STATE OF CONNECTICUT
DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION
PUBLIC UTILITIES REGULATORY AUTHORITY
TEN FRANKLIN SQUARE
NEW BRITAIN, CT 06051
DOCKET NO. 12-06-09
PURA
ESTABLISHMENT
OF
PERFORMANCE
STANDARDS FOR ELECTRIC AND GAS COMPANIES
Nobember 1, 2012
By the following Directors:
Arthur H. House
John W. Betkoski, III
DECISION
TABLE OF CONTENTS
I.
INTRODUCTION ...................................................................................................... 1
A. SUMMARY ............................................................................................................ 1
B. BACKGROUND ...................................................................................................... 1
C. CONDUCT OF PROCEEDING.................................................................................... 3
D. PARTICIPANTS ...................................................................................................... 3
II. AUTHORITY ANALYSIS .......................................................................................... 4
A. ADOPTION OF STANDARDS .................................................................................... 4
B. REPORTING REQUIREMENTS OF SECTIONS 3 AND 4 OF THE ACT ............................... 5
1. Section 3(b), System Hardening ............................................................... 5
2. Sections 3(c)1 and 3(c)2, Current Practices ............................................ 5
3. Section 3(c)(3), Coordination Efforts ....................................................... 6
4. Section 3(c)(4)(A), Tree Trimming Expenditures ..................................... 6
5. Section 3(c)(4)(B), Tree Contact Reliability Impact ................................. 9
6. Section 3(c)(4)(C), Expanded Tree Trimming ........................................ 10
7. Section 3(c)(4)(D), Tree Contact Statistics............................................. 11
8. Section 3(c)(4)(E), Standards for Roadside Care .................................. 12
C. COST RECOVERY ................................................................................................ 14
D. PROCUREMENT OF CONTRACT RESOURCES ......................................................... 14
III. CONCLUSION AND ORDERS ............................................................................... 15
A. CONCLUSION ...................................................................................................... 15
B. ORDERS............................................................................................................. 15
DECISION
I.
INTRODUCTION
A.
SUMMARY
Pursuant to Public Act 12-148, An Act Enhancing Emergency Preparedness and
Response and the General Statutes of Connecticut §16-11, the Public Utilities
Regulatory Authority establishes specific standards for acceptable performance by each
electric distribution and gas company in an emergency in which more than 10% of any
utility’s customers are without service for more than 48 consecutive hours, as well as for
gas companies for a comparable scale emergency. The standards attain the goals of
protecting public health and safety, prevention of service outages or disruptions or
reducing the duration of service outages or disruptions, facilitating restoration of service
after outages or disruptions, and identifying the most cost-effective level of tree trimming
and system hardening necessary to achieve maximum reliability of the system and to
minimize service outages.
This Decision also reviews each utility’s practices
concerning service restoration after an emergency; the adequacy of each utility’s
infrastructure, facilities and equipment; coordination efforts between each electric
distribution company and any telecommunications company, community antenna
television company, holder of a certificate of cable franchise authority or certified
competitive video service provider; and the tree trimming policies of each electric
distribution company.
Additionally, this Decision also orders each electric distribution company and gas
local distribution company to incorporate these Performance Standards into their
Emergency Response Plan and to implement them in their manner of operations. Noncompliance with these standards can subject the electric distribution company or gas
company to the imposition of civil penalties pursuant to §16-41 of the General Statutes
of Connecticut.
B.
BACKGROUND
Public Act 12-148, An Act Enhancing Emergency Preparedness and Response
(Act), requires the Public Utilities Regulatory Authority (Authority or PURA) to establish
industry specific standards for acceptable performance by electric distribution
companies (The Connecticut Light and Power Company (CL&P) and The United
Illuminating Company (UI); collectively, the EDCs) and gas local distribution companies
(Connecticut Natural Gas Corporation (CNG), Yankee Gas Services Company (YGS)
and The Southern Connecticut Gas Company (SCG; collectively, the LDCs) in an
emergency to protect public health and safety, prevent service outages or disruptions,
or reduce the duration of service outages or disruptions, facilitate the restoration of
service after outages or disruptions, and identify the most cost-effective level of tree
trimming and system hardening necessary to achieve maximum reliability of the system
and to minimize service outages. The Act also requires the Authority to submit a report
identifying such standards and any recommendations concerning legislative changes
necessary to implement such standards to the joint standing committee of the General
Assembly having cognizance of matters relating to energy by November 1, 2012.
Docket No. 12-06-09
Page 2
In accordance with the Act, this Decision also reviews:
1.
2.
Each utility’s practices concerning service restoration after an emergency,
including each utility’s:
a.
Estimates concerning potential damage and service outages prior to any
emergency;
b.
Damage and service outage estimates after each emergency;
c.
Restoration management after any emergency, including access to
alternate restoration resources via regional and reciprocal aid contracts;
d.
Planning for at-risk and vulnerable customers;
e.
Policies concerning communication with state and local officials and
customers, including individual customer restoration estimates and the
timeliness and usefulness of such estimates; and
f.
Need for mutual assistance during any emergency.
The adequacy of each such utility’s infrastructure, facilities and equipment, which
shall include an analysis of:
a.
Whether such utility is following standard industry practice concerning
operation and maintenance of such infrastructure, facilities and
equipment; and
b.
Whether such utility had access to adequate replacement equipment for
such infrastructure, facilities and equipment.
3.
The coordination efforts between each EDC and any telecommunications
company, community antenna television company, holder of a certificate of cable
franchise authority or certified competitive video service provider.
4.
The tree trimming policies of each EDC, including:
a.
The amount spent by each EDC for each year since its most recent rate
proceeding;
b.
Each EDC’s System Average Interruption Duration Index (SAIDI) caused
by falling trees and limbs;
c.
The impact of expanding the area adjacent to distribution lines for tree
trimming, including an analysis of the benefits and costs of expansion to
ratepayers and the likelihood that such expansion would decrease
damage to infrastructure, facilities and equipment used to distribute
electricity and decrease service outage frequency or duration;
Docket No. 12-06-09
Page 3
d.
The percentage of service outages during Tropical Storm Irene and the
October, 2011 snowstorm caused by trees and limbs outside the current
trim area based on an analysis of the quantity and effectiveness of prior
tree trimming; and
e.
The standards appropriate for road-side tree care
management standards in utility rights-of-way,
standards, and standards recommended by
Management Task Force (SVMTF) established
Energy and Environmental Protection (DEEP).
in the state, vegetation
right tree-right place
the State Vegetation
by the Department of
5.
Other policies, practices and information that the Authority has determined is
relevant to this review.
C.
CONDUCT OF PROCEEDING
The Authority was assisted in its investigation on the matters in this proceeding
by Jacobs Consultancy Inc. (JCI).
By Notice of Opportunity to Comment dated September 28, 2012, the Authority
offered participants the opportunity to comment on draft standards for restoration. By
Notice of Technical Meeting dated October 2, 2012, the Authority held technical
meetings on October 10, 11, and 12, at its offices, Ten Franklin Square, New Britain,
Connecticut. By Notice of Comment and Oral Argument dated October 17, 2012, the
Authority offered participants the opportunity to comment on its restoration standards
that were revised based on input it received at the above Technical Meetings. No
participants requested oral argument on the proposed restoration standards; therefore,
no oral argument was held.
The Authority issued a final Decision in this matter on November 1, 2012.
D.
PARTICIPANTS
The PURA recognized the following as participants in this proceeding: The
Connecticut Water Company; Department of Homeland Security/Office of Emergency
Communications; The Department of Energy and Environmental Protection, Forestry
Division; Sprint Nextel Corporation; Jewett City Water Company; Hazardville Water
Company; the Office of Consumer Counsel; Comcast Hartford; Olmstead Water Supply
Company, Inc.; Judea Water Company; Tyler Lake Water Company; Verizon Wireless;
Town of Wilton; AT&T Connecticut; Towns of Newtown/Redding; FiberTech
Communications; QualComm-Enterprise Services; Cablevision Systems Corp.; Local
420 – IBEW; Comcast Cable; Charter Communications; Charter Communications
Entertainment 1; Metrocast Communication; the Office of the Attorney General; The
United Illuminating Company; Connecticut Natural Gas Corporation; The Southern
Connecticut Gas Company; Old Newgate Ridge Water Company; Aquarion Water
Company of Connecticut; Valley Council of Governments; New England Cable and
Telecommunications Association, Inc.; Connecticut Conference of Municipalities;
Verizon New York, Inc.; One Communications; Zagorsky, Zagorsky & Galske, P.C.; Ztar
Docket No. 12-06-09
Page 4
Mobile, Inc.; Preston Plains Water Company; CWA-Local 1298; Coxcom, LLC d/b/a Cox
Communications; Thames Valley Communications, Inc.; Conexions, LLC; Statewide
Video Advisory Council; Town of Ridgefield; Consumer Cellular, Inc.; Kevin McCarthy;
Alltel Communications, Inc.; Total Call Mobile, Inc.; Yankee Gas; Heritage Village Water
Company; Torrington Water Company; The Connecticut Light and Power Company; TMobile USA, Inc.; Valley Water Company; Avon Water Company; and West Service
Corporation.
II.
AUTHORITY ANALYSIS
A.
ADOPTION OF STANDARDS
The Authority hereby adopts and requires each EDC and gas LDC to incorporate
these Performance Standards into their Emergency Response Plan (ERP) and to
comply with the electric and gas performance standards attached as Appendix A and
Appendix B, respectively. Non-compliance with these standards may subject the EDC
or the gas LDC to the imposition of civil penalties pursuant to the General Statutes of
Connecticut (Conn. Gen. Stat.) §16-41. In the case of gas companies, these standards
apply to its manner of operations for a comparable scale of outage events.
The Authority notes that initial versions of the draft standards included certain
requirements for communications, staffing, equipment and vegetation management.
However, these topics are complex and involve many other interests other than electric
and gas operations and require a more comprehensive and participative review. Thus,
the Authority will incorporate the above communications, staffing and equipment
standards issues in Docket No. 12-09-13, PURA Investigation of the Best Practices of
Other State Public Utility Commissions, Public Utility Companies and Municipal Utilities'
Emergency Management Best Practices. The Authority will incorporate the abovereferenced vegetation management issues in Docket No. 12-01-10, PURA Investigation
into the Tree Trimming Practices of Connecticut’s Utility Companies.
In its Written Comments to the Authority's October 17, 2012 Notice of Written
Comment and Oral Argument, the OCC stated that the Performance Standards should
require an EDC to implement mobile data terminals (MDTs) or equivalent real time
electronic methods of communication with line crews. The Authority addressed this
issue in Order No. 3 of the Decision in Docket No. 11-09-09, in which the Authority
