better than it did for the

October snowstorm because it had supplemented and pre-staged personnel prior to its

arrival. In October, Orange and Rockland was overwhelmed by the damage caused by

the heavy snow and did not respond as well to the storm conditions it faced this time

around. We found that the Company was slow to supplement crew levels with either

2 See Attachment 1 to this report which lists the Hurricane Irene and Tropical Storm Lee

related recommendations that are applicable here.


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the mutual assistance available from other utility companies or by using independent

contractors. Also, Orange and Rockland was unable to respond properly to the

numerous down wire conditions that were reported to it. Limited telephone calling

capacity at the utilitys call center resulted in some customers being unable to contact

the Company to report their service conditions or to obtain information. Orange and

Rockland also failed to provide customers localized, estimated restoration times which

likely increased the number of customer calls to the Company seeking service

restoration information. Consequently, this report contains specific recommendations

for Orange and Rockland which are intended to improve its future performance.

In the following Chapters, we provide the results of our examination of

each utility companys service restoration performances. Recommendations for

improvements are presented, as necessary, to obtain better storm responses in the

future. The recommendations presented here are designed to build upon those made

in our performance report following Hurricane Irene and Tropical Storm Lee. The

recommendations emanating from the Irene and Lee Report are summarized in

Attachment 1 to this report.

A copy of this report is being sent to the New York utility companies by the

Director of the Office of Electric, Gas, and Water. All New York electric and gas utilities

should review this report and, to the extent they have similar conditions and

circumstances, they should implement the recommendations provided here. The

companies are expected to implement recommendations applicable to their operations

by no later than 30 days from the issuance of this Report. The Companies should report

to Staff within 30 days on their progress in implementing the recommendations and

every three months thereafter, until such time as Staff determines implementation is

complete and reporting is no longer necessary. In addition, Staff expects each progress

report to include the status of implementing the Companys own recommendations

identified in their self-assessments.


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HURRCANEIRENEANDTROPICALSTORMLEE

OUTSTANDINGIMPROVEMENTOPPORTUNITIES3

The October 2011 storm occurred only about a month and a half after

Hurricane Irene and Tropical Storm Lee struck New York State. When the October storm

hit, the utility companies encountered many of the same issues they had experienced

during the earlier storms. This is largely due to the close timing of the three storms.

When the October storm began, the utilities were in the process of

finalizing their Irene and Lee self-assessment reports for submission to Staff.4

Thus, the

utilities had initially begun to identify their planned improvements from their

assessments of the performance during Irene and Lee storms. In October, many of the

identified improvements were only able to be implemented in a provisional or partial

manneror not at all given the short time and limited opportunity between the initial

identification of improvements and the implementation of the resolutions. Without

sufficient time to implement the self-identified improvements drawn from Irene and

Lee, the earlier identified concerns remained matters of concern for the October

snowstorm. Thus, Staff expects the corrective actions identified for Irene and Lee to

also apply to the October storm.

3 The Staff report addressing Irene and Lee describes, in detail, the utility companies storm-

related functions. It also describesthe Departments overall responsibility to review the

adequacy of the utility companies emergency plans, their storm preparations, stormresponses and service restoration efforts. Given the comprehensive description of these

functions contained in the Irene and Lee Report, this report does not reiterate that

information that is conveniently available in our companion report. This report concentrates

on the analysis of the utility performances for the October storm and only briefly refers to

the information available to the reader in the Irene and Lee Report.

4The utilities were granted filing extensions for the Irene and Lee self-assessments to allow

them to remain focused on their recovery efforts for the October snowstorm.


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Staffs investigation of the companies performances during Irene and Lee

culminated in a comprehensive report containing 30 recommendations. Nearly all the

recommendations applicable to the electric utilities also apply to their performances for

the October storm.5

The successful implementation of the recommendations contained

in the Irene and Lee Report will also resolve the similar concerns that were identified in

connection with the October storm. Attachment 1 to this report contains the

recommendations first generated by our review of Irene and Lee that apply equally to

our review of the October 2011 storm.

5Case 11-M-0481 In the Matter of the Outages Caused by Hurricane Irene and Tropical

Storm Lee. In the report, Staff made recommendations for enhancing communications, as

well as improving the restoration of electric, gas, and telecommunications services.


