[34 Pa.B. 2764]
[Continued from previous Web Page] 6. Formal Requests for Exclusion of Service Interruptions as Major Events
The Staff Internal Working Group's Recommendation No. IV-1 states that the Commission should implement a process that will enable EDCs to formally request exclusion of service interruptions for reporting purposes by proving an outage qualifies as a major event. To analyze and set measurable goals for service reliability performance, outage data is partitioned into normal and abnormal periods so that only normal event periods are used for calculating service reliability indices. The term ''major event'' is used to identify an abnormal event, for which this outage data is to be excluded when calculating service reliability indices. 52 Pa. Code § 57.192 currently defines a ''major event'' as follows:
(i) Either of the following:(A) An interruption of electric service resulting from conditions beyond the control of the electric distribution company which affects at least 10% of the customers in an operating area during the course of the event for a duration of 5 minutes each or greater. The event begins when notification of the first interruption is received and ends when service to all customers affected by the event are restored. When one operating area experiences a major event, the major event shall be deemed to extend to all other affected operating areas of the electric distribution company.(B) An unscheduled interruption of electric service resulting from an action taken by an electric distribution company to maintain the adequacy and security of the electrical system, including emergency load control, emergency switching and energy conservation procedures, as described in Section 57.52 (relating to emergency load control and energy conservation by electric utilities), which affects at least one customer.(ii) A major event does not include scheduled outages in the normal course of business or an electric distribution company's actions to interrupt customers served under interruptible rate tariffs.The Staff Internal Working Group identified the following scenarios wherein certain EDCs had inappropriately claimed service interruptions as a major event:
* Combining two separate storm events, of which only one meets the definition of a major event, into one major event.
* Excluding outage data from all operating areas when a major event had occurred in only one operating area.
* Excluding all outage data that took place on any day in which a major event took place, regardless of the actual timeframes in which the major event took place.
Reliability performance will appear to be better than it really is when an EDC excludes more outage data from its reliability calculations than it should. The performance will appear to be better because the number of customers interrupted and/or the customer minutes of the interruption are excluded from the calculations of the performance metrics, thus resulting in lower (better) scores. To avoid the inappropriate exclusion of outage data from any calculated service reliability indices reported to the Commission, the Staff Internal Working Group recommended that a process be established whereby the EDC could formally notify the Commission that it has recently experienced what it believes to be a major event so that the specific outage data associated with the event would be excluded for calculating reliability performance. After providing Commission Staff with the report, the utility would be able to exclude the related outage data from its reliability calculations. The Staff Internal Working Group also recommended that the following outage data be provided in support of the request:
* The starting and ending times of the outage.
* The main operating area(s) affected by the major event, including the causes and number of customers affected.
* The neighboring operating area(s) affected, including the causes and number of customers affected.
It will not be necessary to provide information about neighboring operating areas affected, since the Staff Internal Working Group is recommending that the definition of a major event be revised so that it is based on interruption criteria of the entire service territory of an operating company as opposed to individual operating areas defined by each operating company.
Positions of the Parties
The Energy Association states that while it supports the clarification of what constitutes a major storm, there is not a compelling reason to have a costly and duplicate major storm determination process. EAP states that the information proposed to be included in the formal request form is virtually identical to the information required in Service Outage Report filed under 52 Pa. Code § 67.1; thus, the Commission should eliminate the formal request requirement as being duplicative of existing reporting requirements. If, however, the Commission maintains a major event approval process, EAP requests that the filing be deemed approved after ten days if no Commission action is taken. (EAP's October 10, 2003, Comments, p. 10-12.)
The FE Companies believe that the proposed form would be costly and time consuming for all parties involved. Rather than implement the formal process, the FE Companies propose that the Commission review each company's annual report to determine if there has been any abuse or misunderstanding regarding the claims for major events, and direct any necessary and appropriate adjustments based upon this after the fact evaluation. (FE Companies' October 9, 2003, Joint Comments p.15-16.)
