THE UNITED ILLUMINATING COMPANY Maintenance Plan for Transmission and Distribution Overhead and Underground Lines Revised: 12/22/2014 Table of Contents 1. Executive Overview .........................................................................................................3 2. Introduction ......................................................................................................................3 3. System Description ..........................................................................................................4 4. Vegetation Management ..................................................................................................7 5. Maintenance Practices .....................................................................................................10 5.1. Construction and Maintenance Workforce Organization .........................................10 5.2. Maintenance of Assets and Systems by Area ...........................................................12 5.2.1. Overhead Distribution System .......................................................................12 5.2.2. Underground Distribution System .................................................................14 5.2.3. Overhead Transmission System .....................................................................16 5.2.4. Underground Transmission System ...............................................................17 5.2.5. Substations .....................................................................................................18 5.2.6. Vegetation Management ...............................................................................21 5.2.7. General ..........................................................................................................21 6. Summary of Updated Maintenance Practices ..................................................................21 6.1. Overhead Distribution System Changes ...................................................................23 6.2. Underground Distribution System Changes .............................................................23 6.3. Overhead Transmission System Changes .................................................................23 6.4. Underground Transmission System Changes ...........................................................24 6.5. Substation Changes ...................................................................................................25 6.6. Vegetation Management Changes ............................................................................28 7. List of Attachments ..........................................................................................................28 1: United Illuminating Service Territory Map...........................................................29 2: Vegetation Management Specification .................................................................30 List of Tables 1: System Peak Loads ..................................................................................................4 2: MWHR sales mix for the period 2007-2013 ...........................................................6 3: Breakdown of customers by class for the period 2007-2013...................................6 4: System Miles by Construction Type and Voltage Level .........................................6 5: Construction / Maintenance Work Force Organization ...........................................11 6: Maintenance Practices, Overhead Distribution System ...........................................12 7: Maintenance Practices, Underground Distribution System .....................................14 8: Maintenance Practices, Overhead Transmission System ........................................16 9: Maintenance Practices, Underground Transmission System ...................................17 10: Maintenance Practices, Substations ........................................................................18 2 1. Executive Overview Goals and Objectives Proper maintenance of The United Illuminating Company’s (UI or Company) transmission and distribution facilities has played a major role in achieving high reliability, public safety, and customer satisfaction, and is a key element of the UI corporate strategy. The Company continues active development and implementation of maintenance processes to drive efficiencies into maintenance activities. UI’s electric system maintenance practices focus on cost effectiveness while maintaining high levels of service to our customers. The United Illuminating Company’s Maintenance Program Goals are to: o Work safely everyday o Maintain reliability performance at 1998 levels o Achieve these goals at the minimum cost to our customers The United Illuminating Company’s Maintenance Plan addresses assets in six subsections: o o o o o o Overhead Distribution System Underground Distribution System Overhead Transmission System Underground Transmission System Substations Vegetation Management Reliability Centered Maintenance Since 1997, UI has employed a Reliability Centered Maintenance (RCM) program approach to system maintenance. In general, this approach applies equipment inspection, diagnostic testing, analysis of historical data, and other techniques, to determine the nature and timing of preventive maintenance actions. Hence, in RCM, traditional “time-based” maintenance is supplemented or replaced by predictive or “condition-based” maintenance. The specific strategy for the UI electric system is to move toward condition-based maintenance while continuing appropriate traditional time-based maintenance activities. At UI, the Reliability Centered Maintenance program is a continually evolving process that strives to understand an asset’s potential for failure by focusing resources on preservation of system function, as opposed to traditional maintenance to preserve individual equipment operation. This approach improves cost effectiveness by reducing unwarranted correctivereactive maintenance. 2. Introduction Maintenance is a dynamic process that combines analysis of historical data, carefully developed procedures that use proven predictive maintenance techniques, and cost effective 3 time-based maintenance tasks. The judgment of experienced operating and engineering personnel is continually sought out and incorporated into the Reliability Centered Maintenance Program. UI has developed a work routine that strives to make preventive action a daily responsibility. Electric System Operations personnel traveling in the territory are encouraged to report any abnormal system conditions to the operating department in a proactive manner. The goal of UI’s Maintenance Program is to maximize safety and reliability of the distribution and transmission systems in a cost effective manner. 3. System Description The United Illuminating Company is located in the southwest area of Connecticut on the north shore of Long Island Sound. UI serves seventeen cities and towns surrounding the principal cities of New Haven and Bridgeport. The service territory is approximately 335 square miles with a population of approximately 767,961people1. System peak load for recent years is shown in the following table: Table 1: System Peak Load, 2009 to 2014 Peak Load (MW) Date of Peak Load 2009 1,253 2010 1,365 2011 1,401 2012 1,319 2013 1,365 2014 1,134 8/21/09 7/06/10 7/22/11 7/18/12 7/18/13 9/02/14 The map provided in Attachment 1 shows the UI service territory and the municipalities supplied within the service area. To serve its customers, the UI Company owns, operates and maintains the following: 27 - 115/13.8 kV bulk distribution substations with a capacity of 1,886 MVA. 5 - 115 kV transmission switching stations. 2 - 345/115 kV transmission substations. 7 - 13.8/4.16 kV distribution substations with a capacity of 38 MVA. Approximately 3,284 pole line miles of overhead distribution lines (1 and 3). o This includes primary, secondary an aerial cable and excludes service conductors. 202 miles of underground conduit banks2. 675 miles of underground primary cables (1 and 3) consisting of direct-buried as well as underground duct and splicing chamber construction. 2013 Annual Population Estimates Data for Connecticut’s Towns and Counties as reported on the State of Connecticut Department of Public Health website http://www.ct.gov/dph/cwp/view.asp?a=3132&q=388156 1 2 The reported conduit bank miles have increased significantly due to a change in modeling ductlines. Conduit banks that are physically separated from one splicing chamber to another are now reported as two separate lengths as compared to previously where it they were combined into one length. 4 Approximately 95% of the distribution system is fed at 13,800 volts, with the remaining load supplied at 4,160 or 2,400 volts. Two underground network systems in the downtown areas of New Haven and Bridgeport utilize interconnected secondary cables (120/208Y volt) designed primarily for highdensity urban areas. Some of the larger downtown loads are supplied by 277/480Y volt systems that are not interconnected and are called “spot networks”. The UI transmission system consists of 11.1 circuit miles of overhead 345,000-volt line, 93.2 circuit miles of overhead 115,000-volt line, 17.1 circuit miles of underground 115,000-volt line, and 11.2 circuit miles of underground 345,000-volt line. A summary of the conductor types used in the UI system is found in Table 4 at the end of this section. Note that this table contains mileage of conductor types categorized by voltage level. The data for this table was obtained by using the Company’s Geographical Information System (GIS). The Company’s service area is composed of urban, suburban, and to a lesser extent rural areas. The urban areas are located in the downtown centers of Bridgeport and New Haven, as well as in the smaller cities and towns, including Fairfield, Shelton, Derby, Ansonia, Stratford, Milford, West Haven, Hamden, and East Haven. The remaining service area is mostly suburban. Most of UI’s commercial customers occupy land adjoining the major inter-city highways, such as I-95 and US #1 from Fairfield to East Haven, Route #8 from Bridgeport to Ansonia, I-91 and US #5 from New Haven to North Haven and Routes #10 and #15 from New Haven to Hamden. Most of the large industrial customers are situated along the Railroad Rights-ofWay on the shoreline, and in the Housatonic and Quinnipiac River Valleys. Almost all of the non-commercial areas are suburban residential tracts. The only true rural area left in the service territory is in Easton, except for scattered farms in North Haven, North Branford, and Orange, as well as state and local parklands. Much of the territory, including the rural, suburban, and residential area just outside the urban centers, is heavily treed. Service reliability, without question, is of vital importance to the viability of the Company as well as the local economy and remains extremely important to the Company and all of our customers. In particular, the very existence of our commercial and industrial customers, which comprise approximately 59% of our sales base, depends on UI’s ability to provide reliable service. 5 The following table summarizes the MWHR sales mix for the period 2008-2014: Table 2: MWh Sales Mix for the Period 2008-2014 Customer Class 2008 2009 2010 2011 2012 2013 2014 Original Budget Forecast Residential 39.67% 39.80% 40.30% 40.80% 41.30% 41.90% 43.20% Commercial 47.55% 48.60% 48.10% 47.70% 48.70% 48.10% 48.40% Industrial 12.05% 10.80% 10.80% 10.70% 9.10% 9.10% 7.43% Street Lighting 0.73% 0.80% 0.80% 0.80% 0.90% 0.90% 0.96% Total 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 99.99% The following table summarizes the breakdown of customers by class for the period 2008-2014: Table 3: Breakdown of Customers by Class for the Period 2008-2014 Customer Class 2008 2009 2010 2011 2012 2013 2014 Original Budget Forecast Residential 293,009 292,836 292,670 290,651 289,366 287,519 286,019 Commercial 30,392 30,432 30,493 30,439 30,438 30,195 29,932 Industrial 1,133 1,142 1,091 1,031 1,033 1,022 967 Street Lighting 1,207 1,344 1,202 1,163 1,137 1,109 1,109 Total 325,741 325,754 325,456 323,284 321,974 319,845 318,027 The following table summarizes transmission and distribution system miles by construction type and voltage level: Table 4: Transmission and Distribution System Miles by Construction Type and Voltage Level Circuit Miles Construction Type 15kV or less 115kV 345kV & Higher Tree Wire 2408 0 0 Non-Tree Wire 263 93.2 11.1 Aerial Cable 210 0 0 Self-Supporting Cable 1 0 0 Underground Cable* 672 17.1 11.2 Totals 3554 110.3 22.3 6 Definitions: Tree Wire: All primary wire used in open wire construction that is covered with a 10/64 polyethylene coating. Non-Tree Wire: All primary wire used in open wire construction that either has no insulation (bare) or is covered with a material having little or no insulation value. Aerial Cable: Shielded primary cable suspended from a messenger attached to poles. Self-Supporting Cable: Unshielded insulated primary wire triplexed around a messenger attached to poles. *Underground Cable Distribution: Includes both shielded primary cable in a splicing chamber and duct system, and direct buried cable. Transmission: Includes pipe type, gas insulated, fluid filled and solid dielectric in a splicing chamber and duct system. *Secondaries and services excluded 4. Vegetation Management The United Illuminating Company remains committed to providing high levels of reliability, while simultaneously ensuring customer safety and satisfaction, and controlling cost. In January of 2014, UI began an 8-year Enhanced Tree Trimming Program with the goal of establishing a Utility Protection Zone (UPZ) around all of its primary distribution lines. Beyond the UPZ planned circuit miles program, the Company implements the following vegetation management programs to maintain or enhance the reliability of the electric distribution system: Hazardous Trees: The Hazardous Tree program requires the complete removal to ground of all identified trees. Hazard trees are identified in several ways including; UI vegetation management resources, contractor permissions personnel, tree trim crews, town tree wardens and customers. The hazard tree removal program is designed to remove trees identified as dead, dying, diseased or structurally defective and located outside of the normal trim area, but pose a potential hazard to UI facilities Vine Management: Vine Management is the removal of various vines from poles and guy wires including the ground cut, removal, chip and disposal of debris. Distribution Rights-Of Way Line Clearance: Rights-of-Way Line Clearance is the removal of overgrowth on the distribution right-of ways. Typically, such work is identified and generated during cycle maintenance and through ROW inspections. 