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PERFORMANCEASSESSMENT

OVERVIEW

The October 2011 Northeaster was the third major storm to hit our region

in the span of three months. This storm hit many of the areas that were impacted

earlier by Hurricane Irene and Tropical Storm Leein some locations causing more tree

damage and power outages than did the prior storms.

This storm was an unusually early snowfall for October. It produced more

than 20 inches of heavy, wet snow accumulations in some areas. In at least 20 cities,

the snowfall broke daily and monthly records. Wind gusts, in excess of 30 miles an hour,

were common throughout southeastern New York. These conditions, combined with

substantial amounts of foliage still in place, produced widespread tree damage.

Significant amounts of tree damage, and associated damage to the electric

infrastructure, occurred across the southeastern region of New York, including locations

south and east of the I-88 corridor that runs from Schenectady to Binghamton. As the

storm progressed, customer interruptions climbed on Saturday evening and overnight

into Sunday morning. In all, approximately 400,000 New York State customers lost their

electric service.

Some areas sustained more damage from the Northeaster than they had

from Hurricane Irene. Out-of-state line crews were brought in both before and after the

storm to help with the restoration. To complete the service restorations following this

storm took about a week; the restorations progressed steadily during this period. As

shown in Figure 1, below, fifty percent of customers statewide had their service

restored within three days; ninety percent had their service restored within five days.


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Figure 1: Customer Outages Statewide

The utility companies had restoration crews standing ready for the

October snowstorms arrival. On Saturday, October 29, over 360 crews were available;

over half of the crews were provided by contractors and mutual assistance programs.

By Monday, October 31, over 1,000 line, tree and service crews were working to restore

electric service to customers. The companies retained the contractors who were

working in their service territories, and they obtained additional contractor crews. The

utilities reached out to other utility companies in New York and in states in the Mid-

Atlantic and New England regions, using their established mutual assistance groups.

With more than three million customers in the Northeast affected by this storm,

available line crews were in short supply as many utilities throughout the region were

also in need of mutual assistance support. Nevertheless, the New York utilities were

able to acquire the crews they needed to mount an effective restoration, with the single

exception of Orange and Rockland whose circumstances are discussed below.

All the companies had sufficient materials and equipment for their service

restoration efforts. The companies damage assessors were available on Saturday. But


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given the storms timing, duration, and the road conditions, full-scale damage

assessments could not begin until daybreak Sunday. Con Edison, Central Hudson, and

Orange and Rockland supplemented their damage assessment personnel by using

contractors; NYSEG supplemented its damage assessment force using assessors from its

unaffected Divisions, including personnel provided by its sister company, Rochester Gas

and Electric. As the restoration efforts progressed, the companies relocated their

damage assessors and sent them to heavily-damaged areas to assist in the assessments

and circuit sweeps at those locations. All the companies performed adequate damage

assessments.

In total, over 15,800 down wires were reported for the October storm

more than half ofthe down wires occurred in Orange and Rocklands service area. As

part of our review, we identified that the process of responding to down wire reports is

not as detailed and organized as it could be. Most notable is that the restoration

priority tends to be based on information provided at the time of the down wire report,

which may be limited in facts, and does methodically account for known information

based on its location. As a result, we recommend that all utilities Emergency Plans

should identify the priority for energized wires during an active storm and the priorities

for repair work post storm, taking into account the potential for public harm (including,

for example, population density, pedestrian access, public uses of an area, and the

proximity of the electric facilities to public facilities such as schools) and the safety of

utility employees. We also determined that companies should be more aggressive when

planning for the number of wire guards, particularly when circumstances promote the

likelihood of downed wires, as was the case during Hurricane Irene. As part of the Irene

and Lee Report, Staff recommends that the utilities better defined staffing requirements

for wire guards and identify means to obtain supplemental wire guards to be used in

emergencies in order to meet the staffing requirements. These recommendations also


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apply to this snowstorm and should help improve the overall response to down wires

going forward.