PPL believes that the proposed form for requesting an exclusion is duplicative because most ''major events'' would be associated with storms that require submission of a Storm Outage Report in 52 Pa. Code § 67.1. PPL recommends that the Commission develop a standard reporting format for outages which includes the required information. PPL also recommends that the request to classify a storm as a ''major event'' be part of the Storm Outage Report and that the request be deemed approved unless denied by the Commission within 10 business days. (PPL's October 10, 2003, Comments, p. 5-6.)
The OCA submits that the Commission should retain the formal process for requesting exclusion of major event data from the reported results at this time. The OCA avers that although the Commission provided clarification about the application of the criteria to underlying data in the Tentative Order, the Commission should utilize a formal process to ensure that the criteria are being applied uniformly. The OCA asserts that a formal process to review the continuing use of the regulation is in order, given the significant differences in the application and interpretation of this regulation in the past. (OCA's October 27, 2003, Reply Comments, p. 17-18.).
Disposition
Upon further review of this issue, the Commission orders the implementation of a process by which the utility must submit a formal request for exclusion of service interruptions for reporting purposes, accompanied by data which demonstrates that a service interruption qualifies as a major event as defined by regulations. The outage data to be provided in support of the request will be as follows:
(1) The approximate number of customers involved in the incident/outage.
(2) The total number of customers served in the service territory.
(3) The geographic areas affected, in terms of the county and local political subdivision.
(4) The reason for the interruption, including weather conditions if applicable.
(5) The number of utility workers and others assigned specifically to the repair work.
(6) The date and time of the first information of a service interruption.
(7) The actual time that service was restored to the last affected customer.
Following this Order as Appendix D is a sample Major Event exclusion request form which the Commission directs the companies to use to request exclusions for major events.
We also reject PPL's and EAP's claim that the exclusion request would be duplicative. 52 Pa. Code § 67.1 requires utilities to provide notification to the Commission when 2,500 or 5% (whichever is less) of its customers are without service for 6 hours of more. 52 Pa. Code § 57.192 defines a major event as at least 10% of the customers being without service for at least 5 minutes. Obviously, there is the potential for 2,500 customers to be out of service for more than 6 hours, thus requiring a Section 67.1 report, but not fulfilling the requirements to be classified as a major event. Conversely, there is the potential for large numbers of customers to be out of service for less than 6 hours. In this case, the major event criteria may be met, but a Section 67.1 report would not be required. Contrary to EAP and PPL's assertion that these types of events are unlikely, they can and have occurred. Thus, tying a major event exclusion request to the Section 67.1 report does not conform to this Commission's intent to ensure the application of 52 Pa. Code § 57.192 in a timely and consistent manner.
EAP and FE Companies have characterized the requirement to submit a major event exclusion form as costly and time consuming. However, neither has presented any reasoning for these assertions. In fact, EAP points out the similarities between the forms required for §§ 67.1 and 57.192. This Commission is not aware of any arguments that compliance with the currently effective § 67.1 is costly and burdensome to utility operations. We therefore find EAP and FirstEnergy's assertions to be without merit.
FE Companies' proposal to review each company's annual report to determine if there has been any abuse or misunderstanding regarding the claims for major events is inappropriate. A major event review could occur as late as after four quarterly reports were filed with the Commission for the year in question. If there were adjustments made as a result of a review of a utility's major event exclusion claims, those adjustments would need to be implemented retrospectively in each affected quarterly report. The intent of quarterly report submissions is that the Commission be able to perform a timely review and analysis of a utility's reliability performance on the most accurate information available. Making adjustments to quarterly data 15 to 18 months after the fact clearly does not allow for a timely and accurate analysis. We will therefore not adopt the FE Companies' suggestion in this regard.
EAP and PPL requested that the filing be deemed approved after 10 days if no Commission action is taken. We believe that it is important that a utility know as soon as possible whether its request for a major event exclusion is accepted because of the time and complication associated with the calculation of the various reliability indices. Therefore, we will strive to provide a response to the filing utility within 10 days of the request, but we will give Commission staff 20 days from the date of receipt of the request for exclusion to request any additional information from the utility. If staff does not approve the exclusion, request additional information or reject the exclusion within that time, the filing utility may treat the excluded period as a major event.