ordered as follows:
CL&P shall formulate a plan to assure that real-time damage assessment
and outage restoration data are available from field crews, including crews
from mutual assistance and line crews, and shall take action to ensure
that field crews utilize such technologies. CL&P shall submit its report on
the actions it has taken and plans to take in its submittals in Order No. 1.
Accordingly, the issue of MDTs or equivalent technology deployment is being
addressed pursuant to that Order, and, until that investigation is completed, any
requirement imposed by these standards is premature.
Docket No. 12-06-09
B.
Page 5
REPORTING REQUIREMENTS OF SECTIONS 3 AND 4 OF THE ACT
1.
Section 3(b), System Hardening
Section 3(b) of the Act requires the Authority to “…identify the most cost-effective
level of tree trimming and system hardening, including undergrounding, necessary to
achieve the maximum reliability of the system and to minimize service outages. As
documented in its Decision dated August 1, 2012, in Docket No. 11-09-09, PURA
Investigation of Public Service Companies’ Response to 2011 Storms, Tropical Storm
Irene and the October 2011 snowstorm (the 2011 Storms) had a more severe impact in
CL&P’s service territory than in UI’s service territory. The Authority is currently
investigating cost-effective ways to accomplish “hardening,” or increasing the storm
resiliency, of CL&P’s electric distribution system in Docket No. 12-07-06, Application of
The Connecticut Light and Power Company for Approval of its System Resiliency Plan.
In that proceeding, the Authority will act on a request by CL&P to approve its plan for
improving the storm resiliency of its electric distribution system, including expanding
tree trimming programs and other measures to reduce the impact of major storms. The
Authority is also examining ways to improve the cost-effectiveness of the vegetation
management programs of CL&P and UI in Docket No. 12-01-10. Taken collectively, the
Authority’s actions on these two proceedings will maximize the cost-effectiveness of
EDC expenditures targeted toward improving system reliability under major storm
conditions.
2.
Sections 3(c)1 and 3(c)2, Current Practices
Section 3(c)1 of the Act requires the Authority to review the following EDC and
gas LDC practices concerning service restoration after an emergency, including A)
estimates concerning potential damage and service outages prior to any emergency; B)
damage and service outage assessments after any emergency; C) restoration
management after any emergency, including access to alternate restoration resources
via regional and reciprocal aid contracts; D) planning for at-risk and vulnerable
customers; E) policies concerning communication with state and local officials and
customers; and F) need for mutual assistance during an emergency.
Section 3(c)2 of the Act requires the Authority to review the adequacy of each
utility’s infrastructure, facilities and equipment, including A) whether the utility is
following standard industry practice concerning operation and maintenance of such
infrastructure, facilities and equipment; and B) whether each utility had access to
adequate replacement equipment for such infrastructure, facilities and equipment during
the course of an emergency.
The EDCs and gas LDCs practices have been exhaustively reviewed in the
Authority’s August 1, 2012 Decision in Docket No. 11-09-09 and addressed in that
document. This subject matter was thoroughly reviewed over the course of this
proceeding and modified accordingly by the emergency restoration standards adopted
in this Decision.
Docket No. 12-06-09
3.
Page 6
Section 3(c)(3), Coordination Efforts
Section 3(c)(3) of the Act requires the Authority to review coordination efforts
between each EDC and any telecommunications company, community antenna
television (CATV) company, holders of a certificate of cable franchise authority or
certified competitive video service provider, as those terms are defined in Conn. Gen.
Stat. §16-1, including coordinated planning before any emergency.
CL&P’s coordination efforts with telecommunications companies and with holders
of certificates of cable franchise authority are defined in its ERP. The ERP’s provisions
apply to coordination efforts before, during and after an emergency. No specific
provisions are included regarding community antenna television companies or certified
competitive video service providers; however, such coordination efforts with such
entities are adequately covered by the provisions applicable to coordination with other
telecommunications entities.
UI’s coordination efforts with telecommunication companies and with holders of a
certificate of cable franchise authority are defined in its ERP. The ERP’s provisions
apply to coordination efforts before, during and after an emergency. No specific
provisions are included regarding community antenna television companies or certified
competitive video service providers; however, such coordination efforts with such
entities are adequately covered by the provisions applicable to coordination with other
telecommunications entities.
4.
Section 3(c)(4)(A), Tree Trimming Expenditures
Section 3(c)(4)(A) of the Act requires the Authority to determine the amount
spent by each electric distribution company for tree trimming in each year since such
company's most recent rate case.
Based on data provided by the CL&P and UI, the following charts illustrate the
vegetation management expenditures by each company.
Docket No. 12-06-09
Page 7
CL&P Vegetation Management Expenses
30,000,000
25,000,000
20,000,000
15,000,000
10,000,000
5,000,000
0
2007
2008
2009
Scheduled Maintenance
Other O&M
2010
2011
Capital
Source: Response to Interrogatory EN-10.
CL&P Vegetation Management Miles Trimmed
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500
0
2007
2008
Scheduled Maintenance
Source: Response to Interrogatory EN-10.
2009
Other O&M
2010
Capital
2011
Docket No. 12-06-09
Page 8
UI Vegetation Management Expenses
4,000,000
3,500,000
3,000,000
2,500,000
2,000,000
1,500,000
1,000,000
500,000
0
2007
2008
2009
VM Scheduled Maintenance
2010
2011
Other O&M
Source: Responses to Interrogatories EN-10 and EN-31.
UI Vegetation Management Miles Trimmed
500
480
460
440
420
400
380
360
2007
2008
2009
Source: Responses to Interrogatories EN-10 and EN-31.
2010
2011
Docket No. 12-06-09
5.
Page 9
Section 3(c)(4)(B), Tree Contact Reliability Impact
Section 3(c)(4)(B) of the Act requires the Authority to determine the
system SAIDI, as described in Conn. Gen. Stat. §16-245y, caused by falling
trees and limbs.1 The following charts illustrate this data.
CL&P System Average Interruption Duration Index
(SAIDI) Major Storms Excluded
160
140
Customer Minutes of Interruption
120
100
80
60
40
20
0
2007
2008
SAIDI - Tree Related
2009
2010
2011
SAIDI - All Interruptions
Source: Response to Interrogatory EN-025; CL&P Transmission and Distribution Reliability Performance report dated
March 31, 2012, and filed with the Authority in response to Order No. 12 in Docket No. 86-12-03 Long Range
Investigation To Examine the Adequacy of the Transmision and Distribution Systems of the Connecticut Light and
Power Company and The United Illuminating Company.
1
Conn. Gen. Stat. §16-245y defines the System Average Interruption Duration Index as the sum of
customer interruptions in a 12-month period, in minutes, divided by the average number of customers
served during that period, not including outages attributable to major storms, scheduled outages and
outages caused by customer equipment.
Docket No. 12-06-09
Page 10
UI System Average Interruption Duration Index
(SAIDI) Excluding Major Storms
120
100
80
60
40
20
0
2007
2008
2009
SAIDI - Tree Related
2010
2011
SAIDI - All Interruptions
Source: The Reliability and Performance of The United Illuminating Company’s Transmission and
Distribution System for 2011, filed on March 30, 2012 in Docket 86-12-03.
6. Section 3(c)(4)(C), Expanded Tree Trimming
Section 3(c)(4)(C) of the Act requires the Authority to determine the impact of
expanding the area adjacent to distribution lines for tree management, including an
analysis of the benefits and the costs of such expansion to ratepayers and the likelihood
that such expansion would decrease damage to infrastructure, facilities and equipment
used to distribute electricity and decrease service outage frequency or duration.
Expanding the area adjacent to distribution lines for tree management has both
financial and political implications. The financial impact can be projected first through
identifying the off-rights-of-way (off-ROW) tree population, and then by estimating
various associated costs including: the cost to identifying hazard trees, the cost of
seeking permission from property owners, and finally the costs associated with
conducting work to mitigate hazards or notify property owners of their obligation to
mitigate these hazard trees on their property. The political impact results from
objections and complaints to work in areas where the utilities have no established rights
and where this incursion is viewed as a nuisance and damaging to the environment.
Consequently, the costs associated with the political impacts are much harder to
quantify.
The efforts and costs of expanding the area adjacent to distribution lines for tree
management will be variable for each region or smaller subdivision based on off-ROW
tree conditions. Tree conditions vary significantly between rural, suburban and urban
Docket No. 12-06-09
Page 11
areas. Defining the off-ROW tree population of tall trees capable of falling on the lines
will provide a better gauge of potential costs. Areas with lower off-ROW tree
populations will have very little cost associated. The EDCs should have information on
these conditions.
The scope of this effort may be significantly reduced by identifying the key tree
species that most commonly cause outages during these types of storms and how
outages are most commonly caused by these species. In a study by the Maryland
Public Service Commission (MDPSC) in 2010 subsequent to significant utility electric
service outages from an ice storm and hurricane, it was found that over 75% of outages
resulted from off-ROW trees. However, these outages were caused by only a few
problem species. Various tree species show clear problems and trends with breakage
and behavior during various storm conditions (heavy winds, wet snow or ice).
Identification of these key species within the Connecticut service territory would narrow
the scope of the inspection and number of subject trees. Addressing these key species
should reduce effort and costs with a potentially significant improvement in storm
outage performance.
Potential benefits associated with an expanded trim area adjacent to distribution
lines would include reduced costs for restoration crews and materials along with
reduced claims from customers for spoilage. The utilities should have this information
from prior outages to use in defining benefit ranges. Other non-defined benefits would
include reduction in injuries and reduction in potential litigation costs for damage and/or
loss of life. These benefits would be much more difficult to quantify.
The Authority notes that it is currently determining the reasonableness of efforts
by CL&P to improve the storm resiliency of its system in Docket No. 12-07-06. A
substantial portion of CL&P’s efforts to improve storm resiliency are devoted to
increasing the scope of its enhanced tree trimming program, which is to remove trees
and limbs outside of the normal trim zone. Of the initiatives presented to the Authority
in that proceeding, enhanced tree trimming appears to be the most cost effective.
Based on historical analysis, CL&P expects that enhanced tree trimming (in areas in
which it is applied) will result in a 50% improvement in tree interruptions in non-storm
conditions and a 40% improvement in storm conditions, at a cost of $40,000 per mile.
Response to Interrogatory EN-2 in Docket No. 12-07-06.
7.
Section 3(c)(4)(D), Tree Contact Statistics
Section 3(c)(4)(D) of the Act requires the Authority to determine the percentage
of service outages during the 2011 Storms caused by trees and limbs outside the
current trim area.
No specific data exist to define the exact number of outages caused by trees
from outside the normal utility trim area. However, several estimates from different
sources referring to experience from the 2011 Storms can be compiled to approximate
the number of outages caused by trees from outside the normal utility trim area. The
various parties and their respective estimates are summarized as follows:
Docket No. 12-06-09