During the event, the companies communicated with news reporters, the

media, elected officials, and emergency response organizations. The utilities engaged in

proactive media efforts by issuing multiple press releases daily and by posting available

information on their websites. The utility press releases contained pertinent

information on the outage numbers, crew counts, the estimated times of restoration

(ETRs), the locations for dry ice and bottled water distributions, emergency contact

numbers, and they provided safety precautions about downed wires.6

We found that

the utilities, except for Orange and Rockland, maintained effective communications with

their customers. Although Orange and Rockland did engage in similar outreach

activities as described above, the lack of detailed information, particularly regional and

localized ETRs, reduced the effectiveness of this effort in meeting customer needs.

About 473,000 pounds of dry ice was distributed following the storm. In

addition to distributing dry ice to its own customers, NYSEG supplied dry ice and bottled

water to others for distribution in Dutchess, Putnam, and Westchester County. Con

Edison was challenged in its efforts to secure adequate quantities of dry ice, as dry ice

was in short supply due to high demands from all areas affected. The Company resorted

to distributing ordinary, wet ice to customers in addition to providing dry ice. In the

Irene and Lee Report, Staff has recommended that the utilities identify additional dry ice

suppliers. That recommendation applies as well to the circumstances of the October

storm.

In general, our investigation found that the utilities maintained proper

contacts with critical care facilities and with customers who depend on life support

6 The utilities also regularly provide bill inserts to customers that include information on how

to report the loss of power; how to obtain updates during storms; and, the dangers

presented by downed wires and how to safely avoid the wires.


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equipment (LSE customers). For example, Con Edison monitored the status of facility-

specific emergency generation and provided the three critical care facilities assistance

following the snowstorm to keep their emergency generators operational until their

services were restored. As discussed below, NYSEG did not initiate the required pre-

storm calls, as defined in its procedures, to LSE customers who were on the identified

storm path.

Staff found that Central Hudson was unable to reach three LSE customers,

either by phone or by field visits. The Company properly sought the assistance of

municipal emergency services as a means to contact the unreachable customers.

Central Hudson, however, failed to ascertain whether the emergency services actually

made such contact. The Irene and Lee Report contains a recommendation to the

utilities that they address this concern by using follow-up efforts to verify contacts made

by emergency services during storms.

ORANGE AND ROCKLAND

The peak number of customers without electric service in Orange and

Rocklands service territory was 71,141, or 33% companywide. Orange and Rockland

was hit hardest in its Eastern and Central Divisions, with 43% and 30% of the customers

in these divisions without electric service at peak, respectively.

Orange and Rockland performed poorly in acquiring restoration crews.

The Company had 39 line crews and 16 tree crews ready to perform restoration on

Saturday, October 29. While the number of crews it had at the onset of the storm was

comparable to the other utilities, Orange and Rockland failed to adequately supplement

the initial crew levels to support the restoration effort given the amount of damage

experienced and the number of down wires reported.


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The Company added to its crews, and brought in some contractor and

mutual aid crews, to assist in the restoration effort on Sunday and it continued to

acquire crews over the next five days. On Monday, October 31, the Company had 121

line crews (89 of which were provided by contractors and mutual aid), 65 tree crews,

and 78 service crews. While the majority of crews were assigned to work in the hard hit

Eastern Division, this workforce level was still insufficient given the storm impact in the

service area.

Crew levels peaked on Friday, November 4 when Orange and Rockland

had 374 line, 80 tree, and 154 service crews working to restore service. The Company

completed restoration on Sunday, November 6. We recommend that Orange and

Rockland develop more proactive protocols and procedures for seeking external

contractor and mutual aid crews, from within and outside the State, to ensure that

sufficient crews are requested and acquired before and during emergency response

efforts. The protocols should be incorporated into the Companys Emergency Plan and

contain appropriate actions for the conditions applicable to each of the three storm

event classifications.

Orange and Rockland received reports of over 8,100 down wire incidents

during the course of the stormmore than half the total number of incidents statewide.

To address the large volume of down wires and to mitigate public safety concerns, the

Company increased the number of site safety personnel it had in the field.7

Our review

indicates that Orange and Rockland had 70 site safety personnel available33 were

assigned to the Eastern Division, 13 to the Central Division, and 12 to the Western

Division. In addition, Orange and Rockland employed 76 contractors to assist it in the

site safety work. At peak, the total number of site safety personnel working was 102.

