Legalectric

Nearly two years ago, I attended a hearing for the Delmarva Power Integrated Resource Plan, which was the most bizarre hearing I’ve ever experienced.  At that time, I raised issues about decreasing demand, entered into the record the PJM demand documents that we’d used in the Susquehanna-Roseland transmission docket in New Jersey (also PJM), and raised concerns that no SAIDI, SAIFI and CAIDI reliability info was reported.  After that meeting, I presented Delmarva Power’s attorney Todd Goodman with a well-deserved “Horse’s Ass” award for his performance at that meeting.  The points I’d raised at that meeting about what was missing in their “IRP” were oh-so-valid:

Transcript – Delmarva IRP Hearing December 3 2008

It took a while, but last week, the Washington Post featured an article showing that PEPCO, utility in D.C. and Maryland, and the corporate parent of Delmarva Power, has an inexcusably miserable record for outages.   That’s something that’s demonstrated in the SAIDI, SAIFI and CAIDI reports!  And folks, don’t go conflating transmission with distribution as the cause for the outages, as utilities would have you do.  Anyway, here’s that article:

Washington Post Analysis: Why PEPCO can’t keep the lights on

PEPCO executives acknowledge need to improve reliability

As you read the article, note there’s not a word on D-E-R-E-G-U-L-A-T-I-O-N as a contributory factor, much less the primary reason.

Washington Post analysis: Why Pepco can’t keep the lights on

By Joe Stephens and Mary Pat Flaherty
Washington Post Staff Writers
Sunday, December 5, 2010; 12:38 AM

In high-powered Washington, one of the world’s most wired and connected metro areas, the region’s leading electric company has trouble just keeping the lights on.

Pepco delivers power to 778,000 customers in the District and neighboring parts of Maryland, including some of the most affluent communities and most important institutions in the nation. But in reliability studies, the company ranks near the bottom in keeping the power on and bringing it back once it goes out, an analysis by The Washington Post has found.

In fact, the average Pepco customer experienced 70 percent more outages than customers of other big city utilities that took part in one 2009 survey. And the lights stayed out more than twice as long.

Pepco’s reliability began declining five years ago, records show; company officials acknowledge that they have known of the problem but that they only started to focus on it more recently.

Moreover, Pepco has long blamed trees as a primary culprit for the frequency and duration of its outages, implying that the problem is beyond its control. But that explanation does not hold up under scrutiny, The Post analysis found. By far, Pepco equipment failures, not trees, caused the most sustained power interruptions last year.
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Xcel Energy”s Hiawatha Transmission Project is sticking in my craw again.  I’m having one of those “Xcel is evil” kind of days.  Xcel is hiding reliability information under a claim of “Security.”  How absurd can they get?  Don’t they get that if I was going to blow up substations, a) I don’t need their stupid info to do it, and b) I would have done it a long time ago?  Earth to Mars, that’s not my M.O.  But noooooooooo…

I’ve been looking at Xcel’s SAIDI, SAIFI and CAIDI distribution reliability reports, one of the things I’m happiest about in the 2001 legislative session.  Minn. Stat. 216B.029. Why?  Because Xcel’s Scott Zima testified at the public hearing for the Hiawatha Transmission Line Project that the claimed “reliability” problems did not show up in their SAIDI, SAIFI and CAIDI reports.  WAS ANYONE LISTENING?

What is SAIDI, SAIFI and CAIDI?  They’re distribution reliability indices.  Here are definitions stolen from Rochester Public Utilities 2009 Electric System Engineering & Operations Report:

• SYSTEM AVERAGE INTERRUPTION DURATION INDEX – SAIDI

SAIDI is defined as the average duration of interruptions for customers served during a specified time period.  Although similar to CAIDI, the average number of customers served is used instead of number of customers affected.

The unit of SAIDI is minutes.  A common usage of SAIDI is: “If all the customers on the distribution system were without power the same amount of time, they would have been out for _________ minutes”.

• SYSTEM AVERAGE INTERRUPTION FREQUENCY INDEX – SAIFI

SAIFI described the average number of times that a customer’s power is interrupted during a specified time period.  “SAIFI-short” is calculated using the number of customers affected by momentary interruptions (such as brief breaker or recloser operations).  “SAIFI-long” is calculated using the number of customers affected by sustained interruptions.

The units for SAIFI are “interruptions per customer”.  A common usage of SAIFI is: “On the average, customers on the distribution system experienced _______ interruptions”.

• CUSTOMER AVERAGE INTERRUPTION DURATION INDEX – CAIDI

CAIDI is the weighted average length of an interruption for customers affected during a specified time period.

The unit of CAIDI is minutes.  A common usage of CAIDI is:  “The average customer that experiences an outage on the distribution system is out for ___________ minutes.”

Here’s some background info about SAIDI, SAIFI and CAIDI reports from Edison Institute:

State of Distribution Reliability – 2005

Here’s the Minnesota rule about reporting SAIDI, SAIFI and CAIDI:

7826.0500 RELIABILITY REPORTING REQUIREMENTS.

Subpart 1. Annual reporting requirements.