The authority to respond to the request is delegated to the Bureau of Fixed Utility Services, which shall notify the filing utility in writing of staff's determination. All filings are subject to an audit at a later time by the Bureau of Audits. The utility may appeal staff's determination under 52 Pa. Code § 5.44 by filing a petition within 10 days after service. Requests for major event exclusions must be filed with the Secretary's Bureau and copies served upon the Bureau of Audits and Bureau of Fixed Utility Services prior to the quarterly report in which the exclusion is proposed to be claimed.
7. Commission Enforcement
Several parties raised the issue regarding what action the Commission will take if an EDC's reported indices are higher (worse) than the performance benchmark or higher (worse) than the EDC's performance standard. Generally, we view the new, recomputed benchmarks to represent the EDC's average performance prior to the Act and prior to competition. Since we have tightened the performance standards, we view performance within the standard to approximate the benchmark. Therefore, the Commission will not take compliance enforcement action against any EDC that meets its performance standard. However, once a standard is violated, Commission staff will carefully review all information presented in the EDC's quarterly and annual reliability reports including the EDC's causal analysis, inspection and maintenance goal data, expenditure data, staffing levels and other supporting information and Section 67.1 reports to determine appropriate monitoring and enforcement actions. Depending upon the findings of this review, we may consider a range of compliance actions including engaging in additional remedial review, requiring additional EDC reporting, conducting an informal investigation, initiating a formal complaint, requiring a formal improvement plan with enforceable commitments and an implementation schedule and assessing penalties and fines.
While overall system performance trends that fall in the range between the benchmark and the standard will not be subject to compliance enforcement, the Commission will keep EDCs whose performance is within the standard, but trending away from the benchmark, under review as a precautionary measure.
The Commission will hold the EDCs to the new 3-year standard using 2004, 2005 and 2006 annual data, effective with the April 30, 2007, annual report, and will hold the EDCs accountable to the 12-month standard using data from the last quarter of 2003 and the first three quarters of 2004, effective with the quarterly report to be filed November 1, 2004. Therefore,
It Is Ordered That:
1. The Commission is issuing, under 52 Pa. Code § 57.194(h), final benchmarks and standards for EDCs operating within this Commonwealth as set forth in Appendices A, B and C.
2. The Commission will enforce the 3-year standard on April 30, 2007, and the Commission will enforce the 12-month standard on November 1, 2004.
3. EDCs are directed to use the draft form in Appendix D when requesting the exclusion of service interruptions for reporting purposes by proving that a service interruption qualifies as a major event as defined by regulations.
4. An EDC shall request, in writing to the Commission's Secretary's Bureau, any waivers of reliability reporting requirements necessary to fulfill its obligations under 52 Pa. Code Chapter 57, Subchapter N (Electric Reliability Standards).
5. The Commission shall review and consider the EDC's request for waivers and shall issue Secretarial Letters granting or denying said requests.
6. Copies of this Order be served upon all parties to this proceeding including: EDCs operating in this Commonwealth, the OCA, the Office of Small Business Advocate, EAP and the Pennsylvania AFL-CIO--Utility Division.
7. A copy of this Order and Appendices A, B, C and D shall be filed at the Proposed Rulemaking Docket L-00030161, Rulemaking Re Amending Electric Service Reliability Regulations at 52 Pa. Code Chapter 57.
8. The Secretary certify this Order with Appendices and deposit with the Legislative Reference Bureau for publication in the Pennsylvania Bulletin.
9. Requests for major event exclusions must be filed with the Secretary's Bureau and copies served upon the Bureau of Fixed Utility Services and Bureau of Audits prior to the quarterly report in which the exclusion is proposed to be claimed.
10. Authority is delegated to the Bureau of Fixed Utility Services to determine whether requests for major event exclusions should be accepted or denied. Appeals may be taken under 52 Pa. Code § 5.44 from staff's determination within 10 days of service of the letter.