7 Site safety personnel are used to guard hazardous conditions until crews are available to

perform repairs or make the area safe. Therefore, workforce levels provided are in addition

to personnel used when establishing crew counts.


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Post storm assessments indicate there were over 5,000 down wire reports

received from emergency responders and from customers during the first three days.

Approximately 390 of the reports were addressed by the Companys site safety group.

Despite the Companys efforts to supplement its workforce, the number of down wire

reports it received overwhelmed the Company and the site safety personnel available.

Orange and Rocklands Emergency Plan does not indicate a minimum

staffing level for the site safety group. It merely states that the site safety group should

be mobilized and adjusted accordingly. As recommended in the Hurricane Irene and

Tropical Storm Lee Report, the Company needs to establish minimum staffing levels for

its site safety personnelwith greater staffing provided for those situations that are

likely to cause a high volume of down wires. To increase its workforce resources,

Orange and Rockland is now establishing standard contract terms and conditions with

its contractors for site safety services. This is a positive step in view of the size of the

Company. We also recommend that Orange and Rockland should continue to identify

and train additional in-house personnel to serve as wire guards.

Orange and Rockland uses an outage management system to provide and

monitor job assignments for known down wire incidents. Trouble calls are generated

and updated and this provides a way to assign, track, and report each job. For the

October storm, we requested the Companys data on the number of down wire

incidents that were known to be energized during and after the storm. Orange and

Rockland could not provide Staff this information with any degree of certainty.

Company personnel are dispatched based on all known information.

Depending on how a call is received, the Company obtains some information about a

down wire when it receives the initial report that allows it to prioritize the response

needed. Sometimes an initial report indicates that the down wire is energized;

however, the system used does not effectively reflect the risk of a situation that should

receive a high priority , such as a wire down in a high pedestrian area. Additionally, the


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Companys Emergency Plan does not specify the priority that down, energized wires

should receive during an active storm or what priority repair work related to down wires

should receive post storm. This is an area that should be improved based on our

previous recommendation for all Companies to define how down wires are prioritized

for repair. As part of this effort, Orange and Rockland should also improve the

communication process between its site safety group and crew dispatching group to

ensure all information regarding a down line is readily known.

Orange and Rockland was unable to establish proper ETRs for this event.

The Company received initial damage assessment reports on the evening of October 30

that it used to establish its global ETR for days end Wednesday, November 2. However,

due to the substantial tree damage, numerous downed wires and the large number of

repairs required, Orange and Rockland had underestimated the restoration effort and

was unable to meet this initial projection. As a result, on Tuesday, November 1, the

Company extended its global ETR to days end November 3. The modified global ETR

was achieved for over 90% of the customers affected.

Orange and Rockland did not develop its ETRs on a regional or local basis

for this storm. This is a significant concern to Staff where the Company used the same

approach following Hurricane Irene. This approach and omission fails to adequately

inform the public and it overstates the damage and service restoration efforts for some

areas. By not providing local ETRs, the Company promoted the perception that it was

not restoring services effectively and customers likely placed more calls to the Company

to obtain specific information applicable to their individual service interruption. It is

common for customer frustration to be exacerbated when they need to contact

multiple sources to obtain information that should be readily available. As a result, we

recommend that Orange and Rockland develop and provide to Staff a protocol for


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developing and providing customers localized ETRs for future storm events.8

The

Company should also report to Staff on how it plans to ensure the protocol is followed

properly and it should clearly identify personnel within the organizations that are

responsible for its execution.

Orange and Rocklands slow initial response, and its limited ability to

address down lines, resulted in substantial frustration for customers and local public

officials. The comments the Department received during the course of this

investigation, the numerous news reports and media articles we have seen, and the

impassioned comments made at a public statement hearing held for Orange and

Rocklands recent rate case, all demonstrate the dissatisfaction that customers

experienced with the Companys performance during the October storm.

