On Jan. 23, the Public Service Commission ordered all electric utility companies operating in West Virginia to file a petition to propose a comprehensive vegetation trimming program to maintain all rights-of-way over a proposed period of time.
These petitions for the programs are to be submitted to the PSC within six months and proposals must cover all distribution and transmission lines on an "end-to-end, time-based cycle," based on the utility's specific operational and reliability targets. The proposals must also indicate how the program will be coordinated with other entities who share the right-of-ways or utility poles and also have an obligation to maintain the right-of-ways. Companies will also be required to submit a proposed method for rate recovery of increased costs that will be associated with these right-of-way maintenance programs. The order from the commission stated that these future filings would be subject to public notice, comment, and Commission Review.
The Jan. 23 order closes a general investigation launched by the commission for the purpose of looking into utility responses after the June 29 summer storm that left thousands of West Virginia residents without power for a substantial amount of time. Besides significant damage to electric utility infrastructure, and hence, major loss of electrical power, the commission also noted that landline telephone service was impacted because of the lack of electricity and direct damage to phone lines. Efforts to restore these utilities were hindered by blocked roadways, destruction of transformers and transmission towers, and extreme temperatures. Hurricane Sandy also caused major outages in West Virginia in late October.
The West Virginia Public Service Commission is hoping to avoid some of these types of situations and long utility outages by proposing a comprehensive vegetation trimming program.
The Jan. 23 proceeding was initiated by the commission for the "purpose of examining utility preparedness, utility responses, and utility plans for future events."
Each of the electric utilities operating in the state was made a respondent to this proceeding including American Electric Power (AEP), First Energy, the City of Phillipi, the City of New Martinsville, Craig-Botetourt Electric Company, Harrison Rural Electric Water Company (WVAWC), Beckley Water Company, Frontier Communications (Frontier), and West Virginia Small Public Utilities Association. Reports were filed on Aug. 20 and 21 and Sept. 27. A public meeting was held on Oct. 22 where utility companies presented their derecho reports. Two public hearings were held on Nov. 15 and 19.
A majority of the public comment filed in this investigation has focused on the adequacy of right-of-way maintenance along electric and telephone utility distribution lines; comments contended that the utilities should perform right-of-way tree trimming and brush control more frequently and thoroughly to lessen the extent and duration of storm-related outages.
The PSC reports that some have suggested that rights-of-way issues should be addressed through requiring the utilities to immediately inspect and conduct wholesale cutting and trimming of all encroaching vegetation within all of their rights-of-way; however, the PSC reports that requiring this sort of action, without a prior determination of the cost and subsequent rate increase on customers would "be inconsistent with the commission's responsibility to reasonably regulate utilities and allow recovery of the costs to provide utility service."
At these meetings it was noted that increasing right-of-way maintenance would have associated costs and a direct rate impact on utility customers; however, the report added that "the commission understands and acknowledges that increasing the frequency of tree trimming will have associated costs and a direct rate impact on utility customers, but so do the extensive outages and system damage resulting from major storms."
In the released report, the PSC also recognized the fact that that more aggressive right-of-way clearing will not prevent all outages, particularly those due to storms of the intensity of and duration of the derecho and Hurricane Sandy. "We believe, however, that increased right-of-way maintenance will lessen future storm impacts with regard to the frequency and duration of outages and the resulted impact on customers. Systematically maintenance of rights-of-way will also improve reliability in general."
The PSC further reports that the responsibility to adequately maintain rights-of-way applies to both electric and telephone utilities. In the order released on Jan. 23, however, the PSC has only required electric utilities to file petitions that describe how their programs will be coordinated with other entities, including landline telephone utilities. Following a review of those findings, the PSC may issue an order directing telephone utilities to take similar measures as those required by the electric utilities.
The report states that "several factors combine to make future major storm outages a certainty in West Virginia, including the remote locations of many distribution lines, geography of the land and abundant vegetation along narrow rights-of-ways." Furthermore, the report adds that West Virginia is mostly mountainous and sparsely populated by comparison to other states. Even with "vigilant trimming" the lines will not be fully protected from damage from tall trees rooted or growing outside of the right-of-way.