On or before April 1 of each year, each utility shall file a report on its reliability performance during the last calendar year. This report shall include at least the following information:

A. the utility’s SAIDI for the calendar year, by work center and for its assigned service area as a whole;
B. the utility’s SAIFI for the calendar year, by work center and for its assigned service area as a whole;
C. the utility’s CAIDI for the calendar year, by work center and for its assigned service area as a whole;
D. an explanation of how the utility normalizes its reliability data to account for major storms;
E. an action plan for remedying any failure to comply with the reliability standards set forth in part 7826.0600 or an explanation as to why noncompliance was unavoidable under the circumstances;
F. to the extent feasible, a report on each interruption of a bulk power supply facility during the calendar year, including the reasons for interruption, duration of interruption, and any remedial steps that have been taken or will be taken to prevent future interruption;
G. a copy of each report filed under part 7826.0700;
H. to the extent technically feasible, circuit interruption data, including identifying the worst performing circuit in each work center, stating the criteria the utility used to identify the worst performing circuit, stating the circuit’s SAIDI, SAIFI, and CAIDI, explaining the reasons that the circuit’s performance is in last place, and describing any operational changes the utility has made, is considering, or intends to make to improve its performance;
I. data on all known instances in which nominal electric service voltages on the utility’s side of the meter did not meet the standards of the American National Standards Institute for nominal system voltages greater or less than voltage range B;
J. data on staffing levels at each work center, including the number of full-time equivalent positions held by field employees responsible for responding to trouble and for the operation and maintenance of distribution lines; and
K. any other information the utility considers relevant in evaluating its reliability performance over the calendar year.

Subp. 2. Initial reporting requirements.

By March 30, 2003, each utility shall file its SAIDI, SAIFI, and CAIDI for each of the past five calendar years, by work center and for its assigned service area as a whole. If this information is not available, the utility shall file an explanation of how it has been tracking reliability for the past five years, together with reliability data for that period of time. If the utility has implemented a new reliability tracking system that makes comparisons between historical data and current data unreliable, the utility shall explain this situation in its filing.

Statutory Authority: MS s 216B.81

Xcel has to file these reports annually.  And since Xcel’s Mr. Zima’s testimony that the reliability problems they claim as the basis for need for the Hiawatha Project are NOT reflected in the SAIDI, SAIFI and CAIDI reports (WAS ANYONE LISTENING?), I spent some time looking at the annual reports filed this year:

Xcel’s Initial Filing – Docket 10-310

Xcel’s Initial Filing – Docket 10-310 – Attachment D – Part 1

Xcel’s Initial Filing – Docket 10-310 – Attachment D – Part 2

And there’s another older docket where similar information was recently filed:

Xcel’s Annual Filing – 02-2034 – Part 1

Xcel’s Annual Filing – 02-2034 – Part 2

Xcel’s Annual Filing – 02-2034 – Part 3

To search these dockets,go to www.puc.state.mn.us and click on “Search eDockets” and then plug in the docket numbers.

And here’s an example of what’s wrong with this picture – look at the crudely whited-out Feeder Line column:

Who cares?  Well, I do… why?  Because when they say that the distribution system is such a problem that they need a big honkin’ shiny new transmission line, and then one of their engineers testifies that this distribution “reliability problem” they’re whining about and inflicting an oversized transmission “solution” on a community about ISN’T showing up in the SAIDI, SAIFI and CAIDI distribution reliability reports, that’s a problem.  IS ANYONE TRACKING THIS?  It’s not rocket science, it’s basic vetting of their claims!

Looking at their letter in the filing in Docket 02-2034, there’s this amazing statement:

Security Data

The raw reliability data provided with this filing includes “security data” as
defined by Minn. Stat. § 13.37, subd. 1(a). Xcel Energy believes that some of the
raw data on the disks and/or that has been eFiled could be manipulated to reveal
the location and size of certain facilities that have been summarized in the
Monthly Report. The public disclosure or use of this information creates an
unacceptable risk that those who want to disrupt the electrical grid for political
or other reasons may learn which facilities to target to create the greatest
disruption. For this reason, pursuant to Minn. Stat. § 13.37, subd. 2, we have
excised this data from the public version of our filing.

p. 5,  Xcel’s Annual Filing – 02-2034 – Part I (emphasis added).

Excuuuuuse me?

The public disclosure or use of this information creates an unacceptable risk that those who want to disrupt the electrical grid for political or other reasons may learn which facilities to target to create the greatest disruption.

What a load o’ crap. It is so illogical — those they’re having problems with aren’t necessarily, and probably just AREN’T, the ones to target to create the greatest disruption!

So I calls up Xcel, I do… and leave a message with Bria Shea because Jody Londo who signed the cover letter with the “Security” note was not in, explaining what info in what dockets I’m looking for and that I’m wanting to sign a confidentiality agreement to get it.

But noooooooooooo, guess again.  I get a call back from someone in “Legal” (I didn’t know they had an Illegal department) and here they are making a bogus argument about PUBLIC disclosure, and I’m asking for disclosure with a confidentiality agreement.  She wants to know if I’m a party, which I’m not, there are no parties in these dockets.  And even if a party, even with a confidentiality agreement, no, because it’s a SECURITY issue.  Oh, yeah… right… I’m a terrorist, wanting their “feeder line” information to take out electricity to some select target…  Guess she’s been talking to Mike Krikava, thinking only a terrorist would want to enter a 2005-MAPP map into a transmission proceeding.  That’s as wacky as a judge thinking it’s appropriate to do a transmission proceeding without a map entered in as evidence!

So now I get to “evaluate my options.”  It’s possible to do some triangulation with the reports and with the Attachments to Xcel’s Hiawatha Project Application, but… sigh… we all know what their concern is — that someone might read it and make some sense of it, and understand what it means.