A review of the Companys call center performance data indicates that

customers had difficulty reaching customer service agents to obtain information. We

found that only about 75% of the calls queued for agents were answered.9

As had

occurred during Hurricane Irene, the telephone call volumes Orange and Rockland

received during the October storm exceeded the Companys capabilities. This resulted

in some customers being unable to contact a live agent at the Company. Staff observed

and noted this deficiency in its Hurricane Irene and Tropical Storm Lee Report, which

contains a recommendation for improved call center capabilities.

Orange and Rockland reported to us that it has taken steps to improve its

call centers capabilities early in 2012 and has additional improvements planned for the

future. So far, the improvements include: increased inbound call capabilities (doubling

the number of telephone circuits since Hurricane Irene); contracting with Twenty First

Century Communications to process the overflow of storm calls; sending overflow calls

8 A similar recommendation is also included in the Irene and Lee Report.

9 Orange and Rockland had a 96% overall answer rate, which includes calls answered by

customer agents and calls handled by the Interactive Voice Response System.


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to Con Edison for handling by their representative who have been specifically trained by

Orange and Rocklands staff; and, an improved Interactive Voice Response System that

interfaces with the Companys Outage Management System to provide customers

accurate, up-to-the-minute storm information. Orange and Rockland states that

additional call center enhancements will be forthcoming during the second half of 2012,

followed by a complete redesign of its call center technology by mid-2014.

While these steps move in the right direction, we recommend that the

Company provide Staff updates providing the status of the call center improvements

and system testing that has been performed. After the 30 day reporting requirement,

the updates should continue quarterly until the Companys call center capabilities are

demonstrated to be sufficient to handle a large scale event.

Finally, the information Orange and Rockland provided Staff at the time of

the storm did not accurately state the crew levels the Company possessed. The

Company pointed to inconsistencies in the methods it used to record this information as

a basis for its reporting errors. To manage its resources effectively, a utility must know

the number of crews that are arriving so it can plan their work in advance and arrange

for such logistics as hotel rooms and meals. Staff recommends that Orange and

Rockland improve its methods of managing crew information and develop a formal

process to report accurately its crewing status during an event. The Company has

indicated to us that it is developing a standardized form to collect all necessary

information regarding incoming crews. This will help in this regard and it can also assist

in the development of ETRs.

NEW YORKSTATE ELECTRIC AND GAS

NYSEG experienced outages in four of its Division. At peak, 86,672

customers (10% of the total customers served by NYSEG) were without electric service.


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The majority of the electric service outages occurred in the Brewster Division where, at

peak, 73,605 customers (87% of the Division) experienced a loss of service. On October

31, or two days after the storm, NYSEG completed its service restorations to

approximately 13,000 customers who were affected by the storm in the Liberty and

Mechanicville Divisions. On Saturday, November 5, with the completion of the service

restorations in the Brewster Division, all customers were restored to service.

NYSEG was prepared for the storm with 105 line crews and 58 tree crews

ready to work on Saturday, October 29. Nearly half of the line crews were Company

personnel either stationed locally or brought into the area from other regions that were

unaffected by the storm. NYSEG quickly ramped up its number of crews and it had 205

line crews and 70 tree crews working by October 30, the first day after the storm. By

Monday, October 31, NYSEG had over 350 crews at work in the Brewster Division.

NYSEGs performance during this storm event was a great improvement over some past

performances where supplemental crews were slower to arrive.

There were 4,097 down wires in NYSEGs Brewster Division. A large

number of the circuits affected by the storm were automatically shut down by

protective devices. Of the 4,097 down wires reported, 3,916 were on circuits that were

confirmed to be locked out, which eliminated the immediate dangers associated with

these down wires. As a result, 70 wire guards were assigned in the Brewster Division to

guard the other 181 down wire locations until they could be made safe.

Of the 70 wire guards used in the Brewster Division, only 17 were local;

the remaining guards were brought in from other Division. While NYSEG properly used

employees from its unaffected areas to serve as wire guards, a more widespread storm

may limits its ability to share its personnel. Also, the number of wire guards available

may not be sufficient for future storms if there are less circuit lockouts and more

energized down wires situations. Therefore, we recommend that NYSEG provide and

train more personnel to serve as wire guards for future storms. The training of more


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customers; it conducted field visits to investigate when telecommunication could not be

established. While the Company acted properly following the storm, NYSEG should

have provided pre-storm notifications and it should review its storm preparation

procedures and provide a report to Staff on the steps it will take to help ensure that all

such steps are completed in the future.