11. All requests for major event exclusions shall be subject to audit by the Bureau of Audits.
12. Any EDC requesting its benchmark be modified is directed to file a petition with the Commission outlining the reasons why the benchmark should be modified within 30 days of the date of entry of this Order.
13. Copies of the petition to amend benchmarks and/or standards should be served upon the Pennsylvania AFL-CIO--Utility Division, the OCA and the Office of Small Business Advocate.
JAMES J. MCNULTY,
Secretary
Appendix A
Prior Benchmarks and Recomputed Benchmarks
Reliability Prior Recomputed Reason for Name of EDC
Indices Benchmark Benchmark Recomputation
SAIFI 0.67 0.67 Allegheny Power CAIDI 178 178 Change to One Operating Area SAIDI 116 119 SAIFI 1.15 1.17 Duquesne Light CAIDI 108 108 Change to One Operating Area SAIDI 123 126 SAIFI 0.97 1.06 Met-Ed CAIDI 117 127 Change to One Operating Area SAIDI 113 135 SAIFI 1.07 1.15 Penelec CAIDI 104 115 Change to One Operating Area SAIDI 108 132 SAIFI 1.01 1.02 PUC Definition of a Major Event Penn Power CAIDI 93 92 v. FE Definition SAIDI 95 94 SAIFI 1.23 1.23 PECO CAIDI 112 112 No Change SAIDI 138 138 SAIFI 0.88 0.98 PPL CAIDI 128 145 Change to One Operating Area SAIDI 113 142 UGI SAIFI 0.83 0.83 SAIDI Calculation Correction = CAIDI 169 169 SAIFI × CAIDI SAIDI 147 140 SAIFI 1.29 0.20 Major Events Now Excluded Citizens CAIDI 73 105 SAIDI 73 21 SAIFI 0.39 0.39 SAIDI Calculation Correction = Pike County CAIDI 178 178 SAIFI × CAIDI SAIDI 66 69 SAIFI 2.74 1.23 Wellsboro CAIDI 128 124 Major Events Now Excluded SAIDI 309 153
Appendix B
Benchmarks and Standards for EDC Distribution Reliability Performance
(A) (B)
(C) (D) (E) Rolling Rolling Reliability Recomputed 12-Month 3-Yr Avg. Name of EDC Indices Benchmark Standard Standard SAIFI 0.67 0.80 0.74 Allegheny Power CAIDI 178 214 196 SAIDI 119 172 144 SAIFI 1.17 1.40 1.29 Duquesne Light CAIDI 108 130 119 SAIDI 126 182 153 SAIFI 1.06 1.27 1.17 Met-Ed CAIDI 127 152 140 SAIDI 135 194 163 SAIFI 1.15 1.38 1.27 Penelec CAIDI 115 138 127 SAIDI 132 190 160 SAIFI 1.02 1.22 1.12 Penn Power CAIDI 92 110 101 SAIDI 94 135 114 SAIFI 1.23 1.48 1.35 PECO CAIDI 112 134 123 SAIDI 138 198 167 SAIFI 0.98 1.18 1.08 PPL CAIDI 145 174 160 SAIDI 142 205 172 UGI SAIFI 0.83 1.12 0.91 CAIDI 169 228 186 SAIDI 140 256 170 SAIFI 0.20 0.27 0.22 Citizens CAIDI 105 141 115 SAIDI 21 38 25 SAIFI 0.39 0.53 0.43 Pike County CAIDI 178 240 196 SAIDI 69 127 84 SAIFI 1.23 1.66 1.35 Wellsboro CAIDI 124 167 136 SAIDI 153 278 185 Column C--The recomputed benchmarks based on historical performance excluding major event data using the entire service territory criterion.
Column D--The rolling 12-month standard. The threshold is at 120% of the recomputed benchmark for the major EDCs and 135% of the recomputed benchmarks for the small EDCs.
Column E--The rolling three-year standard. The threshold is at 110% of the recomputed benchmark of each EDC.