7 Distribution Line Clearance Specification – UPZ The Enhanced Tree Trimming specification is the only UI vegetation management specification. The Distribution Line Clearance Specification (DLCS) establishes vegetation management clearance within the UPZ in a rectangular area extending horizontally for a distance of eight feet from any outermost electrical conductor or wire installed from pole to pole and vertically from the ground to the sky. Desirable low height or ornamental trees that are already in the zone or those that are planted under the Right Tree – Right Place program will remain. Compatible trees and shrubs listed in the State Vegetation Management Task Force Report or added by the DEEP may remain in or may in the future be planted within the UPZ. The DLCS creates greater distance between the vegetation and conductor in order to reduce the likelihood that vegetation would impact the electric system during extaordinary weather events. This specification reduces the amount of vegetation that may come in contact with the electric infrastructure and will improve the overall performance of the electric system. On November 1, 2013 the Company submitted its ETT plan to the PURA for review. The plan addresses how the work is being scheduled and prioritized for optimum effectiveness. In addition, the plan contains reporting requirements to UI management and the PURA, the latter of which will include spending, miles trimmed, consent and objection metrics, and the program’s impacts on reliability on a circuit and annual system basis. UI prepared this plan using Reliability Centered Maintenance principles and the following considerations: 1. Prioritized the worst performing circuits based on vegetation related outage performance (SAIFI) 2. Incorporated a focus on State and municipal priority locations 3. Made adjustments to the plan to accommodate excessive vegetation growth based on the timing of the previous cycle 4. Made additional adjustments to meet yearly budget targets. During the first 6 months of 2014, UI: Worked with its contractor to inform and train the Work Planners and tree crews about the new program. Developed and implemented a comprehensive communication strategy. Held public information sessions in all 17 communities. Updated all of its customer contact collateral – brochure, consent form, notification letter and door hanger Began pruning and removing trees using the new UPZ specification in the towns of Bridgeport, Hamden, Orange and Shelton 8 Based on the success of the pilot program, UI moved to full program implementation in July. UI’s strategy is to obtain abutting property owner consent for all non-emergent tree work far enough in advance to optimize the use of the line clearance crews. This method requires UI’s contractors to begin the notification process at least three months in advance to achieve this strategy and fully implement the requirements of Public Act 14-151. Transmission Vegetation Management Program Transmission lines are maintained on a four year cycle (approx. 25% per year). The cycle based tree and brush work is supplemented with inspection of 100% of the overhead transmission lines. UI’s Transmission Vegetation Management Program (TVMP) complies with the North American Electric Reliability Corporation (NERC) FAC-003-1 Standard, covering all the transmission lines operated at 200kV and above, and specific lower voltage lines designated by the Northeast Power Coordinating Council (NPCC) as being critical to the reliability of the electric system in the region. Transmission line ROW are inspected annually by foot patrol for the purpose of identifying vegetation conditions that could encroach the vegetation to conductor clearance requirements, impact electric service reliability or create a hazard to the public. UI has implemented the use of Light Detection and Ranging (LiDAR) imaging and processing capabilities on a 2 year cycle to improve the inspection program. The LiDAR survey from 2012 identified vegetation conditions that are being prioritized and scheduled with the annual planned trimming. Any vegetation conditions which might immediately affect operation or maintenance of the lines are addressed immediately. All data from the inspections is captured electronically and then imported into a tracking database. Reports are generated from this database to assist in developing work schedules and tracking work to completion. The UI Line Clearance Arborist re-inspects all reported vegetation items, develops the maintenance trimming schedule, prioritizes work and coordinates with the railroad entities. Field audits are completed to ensure the work performed meets the TVMP requirements. UI continues to work with local tree wardens, as well as civic and professional groups, to help educate customers about the proper selection and care of trees that may be planted near UI’s electric facilities. In addition, safety brochures are distributed annually through bill inserts, and other events are held to educate the public on the dangers associated with energized wires and the importance of having qualified tree contractors or UI line clearance crews remove hazardous tree growth. We believe that we can continue to provide safe, reliable service in a cost-effective manner by working together with our customers in matters of line clearance and vegetation management. UI’s Vegetation Management Specification is appended to this document as Attachment 2. 9 5. Maintenance Practices The primary goal of Reliability Centered Maintenance (RCM) is to keep equipment operating properly while minimizing total maintenance costs. RCM uses proven predictive maintenance techniques to schedule cost effective maintenance only when needed (based on experience, inspection and testing results, manufacturers’ data, etc.) to prevent critical failures. It should be understood that the term maintenance, as used at UI, includes both inspection and maintenance activities. UI crews perform construction, inspection and maintenance activities, thereby developing a balanced, well-rounded work force and minimizing costs. UI employees perform the majority of maintenance work on the distribution system, with the exception of tree trimming, pole inspection and treatment, and street light repair/replace, which are done by outside contract crews. During peak constructions periods, outside contract crews may augment UI crews on construction projects. Outside contract crews are also used on UI’s transmission system for both major construction and maintenance functions. Maintenance practices in the following sections are organized as noted below: Construction / Maintenance Work Force Organization Equipment Maintenance by Area Overhead Distribution System Underground Distribution System Overhead Transmission System Underground Transmission System Substations Vegetation Management (Attachments 2) General 5.1. Construction and Maintenance Workforce Organization The following is a staffing summary by section and grade of UI’s construction and maintenance departments (as of August 8, 2014): 10 Table 5: Construction and Maintenance Work Force Organization Department Position Manager, System Maintenance Maintenance Engineer System Maintenance Civil/Structural Engineer Total System Maintenance Manager, Vegetation Management Line Clearance Arborist & Technician Vegetation Management Line Clearance TVM Lead Total Vegetation Management General Manager - Construction Operations Senior Operations Specialist Sr Principal Analyst Manager – Power Delivery Lead Supervisor - Power Delivery Supervisor - Power Delivery Scheduler - Power Delivery Line Worker 1st Class & Sr. Line Worker 1st Class Line Worker 2nd & 3rd Class (Apprentice) Line Restoration Leader Power Delivery (PD) Line Group Leader Cable Splicer 1st, 2nd & 3rd Class Underground Working Leader Underground Inspector Manager - UG Construction Supervisor - UG Construction PD -UG Equipment Specialist & Helper A Business Systems Analyst Administrative Clerks - PD Total Power Delivery (PD) Manager - T&S Lead Supervisor - T&S Supervisor - T&S Scheduler - T&S Substation Utility Worker Substation Maintenance Worker Substation Electrician Const. & Maint. Worker Transmission & Substation (T&S) Substation Electrician 1st Class Substation Electrician 2nd Class Substation Electrician 3rd Class Substation Electrician Specialist Glove Lab Technician Administrative Clerks - T&S Total Substation (T&S) Test Manager Test Supervisor Lead Test Engineer Test Department Test Engineer Test Technician Communication Engineer NERC Coordinator Total Test Total Construction & Maintenance Work Force 11 Number 1 7 1 9 1 5 1 7 1 1 1 1 3 6 2 33 20 8 38 12 2 3 2 2 10 2 3 150 1 2 8 1 4 2 20 3 6 0 10 1 1 59 1 2 2 0 15 1 1 22 247 5.2. Maintenance of Assets and Systems by Area The Company uses a software application called Maximo® to manage the maintenance of equipment. Maximo® serves many functions, as it contains historical asset record data along with an asset registry, and also generates work orders associated with preventive and corrective maintenance plans. Several other databases are utilized in conjunction with Maximo® for implementing the RCM plan. These databases are linked where possible. UI visually inspects its overhead equipment in accordance with defined RCM programs and whenever work is being performed on the system. The major components of UI’s Overhead Distribution System are identified below. Details of maintenance and inspections are noted in each asset category. It should be noted that, in the course of any inspection and maintenance process described in this report, all hazards, damage, and other abnormal conditions affecting equipment on the UI system, are immediately reported to appropriate supervision, who then analyze the situation and coordinate corrective actions. Also, additional attention is given to any equipment as deemed appropriate by Electric System Maintenance. The following tables list maintenance practices for major components of the overhead and underground distribution and transmission systems 5.2.1. Table 6: Maintenance Practices, Overhead Distribution System Category Sub Category Frequency Task Description During pole inspection and when working on pole Visual Inspection 6 Years and when working on pole Above ground line visual inspection Poles, =>10 years old 6 Years and when working on pole Visual inspection above and below the ground line. Internally treated for decay below the ground line if necessary. Wire, All During pole inspection and when working on pole Visual Inspection Wire, 3 phase lines Annual Infrared Inspection Wire, Single phase lines Performance Based Infrared Inspection General Poles, <10 years old Poles and Ancillary Equipment Overhead Wire 12 Notes Includes poles, ancillary equipment, wire and cable, hardware, fault indicators, lightning arresters, switches and other equipment associated with an installation. Below ground line treatment involves excavating to a depth of 18 inches and treating the pole below grade Problems reported in the Circuit Interruption Reporting System are reviewed for further investigation and corrective action. Table 6: Maintenance Practices, Overhead Distribution System (continued) Category Sub Category Task Description Notes Upon Installation Dielectric test of insulation integrity A dielectric test is performed whenever a section is replaced or a cable termination or splice is replaced. Paper Insulated Lead Covered (PILC), 13.8kV Circuits As above for Aerial Cable In addition to a visual inspection when working on a pole. The majority of this type of cable has been replaced on a programmatic basis. Aerial PILC Cable still remains attached to bridge overpasses where splice chambers and ductline are required to replace it 3 phase lines Annual Infrared Inspection 3 phase lines Annual Infrared Inspection Single phase lines Performance Based Infrared Inspection All 10 Years Replace All Frequency Aerial Cable Insulators, Lightning Arresters, Hotline Clamps, Stirrups and Splices Switches, Disconnects and Fused Cutouts Overhead Fault Indicators Pole Mounted Transformers Utilization Transformers See Notes Step-down Transformers Monitored as Required Electronic monitoring devices monitor phase loading Annual Signal tested through SCADA Annual Visual Inspection Radio Controlled Pole Mounted Capacitor Banks Transformers whose PCB content is unknown, are loaded at or near nameplate ratings and those found in poor condition have been identified and are included for replacement in the Company's 10 Year Plan Fixed Annual All Annual Visual Inspection Infrared Inspection 13 Table 6: Maintenance Practices, Overhead Distribution System (continued) Category Pole Mounted Voltage Regulators Pole Mounted Reclosers Sub Category All All Frequency Task Description Notes Annual Operationally tested and inspected. Operations counter recorded, voltage and settings confirmed with asset records Action taken based on current RCM criteria and data review. Annual Infrared Inspection 2 Times Per Year Gas pressure, Ambient temp, Operations counter recorded, batteries tested and recorded for asset tracking. Annually