CENTRAL HUDSON

Central Hudson sustained the largest number of customer outages during

this storm. At the peak, 147,958 customers (49% of the total customers served) were

without service. Several of Central Hudsons Divisions sustained severe damage. The

Fishkill Division experienced a 74% loss of electric service to customers; 65% of the

customers in the Poughkeepsie and Newburgh Divisions were without service. Despite

such large numbers of customers without service, Central Hudson was able to restore

service quickly. It was the first of the four utilities to complete its service restoration

efforts.

Central Hudson was ready for the storm on Saturday, October 29, with 56

line crews, 37 tree crews, and 12 service crews. It acquired more crews as the service

restoration efforts progressed. By Monday, October 31, Central Hudson had 150 line

crews (100 provided by contractors and mutual assistance), 88 tree crews, and 15

service crews. Central Hudson was able to restore service to all customers by Friday,

November 4.

Central Hudson reported 1,698 down wires during the October

Northeaster. Of this amount, 59% were received the first day of the storm. The

Company had 105 site safety personnel available from its various organizations In

addition, Central Hudson obtained 10 contractors to supplement its wire guard staff.


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The number of down wires during this major storm exceeded the number

of wire guards that Central Hudson had available. The Company has since embarked on

a project to better manage down wires and to fulfill the need for more wire guards.

Central Hudson has an agreement with a local vendor to supply trained and equipped

personnel who can respond to reports of down wires. Individuals will be trained to

identify the types of electric conductors that are down; others will be trained to guard

the public from the down wires. These additional resources will increase Central

Hudsons ability to respond to a greater number of down wires than it is currently able

to do.

In February 2012, Central Hudson initiated a pilot program that is

investigating the use of GIS-based and mobile applications to assist its wire responders.

This project uses a software program to prioritize, to dispatch personnel, and to track

reports of down wires. Central Hudson is testing this new technology, and the use of

GIS and street map data, to group the down wire reports and to eliminate duplicate

responses. It hopes to develop a down wire report database that can be quickly

updated and accessed by field crews and office personnel. We consider both of these

projects encouraging. If successful, they should be evaluated for application throughout

its service territory.

Central Hudson effectively communicated with local public officials during

the storm event. The Companys first global and regional ETRs were established within

a reasonable amount of time and with a reasonable degree of accuracy. As stated in the

Companys report, the ETR process can be improved by obtaining the information

learned by the damage assessors and the crew guides as frequently as possible. The

Company is pursuing the use of mobile data collectors to allow them to communicate

with the central office more often than they did during this snowstorm. The use of

technology to aid in the communication of information during a storm is also a

recommendation in the Irene and Lee Report and we support this effort.


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CON EDISON

Con Edisons service area was the first in the State to be hit by the

Northeaster. On Saturday evening, at its peak, 92,616 customers were without service.

Of these, 79,355 were located in Westchester where 23% of customers were without

service. Con Edison had 27 line crews, 15 tree crews, and 19 service crews ready on

Saturday, October 29. By Monday, October 31, the Company had 154 line crews, 76

tree crews, and 120 service crews working to restore electric service to customers. The

majority of these crews, over 80%, were located in Westchester. As service to

customers in the Bronx, Brooklyn, Manhattan, Queens, and Staten Island was restored,

crews were moved to Westchester to support the restoration efforts there. By

Wednesday, November 2, Con Edison had nearly 400 crews working in Westchester. On

Friday, November 4, service was restored to all customers.

During the storm, Con Edisons records show that it received 1,817 down

wires reports. Of this amount, 473 reports were provided by emergency responders,

including 911 operators, fire departments, police departments and local public works

departments. Damage assessors and tree crews were assigned to verify the reports of

down wires and the reports of trees on wires.