Page 12
Davies Consulting, which was retained by CL&P to analyze its response to the
2011 Storms, determined that most of the damage was caused by trees that
would not have been subject to normal vegetation maintenance trim;2
Liberty Consulting, the Authority’s consultant in Docket No. 11-09-09, determined
that approximately 80% of the outages were attributable to trees;3
The Two-Storm Panel Report estimated that up to 90% of the wires down during
Tropical Storm Irene were caused by trees;4
A study commissioned by the MDPSC5 examined outage data from 892 outages
and concluded that 78% of the outages were caused by trees off-ROW.
Based on these respective estimates, an indicative figure of the outages caused by
trees outside of the normal trim zone is approximately 78% of tree-related outages and
62% (80% x 78%) of all outages.
8.
Section 3(c)(4)(E), Standards for Roadside Care
Section 3(c)(4)(E) of the Act requires the Authority to determine the standards
appropriate for road-side tree care in the state, vegetation management practices in
utility rights-of-way, right tree-right place standards, and any other tree maintenance
standards have been recommended by the SVMTF.
Standards appropriate for tree management include the following:

Selection of appropriate trees near utility lines that will not interfere with electric
service reliability or physical or visual access for facility construction, operation,
inspection, inspection or repair. Many utilities, including CL&P and UI, have
active Right Tree-Right Place (RTRP) programs in place. The nationally
recognized organization that serves as the focal point for this type of program is
the Arbor Day Foundation (ADF). The ADF sponsors the Tree City, Tree Line
and Tree Campus programs that recognize communities, utilities and schools
that follow RTRP guidelines established by ADF. These guidelines include
selection of trees that will not interfere with electric service safety and reliability.
RTRP programs advocated by the ADF, utilities and other organizations include
development of lists of trees appropriate for planting near to electric facilities that
will not interfere with those facilities.
The SVMTF recommends establishment of a “Management Zone” approach that
includes an area up to 100 feet on either side of the overhead lines. Selection
and installation of trees within this Management Zone would be restricted
according to the distance from the lines. Wire Zones and Side Zones would be
defined with only certain trees that reach a defined maximum height permitted
within the defined zone.
2
Response to Interrogatory EL-21 in Docket No. 11-09-09, Attachment, pp. 93-97.
Liberty Consulting Report to the Authority in Docket No. 11-09-09, p. 34.
4 Governor’s Two Storm Panel Report, pp. 8-13.
5 mocoalliance.org/wp-content/upload/pepco-tree-report.pdf.
3
Docket No. 12-06-09