Oil Insulated Street Lights 5.2.2. Infrared Inspection Internal and Operational testing 7 Years Failure Repair or Replace as required 7 Years Relamp, replace photocell and perform general maintenance All Based on current RCM criteria Failures are reported by customers, police and UI personnel. Table 7: Maintenance Practices, Underground Distribution System Category Splicing Chambers and Secondary Network Vaults Sub Category General Frequency During inspection and when working at a specific location Task Description Visual Inspection of electrical components and hardware, and structural elements Notes 10 Years Visual inspection of the electrical and physical condition of the location and equipment contained therein. Equipment includes grounding, cable racks, cable supports, covers, roofs, frames and other structural elements. Network Protectors Annual Network Transformers and Switches Annual Network Transformers Visual Inspection including protector status, nitrogen blanket pressure and overall condition assessment Visual Inspection including oil level inspection and recording and overall condition assessment 14 Table 7: Maintenance Practices, Underground Distribution System (continued) Category Sub Category All Primary Cable Wire and Cable Primary Cable, Paper Insulated Lead Covered (PILC), 13.8kV Circuits Solid Dielectric Primary Cable Distribution Cable Padmounted Transformers and Junction Enclosures Frequency When any work to the electrical insulation of a cable is performed Task Description Dielectric Testing Some of the PILC has been replaced on a programmatic basis. As above for Primary Cable As above for Primary Cable During inspection of the splicing chamber or vault Visual inspection for safety hazards, security, electrical integrity and damage PMH & G&W Annual Visual inspection for safety hazards, security, electrical integrity and damage PME & Vista 2 Years Visual inspection for safety hazards, security, electrical integrity and damage Transclosures Transformer Vaults Visual inspection for safety hazards, security, electrical integrity and damage 5 Years Visual inspection for safety hazards, security, electrical integrity and damage 3 Years Annual CustomerOwned Facilities Transformer Cages On-going program 15 Replacement of remaining PILC cable will be done based on performance and potential failure impact on system reliability. Replacement is performance based Visual inspection 5 Years Padmounted Switches Notes Second physical barrier installed on all locations Abnormal conditions are brought to the customer's attention for remediation and work is scheduled appropriately These installations are being replaced based on prioritization established from the inspection program, when the customer’s service is abandoned, at the customer’s request or when system upgrades are required. 5.2.3. Table 8: Maintenance Practices, Overhead Transmission System Category Sub Category All Frequency 2 Years Towers Connectors, Conductors, Terminations and Insulators Wood 6 Years Cathodic Protected Steel Structures 2 Years All Substation Components All Foundations Right-of-Ways (ROW) Task Description Notes Inspected by outside contractors. Inspection includes items such as ground conductor integrity, paint condition, installation of proper signage, etc. Ground level inspection of the structure. Test and review results for proper operation of the passive cathodic protection system Climbing inspections are performed as required. 2 Years Visual inspection 2 Years Visual inspection by air (helicopter) which includes an infrared thermography inspection Conditionbased Corona Imaging Semi-annual 2 Years Cathodic Protected Caissons 2 Years Vegetation Annual Light Detection and Ranging Inspection (LiDAR) 2 Years 16 Visual and thermographic inspection Visual inspection of condition Test and review results for proper operation of the passive cathodic protection system Visual Inspection Identify and measure vegetation clearances to conductors on and along UI ROW 5.2.4. Table 9: Maintenance Practices, Underground Transmission System Category Sub Category Frequency Task Description Annual Visual inspection All Components When working in a specific location Visual inspection of accessible portions Terminations Biannual Visual and Thermography Inspection Termination Support Structures Cable and Cable Terminations Splicing Chambers Cable Pressurization and Pumping Systems High Pressure Fluid Filled (HPFF) Cable and Terminations Low Pressure Fluid Filled (LPFF) Cable and Terminations Solid Dielectric Cable 3 Years 2 Years Annual High Pressure Fluid Filled (HPFF) and Solid Dielectric Cable Lines 5 Years, during cable inspection or when working in a specific location Low Pressure Fluid Filled (LPFF) Lines 2 Years 345kV Solid Dielectric Lines in ConnDOT Right-ofWays In accordance with the requirements of the Conn DOT Bridge Inspection Manual All Monthly Dielectric Fluid 3 Years High and Low Pressure Set points 2 Years Annual Active Cathodic Protection Systems Monthly 17 Fluid is tested for dielectric quality and dissolved gasses. Visual inspection Condition assessments are done when inspections indicate further action, which includes an accelerated systematic evaluation of the present condition and future maintenance/replacement requirements for the underground infrastructure. Visual inspection and pressure readings are recorded and reviewed These are the sample points for the HPFF Cable noted above Tested and Calibrated Output is verified at intermediate test points and at the underground cable extremities in the substation. Visual condition assessment. Voltage and current values are recorded and reviewed. Notes Additional inspections are performed through monthly substation patrol inspections. Additional inspections of accessible equipment are performed during various substation inspections. 5.2.5. Table 10: Maintenance Practices, Substations Category Bulk Substation current carrying equipment Distribution Substation current carrying equipment Stationary Battery Systems Sub Category Outside equipment and equipment accessible within the building All Installations Frequency Transformers and Reactors Visual inspection of overall condition including electrolyte levels (if applicable), voltage and current levels and physical condition of components Conductance and voltage testing and trending Oil quality and Dissolved Gas Analysis (DGA) is performed and reviewed Visual Inspection Monthly Annual Transmission Class Circuit Breakers 4 Years Distribution Substations Condition based Bulk Oil (OCB) 2 Years Gas Insulated (SF6) Gas Insulated (SF6) Infrared Thermography Inspection Includes exterior and interior components. Action taken based on current RCM criteria and data review. Annual Monthly Bulk and Transmission Substations Notes Bi-annual Annual All Task Description 10 Years Power factor and excitation testing for the integrity of insulating materials, windings, bushing insulation. Load Tap Changer operation. Operational testing of external components is performed to ensure the proper operation of alarms and monitoring equipment. Timing and motion, power factor testing and oil quality analysis Level 2 (major), 10 year frequency: Outage required, isolating switches opened and grounds applied as required, Level 1 Items plus Timing and Motion, Alarm points, Contact Resistance Level 1 (minor) 5 year frequency: Thorough visual inspection, alarm settings, hydraulic fluid level and gas moisture analysis 5 Years 18 In accordance to industry accepted standards and applicable NERC / NPCC requirements Distribution substation transformers are tested only if infrared inspections, oil testing or a visual inspection detect an issue Internal inspections and overhauls are condition based but typically will not exceed the manufacturer’s recommendation Table 10: Maintenance Practices, Substations (continued) Category Distribution Class Circuit Breakers Sub Category Frequency Oil (OCB) 6 Years Air Magnetic (ACB) Vacuum Interrupters (VCB) Task Description Per manufacturer’s recommendation or based on Best Industry Practice 7 Years 10 Years Monthly and whenever a station is visited Includes testing of security systems, security inspections of interior and exterior facilities, fire-extinguisher inspections, first-aid kit inspections and similar tasks Security and Safety Maintenance and testing of security components and communications Annual Buildings and Structures General Notes Facilities are cleaned, operation counts are taken and minor maintenance activities are performed Gutters and downspouts are inspected and cleaned Substation roofs are inspected Monthly Annual Roof Systems 4 Years 19 NERC standard CIP006 requires periodic testing of the system. Performing this testing with our existing perimeter alarm testing utilizes the same resources to perform both tests. Selected substations Table 10: Maintenance Practices, Substations (continued) Category Sub Category Frequency Capacitor Bank All 7 Year cycle CCVT Secondary Voltage Trending All 3 Year cycle Voltage Reduction All Bulk Distribution Substations Protective Systems and Substations as defined by North American Electric Reliability Council (NERC) Standards and Northeast Power Coordinating Council (NPCC) Protective Systems Special Protection Systems as defined by North American Electric Reliability Council (NERC) Standards and Northeast Power Coordinating Council (NPCC) Non-Bulk (Distribution) Stations Task Description Annual As specified in NERC Standards Electrical integrity testing and visual inspection, replacement of cans or blown fuses, VBM ductor and hypot test, general cleaning by Substation Measure and recording secondary voltage to identify problems while the failure is in its infancy. Inspect the CCVT secondary junction box and internal components. Voltage reduction system communication testing. Verify 2.5% and 5% voltage reduction can be initiated from control center. NERC Standards include: PRC-005-1: “Transmission and Generation Protection System Maintenance and Testing” PRC-008-1: “Implementation and Documentation of UFLS Equipment Maintenance Program” PRC-011-0: “UVLS System Maintenance and Testing” As specified in NPCC Directories Directory #3 “Maintenance Criteria for Bulk Power System Protection.” NPCC As described in NPCC Directory #7 “Special Protection Systems”. As described in PRC-012-0: “Special Protection System Review Procedure” and PRC-017-0: “Special Protection System Maintenance and Testing” NERC Based on removal program 20 Test and adjust protective relaying as required Notes Systems include protective relaying, batteries and battery chargers, circuit breakers, transformers and protective relaying telecommunication s These protection systems are designed to detect abnormal system conditions, and take corrective action other than the isolation of faulted elements. This suspended based on current removal schedule 5.2.6. Vegetation Management The Vegetation Management Plan is described in Section 4. The current “Vegetation Management Specification” for 2014 through 2021 is included as Attachment 2. 5.2.7. General Employee awareness of system conditions constitutes a vital source of information for UI to address maintenance requirements. Employees, as they travel to their work locations throughout UI’s territory, are encouraged to be observant and report any abnormal conditions to Electric System Operations & Maintenance so that appropriate action can be taken. This information, along with reports via telephone or written communication from our customers or others regarding abnormal system conditions, is captured in the computer-based Customer Request System. It is then forwarded to Electric System Operations & Maintenance for investigation and resolution, as required. The trouble conditions and subsequent resolution is captured in the customer call system, SAP. 6. Summary of Updated Maintenance Practices In 2014 the Company conducted a comprehensive review of its RCM plans to determine if the current activities and cycle for each plan was being implemented effectively and the work activities were being done efficiently. A team of subject matter experts involved in routine system maintenance activities reviewed each RCM plan utilizing their knowledge of inspection and testing techniques, manufacturers’ recommendations, utility best practices and regulatory compliance requirements. The review took into consideration maintenance inspection and testing techniques that have evolved over the years with changes in technology, tools, industry wide learning of equipment maintenance history, and monitoring capabilities. We found that while most of the plans have incorporated these changes, all plans needed a review utilizing the same methodology used in the creation of the RCM plans originally with the goal of performing only the necessary maintenance and minimizing cost. Inspection and maintenance is currently being performed as described in earlier sections. The following tables summarize the recommended changes to the maintenance cycle and practices for the major components of the T&D system. These changes are currently being implemented and will be fully incorporated into the maintenance plans in 2015. The Company continues to operate and maintain its system generally using the same practices that were in place as of the Maintenance Plan dated December 17, 2013. The maintenance practices in use are defined in our Reliability Centered Maintenance program, which has been in effect for approximately sixteen years. The Company continuously looks for opportunities to improve both operational performance and cost efficiency. In response to Docket No. 13-01-19, “Application of The United Illuminating Company to Increase Rates and Charges”, PURA approved $100 million for an 8 year plan for vegetation management during 2014-2021. This system hardening is based on Enhanced Tree Trimming 21 (ETT) practices as presented in the State’s Vegetation Management Task Force (SVMTF) report. The major components of UI’s proposed program are: 1. DLCS will be UI’s new specification, creating an eight-foot side clearance ground to sky, retaining desirable low height or ornamental trees within the zone or those that are planted under the Right Tree – Right Place program. Additionally, the Company will identify and remove whole or parts of hazardous trees from outside of the zone that could fall causing damage to utility infrastructure, facilities or equipment. 