In anticipation of the expected damage, Con Edison supplemented its site

safety group with 139 contractors who were used to respond to the reports of downed

wires. The contractors, combined with Con Edisons more than 350 wire guards,

provided adequate safety personnel to guard the 1,817 down wires reported. We are,

however, concerned about the Corporate policy for responding to events. For example,

Orange and Rockland received more than four times the number of wire down reports

when compared to Con Edison. As previously stated, Orange and Rockland used

approximately 150 site safety personnel to respond to down wire reports. By contrast,

Con Edisons used nearly 500 site safety personnel to respond. We believe this disparity

is something that needs to be reviewed and addressed to ensure that the Companies


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CONCLUSIONANDRECOMMENDATIONS

The October storm occurred approximately a month and a half after

Hurricane Irene and Tropical Storm Lee. The electric utility companies encountered

many of the same issues in all three storms because of their close proximity to one

another. Not surprisingly, our investigation found that several of the issues identified in

the October snowstorm also existed during the Hurricane Irene and Tropical Storm Lee

restoration. As a result, the recommendations presented here build upon those made

by Staff in the performance report we provided following Irene and Lee.

Except for Orange and Rockland, we did not find that the utilities had

difficulties acquiring the crews needed to perform service restorations. Nor did the

utilities (except for Orange and Rockland) encounter difficulties communicating with the

customers, the media, and public officials via traditional communications channels. We

found that NYSEG should have issued estimated restoration times earlier in its less

affected Divisions; it needs to take additional steps to ensure LSE customers are

contacted prior to a storm; and, the Company should train additional personnel to serve

as wire guards in certain Divisions.

Orange and Rockland was overwhelmed by the damage caused during the

October storm. We found that it was slow to supplement its crewing levels and it was

unable to respond properly to the numerous down wire conditions reported to it. As a

result of the limited capacity of the Companys call center, customers were unable to

contact the Company to report their service conditions or to obtain information.

Orange and Rockland also failed to provide localized estimated restoration times, which

added to customer calls to the Company to obtain information specific to them.

This Report presents our recommendations for corrective actions, as

summarized below. The recommendations are designed and intended to improve the

utilities future storm responses. This Report will be provided to all New York utilities


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for them to review and determine whether they have similar conditions that warrant

their attention. To the extent that they do, they too should implement improvements

to address future storms adequately. A copy of this Report is being sent to all the major

electric utility companies by the Director of the Office of Electric, Gas, and Water. They

are expected to implement all recommendations, as appropriate, no later than 60 days

from their receipt of the Report.

Staff Recommendations:

All utilities should define in its Emergency Plan how down energized wires areto be prioritized during an active storm and in what priority repair work related

to down energized wires should be performed post storm, taking into accountthe potential for public harm (including for example, the population density of

the area, the level of pedestrian access and use of the area, and the proximity

of facilities such as schools) and the safety of utility employees.

Orange and Rockland should develop more proactive protocols and proceduresfor seeking external, contractor, and mutual aid crews from inside and outside

of the State to ensure that crews are requested and acquired prior to and

during emergency response efforts. The protocols should reflect appropriate

actions based on conditions applicable to each of the three storm event

classifications described in its Emergency Plan and be provided to Staff. Orange and Rockland should provide quarterly updates regarding all call center

improvements and system testing performed. These updates will continue until

Staff is satisfied with the Companys call center capabilities.

Orange and Rockland should develop and provide to Staff a protocol on how itwill develop localized ETR on a forward going basis.

Orange and Rockland should continue to identify and train additional in-housepersonnel to serve as wire guards. The Company should provide Staff a report

indicating the number of new personnel identified, training schedules, and

forecasted number of wire guards available by month through December 31,

2013.

Orange and Rockland should develop a formal process to manage crewinformation such that it will be able to accurately report its crewing status

during an event.


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Orange and Rockland should also improve the communication process betweenits site safety group and crew dispatching group to ensure all information

regarding a down line is readily known.

NYSEG should strive to issue regional and local ETRs earlier during an event.The Company should provide Staff a report on the actions and verification

processes it will be taking to ensure the ETRs will be issued in a timelier

manner.

NYSEG should identify and train personnel in the Brewster, Lancaster, Liberty,and Oneonta Divisions to serve as wire guards during future storms. The

Company should provide Staff a report indicating the number of new personnel

identified, training schedules, and forecasted number of wire guards available

by month through December 31, 2013.