Page 13
Application of technically correct tree management standards and practices
(pruning and removal) to appropriately manage decadent trees and tree parts
that are more likely to fail sandards for utility vegetation management can be
found within the American National Standards Institute (ANSI) A300 series for
tree care. Standards most applicable for these purposes include:
o ANSI A300 Part 1: Tree, Shrub, and Other Woody Plant Maintenance –
Standard Practices, Pruning;
o ANSI A300 – Part 7 – Integrated Vegetation Management, subpart a.; Electric
Utility Rights-of-way;
o ANSI Z133.1 Arboricultural Operations Safety;
o OSHA 29 CFR 1910.269; and
o Best Management Practices, Utility Pruning of Trees.
Standards must recognize and provide for removal of overhang to protect against
ice and snow loads. Impact of ice and snow loads varies with tree species, (e.g.,
white pine branches significantly sag when loaded with ice or snow whereas oak
branches are not as affected), and so species impacts should be recognized and
addressed within these standards.
The SVMTF recommended that management standards be developed to
address management of volunteer trees and vines. The SVMTF recognizes that
volunteer trees and fast-growing vines have impacted storm damage and require
additional management.

The Hazard Tree Identification and Management Standards and Practices should
define routine inspection and documentation requirements for structurally
defective trees and species that can be reasonably identified by qualified
personnel who are positioned on utility easements or public property near to
electric facilities.
The SVMTF recommends tree removal standards be
developed to effectively identify hazard trees in a timely manner and trigger
appropriate pruning or removal actions to minimize the risk of falling trees or tree
parts for the electric facilities and public. This standard should include definition
of minimum inspection procedures, identification of minimum qualifications of
inspectors, description of minimum conditions to be observed and thresholds for
action, and the procedure to conduct appropriate mitigation work, or report
refusals. The standard should clearly define the responsible mitigation party as
the utility or property owner. The SVMTF has recommended inclusion of
property owner notification and consent procedures.
The SVMTF recommends standards be established for tree species and heights
within the defined Management Zone. Species and tree heights would be
managed within Wire Zones and Side Zones to balance procurement of tree
benefits with the integrity and reliability of the electric system.

Line clearance management cycle standards that are appropriate for tree growth
rates, tree conditions, and species characteristics. The SVMTF, CL&P and UI
have suggested a four-year cycle management program including a more
Docket No. 12-06-09
Page 14
aggressive overhang removal process. In fact, growth rates in coastal regions
may require a shorter, three-year cycle. Mortality or disease conditions may also
require shorter cycles on a short or long-term basis. Standards should be based
on focused research and conclusions based on findings representative of the
differing growth regions and tree conditions within the State.

Requirements that adequate financial resources be allocated to reasonably
complete tree and vegetation management work within the defined cycle. The
SVMTF has recommended that annual plans be submitted that describe and
document work scope with corresponding budget details. These annual plans
would include descriptions of planned maintenance within each town.

The SVMTF recommends standards be established to develop and conduct tree
inventories that include risk mapping of areas more likely to sustain storm
damage and that are sensitive to electric service interruptions (critical social or
emergency service headquarters, high population centers, key access roads,
etc.). Tree inventories are recognized by many utilities and the US Forest
Service as key components of effective tree management programs.
The Authority will consider the above standards for vegetation management in
the course of its proceedings in Docket No. 12-01-10.
C.
COST RECOVERY
The Authority recognizes that this Decision may result in the incurrence of costs
by the EDCs and LDCs to comply with requirements of the outage restoration
standards. The Authority determines that costs incurred by the EDCs and LDCs to
comply with the requirements of this Decision are generally recoverable in rates in a
future proceeding in which the EDC or LDC seeks to recover such costs, including
carrying charges calculated at the EDC or LDC average cost of capital, subject to
Authority review and approval of all such expenditures. In anticipation of such a future
proceeding in which detailed review of such expenditures by the Authority will be
necessary, each EDC and LDC shall maintain thorough documentation of all
expenditures related to compliance with the requirements of this Decision.
D.
PROCUREMENT OF CONTRACT RESOURCES
During the course of this proceeding, CL&P discussed its progress in achieving
an option-like arrangement to have first rights to call upon contractor support during
major storm conditions, to augment its own line resources. According to CL&P, this is a
first-of-a-kind concept in application to contract resources, and, to date, it has not
received enough information to determine the financial commitment that would be
required to subscribe a contract workforce under such an arrangement. Tr. 10/10/12, p.
72. The Authority believes that it is therefore most appropriate to proceed on this matter
as a pilot program, so that the Authority and CL&P can determine whether such
resources are cost effective. The Authority therefore orders implementation of this pilot
program below.
Docket No. 12-06-09
Page 15
III. CONCLUSION AND ORDERS
A.
CONCLUSION
The Authority has established performance standards that provide a clear
standard of care for electric distribution company and gas local distribution company
performance in an emergency. Each EDC and gas LDC is hereby required to
implement these standards. The Authority believes the standards established herein
compare favorably to similar standards established in other jurisdictions. The Authority
also provides all reporting information required to be submitted by Sections 3 and 4 of
the Act.
B.
ORDERS
For the following Orders, submit an original and two copies of the required
documentation to the Executive Secretary, Public Utilities Regulatory Authority, Ten
Franklin Square, New Britain, CT 06051, and file an electronic version through the
Authority’s website at www.ct.gov/pura. Submissions filed in compliance with Authority
Orders must be identified by all three of the following: Docket Number, Title and Order
Number.
1.
CL&P, UI, YGS, CNG and SCG shall incorporate the Performance Standards in
Appendices A and B, as appropriate, into their ERP and to implement them in
their manner of operations.
2.
Not later than November 23, 2012, CL&P and UI shall submit a report on the
state of their compliance with the EDC emergency restoration standards. In this
report, CL&P and UI shall clearly lineate each requirement of the standards that it
is presently not in compliance with, and shall state its plans for becoming
compliant with each requirement.
3.
Not later than the end of each calendar quarter, March 31, June 30, September
30, and December 31, CL&P and UI shall submit a report on the status of
compliance with the EDC emergency restoration standards, including a clear
statement on each requirement it is presently not in compliance with and plans
for becoming compliant. This Order begins with a report due December 31,
2012, and ends with the report stating that the company is in compliance with all
requirements of the standards.
4.
Not later than November 23, 2012, YGS, CNG and SCG shall submit a report on
the state of their respective compliance with the LDC emergency restoration
standards. In this report, YGS, CNG and SCG shall clearly lineate each
requirement of the standards that it is presently not in compliance with, and shall
state its plans for becoming compliant with each requirement.
5.
Not later than the end of each calendar quarter, March 31, June 30, September
30, and December 31, YGS, CNG and SCG shall submit a status report on the
status of compliance with the LDC emergency restoration standards, including a
clear statement on each requirement it is presently not in compliance with and
Docket No. 12-06-09
Page 16
plans for becoming compliant. This Order begins with a report due December
31, 2012, and ends with the report stating that the company is in compliance with
all requirements of the standards.
6.
CL&P shall initiate a pilot program to determine the feasibility and costeffectiveness of achieving an option arrangement to procure contractor resources
to support restoration and safety activities during and after a major storm. Not
later than March 31, 2013, CL&P shall provide a report to the Authority on its
experience in procuring such resources, and its plans to utilize resources
procured under such arrangements to supplement its own line forces in the
future.
Appendix A
State of Connecticut
Department of Energy and Environmental Protection
Public Utilities Regulatory Authority
Electric Distribution Company
Emergency Performance Standards
Docket No. 12-06-09
1.
Page 2
Purpose and Applicability
The purpose of these standards is to ensure that the electric distribution companies (EDCs) are
prepared for emergencies and disasters in order to minimize damage and inconvenience to the
public which may occur as a result of electric system failures, major outages, or hazards posed
by damage to electric distribution facilities. These standards apply to any Emergency Event,
which is defined as electric service interruptions involving 10% or more of the EDC’s total
number of customers who are out for a period of 48 consecutive hours or more. These
standards will facilitate investigations of the Public Utilities Regulatory Authority (PURA or
Authority) into the reasonableness of the utility’s response to Emergency Events. It should be
noted that these standards do not relieve the EDCs from the requirements of other standards
pertaining to service restoration for events of less severity than an Emergency Event, as defined
above.
2. Preparation
Each EDC will develop and implement the plans, procedures and conduct associated activities,
such as exercises, required by these standards and it’s Emergency Response Plan (ERP or
plan).1 In addition to submitting its ERP to the PURA for reviews of emergency plans every two
years, on or before July 1st, pursuant to the General Statutes of Connecticut (Conn. Gen. Stat.)
§16-32e, each EDC will also file the ERP in full when there have been any material changes in
the ERP.
a.
Emergency Response Plan
Each EDC will develop, implement, maintain and utilize an ERP so that the EDC is adequately
and sufficiently prepared to restore service to its customers in a safe and reasonably prompt
manner during an Emergency Event. The plan will help ensure that an EDC’s performance of its
responsibilities in the ERP, in conjunction with responsibilities and work performed by State
agencies, municipalities, other utility companies and the citizens of Connecticut, can collectively
help effectuate the State’s overriding goal to protect life and property during an emergency or
major outage. In addition, the plan will help assure each EDC effectively communicates the
scope and expected duration of an outage with the public, government entities, and other
utilities. This shall include at a minimum, but not be limited to the following.
i.
Alignment with NIMS/ICS
The ERP for each EDC should incorporate the structure and process of the National Incident
Management System (NIMS) and utilize the Incident Command System (ICS) to permit decentralization and re-centralization of command and control throughout an Emergency Event in
order to provide optimum and efficient response and utilization of resources.
1
In the event of ambiguity between these Standards and the ERP, the ERP shall be the primary control
document.
Docket No. 12-06-09
ii.
Page 3
Escalation Levels/Emergency Operations Center
Each ERP must contain escalation levels that define actions and trigger points consistent with at
least the following level of customer outages:




Level 1: 10% of all customers out;
Level 2: 30% of all customers out;
Level 3: 50% of all customers out; and
Level 4: 70% of all customers out.
These and other defined trigger points should be designed to direct the EDC to ensure:
 The decision to activate the EDC’s Emergency Operations Center (EOC) follows a
consistent level of emergency;
 Damage Assessment (DA) is expanded and enhanced in response to a pre-determined
level of customer outages;
 Estimated Restoration Times/Estimated Time to Restore (ERT/ETR) are suitably
tailored, whether automated or manually-provided, to the level of outage and the
accuracy of the data. This is especially critical for automated feeds to local or cloudbased Interactive Voice Response (IVR) facilities;
 Staging areas for food, fuel, materials, field work force, and lodging and other
decentralization efforts are optimized according to the level of outage; and
 Adequate staffing is designated for communications during the Emergency Event, in
particular assignment of staff to specific stakeholder categories, such as media, local
officials, customers, etc.
iii.
Damage Assessment
The ERP shall describe the process for assessing damage and, where appropriate, the use of
contingency resources required to expedite a response to the emergency. The ERP should
also specify the mode(s) of delivery of damage assessments. For example, mobile data
terminals or other electronic methods can be used, but are not required to be used to update
outage management system (OMS) to aid in restoration planning and estimated time of
restoration.
iv.
Restoration Priority
The ERP shall include guidelines for setting priorities for service restoration. In general, the
EDC shall set priorities such that service is restored first to critical customers, and second such
that the largest number of customers can receive service in the shortest amount of time. This
provision does not prohibit an EDC from simultaneously restoring critical customers, the largest
number of blocks of customers, and performing other restoration activities as described in its
ERP.
Docket No. 12-06-09
v.
Page 4
Safety
The ERP shall describe how the EDC will ensure the safety of the public and utility employees
and the EDC’s procedures for safety standby. The ERP shall include contingency measures
regarding the resources required to respond to an increased number of reports concerning
unsafe conditions.
vi.
Mutual Assistance
The ERP must be designed to provide for mutual assistance parameters that describe how the
EDC intends to employ resources available pursuant to mutual assistance agreements for
emergency response. Mutual assistance shall be requested when the EDC reasonably believes
that local resources are inadequate to assure timely restoration of service or public safety, or if
mutual assistance would substantially improve restoration times or mitigate safety hazards. The
ERP should include a storm matrix for various storm levels that identify the necessary mutual
aid and/or contractor resources necessary to restore customers within a prescribed time period
range. Additionally, the matrix should identify different types of storms and establish resource
requirements specific to those types of Emergency Events.
The ERP shall recognize the need to communicate mutual assistance activities with specified
state and local agencies. The ERP must also specify mutual assistance protocols and
prioritization. These could include: utilization of holding company resources, contract crew
reservations, local utility assistance, and organizations the EDC belongs to and participates in,
such as the North East Mutual Assistance Group (NEMAG), Edison Electric Institute (EEI)
Restore Power, and others as appropriate. The ERP must stipulate at what level of outage or
anticipated outage level the EDC will request mutual assistance, taking into account travel times
from remote resources, so as to ensure sufficient resources to rapidly and efficiently provide
restoration.
Each EDC shall annually notify the PURA by July 1st of the mutual aid groups to which it belongs
and whether there have been changes in the membership of those groups or material changes
in the rules of those groups within the previous 12 months.
The utility's ERP shall include a storm matrix for various storm levels that identifies the mutual
assistance and/or contractor resources necessary to restore customers; and in addition should
provide terms for revised mutual assistance resources after the initial forecast.
b.
i.
Communications Plans
State Agencies
Each EDC shall establish written communication protocols for timely and accurate information
exchange between the EDC and a pre-determined list of state agencies during Emergency
Events impacting larger areas such as multiple jurisdictions or state-wide. At a minimum this
should include:
Docket No. 12-06-09
Page 5
1. A database of relevant agencies such as the PURA, Department of Homeland Security
officials, and Department of Emergency Services and Public Protection, including current
contact information that is updated at least twice per calendar year;
2. Clearly defined communication channels for exchange of information during an
Emergency Event, such as WebEOC, email, website, social media, etc.;
3. Defined baselines for frequency of regular updates between the EDC and
pre-determined state agencies; and
4. Protocols establishing meetings twice per calendar year with the PURA, Department of
Homeland Security officials, and Department of Emergency Services and Public
Protection officials to:




Review and confirm coordination protocols for communication during an Emergency
Event;
Update and verify contact information among agencies;
Exchange other relevant information; and
Create a record of discussions to be shared among all defined agencies.
Each EDC shall establish protocols for participating in Emergency Support Function (ESF)-12
for Emergency Events impacting larger areas such as multiple jurisdictions or state-wide. At a
minimum this should include:
1. The staff assigned to serve as liaisons with ESF-12 team members; and
2. Participation in ESF-12 emergency exercise training as conducted by state agencies.
ii.
Local Agencies
Each EDC shall establish written communication protocols for timely and accurate information
exchange between the EDC and any pre-determined local agency such as public safety officials
and agencies, local elected officials, and others the EDC deems appropriate during Emergency
Events impacting multiple jurisdictions. At a minimum this should include:
1. A written description of Town Liaison or similar programs with clearly defined roles and
responsibilities, staff identified to serve in these roles, and training schedule;
2. A database of relevant local agencies, including current contact information for
individuals and departments, updated at least once per calendar year;
3. Clearly defined communication channels for exchange of information during an
Emergency Event, such as WebEOC, possibly supplemented with other channels such s
company website, email and social media;
4. Defined baselines for frequency of regular updates between the EDC and predetermined local agencies; and
5. Protocols establishing pre-event meetings at least once per calendar year with predetermined local agencies to:
 Review and confirm coordination protocols for communication during an Emergency
Event;
 Update and verify contact information among agencies;
Docket No. 12-06-09