2. UI will document and track all objections, requests for modification and decisions made by municipal tree wardens and the State Department of Transportation through the full execution of Public Act 14-151 that cause nonconformities, or areas where UI is not able to meet these specifications within and outside of the Utility Protection Zone (UPZ). Instances of outages caused by nonconforming trees will be documented and considered a reportable performance attribute. 22 6.1. Overhead Distribution System Changes Category Sub Category Pole Inspection Wood Poles Infrared Inspection Wire, 3 Phase lines, Single Phase lines, and Equipment Pole Mounted Reclosers All Change Rationale for Change In 2014 all poles in the territory (UI & AT&T) have been visually inspected. 2015-2018 poles requiring ground line inspection will be excavated to a depth of 18 inches and remedial treatment applied. All wood distribution poles will continue to be inspected on a 6 year cycle. The scope of the inspection has expanded to incorporate primary, secondary and service wires and primary switch configuration. The scope of the inspection program now identifies and resolves issues with missing grounds. Based on industry reporting criteria and action levels a 5°C change was selected. Estimated reduction (up to 30%) in reportable hotspots and follow-up repair costs minimal risk. Improved efficiencies. Increase in efficient use of resources by not requiring multiple crews to visit a recloser for tasks that can be performed together by one crew. Reporting criteria changed from 15°C to 20°C rise compared to a reference temperature. 3 times per year to 2 times per year. Lineman craft to perform inspection and maintenance. 6.2. Underground Distribution System Changes Category Padmounted Switches Sub Category PMH & G&W Change Rationale for Change Select manufacturer models with known failure modes have been eliminated or corrected. The inspection and maintenance now incorporates specific tasks to identify equipment conditions. Follow-up maintenance activities are scheduled address abnormal conditions. Cycle change from Biannual to annual. 6.3. Overhead Transmission System Changes Category Towers, Conductors, Terminations, Insulators and Foundations Sub Category All Change Rationale for Change Cycle change from annual visual inspection to every 2 years In consideration of a separate annual vegetation inspection, a 2 year cycle for aerial LiDAR survey inspection, and aerial infrared and corona testing, this inspection category can be extended. The cycle change has no associated risks to system reliability since inspectors are conducting a visual foot inspection and reporting abnormal conditions. A more in depth inspection will be conducted every 2 years with tower and foundation condition assessments. 23 6.4. Underground Transmission System Changes Category Cable and Cable Terminations Splicing Chambers Sub Category 345kV Solid Dielectric Cable Low Pressure Fluid Filled (LPFF) Lines Change Cycle change from 5 years to annual. The Company continues to conduct annual inspections of the cable support systems. As previously reported, findings from previous inspections articulated a need for a thorough forensic assessment of the environmental damage evident upon racking hardware and clamps in the 345kV splice chambers. Cycle change from annual to 2 years. 24 Rationale for Change The degradation observed in the inspections of previous years appeared to continue to an extent that strongly suggested a need for specialized assistance in assessing the evidence and determining its cause. In this way, the affected components could be responsively redesigned and more durable substitutes provided by the Original Equipment Manufacturers. Inspection frequency is expected to continue at one per year, at least until the issues attending this problem have been demonstratively ameliorated. The Company has conducted the annual inspections with the OEM and continues to work with them in resolving this issue. Eliminate annual inspection; retain combined inspection/oil sampling every 2 years. Splicing chambers were found to be in good structural condition from recent inspections. Low risk based on engineering experience and knowledge of cable system. 6.5. Substation Changes Category Capacitor Bank Transformers and Reactors Transmission Class Circuit Breakers Sub Category Change All Cycle Change from 4 year to 7 year Bulk and Transmission Substations Cycle change from 3 years to 4 years Gas Insulated (SF6) Cycle change from 6 years to 10 years for full inspection and 5 years for gas analysis. Create 2 different levels of maintenance tasks. 25 Rationale for Change During breaker maintenance perform critical tasks only (maintenance Task Description). Other maintenance is driven by issues (blown fuses, alarms, substation patrol visual). Coordination with breaker maintenance eliminates switching being done twice on the same feeder. Also, extension of cycle will result in cost savings, although off-cycle corrective maintenance may be require as they do currently. Based on industry best practices, historical maintenance records and continued annual predictive oil analysis the cycle has been extended with no associated reliability impacts Timing and motion of the newer GCBs may be extended to a less frequent cycle due to excellent manufacturing and operating tolerances. Level 1 (minor) 5 year frequency: Thorough visual inspection, alarm settings, hydraulic fluid level and gas moisture analysis Level 2 (major), 10 year frequency: Outage required, isolating switches opened and grounds applied as required, Level 1 Items plus Timing and Motion, Alarm points, Contact Resistance 6.5. Substation Changes(continued) Category Distribution Class Circuit Breakers CCVT Secondary Voltage Trending Buildings and Structures Sub Category Change Air Magnetic (ACB) Cycle change from 6 years to 7 years All Cycle change from annual to 3 years Roof Systems Cycle change from 3 year to 4 year. Annual gutter cleaning at selected substations. 26 Rationale for Change Extend cycle to 7 years, in consideration of location/environment (maybe not for all breakers) and existing condition concerns. Provide training for substation electricians to improve their knowledge so maintenance activities are being performed properly. Create a new maintenance Job Plan. - Create a 1 or 2 page Job Plan with a specific breaker service pamphlet. The service pamphlet can be reused throughout the year and ensure the same service is performed to all similar breakers. Extend cycle as the majority of the older potentially problematic CCVT's have been replaced as part of a capital program. Retain annual CCVT trending for station with problematic units until replaced. Evaluate a system-wide project to ensure all CCVT's are monitored accurately via SCADA, possibly through a device which could be installed at the base of each CCVT to eliminate voltage drop concerns. Extension to 4 years would not affect warranty on roofs per TREMCO discussion. Possible reactive maintenance costs if failure occurs during additional year before inspections - this is felt to be a very low risk due to generally newer age of substation roof systems from recent and ongoing replacements. 6.5. Substation Changes (continued) Category Sub Category Bulk Substation Feeder Protective Systems (Relay Testing) Change Rationale for Change Cycle change from 6 years to 8 years Extend cycle to every 8 years to align with 2nd cycle of transmission relay testing. Gaining efficiency by coordinating with other relay testing at the same station. If a relay had a problem it may go undetected for a longer period compared with the current maintenance practice; however, this is minimized with having both phase and ground relays with a much lower probability of something common to both failing together. Transformer and Distribution Bus (Electromechanical) Cycle change from 4 years to 8 years Transformer and Distribution Bus (Microprocessor) Cycle change from 6 years to 8 years Distribution Low Voltage Substation Feeder Suspend, evaluate low voltage substation removal program annually 27 Extend cycle to every 8 years to align with 2nd cycle of transmission relay testing. Gaining efficiency by coordinating with other relay testing at the same station. If a relay had a problem it may go undetected for a longer period compared with the current maintenance practice; however, this is minimized with having redundant primary and secondary protection schemes with a much lower probability of both schemes failing simultaneously. Evaluate annually based on LVSS removal program schedule. If the current LVSS removal plan is executed in years currently planned for, or if accelerated, feeder relays at these stations will not require any further testing. Reduction in O&M costs in consideration of recent test cycle and LVSS decommissioning plans. 6.6. Vegetation Management Changes Object Vegetation Management Change Rationale for Change The Company’s specification, DLCS, for enhanced tree trimming establishes vegetation management within the "Utility Protection Zone" (UPZ) which is the rectangular area extending horizontally for a distance of eight feet from any outermost electrical conductor or wire installed from pole to pole and vertically from the ground to the sky through a four year cycle. The specification requires the pruning and removal of trees and limbs within the utility protection zone and retaining desirable low height or ornamental trees that are already within the zone or those that are planted under a Right Tree – Right Place program. Additionally, the Company identifies and removes hazardous trees from outside of the zone that could fall causing damage to utility infrastructure, facilities or equipment Docket No. 12-01-10 PURA Investigation Into The Tree Trimming Practices of Connecticut Utility Companies 7. List of Attachments 1. UI Service Territory Map 2. Vegetation Management Specification, December 2013 28 ATTACHMENT 1 The United Illuminating Company Service Territory Map Fairfield County New Haven County Bridgeport Easton Fairfield Shelton Stratford Trumbull Ansonia Derby East Haven Hamden Milford New Haven North Branford North Haven Orange West Haven Woodbridge Vegetation Management Specification ATTACHMENT 2 THE UNITED ILLUMINATING COMPANY VEGETATION MANAGEMENT SPECIFICATION Revised November 2014 Vegetation Management Specification Table of Contents Introduction ........................................................................................................................................................................32 Scope ......................................................................................................................................................................................33 Regulations ..........................................................................................................................................................................33 Evaluation ............................................................................................................................................................................34 A. Distribution Line Clearance Specification– Utility Protection Zone (DLCS) .......................................34 B. Other Clearance and Operational Requirements ..........................................................................................37 C. Substation Vegetation Maintenance Requirements .....................................................................................38 D. Transmission Rights-of-Way Clearance Requirements ..............................................................................38 E. Distribution Rights-of-Way Clearance Requirements .................................................................................39 Workflow Management ..................................................................................................................................................39 Methods/Practices ...........................................................................................................................................................40 Contractor Responsibilities...........................................................................................................................................42 Glossary ................................................................................................................................................................................46 General Worker Guidelines ...........................................................................................................................................48 Customer Consent Process ............................................................................................................................................49 Exhibit A ...............................................................................................................................................................................54 Exhibit B ...............................................................................................................................................................................55 Exhibit C................................................................................................................................................................................56 Exhibit D ...............................................................................................................................................................................57 Exhibit E................................................................................................................................................................................58 Exhibit F ................................................................................................................................................................................59 Exhibit G ...............................................................................................................................................................................60 Exhibit H ...............................................................................................................................................................................61 Exhibit I .................................................................................................................................................................................62 Exhibit J .................................................................................................................................................................................63 31 Vegetation Management Specification Introduction The United Illuminating Company remains committed to providing high levels of reliability, while simultaneously ensuring customer safety and satisfaction, and controlling cost. In 2013, the Company completed the sixteenth year of the Performance-Based tree trimming program. All customer requests and concerns about tree conditions are investigated and tree work is performed as required to eliminate those concerns whether from an electric safety or reliability point of view. From 1997 to 2013 the overhead distribution line clearance program consisted of a split four-year and eight-year cycle for planned tree trimming. The three-phase portion of the system was trimmed on a fouryear cycle, while the single-phase portion of the system was trimmed on an eight-year cycle or where performance triggered more frequent trimming. Any single-phase portion of the system that experienced two or more tree related outages in a 36-month period was, at a minimum, trimmed to minimize the potential for future outages. Other system modifications, such as reconductoring bare wire with covered conductor, may also be performed to help minimize the potential for future tree related outages. In addition, tree work is completed at new construction sites as needed. Beyond the Line Clearance planned circuit miles program, the Company implements the following vegetation management programs to maintain or enhance the reliability of the electric distribution system: Hazardous Trees: The Hazardous Tree program requires the complete removal to ground of all identified trees. Hazard trees are identified in several ways including; UI vegetation management resources, contractor permissions personnel, tree trim crews, town tree wardens and customers. The hazard tree removal program is designed to remove trees identified as dead, dying, diseased or structurally defective and located outside of the normal trim area, but pose a potential hazard to UI facilities. The process involves identification of hazardous trees through the circuit trimming program, reliability engineer, and Line Clearance Arborist and Technicians followed by communications with customers, CDOT and/or municipalities to inform them of the hazard and to obtain their consent to remove. Vine Management: Vine Management is the removal of various vines from poles and guy wires including the ground cut, removal, chip and disposal of debris. Distribution Rights-Of Way Line Clearance: Rights-of-Way Line Clearance is the removal of overgrowth on the distribution rights-of ways. Typically, such work is identified and generated through ROW inspections and maintenance trim cycles. 32 Vegetation Management Specification Transmission lines are trimmed on a four year cycle (approx. 25% per year). The cycle based trimming is supplemented with inspection of 100% of the overhead transmission lines. UI’s Transmission Vegetation Management Program (TVMP) complies with the North American Electric Reliability Corporation (NERC) FAC-003-1 Standard, covering all the transmission lines operated at 200kV and above, and specific lower voltage lines designated by the Northeast Power Coordinating Council (NPCC) as being critical to the reliability of the electric system in the region. Transmission line ROW are inspected annually by foot patrol for the purpose of identifying vegetation conditions that could encroach the vegetation to conductor clearance requirements, impact electric service reliability or create a hazard to the public. UI continues to work with local tree wardens, as well as civic and professional groups, to help educate customers about the proper selection and care of trees that may be planted near UI’s electric facilities. In addition, safety brochures are distributed annually through bill inserts, and other events are held to educate the public on the dangers associated with energized wires and the importance of having qualified tree contractors or UI line clearance crews remove hazardous tree growth. We believe that we can continue to provide safe, reliable service in a cost-effective manner by working together with our customers in matters of line clearance and vegetation management. Scope The scope of this specification is to provide requirements and guidelines for line clearance pruning and the removing of trees, brush and other vegetation in close proximity to overhead electric distribution facilities located on public and/or private rights-of-way. General: The Company: The United Illuminating Company (UI) Contractor: The firm that has been awarded a formal contract to perform work Regulations All work practices and definitions, except as otherwise specified herein, shall be in accordance with all applicable Industry, Federal, State and Local laws and regulations, approved standards and safety practices. These include all applicable sections of the following but are not limited to: OSHA 29CFR 1910.269 Electric Power Generation, Transmission & Distribution NERC FAC-003-1 Transmission Vegetation Management Program or current standard ANSI A300 “Standard Practices for Trees, Shrubs and Other Woody Plant Maintenance” ANSI Z133.1 “Pruning, Trimming, Repairing, Maintaining and Removing Trees, and Cutting Brush – Safety Requirements” NESC Connecticut General Statutes Department of Transportation Local Ordinances “Pruning Trees Near Electric Utility Lines” by Dr. Alex L. Shigo Best Management Practices, Utility Pruning of Trees. 33 Vegetation Management Specification Evaluation Each tree must be evaluated individually at least 10 days prior to any non-emergent tree work being performed by contractor work planners and/or crew personnel. At the time of the evaluation, consent will be obtained from the property owner. Consideration must be given to the tree species, condition, growth rate and failure characteristics, PROW limitations, tree location, the potential combined movement of vegetation and conductors during routine winds, and sagging of conductors due to elevated temperatures or icing when performing line clearance. This evaluation should include growth rate, species, shape, condition and location of the tree and the likelihood of encroachment to the UPZ. When requesting written consent for tree pruning or removal from municipal tree wardens, the State Department of Transportation, abutting property owners and private property owners, UI’s tree contractor Work Planners will use the 8 foot line clearance dimension as the starting point for evaluation of the UPZ and will normally request the removal of all encroaching trees and limbs. The actual distance will result from the required cut of the tree so that a healthy tree remains. Pole mounted electrical equipment such as transformers, capacitors, switches, etc. should be provided at least ten (10) feet of clearance and in accordance with the DLCS – UPZ. Secondary and service conductors should be cleared such that tree limbs do not rub conductors or entangle the wire. A. Distribution Line Clearance Specification– Utility Protection Zone (DLCS) DLCS establishes the "utility protection zone" which is the rectangular area extending horizontally for a distance of eight feet from any outermost electrical conductor or wire installed from pole to pole and vertically from the ground to the sky. DLCS includes cutting, trimming and removal of tree limbs or trees within the utility protection zone and retaining desirable low height or ornamental trees that are already within the zone or those that are planted under a Right Tree – Right Place program. Additionally, the Company would identify and remove in whole or in part hazardous trees that could fall from outside of the zone causing damage to utility infrastructure, facilities or equipment.. The following drawings illustrate the Utility Protection Zone: 34 Vegetation Management Specification 35 Vegetation Management Specification 36 Vegetation Management Specification B. Other Clearance and Operational Requirements Trees or limbs imminently hazardous to any part of the Distribution System shall be patrolled and mitigated with notification to and approval from qualified UI personnel. Photographic evidence of the imminent threat is secured prior to threat mitigation, where possible or practical. Pole mounted electrical equipment such as transformers, capacitors, switches, etc. should be provided at least ten (10) feet of clearance in accordance with the DLCS. Secondary and service conductors should be cleared such that tree limbs do not rub conductors or entangle the wire. Remove hazard trees within the UPZ and on private property after obtaining written consent from the abutting private property owner. Pruning cuts shall be performed in a manner that retains the structural integrity and health of the vegetation. Consideration shall be given to critical loads and the number of customers served by the circuit segment where tree work is performed. No tree work shall be performed (pruning or removal) within the public right-of-way without a permit from the municipal tree warden or the State Commissioner of Transportation. Any non-hazardous tree located in whole or in part within the UPZ may be retained, provided that its species, condition and growth rate indicate that pruning without removal will reduce the risk of harm to the utility infrastructure. Written consent shall be obtained from the tree owner to prune or remove a tree on private property. “Brush” is defined as an undesirable woody plant normally maturing at 20 feet or more in height, with single or multiple stems, and with a small, minimal, or no crown. It shall have a diameter at breast height (DBH, 4.5 feet above ground) of 6 inches or less. Brush shall be cut to the ground line where topography and obstructions will permit. Vines shall be removed from down guys and poles. If vines are in contact with energized wires, the worker while in an aerial lift shall cut out a section of the vine stem measuring approximately one (1) foot in length starting at a point approximately 30 inches below the lowest electric wire. Then, the worker shall ground cut the vine(s) a minimum 5 feet from pole or down guy. Street Lights – The local municipality is responsible to perform routine maintenance trimming to maintain street light patterns on sidewalks and roadways. Conflicts with energized lines shall be referred to UI by the municipality. Limbs in direct contact with street light mast or head shall be pruned clear to reduce possibility of equipment damage. Private Area Lights – During routine maintenance, pruning should clear any vegetation on the pole which is obstructing the pole-mounted fixture. 37 Vegetation Management Specification C. Substation Vegetation Maintenance Requirements Substation facilities are maintained year-round to ensure security and safety of workers and the public. Trap rock within the fenced-in and energized areas must always be kept free of vegetation. Maintaining a vegetation-free, substation ground surface reduces ground potential to workers in the substation yard. It also eliminates tripping hazards. The Contractor will perform manual, mechanical, and pesticide application to maintain a bare ground for the substation facilities. All Substation perimeter fences must be kept clear of all vegetation on both inside and outside. Substation equipment, facilities, security equipment are to be maintained free of vegetation assuring safe operation of equipment, safety to public and workers, and secure facilities. Property boundaries and terrain permitting, a minimum of 10 feet outside of perimeter fences is to be kept clear of all tall-growing vegetation including no overhang to any fence from abutting trees or vegetation. Any potential climbing access to the substation yard is to be eliminated. For erosion control, grasses, ferns and other low-growing species are allowed in the 10 foot perimeter fence buffer zone with the exception of any invasive species (vines, olive, multi-flora rose, etc.). This buffer zone area is maintained once annually, with spot clearing as necessary. D. Transmission Rights-of-Way Clearance Requirements Rights-Of-Way (ROW) clearing and maintenance shall be performed in accordance with “The United Illuminating (UI) Transmission Vegetation Management Program” (TVMP). The TVMP is in compliance with and adheres to guidelines set forth in NERC FAC-003-1. Floor Maintenance: All ROW will be cleared of tall-growing and invasive species; leaving low-growing shrubs, ferns, forbs and grasses. To provide for inspection of facilities, where terrain permits, vegetation will be cleared to allow for foot and/or vehicle access. Side Maintenance: All encroaching side vegetation will be pruned back in accordance with ANSI A300 pruning standards and to a minimum of 