NYSEG should review its storm preparation procedures and provide a report toStaff on steps it will take to help ensure that pre-storm calls to LSE customersare completed in the future.

Con Edison and Orange and Rockland should provide a report to Staffidentifying corporate level policies that ensure that the Companies responses

are adequate and generally consistent with each other.

Central Hudson should continue to investigate the use of GIS-based and mobileapplications to assist in optimizing the response of wire responders and should

be evaluated throughout its entire service territory to determine the

applicability.


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ATTACHMENT 1HURRICANE IRENE RECOMMENDATIONS

The following is a summary of the recommendations included in the

Hurricane Irene and Tropical Storm Lee Report that apply to the electric utilities.

COMMUNICATIONS

Utility Call Centers

Orange and Rockland should provide to Staff a report outlining the steps it will taketo improve overall call center technology and performance during storms.

Media and Customer Communications

Central Hudson and NYSEG should report on their enhancements for the provision ofETRs and their presentation on website maps.

NYSEG should provide a local presence in severely impacted areas and identifyalternative means to improve communication with county offices.

Communications with Public Officials

All utilities should extend invitations to local and state elected officials representingdistricts in their service territories to be included on their municipal call lists.

Alternative Communication Technologies

All utilities should investigate ways to continue to expand the use of newertechnologies to communicate with customers during outages (i.e., email, text

messaging, and social media) and report their findings to Staff.


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ELECTRIC SERVICE

Restoration

Orange and Rocklands emergency plan should formally incorporate the CorporateCoastal Storm Plan. The electric utilities should formalize agreements with property owners to

temporarily stage crews, materials, and equipment during restoration at strategic

locations that would be useful for future restoration efforts.

Each electric company should develop procedures relating to the use of contracteddamage assessors, including training requirements. Their Emergency Plans should

identify when these procedures would be used.

National Grid and Con Edison should investigate the use of mobile data collection fordamage assessment by company and contracted personnel and report their finding

to Staff.

Each electric utility should expand its emergency plan to include procedures forobtaining crews from distant states. The emergency plans should include contact

information for utilities, contractors, and mutual assistance groups and acknowledge

travel and rest time restrictions before the crews can be deployed into the field.

All electric utilities should better define minimum staffing requirements for thenumber of wire guards to be used in their emergency plans. The requirements

should also identify alternate staffing levels when conditions, such as a hurricane,

will likely cause an increase in the number of down wires.

All electric utilities should modify their Emergency Plans to identify the means toobtain supplemental wire guards through contractors during or prior to an

emergency when employees may not be available to serve as guards because they

are needed for alternate functions.

All electric utilities should modify their Emergency Plans to define when it would beappropriate to use municipal field liaisons or a similar process to facilitate the

removal of hazardous conditions.


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NYSEG should examine its Company as a whole to establish an optimal crewdeployment to achieve restoration for the largest number of customers in the least

amount of time.

As the restoration progresses, Orange and Rockland and NYSEG should revise theirpractices to provide ETRs that are different from the global projection for regional

sections of their territories, which may be smaller than their divisions, and continue

to refine the ETRs until all localities have their own ETRs.

All electric utilities should continue to work with referral entities to strengthenfollow-up processes and to ensure that feedback regarding LSE customers that have

been referred for contact assistance are obtained and recorded.

To ensure better availability of dry ice in future events, all electric utilities shouldreview their procurement procedures and identify additional contractors, further

inland, who can provide dry ice in the event of a storm impacting the East Coast.

Reporting

Guidelines for writing self-assessment reports should be developed through acollaborative process including Staff and the electric utilities to ensure future reports

contain all appropriate information and provide a comprehensive discussion of key

decisions and actions taken. The resulting guidelines shall apply to all electricutilities.

All electric utilities should provide comprehensive reports that discuss all aspects ofthe restoration when required to submit storm updates.

System Reliability and Resiliency

All electric companies should review facilities that are susceptible to outside factors,such as flooding, excessive tree damage, or limited access, to determine whether

reasonable infrastructure improvement or increased maintenance could be made to

reduce the customer impact of a storm or facilitate the ability of the utility to restore

service.

ny psc report on october 2011 nor'easter response

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