Page 6
Exchange other relevant information; and
Create a record of discussions to be shared among all defined agencies.
Each EDC shall establish written protocols for initiating contact with defined staff from each
municipality served no later than two days prior to an expected event, or as soon as reasonably
practicable based on availability of adequate information.
Each EDC shall coordinate with local agencies within their service territory to develop one
standard template listing the type of information that must be relayed to those local agencies
prior to an Emergency Event to ensure consistency of information across jurisdictions and to
meet their needs for relevant information. At a minimum the template should include:
1. Local agency recipients including contact information;
2. The frequency of updates that will be provided throughout the Emergency Event; and
3. A method for disseminating information to local agency designees.
Each EDC shall develop one standard template listing the type of information that must be
relayed to those local agencies within their service territory throughout an Emergency Event to
ensure consistency of information across jurisdictions and to meet their needs for relevant
information. At a minimum the template should include:
1.
2.
3.
4.
5.
6.
iii.
Local agency recipients including contact information;
The frequency of updates that will be provided throughout the Emergency Event;
A method for disseminating information to local agency designees;
Restoration information, as available;
The extent of impact; and
Emergency contacts for local agencies.
Other Utilities
Each EDC shall establish protocols for adequate and timely communication and coordination
between itself and appropriate electric distribution, gas, telephone or telecommunications
company or voice over Internet protocol service provider, as defined in Conn. Gen. Stat.
§28-30b. These protocols must be established to permit communication and coordination for
Emergency Events with and without activation of the State of Connecticut Emergency
Operations Center (State EOC). During Emergency Events in which the state EOC is opened,
the EDCs are expected to provide liaison and expert staffing in the state EOC to fulfill the
requirements of ESF-12.
c.
Exercises
Each EDC must conduct and participate in training and drills/exercises to ensure effective and
efficient performance of personnel during Emergency Events, and to ensure that each EDC has
the ability to restore service to its customers in a safe and reasonably prompt manner.
Docket No. 12-06-09
i.
Page 7
Annual Exercises
1. Each EDC shall conduct an exercise using the procedures set forth in the utility’s ERP.
If the EDC uses the plan during such 12 month period in responding to an Emergency
Event, the utility must then complete an exercise within 18 months;
2. Each EDC shall annually evaluate its response to an exercise or major outage. The
evaluation shall be provided to the PURA within 60 days after the exercise or event;
3. Each EDC shall train designated personnel each calendar year in preparation for events.
The training shall be designed to overcome problems identified in the evaluations of
responses to an event or exercise and shall reflect any relevant changes to the EDC’s
plan;
4. Each EDC shall provide no less than ten days prior notice of its annual exercise to the
PURA, the Department of Emergency Services and Public Protection, the chief elected
official of each municipality in its service territory and any state-established emergency
office(s) for the region(s) in which the exercise is to be performed, and to appropriate
local authorities; and
5. The EDC shall participate in other emergency exercises, which are conducted by the
state or any state-established emergency office for one or more regions in the EDC’s
service territory, that is designed to address problems on electric distribution facilities or
services and to which the utility has been invited to participate.
ii.
Large-scale/Regional Exercises
1. Every three calendar years, each EDC shall conduct or participate in a comprehensive
emergency exercise to test and evaluate major components of its plan and shall invite a
cross-section of the following, or their representatives, located within the EDC’s service
territory, to the exercise:





Chief elected official and other elected officials;
County/regional emergency management directors;
Fire and police departments;
Community organizations such as the American Red Cross, which have participated
in prior such exercises or which the EDC reasonably concludes should participate in
such exercises; and
the PURA.
2. Each EDC shall participate in each statewide emergency preparedness drill conducted
by the state in which the state extended an invitation for participation to the EDC;
3. The large-scale exercises that are held every three years should consider the highest
level event covered in the ERP, for example, a Level 4 event, with up to 70% of its
customers suffering an extended outage; and
Docket No. 12-06-09
Page 8
4. Provide after-action and lessons-learned reports to the EDC’s participants and any other
participants whom the EDC recommends should modify or improve their performance,
and file these with PURA within 60 days following each exercise.
3. Restoration/Recovery
Each EDC shall restore service to its customers in a safe and reasonable manner during all
service interruptions and outages. During an Emergency Event, this shall include at a minimum
implementing all applicable components of a utility's ERP related to restoration of service, as
described in the following:
3.1. Damage Assessment
Each EDC shall execute its process for assessing damage and providing timely updates to the
outage management system (OMS), or to the EDC’s alternative process to the OMS if there is
an OMS failure, of the extent of system damage utilizing processes and/or technology to
minimize the latency between damage assessment and restoration work planning and
estimations of estimated time of restoration.
3.2. Restoration Priority
Each EDC shall abide by the guidelines and priorities for service restoration contained in its
ERP. In general, the utility shall set priorities so that service is restored first to critical
customers, and second so that the largest number of customers can receive service in the
shortest amount of time, but this provision does not prohibit a utility from simultaneously
restoring critical customers, the largest number or blocks of customers, and performing other
restoration activities described in its ERP.
3.3. Communications Execution
3.3.1. State Agencies
Each EDC shall establish success measures to evaluate communication prior to and during
events with a pre-determined list of state agencies to identify opportunities for improvement.
3.3.2. Local Agencies
Each EDC shall establish success measures to evaluate communication prior to and during
events with a pre-determined list of local agencies substantially impacted by the Emergency
Event in its service territory to identify opportunities for improvement.
3.4. Mutual Assistance
Each EDC shall employ the storm matrix referenced in Section 1.1.6, Mutual Assistance to
define anticipated resource requirements in advance of the Emergency Event, as soon as initial
notification of the reasonable likelihood of the occurrence of an event is known. Based on the
matrix, determine the optimum time, after the onset of an Emergency Event, to begin the
process of evaluating and documenting the need for mutual assistance. The EDC is not
Docket No. 12-06-09
Page 9
required to seek assistance if it would not substantially expedite restoration of electric service or
substantially promote public safety. The EDC should periodically reevaluate the need for
assistance during the period of the outage.
3.5. Safety
Each EDC shall review safety expectations with incoming contractor(s) and utility mutual aid
support crews prior to allowing these crews to begin restoration work. This would include U.S.
Occupational Safety and Health Agency requirements and the EDC’s own safety standards.
EDCs should also continue to be responsible for reporting safety incidents to the PURA in
compliance with the applicable accident reporting requirements of §16-16-3 of the Regulations
of Connecticut State Agencies, and applicable provisions in the Code of Federal Regulations
(CFR) specific to electric power transmission and distribution at 29 CFR Part 1910.269.
3.6. Restoration Targets
Each EDC shall make all reasonable efforts to restore service within the shortest time
practicable consistent with ERP targets and safety. During an Emergency Event, this shall
include, at a minimum, implementing all applicable components of the utility’s ERP related to
restoration of service.
3.7. After Action Report
Each EDC shall submit a written report to the PURA within 60 days after the end of an event. In
preparation for these reports, the EDC should establish a standard template for collecting
desired information following an event from staff at all levels of the EDC, each municipality and
local agencies within its service territory impacted by the Emergency Event, as well as the
Department of Emergency Services and Public Protection in order to assist in lessons learned
and continual improvement. These may include:
1. Information necessary to evaluate pre-established measures defined under
Restoration/Recovery;
2. Facilitated forums to gather information and exchange ideas for improvement between
EDC staff at all levels of the organization;
3. Facilitated forums to gather information and exchange ideas for improvement with
agency representatives; and
4. Identification of gaps and develop action steps for addressing areas for improvement.
Appendix B
State of Connecticut
Department of Energy and Environmental Protection
Public Utilities Regulatory Authority
Natural Gas
Local Distribution Company
Emergency Performance Standards
Docket No. 12-06-09
1.
Page 2
Purpose and Applicability
The purpose of these standards is to ensure that Local Gas Distribution Companies (Gas LDC)
are prepared for emergencies and disasters in order to minimize damage and inconvenience to
the public which may occur as a result of gas system failures, major outages, or hazards posed
by damage to natural gas distribution facilities. These standards pertain to an Emergency
Event, which is defined as gas service interruptions involving 1%1 or more of the Gas LDC’s
total number of customers who are out for a period of 48 consecutive hours or more. These
standards will facilitate Public Utilities Regulatory Authority (PURA or Authority) investigations
into the reasonableness of the Gas LDC’s response to emergencies and major outages. It
should be noted that these standards do not relieve the Gas LDCs from abiding by other
standards pertaining to service restoration for events of less severity than an Emergency Event
as defined above.
2. Preparation
Each Gas LDC shall develop and implement plans and procedures, and conduct associated
activities, such as exercises required by these standards and its Emergency Response Plan
(ERP or plan).2 In addition to submitting its ERP to the PURA for review every two years on or
before July 1st pursuant to the General Statutes of Connecticut (Conn. Gen. Stat.) §16-32e,
each Gas LDC will file the ERP in full any time there are material changes in the ERP.
b.
Federal Safety Standards
Each Gas LDC must have written procedures consistent with those required by 49 U.S.C. §§
60101 through 60125; 49 C.F.R. Part 192 Transportation of Natural and Other Gas by Pipeline:
Minimum Federal Safety Standards.
c.
Emergency Response Plan
Each Gas LDC shall develop, implement, maintain and utilize an ERP so that the Gas LDC is
adequately and sufficiently prepared to restore service to its customers in a safe and reasonable
manner during an Emergency Event. The plan will help ensure that the Gas LDC, in
conjunction with State agencies, municipalities, other utility companies and the citizens of
Connecticut can collectively effectuate the State’s overriding goal to protect life and property
during an emergency event and communicate the scope and expected duration of an outage.
This shall include at a minimum, but not be limited to the following:
1 In developing these gas standards, a realistic level of potential gas service interruptions as compared to electric
service interruptions was sought. Based on gas industry experience 1% or more of the Gas LDC’s total number
of customers who are out for a period of 48 consecutive hours is a more appropriate initial trigger point than the
10% used for EDCs.
2 In the event of ambiguity between these standards and the ERP, the ERP shall be the primary control document.
Docket No. 12-06-09
i.
Page 3
Alignment with NIMS/ICS
The ERP for each Gas LDC should incorporate the structure and process of the National
Incident Management System (NIMS) and utilize the Incident Command System (ICS) to permit
de-centralization and re-centralization of command and control throughout the Emergency
Event in order to provide optimum and efficient response and utilization of resources.
ii.
Escalation Levels
The ERP must contain escalation levels that define actions and trigger points consistent with at
least the following level of customer outages:




Level 1:
Level 2:
Level 3:
Level 4:
1% of all customers out;
3% of all customers out;
5% of all customers out; and
7% customers out.
These and other defined trigger points should be designated to direct the Gas LDC to ensure:
 The decision to activate the staff and the Gas LDC’s Emergency Operations Center
(EOC) follows a consistent level of emergency;
 Identification of staging areas for food, fuel, materials, field work force, and lodging;
 Designated staffing for communications during Emergency Event;
 Sufficient personnel based on category of Emergency Event; and
 Assignment of staff to specific stakeholder categories, such as media, local officials,
customers, etc.
iii.
Damage Assessment
The ERP shall describe the process for assessing damage and, where appropriate, the use of
contingency resources required to expedite a response to the Emergency Event. The ERP
should also specify the mode of delivery of damage assessments, for example, mobile data
terminals or other electronic methods or processes can be used, but are not required to be used
to provide timely updates to facilitate restoration planning and estimated time of restoration.
iv.
Restoration Priority
The ERP shall include guidelines for setting priorities for service restoration. In general, the
Gas LDC shall set priorities so gas service is restored first to critical customers, and second so
that the largest number of customers can receive service in the shortest amount of time taking
into account safety protocols and operating practices when restoring the affected portion of the
distribution system.
v.
Safety
The ERP shall describe how the Gas LDC will ensure the safety of the public and utility
employees. The plan shall include contingency measures regarding the resources required to
respond to an increased number of outages.
Docket No. 12-06-09
vi.
Page 4
Mutual Assistance
The ERP must be designed to provide for mutual assistance parameters that describe how the
Gas LDC intends to employ resources available pursuant to mutual assistance agreements for
emergency response. Mutual assistance shall be requested when the Gas LDC reasonably
believes local resources are inadequate to assure timely restoration of service or public safety,
or if mutual assistance would substantially improve restoration times or mitigate safety hazards.
The plan shall recognize the need to communicate mutual assistance activities with specified
State and local entities. The plan must also specify mutual assistance protocols and
prioritization, for example, utilization of holding company resources, contract crew reservations,
local utility assistance, and organizations the Gas LDC belongs to and participates in, such as
the Northeast Gas Association (NGA), American Gas Association (AGA), and others as
appropriate. The plan must stipulate at what level of outage or anticipated outage level the Gas
LDC will request mutual assistance, so as to ensure sufficient resources to safely, rapidly, and
efficiently provide restoration.
Each Gas LDC shall notify the PURA annually of the mutual assistance groups to which it
belongs and whether there have been changes in the membership of those groups or material
changes in the rules of those groups since the previous notification.
d.
i.
Communications Plans
State Agencies
Each Gas LDC shall establish written communication protocols for timely and accurate
information exchange between the Gas LDC and the list of predetermined state agencies set
forth in the ERP during Emergency Events impacting larger areas such as multiple jurisdictions
or state-wide. At a minimum this should include:
1. Database of relevant agencies such as the PURA, Department of Homeland Security
officials, and Department of Emergency Services and Public Protection, including current
contact information that is updated annually;
2. Clearly defined communication channels for exchange of information during an
Emergency Event, such as WebEOC, possibly supplemented with other channels such
as company website, email and social media;
3. Defined baselines for frequency of regular updates between the Gas LDC and predetermined state agencies; and
4. Protocols establishing annual meetings or communication with the PURA, Department of
Homeland Security officials, and Department of Emergency Services and Public
Protection officials to:




Review and confirm coordination protocols for communication during an Emergency
Event;
Update and verify contact information among agencies;
Exchange other relevant information; and
Create a record of discussions to be shared among all defined agencies.
Docket No. 12-06-09
Page 5
Each Gas LDC shall establish protocols for participating in the Emergency Support Function
(ESF)-12, as activated by the State for Emergency Events impacting larger areas such as
multiple jurisdictions or state-wide. At a minimum this shall include:
1. Assigned staff to serve as liaisons with ESF-12 team members such as regional
coordinators and representatives; and
2. Participation in state-sponsored ESF-12 emergency exercise training.
ii.
Local Agencies
Each Gas LDC shall establish written communication protocols for timely and accurate
information exchange between the Gas LDC and any pre-determined local agency that is listed
in its ERP such as public safety officials and agencies, local elected officials, and others the
Gas LDC deems appropriate during Emergency Events impacting multiple jurisdictions. At a
minimum this shall include:
1. Written description of Town Liaison or similar program with clearly defined roles and
responsibilities, staff identified to serve in these roles, and training schedule;
2. A database of relevant local agencies, including current contact information for
individuals and departments that is updated annually;
3. Clearly defined communication channels for exchange of information during an
Emergency Event, such as WebEOC; possibly supplemented with other channels such
as company website, e-mail and social media;
4. Defined baselines for frequency of regular updates between the Gas LDC and predetermined local agencies; and
5. Protocols establishing annual meetings with pre-determined local agencies to:
 Review and confirm coordination protocols for communication during an Emergency
Event;
 Update and verify contact information among agencies;
 Exchange other relevant information; and
 Create a record of discussions to be shared among all defined agencies.
Each Gas LDC shall establish written protocols for initiating contact with defined staff from each
municipality served. Information should be conveyed as soon as reasonably practicable based
on availability of adequate information.
Each Gas LDC shall develop a standard template listing the type of information that must be
relayed to local agencies throughout an Emergency Event to ensure consistency of information
across jurisdictions and to meet their needs for relevant information. At a minimum the template
shall include:
Docket No. 12-06-09
Page 6
1. Local agency recipients including contact information;
2. Frequency of updates that will be provided throughout the Emergency Event;
3. A method for disseminating information to local agency designees;
4. Restoration information, as available;
5. Extent of impact; and
6. Emergency contacts for local agencies.
iii.
Other Utilities
Each Gas LDC shall provide protocols to ensure adequate and timely communication and
coordination between any appropriate gas distribution, electric, telephone or
telecommunications company or voice over Internet protocol service provider, as defined in
Conn. Gen. Stat. §28-30b. These protocols must be established to permit communication and
coordination for Emergency Events with and without activation of the State of Connecticut
Emergency Operations Center (State EOC). During Emergency Events in which the State EOC
is opened, the Gas LDCs are further expected to provide liaison and expert staffing to fulfill the
requirements of ESF-12.
e.
Exercises
Each Gas LDC must conduct and participate in training and drills/exercises to ensure effective
and efficient performance of personnel during Emergency Events, and to ensure that each Gas
LDC has the ability to restore service to its customers in a safe and reasonable manner.
i.
Annual Exercises
1. Each Gas LDC shall conduct an exercise annually using the procedures set forth in the
Gas LDC’s ERP. If the Gas LDC uses the plan during the year in responding to an
Emergency Event, that Emergency Event shall qualify as an annual exercise, and the
Gas LDC is not required to conduct an exercise for that period, but must conduct the
next exercise within eighteen months;
2. Each Gas LDC shall annually evaluate its response to the exercise or Emergency Event.
The evaluation shall be provided to the PURA within 60 days after the exercise or
Emergency Event;
3. Each Gas LDC shall annually train designated personnel in preparation for Emergency
Events. The training shall be designed to overcome problems identified in the
evaluations of responses to an Emergency Event or exercise and shall reflect relevant
changes to the plan;
Docket No. 12-06-09
Page 7
4. Each Gas LDC shall provide no less than ten days prior notice of its annual exercise to
the PURA, the Department of Emergency Services and Public Protection, the chief
elected official of each municipality in its service territory and any governmental
emergency offices for the region in which the exercise is to be performed; and
5. The Gas LDC shall participate in other emergency exercises which are conducted by
the state or any governmental emergency office for one or more regions in the Gas
LDC’s service territory that is designed to address problems on gas distribution facilities
or services, including those emergency exercises of the state emergency offices.
ii.
Large-scale/Regional Exercises
1. Every three years, each Gas LDC shall conduct or participate in a comprehensive
emergency event exercise to test and evaluate major components of its emergency plan
and shall invite a cross-section of the following, or their representatives, to the exercise:

Chief elected official of each affected municipality;

Regional emergency management directors

Fire and police departments;

Community organizations such as the American Red Cross; and others which have
participated in prior such exercises or which the Gas LDC reasonably concludes
should participate in such exercises; and

The PURA.
2. Each Gas LDC shall participate in each statewide emergency preparedness drill
conducted by the state in which the state extended an invitation for participation to the
Gas LDC;
3. The exercises held every three years should consider the highest level emergency event
covered in the ERP, for example, a Level 4 emergency event, with 7% or more of its
customers experiencing an extended outage in excess of 48 consecutive hours; and
4. Each Gas LDC shall provide after-action and lessons-learned reports to participants and
file these with the PURA within 60 days following each exercise.
3. Restoration/Recovery
Each Gas LDC shall restore service to its customers in a safe and reasonable manner during all
service interruptions and outages. During an Emergency Event, this shall include at a minimum,
Docket No. 12-06-09
Page 8
but not be limited to, implementing all applicable components of a Gas LDC’s ERP related to
restoration of service, as described in the following:
3.1. Damage Assessment
Each Gas LDC shall execute its process for assessing damage and providing timely notification
through the communication paths defined in the ERP of the extent of system damage utilizing
processes and/or technology to minimize the latency between damage assessment and
restoration work planning and Estimated Time of Restoration.
3.2. Restoration Priority
Each Gas LDC shall abide by the guidelines and priorities for service restoration contained in its
ERP. In general, the Gas LDC shall set priorities so that service is restored first to critical
customers, and second so that the largest number of customers receive service in the shortest
amount of time taking into account safety protocols and operating practices when restoring the
affected portion of the distribution system.
3.3. Communications Execution
iii.
State Agencies
Each Gas LDC shall establish success measures to evaluate communication during Emergency
Events with state agencies to identify opportunities for continual improvement.
iv.
Local Agencies
Each Gas LDC shall establish success measures to evaluate communication during Emergency
Events with local agencies to identify opportunities for continual improvement.
3.4. Mutual Assistance
Each Gas LDC shall determine the optimum time, after the onset of an Emergency Event, to
begin the process of evaluating and documenting the need for mutual assistance. The Gas
LDC is not required to seek assistance if it would not reasonably be expected to substantially
expedite restoration of gas service or promote public safety. The Gas LDC shall reevaluate the
need for mutual assistance throughout the period of the Emergency Event.
3.5. Safety
Each Gas LDC shall review safety expectations with incoming contractor(s) and utility mutual
aid support crews prior to allowing these crews to begin restoration work. This would include
OSHA requirements and the Gas LDC’s additional safety standards. Gas LDCs should also
continue to be responsible for reporting safety incidents to the PURA in compliance with the
accident reporting requirements in §16-16-3 of theRegulations of Connecticut State Agencies.
Docket No. 12-06-09
Page 9
3.6. Restoration Targets
Each Gas LDC shall make all reasonable efforts to restore service interruptions within the
shortest time practicable consistent with the ERP and with safety. During an Emergency Event,
this shall include at a minimum, but not be limited to, implementing all applicable components of
the Gas LDC’s ERP related to restoration of service.
3.7. After Action Report
Gas LDCs shall submit a written report to the PURA within 60 days after the end of an
Emergency Event. In preparation for these reports, the Gas LDC should establish a standard
template for collecting desired information following an Emergency Event from staff at all levels
of the Gas LDC, as well as the Department of Emergency Services and Public Protection and
local agencies, in order to assist in lessons learned and continual improvement. These may
include:

Information necessary
Restoration/Recovery;

Facilitated forums to gather information and exchange ideas for improvement between
Gas LDC staff at all levels of the organization;

Facilitated forums to gather information and exchange ideas for improvement with
agency representatives; and

Identification of gaps and development of action steps for addressing areas for
improvement.
to
evaluate
pre-established
measures
defined
under
The Connecticut Department of Energy and Environmental Protection is an
Affirmative Action/Equal Opportunity Employer that is committed to requirements
of the Americans with Disabilities Act. Any person with a disability who may
need information in an alternative format may contact the agency’s ADA
Coordinator at 860-424-3194 or at deep.hrmed@ct.gov. Any person with limited
proficiency in English, who may need information in another language, may
contact the agency’s Title VI Coordinator at 860-424-3035 or at
deep.aaoffice@ct.gov. Any person with a hearing impairment may call the State
of Connecticut relay number – 711. Discrimination complaints may be filed with
DEEP’s Title VI Coordinator. Requests for accommodations must be made at
least two weeks prior to any agency hearing, program or event.
DOCKET NO. 12-06-09
PURA
ESTABLISHMENT
OF
PERFORMANCE
STANDARDS FOR ELECTRIC AND GAS COMPANIES
This Decision is adopted by the following Directors:
Arthur H. House
John W. Betkoski, III
CERTIFICATE OF SERVICE
The foregoing is a true and correct copy of the Decision issued by the Public
Utilities Regulatory Authority, State of Connecticut, and was forwarded by Certified Mail
to all parties of record in this proceeding on the date indicated.
November 1, 2012
Kimberley J. Santopietro
Executive Secretary
Department of Energy and Environmental Protection
Public Utilities Regulatory Authority
Date