20 feet where ROW, Easement, or private property owner consent permits. While performing rights-of-way cycle maintenance, floor and side, and where possible/accessible, off ROW trees are to be inspected for their potential fall-in risk and hazard to the conductors, towers, and facilities. The UI Transmission Vegetation Management Lead is to be notified for follow-up inspection, immediately after a potentially hazardous tree is located. Site conditions dictate the best and most efficient method to clear utility ROW. No right-of-way terrain is level for its entire length. Additionally, UI ROW traverse a variety of field conditions including grades greater than 45 degrees, wetlands, landscaped private property, railways, and areas inaccessible by vehicle. Consequently, the use of manual, mechanical, herbicide, or other vegetation control methods will be implemented where most practical. Note: The use of herbicide on UI ROW is 38 Vegetation Management Specification currently under consideration for use and is being evaluated. There is currently no use of herbicide on UI ROW. The Contractor working on the United Illuminating’s ROW is to adhere to all applicable federal, state and local laws and ordinances. E. Distribution Rights-of-Way Clearance Requirements I. General Distribution ROW are to be maintained clear of trees to permit access for line maintenance and provide for safe operation. Such land strips are usually occupied and maintained under long term easements. The Contractor shall contact the Line Clearance Arborist or designee if at any time during ROW maintenance there is uncertainty as to easement rights to prune or remove trees on a private ROW. II. Tree Pruning and Removal Vegetation management of ROW will adhere to the new Distribution Line Clearance Specification. Vines on poles, towers and fixtures shall be ground cut, cleared, and removed. Brush, when access prevents chipping, shall be handled in such a manner as to avoid obstructing roadways, pathways, and waterways or leaving a distinct fire hazard. Brush is to be wind-rowed at right-of-way edge. Potential hazard trees outside an established R.O.W. shall be removed as directed by UI’s Line Clearance Arborist, or designee, or crew foreman after the customer’s permission has been obtained. Workflow Management UI has established a Distribution Line Clearance Specification and VM Program with an objective of improving the efficiency and effectiveness of Vegetation Management. Some key areas of focus for this program include: The creation and scheduling of all line clearance activities in a single, mobile enabled system Providing the ability to access and report on information in a timely and accurate manner A reduction or elimination of paper based processes This program supports the Company’s ability to establish the DLCS and adhere to the processes outlined in Public Act 14-151 and the Decision in Docket No. 12-01-10. UI has developed a paperless, computer tablet based workflow to manage the property owner consent, objection and request for modification, and quality control processes. 39 Vegetation Management Specification The success of this program is dependent upon the ability to improve performance on a daily basis, the ability to document and manage the vegetation management workflow process, and the ability to become a data driven organization for the purpose of continuous improvement. Areas of focus will be on: Identification of tree pruning and removal needs Obtaining municipal Tree Warden permits and property owner consent Objections and requests for modification and documentation of same Work order creation Scheduling of crews Close-out and reporting The process should be ‘paperless’ Methods/Practices I. General Directional pruning, as defined in ANSI A-300 shall be used as a guide to achieve required clearances for trees that are to be maintained and not removed. Qualified Line Clearance workers are to use their professional judgment and knowledge to obtain the necessary clearances based upon the specification for the circuit being worked on. Climbing irons or “hooks” should not be used except in cases involving tree removal work or where field conditions make vehicular access impossible. The completed job shall result in adherence to clearances specified in Section A, correctly pruned trees per accepted arboricultural standards as described in ANSI A-300, all required reporting forms (time sheets, approval and production forms, etc.) completed accurately, and the satisfactory and safe operation of the overhead distribution system. II. Tree Removal For any tree removal, the Contractor will follow the Customer Consent Process. Tree crews shall not undertake any work involving hazardous conditions that could lead to potential outages or damage to equipment. All concerns or uncertainty of risk should be directed to the Utility Arborist. III. Tree Stump Removal Tree stump removal, if desired, is the jurisdiction and responsibility of the tree’s owner: CT State DOT, the local municipality, or private property owner. Stumps on private R.O.W.’s shall be cut low enough to permit unhindered travel of motorized equipment. 40 Vegetation Management Specification IV. Brush “Brush” is defined as an undesirable woody plant normally maturing at 20 feet or more in height, with single or multiple stems, and with a small, minimal, or no crown. It shall have a diameter at breast height (DBH, 4.5 feet above ground) of 6 inches or less. Brush shall be cut to the ground line where topography and obstructions will permit. V. Clean-up & Disposal All brush and debris resulting from all planned work and scheduled cyclical maintenance work shall be completely removed from the work area (e.g. fine twigs and litter removed from lawns, the street, sidewalks and driveways). Brush or wood shall not be allowed to remain on public thoroughfares or on private property overnight unless arrangements have been made by the contractor’s crew leader or UI Arborist, or designee with the tree’s owner. All line clearance by-products (e.g. brush, wood chips, logs, wood, etc.) must be disposed of at approved sites and in the most economical way. Brush or wood shall not be burned. The removal of brush, debris, or wood resulting from an unplanned event, (e.g. Tree or limb failure, naturally occurring limb abscission, minor or major weather event,) is not the utility contractor’s or UI’s responsibility to remove, It’s the responsibility of the tree’s owner. Every effort shall be made to clear brush, debris, and wood generated from an unplanned event, from roadways, sidewalks, and driveways to allow for vehicle and pedestrian passage. Door-hangers provided by UI, are to be used to communicate to UI customers the procedures regarding clean-up and/or follow-up for unplanned events. 41 Vegetation Management Specification Contractor Responsibilities I. General The Contractor is responsible to provide the Company with workers that are properly trained to perform their work safely and competently and interact with the public with professional courtesy at all times. All work shall be in accordance with recognized and approved arboricultural standards and perform in accordance with all Federal OSHA, ANSI, State and Local requirements appropriate for such work. The contractor will also comply with the Contract terms, rules and specifications established by United Illuminating for such work. Contractor is to obtain all permits and licenses imposed by law, pay all charges and fees, and give notices necessary and incidental to the due and lawful prosecution of the work. Contractor is to provide certified copies of liability insurance coverage for public and private liabilities which may arise in connection with their work. Contractor is to provide all labor, tools, equipment, transportation and materials to perform line clearance work. Apparatus shall be in proper operating condition and adequately maintained. Contractor shall provide employees with suitable foul weather gear and other apparatus necessary to perform night emergency work, including emergency lighting. The contractor’s equipment shall be neat appearing. Appropriate first-aid supplies, as required by OSHA, shall be a part of the standard equipment on all vehicles. Adequate spare equipment and tools shall be readily available to insure that workers are not delayed in performing the required work. The billing rate for equipment shall be all-inclusive including, but not limited to: fuels, lubricants and maintenance, hand and power tools. Each crew is to have a copy of these standards and specifications and Dr. Shigo booklets (“Pruning Trees Near Electric Utility Lines) on each crew truck/work location. Each crew is to be trained to understand and retain this specification, have knowledge of all procedures and policies, understand all glossary definitions and perform all work compliant with all company applicable specifications/requirements. II. Safety The contractor shall take the necessary precautions to prevent personal injury or damage to property and shall conduct operations with a minimum of interference to traffic or inconvenience to the public. In this area of safety and health, the contractor shall: a. Observe the contractor’s safety rules at all times. b. Treat every circuit and/or line as energized. c. Observe all applicable Federal, State, and Local laws. d. Adhere to all company safety rules 42 Vegetation Management Specification If in the judgment of the contractor’s foreman, it is hazardous to perform the assigned work with the circuit or conductors energized, UI supervision shall be contacted. The necessary protective line hardware or de-energized circuit(s) or conductors will be provided by UI. ANY tree that is observed to have potential child access to any conductor, equipment, or UI facility, is to be reported immediately to the UI Arborist, or designee III. Damage Notification The contractor crew foreman and/or General Foreman is to notify the UI Arborist or designee, as soon as possible, of all defects, damage, etc., observed on UI overhead facilities (e.g. leaking transformer, wire off pin, pole top pin, broken basket, etc.). This notification is required regardless of cause. Dangerous conditions should be reported immediately. Any damage caused to private property, at any time, is to be reported immediately to the UI Arborist or designee and resolved as soon as practical with the aggrieved party, with courtesy and professionalism. IV. Work Assignments Line clearance work addresses four major categories: DLCS New Capital Construction Customer Requests Special Projects UI will provide necessary maps and report forms to the contractor indicating the planned work area. UI Supervision reserves the right to re-assign a crew(s) from their scheduled work area to a temporary work area as conditions and needs warrant, at any time. V. Traffic Control The Contractor will be responsible for coordinating and scheduling of traffic control for all work billable monthly as a separate item and passed through to UI with required back up (invoices, sign-off slips, etc.). A monthly Traffic Control Invoice Status Summary sheet will be provided to UI indicating individual municipal charges and payment status. VI. Reports The foremen of each crew shall record required billing and production information on the contractor daily time sheet or applicable forms. All reporting forms and time sheets are to be delivered to the UI Line Clearance personnel at the end of each working week. In addition, the Contractor shall provide monthly reporting via electronic format on safety, productivity, customer objections, and summary report of performance as required by UI. NOTE: UI and its contractor(s) will work together to further define additional reporting requirements and methods of tracking. 43 Vegetation Management Specification VII. Public Contact A. Consent 1. DLCS The contractor, as an agent for UI, shall request consent from the abutting property owner to prune or remove trees around electric conductors on public or private property. In the interest of public relations: a. Confirm that the person you are speaking to is the property owner. b. Clearly convey exactly what needs to be pruned or removed to establish the UPZ and maintain safe, reliable electric service. c. Once an agreement has been reached, repeat and confirm the plan, and have the property owner sign the consent form. d. If the property owner is not home, leave a customer door hanger package (hanger, brochure and consent form) on the door. Contractor shall not obligate UI to make any payments to another party, nor make any promises or representations of any nature to another party for, or on behalf of UI, without prior approval of UI. 2. State Highway Each crew must have a copy of the State Tree Trimming Permit with Permit Number when performing tree work on a State Highway. B. Complaints In managing complaints, the contractor shall use its best effort to maintain and promote good public relations. The contractor shall not make payment to local inspectors, property owners or any other persons for any right to trim or remove trees. The contractor shall immediately inform UI of any damage complaints from a customer, regardless of the cause or extent of damage and of all resolutions and settlements. The contractor shall give immediate attention to, and shall use its best efforts to promptly, courteously and equitably respond to, adjust and/or settle, without obligation to the UI, all complaints received by the contractor from third parties arising out of, or in connection with, performance of their work. C. Customer Relations Contractor crew members are UI representatives to our customers. Consequently, each person is expected and required to treat the customer in a professional and courteous manner. If any crew member is approached by the abutting property owner, State, or municipal official and cannot properly address their concern; they are to contact their supervisor immediately who will immediately respond to the customer’s concerns. The contractor shall notify UI of all customer complaints and damage claims . 