To:
Stakeholder ESA
Subject:
Date:
re: ESA Launches Public Consultation - Impact on Adjusting Regulation 22/04
July-22-16 4:01:20 PM
Please find below Hydro One Networks Inc.’s responses regarding: O Reg. 22/04 proposed changes,
under the Electricity Act, 1998, S.O. 1998, c. 15, Sched. A; public consultation July 2016:
Name of the responding individual or organization: Raymond Micallef, P. Eng., c/o Darlene
Bradley; Hydro One Networks Inc.
To what stakeholder group you belong: Local Distribution company Responses to the questions posed in the consultation document above. You can elect not to
answer a question. You may also make additional comments on the proposal:
1. What, if any, are the benefits associated with the proposed expanded
reporting requirements?
· For Hydro One we believe that the benefit would be minimal. Hydro One reports defects
and trouble calls and tracks such in our system of record. We do analysis and trending of
common defects or problems and use this information to drive standards development or
modification; to support maintenance and capital programs; and our follow up through
interactions with entities such as the ESA; CSA; IEEE and other related industry forums. · The benefit of the proposed expanded reporting legislation could be that the Authority
would have more information that could be used on target campaigns to increase public
and industry safety awareness and standards to support incident prevention. 2. What, if any, are the risks associated with the proposed expanded
reporting requirements?
· Without clarity in wording there could be varying interpretation by industry participants
introducing risk to the data completeness and value.
· Regulatory requirements could result in a focus on compliance which is not necessarily
reflective of a good safety culture which is the ultimate objective.
· Value is in being able to drive a change in how safety is considered and viewed by all. There
is risk in achieving the desired value if there is not mechanism for collaboration with the
Authority’s jurisdictional partners, being the Ministry of Labour, local Police Services or Fire
Marshals etc. For ultimate value a system for which the ESA can fulfill their mandate with
investigation information transferring seamlessly with the same confidentiality and security
rigour to prevent any unwanted release of information and collaboration on initiatives to
minimize risks (such as the attempt made to have the MOL consider requirements for non
conductive ladders for use around electrical equipment for any worker).
· Impact on utility ability to manage legal follow up with incidents and equipment defects.
3. What, if any, is the likely impact on LDCs to meet these proposed
requirements including:
Estimated financial and administrative costs?
The following costs would be associated with this change:
·
For Hydro One we believe that we report existing requirements adequately through our
control room dispatch managers, The proposed reporting would rely on trades staff. As
such training on the requirement and reporting for a large number of staff would be
required to ensure they recognize the addition responsibility and systems are set up to
support the same. An estimated $400k to transition and sustainment could conservatively
cost $150k/annum and perhaps additional resources for tooling and data infrastructure
enablement. Comparison of impact with current reporting requirements?
·
Addition of Trades staff vs. our Control room Dispatch team engaged in reporting and
enabling the infrastructure to do so.
How many additional incidents would have been reported in the last five
years under these expanded requirements?
·
Hydro One has no information to amount or frequency of these events.
4. If you are an LDC that currently voluntarily reports meter-related serious
incidents to ESA, what have been the administrative and/or financial impacts,
if any, on your organization? What, if any, have been the benefits and/or risks
of doing so?
·
Hydro one has not voluntarily reported meter related events to the Authority.
What, if any, impact would these changes have on non-LDC stakeholders?
·
·
·
Customers of LDCs may be obliged via the legislation to cooperate for investigative
processes as deemed necessary to support the intent of the same legislation. Costs to establish and maintain the infrastructure and processes for this reporting would be
required in rates.
Impact of manufacturers. Manufacturers currently have standards and quality
management processes including follow up on equipment performance. Where a trend is
recognized this may include technical bulletins to advise of a refurbishment or retrofit or
recalls. Release of specific information publically for individual events, could be of concern
to manufacturers.
6. What approach best serves the Ontario public and the interest of
electrical safety?
Continued focus on equipment standards that provide a safe infrastructure and equipment for the
people of Ontario.
Continued focus on awareness of electrical hazards and situational awareness, including
collaboration with other agencies, to address contacts from cranes, dump trucks, ladders, dig in’s,
etc.
7. What would Ontarians expect in terms of oversight and reporting of such
incidents?
Ontarians would expect Standards that reduce risk of failure or ensure that safe failure methods to
prevent incidents vs reporting incidents. Understanding of the significant contributors, what has
been done to mitigate risk, the impact these actions have taken. Hydro One has internal reporting
and analysis of equipment and system performance that provide this analysis and actions. Sharing
through a forum such as the LDC advisory committee would be an effective forum to promote
sharing between utilities.
Of the options proposed, option A, enhanced reporting related to meters, would be preferred due
to
· the containment in scope and expectations which would support consistency in
requirements.
· Risks associated with costs, legal action, manufacturer concerns, etc will still apply.
· Risk related to collaboration on actions to mitigate risks from agencies such as MTO, MOL,
etc would be less impactive.
· Collaboration around access and investigation rights would be required for successful
implementation
Thank you for the opportunity to participate in this consultation.
Raymond Micallef, P. Eng.
Technical Services Manager
Hydro One Networks Inc.
12N-483 Bay St. | Toronto, On | M5G 2P5
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