Appendix C
Rolling 12-Month Standard for Major EDCs
(120% of Benchmark)
(A)
(B) (C) (D) (E) (F) (G) 2-Std. Dev. Proposed Above Rolling Reliability Current Current Recomputed Recomputed 12-Month Name of EDC Indices Benchmark Standard Benchmark Benchmark Standard SAIFI 0.67 1.08 0.67 1.08 0.80 Allegheny Power CAIDI 178 223 178 224 214 SAIDI 116 159 119 241 172 SAIFI 1.15 1.46 1.17 1.49 1.40 Duquesne Light CAIDI 108 127 108 127 130 SAIDI 123 143 126 189 182 SAIFI 0.97 1.29 1.06 1.29 1.27 Met-Ed CAIDI 117 140 127 155 152 SAIDI 113 155 135 200 194 SAIFI 1.07 1.70 1.15 1.42 1.38 Penelec CAIDI 104 134 115 141 138 SAIDI 108 140 132 201 190 SAIFI 1.01 1.41 1.02 1.41 1.22 Penn Power CAIDI 93 117 92 119 110 SAIDI 95 154 94 168 135 SAIFI 1.23 1.70 1.23 1.70 1.48 PECO CAIDI 112 144 112 143 134 SAIDI 138 196 138 244 198 SAIFI 0.88 1.14 0.98 1.19 1.18 PPL CAIDI 128 155 145 190 174 SAIDI 113 155 142 226 205
Rolling 12-Month Standard for Small EDCs
(135% of Benchmark)
(A)
(B) (C) (D) (E) (F) (G) 2-Std. Dev. Proposed Above Rolling Reliability Current Current Recomputed Recomputed 12-Month Name of EDC Indices Benchmark Standard Benchmark Benchmark Standard SAIFI 0.83 1.35 0.83 1.35 1.12 UGI CAIDI 169 304 169 305 228 SAIDI 147 331 140 412 256 SAIFI 1.29 3.10 0.20 0.38 0.27 Citizens CAIDI 73 156 105 230 141 SAIDI 73 123 21 86 38 SAIFI 0.39 0.58 0.39 0.58 0.53 Pike County CAIDI 178 283 178 283 240 SAIDI 66 112 69 165 127 SAIFI 2.74 6.16 1.23 1.91 1.66 Wellsboro CAIDI 128 195 124 252 167 SAIDI 309 565 153 483 278 Column C--The current benchmarks established December 16, 1999 at Docket No. M-00991220. It represents the five-year average of the historical performance for years 1994-1998.
Column D--The current standards established December 16, 1999 at Docket No. M-00991220. The standard is plus two standard deviations from the established benchmarks.
Column E--The recomputed benchmarks based on historical performance excluding major event data using the entire service territory criterion.
Column F--Represents what the current standard would be if applying the two-standard deviation methodology to the recomputed benchmarks.
Column G--The proposed rolling 12-month standard. The threshold is at 120% of the recomputed benchmark for the major EDCs and 135% of the recomputed benchmarks for the small EDCs.
Appendix D
REQUEST FOR EXCLUSION OF MAJOR OUTAGE FOR
RELIABILITY REPORTING PURPOSES TO
PENNSYLVANIA PUBLIC UTILITY COMMISSION
P O BOX 3265
HARRISBURG, PA 17105-3265Reports require an original and one copy to be filed with the Secretary's Bureau.
Information Required:
1. Requesting Utility: __________
Address: __________
__________
2. Name and title of person making request:
_________________ _________________
(Name) (Title)3. Telephone number: _________________
(Telephone Number)4. Interruption or Outage:
(a) Number of customers
affected:
Total number of customers in
service territory: __________(b) Number of troubled locations in each geographic area affected listed by county and
local political subdivision:__________
__________
__________
__________
(c) Reason for interruption or outage, including weather data where applicable:
__________
__________
__________
__________
(d) The number of utility workers and others assigned specifically to the repair work:
__________
(e) The date and time of the first notification of a service
interruption: _________________(f) The actual time that service was restored to the last affected
customer: _________________Remarks: __________
__________
__________
__________
__________
[Pa.B. Doc. No. 04-931. Filed for public inspection May 21, 2004, 9:00 a.m.]
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