44 Vegetation Management Specification Numerous contacts with local municipalities and customers provide an excellent opportunity to make a positive impression. A worker’s appearance, attitude and methods of approach must reflect creditably upon the Company. They must possess a good knowledge of human nature, arboriculture and have the ability to quickly evaluate situations to secure tree work permissions and, at the same time, establish friendly relations. 45 Vegetation Management Specification Glossary Brush Clearance “Brush” is defined as an undesirable woody plant normally maturing at 20 feet or more in height, with single or multiple stems, and with a small, minimal, or no crown. It shall have a diameter at breast height (DBH, 4.5 feet above ground) of 6 inches or less. The distance from the conductor to the part of the tree that will interfere with or grow into the conductor first. Crew Foreman The tree contractor’s crew leader working with and supervising the line clearance crews. Diameter Breast Height (DBH) Diameter of tree or brush at a point 4 ½ feet above the ground. Distribution Line Clearance Specification (DLCS) The pruning or removal of vegetation to establish a utility protection zone, without removal of low growing desirable tree species. General Foreman Supervisory personnel working for the contractor who has responsibility for work performed by that particular contractor’s tree crews. Ground Cutting Completely removing trees or brush at the ground level. Hazardous Tree "Hazardous tree" means any tree or part of a tree that is (1) dead, (2) diseased, (3) extensively decayed, or (4) structurally weak which, if it falls, would endanger life or property, including utility infrastructure, facilities or equipment. Assigning tree trimming crews in a manner that does not involve systematic, scheduled program maintenance work. Hot-Spotting Line Clearance Controlling vegetation to maintain proper clearance from conductors. Synonymous with tree clearing, tree trimming or vegetation management. Natural Trimming Trimming to reduce the height and/or spread of a tree, while attempting to maintain the tree’s natural form, by cutting branches back to a lateral limb, towards the center of the crown. A method by which branches are cut to the branch collar at a suitable parent limb back toward the center of the tree. This method of trimming is sometimes called “dropcrotching” or “lateral, trimming”. Natural trimming is also directional trimming, since it tends to guide tree growth away from wires. Overhanging Limbs Tree limbs extending over the top of conductors. Pruning The removal in a scientific manner of dead, dying, diseased, 46 Vegetation Management Specification interfering, objectionable, and/or structurally weak branches using arboricultural accepted techniques. Removal Completely removing an entire tree to ground level; required when a tree is described as a hazardous tree or when a tree should be removed for other reasons. Reliability Circuit Trim Schedule (RCTS) The master schedule list of UI’s overhead distribution circuits that is based on reliability performance, time-based maintenance, and Tier 1&2 town and state facility priorities. Rounding Over Not accepted. The making of many small cuts so that the tree top is sheared in a uniform line. This creates an unhealthy tree condition and results in rapid regrowth directly back toward the area intended to remain cleared. Also known as “topping” Sag The vertical distance that a conductor will drop due to heavy load current and/or high temperature. Shearing See “Rounding Over” Shrub A desirable woody plant normally maturing at less than 15 feet in height, presenting a generally bushy appearance because of its several erect or spreading stems. Side Pruning Pruning back or removing the side branches that are encroaching the utility protection zone; required where trees are growing adjacent to conductors. Species The basic category of biological classification intended to designate a distinct group or kind of plant or animal having common attributes. Sway The horizontal distance that a conductor will move due to wind. Top Pruning Pruning back portions of the upper crown of a tree; required when trees are located directly beneath a conductor. Tree "tree" is defined as a woody plant normally maturing at 20 feet or more in height, usually with a single trunk, un-branched for several feet above ground, with a definite crown. It shall have a diameter at breast height (4.5 feet above ground) of greater than 6 inches Tree Crown Upper portion of the tree; the branches or leaf area. Trimming See “Pruning” Trim Cycle The desired period of time to repeat vegetation management. Utility Protection Zone (UPZ) Any rectangular area extending horizontally for a distance of eight feet from any outermost electrical conductor or wire installed from 47 Vegetation Management Specification pole to pole and vertically from the ground to the sky. General Worker Guidelines First impressions count! The following items are important to remember at all times: Crew Image Be neat in appearance. Have an orderly appearance of the work vehicles. Be professional in conduct and attitude. Have energetic work habits. Public Relations Be courteous and sociable. Be attentive to customer’s concerns. Have respect for the customer’s property. Leave the area as you first found it (or better). Job Knowledge Conduct a “Tailboard Conference” before starting the job (e.g. Confirm what, who, where, why, etc.). Be knowledgeable in utility vegetation management practices and safety. Prepare before approaching a customer (e.g. Have in mind the importance to trim the line, the species of tree involved, type of trim needed, etc.). Have confidence in yourself. Communication - (for anyone addressing a customer to gain consent to prune or remove) Control the volume and tone of your voice. Maintain professional body language. Concentrate on what the customer is saying. Don’t interrupt. Don’t draw premature conclusions. Ask questions. Identify clearly what work is to be done. Confirm it. Prune/clear only what had been discussed. You represent the UI Company and are expected to treat the customer with respect and value 48 Vegetation Management Specification CUSTO M E R CON SE NT P ROCESS Dated: No vember 17, 2014 49 Vegetation Management Specification This section of the plan has been amended to comply with changes to the notification and consent process required by Public Act 14-151. Preface UI overhead Distribution infrastructure requires sufficient clearance from all vegetation to ensure safe, reliable electric service to our customers. Successful Vegetation Management performed on State, municipal, or a customer’s property, secured through Notification, Permit, and/or Appeals processes, is paramount and achieved through good communications and public education. Purpose To provide the Company and its Contractor(s) a formal process for obtaining consent from a property owner to perform enhanced UPZ line clearance work and resolve cases where the property owner objects or requests a modification to the proposed Vegetation Management (VM). Scope The scope of the Customer Consent Process applies to vegetation management work performed on UI’s overhead Distribution System. Connecticut law requires UI to notify the abutting property owner of vegetation maintenance that is planned within the Utility Protection Zone (UPZ). Notification is allowed for the pruning or removal of trees within the public right-of-way. Written consent is required for trees on private property. UI requests property owner consent, Exhibit A, so that we may maintain safe and reliable electric service to customers and so that decisions regarding the extent of tree pruning and removal are made at the local level. Property Owners have the right to object or request a modification to the proposed tree work. If they do not consent, the law gives UI the right to appeal their objection or request for modification to either the tree warden or the State Department of Transportation or the Public Utilities Regulatory Authority. Responsibilities Contractor: 1. Obtain consent from abutting property owner within planned work area before starting any VM. If the property owner is not home, a “door knob hanger” (See Exhibits B&C), notification information, shall be delivered to the abutting property owner. Two additional attempts shall be made to obtain consent of VM using the best means available and practical (door-hanger, direct phone calls, etc.). All attempts to make contact for the VM shall be logged noting the dates and times that the attempts were made. 2. Where property owner contact for consent cannot be obtained after three attempts, the contractor Work Planner will identify the property as a no contact in the work plan database and visit the town hall and determine who owns the property from the public land records. Using this information, UI will send no contact letters (See Exhibit D), using US Postal Service CERTIFIED MAIL, to the property owners notifying them of UI’s intent to prune and/or remove trees within the UPZ. 50 Vegetation Management Specification 3. For the Transmission Vegetation Management Program the Contractor will use the “NERC Clearance Issues” forms Clearance 1 and 2 (Exhibit E & F), or other applicable provided forms, for reporting locations not meeting those standards. Note the “Job Issue” or difficulty (customer consent, access problem, permit/legal issue, or arboricultural issue) that caused the non-compliant clearance, Exhibit E & F UI employees, Line Clearance contractors, (Line Clearance contractors and ROW inspection contractors) are to notify the Transmission Vegetation Management Lead or designee via cell phone immediately of any locations that do not meet the NERC FAC-003-1 Clearance 2 standard. (clearance distance of 10 feet for 345KV and 4 feet for 115KV lines) These forms should be forwarded to the UI Transmission Line Clearance Arborist or designee at the end of each week. In addition, “Serious” Conditions are to be reported to Supervision verbally when found. The Transmission Vegetation Management Lead or designee is to review all reports and forms forwarded by the Line Clearance and ROW inspection contractors and will proceed as follows: a. Re-Inspect all locations reported as not meeting either Clearance 1 or 2 this is to verify the information reported. b. The Transmission Vegetation Management Lead or designee works with the property owner, the Line Clearance Tree Contractor; UI’s Transmission Operations, Real Estate, and Legal Departments to secure permissions/approvals to achieve the clearances necessary to be compliant and meet TVMP specifications. . c. Any unresolved and unmitigated clearance conditions are reported by location to UI’s Transmission Operations, Real Estate, and Legal Departments for review to explore any alternatives for eventual mitigation and resolution of the non-compliant condition. The TVMP Permission and Tracking Process diagram (Exhibit D) depicts the process of obtaining permission from property owners and tracking all locations that do not meet the NERC FAC-003-1 standards, Clearances 1 & 2. Objections or Requests for Modification When there is an objection, the work planner works with the property owner to determine what level of pruning is acceptable using the following guidelines: If a removal is objected to, request the removal of all overhanging limbs within the UPZ. If the removal of all overhanging limbs within the UPZ is objected to, request the removal of all limbs within 20 feet above, 10 feet below and 8 feet to the side of the conductors. If the removal of 20 feet above, 10 feet below and 8 feet to the side of the conductors is objected to, request the removal of all limbs within 15 feet above, 10 feet below and 8 feet to the side of the conductors. If the removal 15 feet above, 10 feet below and 8 feet to the side of the conductors is objected to, request the removal of all limbs to achieve the previous obtained clearance. Remove suckers, deadwood and limbs with structural defects. Objections that result in requests for modification (RFM) for some of the trees at the property are recorded as Partial Objections. If the property owner objects to all tree work or all work is a request for 51 Vegetation Management Specification modification, the objection is recorded as a Full Objection. For each objected (or request for modification) tree, the work planner will record the tree species, diameter at breast height (DBH), hazard and risk characteristics, reason for the objection or modification, and take a photo of each tree. This data is included in the Tree Warden Review report. The property owner is then asked to sign the consent form either electronically (via the Vegetation Management mobile application) or on hard copy. On Tuesday of each week, UI reviews the previous week’s objections and RFMs to determine if the tree conditions merit a review of the electrical system impacts or, if it is a RFM, whether the modification is acceptable. If UI accepts the RFMs, the objection process is complete and a tree crew job assignment is created. On Wednesday of each week, objections and RFMs deemed unacceptable from the previous step are passed on to UI Operations Engineering to determine the electrical system (ES) impacts and a review by the Tree Warden or the State Department of Transportation (DOT) is recommended if one or more of the following criteria are met: Greater than 100 customers affected Municipal Priority affected State priority affected Blocked assisted living center Blocked medical customer Blocked municipal priority Blocked state priority Each week, the objections and RFMs are sent to the Tree Warden or DOT in the form of a Tree Warden Review report and request a decision within 10 days. For each tree that