The report notes that the PSC has been informed of the construction methods used when electric distribution facilities were originally placed before the time of motorized vehicles, drills and paved roads. Men with shovels set the poles, whereas mules and horses were used to haul poles, facilities, and wire spans through the woods along the shortest possible routes between residences or towns. Chosen routes were not on public rights-of-way but instead stretched up and down steep hillsides on narrow, private rights-of-ways. The PSC report states that these lines still remain in use today and, consequently, are at greater risk from falling trees outside of the rights-of-ways.
First Energy's report to the PSC noted that in one case, 14 poles had to be replaced to restore electricity to one customer, AEP informed the PSC that since the 2009/2010 winter storm, it has implemented the use of helicopters to set poles in rugged areas.
One possibility that was mentioned during the meetings would be to replace off-roadway lines with new longer lines along roadways. However, this would prove to be costly for utility companies because of the longer distribution wires, additional poles and facilities, as well as the legal costs to acquire additional rights-of-way from some private landowners. Burial of lines, as proposed by customers, is an even more expensive solution.
Utility customers also expressed concerns over the priority utilities had to restore service; hence, the PSC included a review of restoration priorities in its investigation. American Electric Power and First Energy, along with WVAWC, all appear to have reasonable restoration priorities according to the commission. The utility companies all focus on restoring power to hospitals, nursing homes, and hospice facilities first, followed by restoring power to areas which achieve restoration for the largest groups of customers as a priority.
Frontier also reported that their first priority is maintenance of telephone service to emergency 911 centers.
Each utility was also required to state in their storm reports any new plans to existing procedures to improve outage response.
As for future plans to be implemented, AEP reported that it had conducted an internal review of its restoration process and would "improve its overall processes to incorporate impacts to both distribution and transmission facilities by: researching 'pre-certification' contracts and outside resources to ensure familiarity with the AEP safety procedures to increase the safety and timelines of deployment; evaluating options for fatigue management to address the conditions of extreme heat and long working hours; evaluating the use of non-traditional employees such as retirees to perform restoration roles; and exploring the increased use of helicopters." The AEP also noted equipment upgrades or replacements that could enhance reliability.
First Energy noted a need to add an additional staging site to the existing four sites for the provision of materials and meals to workers. The utility company also plans to identify in advance additional housing in mobile units; establish a network of retailers to facilitate distribution of ice and water to hardest hit areas; and work with state government and communication providers to find solutions to areas which lack mobile communications.
Frontier Communications' plans include increasing security for generators where practicable, prioritizing 911 center sites and facilities for generator backup; reviewing its 911 Public Safety Answering Points communication plan for disaster situations; enhancing network visibility, and modifying procedures to ensure that back-up power and replacement parts are available.
WVAWC stated in its report that it will consider contracts with fuel supplier to supply fuel for generators, vehicles, and equipment during emergencies; continue the installation of quick connections and transfer switches to equipment that require a generator to reduce transition time; provide backup systems for critical remote telemetry sites to enable continual monitoring of its system even during power outages; categorize in advance its equipment by type and size of generator needed; initiate plans for GIS system mapping to assist in directing employees and contractors to certain locations during emergencies; stockpile cots and nonperishable foods and drinks for employee use during emergencies; improve communications through use of government calling cards; and improve coordination of activities between FEMA, the DOH, and the electric utilities to improve restoration results.
The PSC reports that in addition to the electric utility rights-of-way programs required by the order, the major utilities are expected to follow through on the above-mentioned plans.
Following the PSC investigation of the severe winter storm and subsequent outages in the winter of 2009/2010, the commission adopted "new electric reliability rules, indices, targets, and reporting requirements that will require plans for remedial actions when reliability target are not met." These rules are referred to the "Electric Rules." Prior to recent rule amendments, electric utilities "were required to keep power lines free of vegetation, maintain records of interruptions of service, and inform the PSC about time, duration, cause, and location of service interruptions."
Under the new Electric Rules, if electric utilities fail to meet specific targets listed in the rules, they are required to report to the PSC for review and further action. The report states that "The commission expects that the electric utilities' efforts to adhere to the new Electric Rules and the implementation of cycle-based vegetation clearing programs will significantly improve reliability throughout the state."