requires a decision, the Tree Warden is asked to render a decision as one of the following: Hazard Sustained Sustained with Modifications Overturned When the Tree Warden’s rulings are received they will be recorded and reviewed by UI Vegetation Management to determine the next step: If the Tree Warden rules a tree to be hazardous, the customer will be notified, if time allows due to the hazard, and work will be scheduled to prune or remove the tree as necessary. If the Tree Warden rules and overturns the objection or RFM, the property owner is notified that UI plans to proceed with the planned work. (The property owner has an opportunity within 10 days of the Tree Warden’s ruling to either accept the ruling or appeal to PURA.) 52 Vegetation Management Specification If the Tree Warden rules and sustains the objection or RFM (with or without modifications), UI will either perform the work within the limits of the modification, appeal to PURA, or let the objection or RFM stand. (UI has 10 days to decide to accept the Tree Warden’s ruling or appeal to PURA). UI will record and review the reasons for the Tree Warden sustaining or overturning a property owner objection or modification and then decide if an appeal of the Tree Warden’s decision will be made to PURA. UI has established a guideline for determining when it will appeal a Tree Warden decision to PURA. Objections and/or requests for modification will normally be appealed, if one or more of the following criteria are met: Communication facilities at risk Hazardous Tree High customer impact >500 customers High risk customers (medical, assisted living, etc.) Major fuel terminal at risk Major roadway blockage risk Modification does not reduce risk Multiple Critical facilities at risk Multiple tree risk factors Road blockage of critical facilities Sewage treatment facility at risk Tree warden did not provide a ruling Water treatment/pumping facility at risk Flow charts for the consent, objection and no contact processes are provided in Exhibits G, H and I. 53 Vegetation Management Specification Exhibit A: 54 Vegetation Management Specification Exhibit B 55 Vegetation Management Specification Exhibit C 56 Vegetation Management Specification Exhibit D The United Illuminating Company 100 Marsh Hill Road, Orange, CT 06477-3629 203-499-2000 Date Dear Property Owner: United Illuminating (UI) is performing line clearance tree work in your neighborhood to ensure safe, reliable and cost effective service during normal weather and to ensure a more resilient electrical system during extraordinary weather events. UI was directed to perform this work after the damage caused by major storms in 2011 and 2012. We recently attempted to contact you directly at your property at (insert address here) but were unable to make a connection after 3 attempts. Prior to performing any tree work within the Utility Protection Zone (UPZ) or on or overhanging any public road, public highway or public ground, Connecticut state law requires that we provide the abutting property owner or private property owner with notification of our intended work at least 15 business days prior to the start date of any pruning or removal. Please consider this letter your formal notification of our intention to prune and remove all trees and limbs within the UPZ. Additional information regarding UI’s Vegetation Management program can be found in the attached brochure or on UI’s website at www.uinet.com/trees. You may also send requests for information to trees@uinet.com. You may consent, object or request a modification to the proposed tree work. If you object or request a modification, you must send a written objection or request for modification within 10 business days of receiving this notice to both UI and your municipal tree warden or, if your property abuts a state road, the Connecticut Department of Transportation, or by electronic mail to trees@uinet.com. An objection may include a request for consultation with the tree warden or the Commissioner of Transportation. Please note that an objection or request a modification begins a review process that may ultimately be decided by the Connecticut Public Regulatory Authority (PURA). If you exercise your right to object to the proposed tree work, or request a modification, it may increase the risk that you or your neighbors will lose power if a storm or extraordinary weather event brings trees in contact with UI’s electrical equipment. However, you will not be billed for any resulting damage to UI’s system. If you do not file an objection or request for modification within the 10 business day objection/modification period, our tree contractor will proceed with the work for which notice of pruning or removal has been delivered. Sincerely, David A. Goodson Manager Vegetation Management United Illuminating 100 Marsh Hill Road Orange, CT 06477 Tree Warden or DOT Address Street Town, CT 06XXX 57 Vegetation Management Specification Exhibit E: NERC CLEARANCE 1 ISSUES LOG SHEET (example) The lis t below is a com pilation of locations logged by the Tree Contractor where CLEARANCE 1 (NERC FAC-003-1) could not be obtained. LINE # TWN ST. REFERENCE TOWER/ CAT.# BRIEF WORK DESCRIPTION Signs of Burning MN MN UI LINE TOWN FLAG? Ground? OUT? PD? JOB ISSUE OUTAGE Tent.START COMPL LENGTH DATE DATE Cust.Perm. Access Permit Legal Bucket Climb(s) Cust.Perm. Access Permit Legal Bucket Climb(s) Cust.Perm. Access Permit Legal Bucket Climb(s) Cust.Perm. Access Permit Legal Bucket Climb(s) Cust.Perm. Access Permit Legal Bucket Climb(s) Cust.Perm. Access Permit Legal Bucket Climb(s) kb/NERC critcal CLEARANCE 1 log sheet.xls Forward list to the UI Line Clearance Dept. along with all weekly paperwork. 58 Vegetation Management Specification Exhibit F: NERC CLEARANCE 2 ISSUES LOG SHEET (example) The lis t below is a com pilation of locations identified via the annual ROW foot ins pection that do not conform with CLEARANCE 2 of NERC FAC-003-1 (IEEE 516-2003) LINE # TWN ST. REFERENCE TOWER/ CAT.# BRIEF WORK DESCRIPTION Signs of Burning UI LINE TOWN MN MN PD? FLAG? Ground? OUT? JOB ISSUE OUTAGE Tent.START COMPL DATE DATE LENGTH Cust.Perm. Access Permit Legal Bucket Climb(s) Cust.Perm. Access Permit Legal Bucket Climb(s) Cust.Perm. Access Permit Legal Bucket Climb(s) Cust.Perm. Access Permit Legal Bucket Climb(s) Cust.Perm. Access Permit Legal Bucket Climb(s) Cust.Perm. Access Permit Legal Bucket Climb(s) kb/NERC critcal CLEARANCE 2 log sheet.xls Forward list to the UI Line Clearance Dept. immediately upon completion 59 Vegetation Management Specification Exhibit G: Property Owner Consent Process Property Owner Located Yes Property Owner Consents Yes Create Job Assignment No No 100% Objection No Contact No Request for Modification Accept Modification Yes Yes Tree in Contact or Burning Perform work without consent Yes No No Start 10 Day Decision Calendar Notify Tree Warden or State DOT No Agree with Property Owner Appeal to PURA No TW/DOT Decision No Agree with UI Yes Yes UI Appeal To PURA Declare Hazard Start 10 Day Appeal to PURA Calendar No Yes Require alternate Modification Agree with TW Modification 60 Property Owner Appeal to PURA Yes Vegetation Management Specification Exhibit H: Tree Warden or DOT Objection Decision Process TW/DOT Decision Yes Notify Property Owner of TW/DOT Decision No Declared Hazard Yes Notify Property Owner that Contractor will Perform Work Create Job Assignment No In favor of Property Owner No Yes UI Appeal to PURA Yes Yes Request Mediation Appeal to PURA No Notify Property Owner of Decision and ask if they plan to appeal to PURA 30 Day Clock Starts Yes Property Owner Appeal to PURA No 60 Day Clock Starts No 61 Vegetation Management Specification Exhibit I: Property Owner No Contact Process No Contact Research Public Land Records Obtain Property Owner Address Mail CERTIFIED MAIL Notification Letter Wait 15 days for Property Owner Response Property Owner Objects No Create Job Assignment Yes Proceed to Objection Process 62 Vegetation Management Specification Exhibit J: Vegetation Management Plan Metrics 1. Work scope and budget details (NOTE: All data is year-to-date through December 17, 2014 and represents preliminary results based on data collected using the Company’s newly developed Mobile Vegetation Management System application, and corporate budget and expense tracking systems): a. b. c. d. e. f. g. h. i. 2. 3. 4. Roadside miles scheduled, backbone and lateral; 84 miles of 3 phase, 54 miles of single phase, 138 total miles Cost - $7,930,439 Right-of-way miles, brush control and side pruning; 22.6 miles of transmission right-of-way Cost - $984,700 Risk tree removal; See # 9 below for tree counts Cost – not tracked separately Vine control; 1,013 locations Cost - $59,700 Traffic control; Cost – Utility Protection Zone $1,834,737, Customer Requests $67,328 Customer request tree work; Cost - $646,980 Mid-cycle; UI does not perform mid-cycle tree work Emergency restoration, minor storm; $385,838 Other. UI will provide a summary of additional costs and work scope results after the completion of the year. Tree and brush work specification. See section 7.2. Line clearance organization. See section 5.1. Property owner notification and consent procedures. See Attachment 2, CUSTOMER CONSENT PROCESS. 63 Vegetation Management Specification 5. The planned maintenance within each town within the EDC’s service territory. CIRCUIT ID 1433 1441 3671 2682 2687 500 501 506 510 512 513 514 516 3631 3636 3638 1692 1754 1756 2622 2623 2625 1540 1545 1548 79Y 79Y PHASE COUNT Three Phase Three Phase Three Phase Three Phase Three Phase Single Phase Single Phase Three Phase Single Phase Three Phase Single Phase Three Phase Single Phase Single Phase Single Phase Single Phase Three Phase Single Phase Single Phase Single Phase Single Phase Three Phase Three Phase Three Phase Three Phase Three Phase Single Phase MILES 1.79 12.67 7.68 0.05 0.91 3.7 2.88 6.96 6.06 14.92 1.58 5.91 6.39 3.05 5.17 8.59 2.19 11.95 7 4.13 2.65 4.44 6.43 8.51 8.3 1.76 0.7 146.37 Primary Town West Haven Orange Ansonia Fairfield Trumbull Shelton Shelton Shelton Shelton Shelton Shelton Shelton Shelton Milford Milford Milford Hamden North Haven North Haven Bridgeport Bridgeport Bridgeport North Branford North Branford North Branford Hamden Hamden 64 Vegetation Management Specification 6. Number of property owner/customer objections by town in prior year. Town Work Type Ansonia Bridgeport Bridgeport Derby East Haven East Haven Easton Easton Fairfield Fairfield Hamden Hamden Milford Milford New Haven New Haven North Branford North Branford North Haven North Haven Orange Orange Shelton Shelton Stratford Stratford Trumbull Trumbull West Haven West Haven Woodbridge Prune Prune Removal Removal Prune Removal Prune Removal Prune Removal Prune Removal Prune Removal Prune Removal Prune Removal Prune Removal Prune Removal Prune Removal Prune Removal Prune Removal Prune Removal Prune Trees 1 4 7 5 11 20 15 4 4 8 4 2 138 127 18 186 50 4 47 88 23 20 15 13 2 1 10 4 11 10 5 857 65 Vegetation Management Specification 7. Number of property owner/customer objections by town in prior year accepted by the Tree Warden. Town TW Decision East Haven East Haven New Haven Orange Orange Objection Sustained Trees 3 1 8 1 2 Objection Sustained with Modification Objection Sustained Objection Sustained Objection Sustained with Modification 8. Number of property owner/customer requests for modifications and decisions reached. NOTE: Where the Tree Warden decision reads “Not Appealed by UI” this means that UI accepted the requested modification because the tree was not a high risk at this time. Requested Modification Tree Warden Decision Result 20ft Overhead 20ft Overhead 8ft, 10ft, 15ft 8ft, 10ft, 15ft 8ft, 10ft, 15ft Prune to Previous Clearance Prune to Previous Clearance Prune to Previous Clearance Prune to Previous Clearance Not appealed by UI 20ft Overhead Remove 8ft, 10ft, 15ft Remove Under Review Prune to Previous Clearance Under Review Prune to Previous Clearance Prune to Previous Clearance 51 1 193 1 2 493 1 2 9 Remove all Overhang Under Review Remove all Overhang Remove all Overhang 2 17 31 3 Remove all Overhang 1 Prune to Previous Clearance Prune to Previous Clearance Remove all Overhang Remove all Overhang Remove all Overhang Declared as Hazard Not appealed by UI Declared as Hazard Under Review Not appealed by UI No Ruling No Ruling - Private Tree Objection Sustained Objection Sustained with Modification Under Review Not appealed by UI Objection Sustained Objection Sustained with Modification 66 Trees Vegetation Management Specification 9. Number of trees per town assessed to be hazardous or non-hazardous. Town Ansonia Bridgeport East Haven Easton Fairfield Hamden Milford New Haven North Branford North Haven Orange Redding Shelton Stratford Trumbull West Haven Woodbridge Hazard Trees 2 15 21 86 15 9 46 2 3 41 17 1 12 6 32 7 8 323 NonHazard Trees 96 374 9 144 60 87 292 945 256 360 551 1206 2741 17 134 73 20 8011 67 Vegetation Management Specification 10. Number of property owners/customers who give affirmative consent versus non responses. Town Ansonia Bridgeport Derby East Haven Easton Fairfield Hamden Milford New Haven North Branford North Haven Orange Redding Shelton Stratford Trumbull West Haven Woodbridge Town Milford New Haven North Haven Shelton Affirmative Consent 105 265 2 48 29 25 68 263 1 288 193 324 1 984 4 128 13 5 No Response 2 1 2 1 11. Number of mediations conducted and outcome of mediation. None. 12. Number of objections appealed to PURA by either the EDC or landowner and outcome. None. 13. Number of removals of non-hazardous trees. See response to 9. 14. Number of RTRP trees planted by the EDC, reasons for planting, costs. None. 15. Did property owner maintain the newly planted tree? Not applicable. 16. Number of stumps ground by EDC, reasons for stump grinding, costs. 32 stumps ground, loamed and seeded. Cost - $17,542. Agreements reached with abutting property owners prior to the final decision in Docket 12-0110 68