The Moreland Commission on Utility Storm Preparation and Response, in its June 22 final report to New York Gov. Andrew Cuomo, recommended that utilities harden their systems by prioritizing investments in infrastructure to be more resilient to the ever-increasing threat of severe weather.
Cuomo directed the commission in November 2012 to investigate the state’s power utility companies’ response to recent storms affecting New York and the adequacy of regulatory oversight of the utilities, as well as to review the state’s energy agency and authority functions, according to a June 23 statement from the governor.
In its report, the commission recommended that the infrastructure-hardening costs be paid as a preferred first step by redirecting funding that is currently collected from ratepayers through the temporary state energy and utility service conservation assessment and provided to the State General Fund to now support electric infrastructure-hardening investments.
As that will likely not provide enough resources, other funding options are redirecting clean energy funds, the commission added, noting, “The commission believes, as difficult and costly as it may be, that it is better to pay for storm hardening now, rather than pay the devastating costs that failure to harden will cost later.”
The commission also said that the state should create an independent consumer advocacy board that represents all utility ratepayers in rate cases and general consumer-related functions.
Furthermore, the commission said that the more than 100 energy efficiency portfolio standard (EEPS) programs regulated by the state Public Service Commission (PSC), and administered by the New York State Energy Research and Development Authority and the utilities, have led to customer confusion and unnecessary competition between a state agency and the investor-owned utilities.
The commission recommended that the PSC continue regulating the EEPS program, but that the responsibility for program administration is clearly delineated between NYSERDA and the investor-owned utilities so they are not competing for the same customer base.
The commission identified industry-wide deficiencies that need to be addressed across all utilities, including flaws in the drafting, drilling and actual effectiveness of utility emergency response plans; failure to develop localized estimated restoration times and failure to explain the difference between those two estimates to customers; inadequate planning for the effects of storm surge flooding; and the depleted rank of lineworkers in the industry.
For instance, the preparation and response to coastal flooding of Consolidated Edison’s (NYSE:ED) Consolidated Edison Company of New York was inadequate. The company was severely affected by coastal flooding during Hurricane Sandy, where around 30,000 of its customers experienced flood damage.
The company also faced significant flooding to its own equipment, including flooding that resulted in an explosion-like arcing of a piece of equipment in a transmission substation, the commission added.
Another company, New York State Electric and Gas (NYSEG), had problems providing timely localized estimated times of restoration (ETRs) to customers within its Brewster service territory during Sandy. Its slow damage assessment process contributed to its failure to provide timely localized ETRs. The commission also said that NYSEG’s insufficient vegetation management along its transmission rights-of-way further complicated the damage assessment process.
National Grid New York also did not adequately plan for flooding during Hurricane Irene and Tropical Storm Lee, the commission said, adding that the company chose not to undertake a comprehensive risk analysis of its potentially flood-prone installations, instead doing piecemeal evaluations of its transmission substations and of those substations that had been affected by flooding in the past.
“National Grid has reviewed the final report of the Moreland Commission on Utility Storm Preparation and Response and we share in its goal of providing the highest level of service to our New York customers, especially given the unprecedented frequency and intensity of recent storms,” Ken Daly, National Grid president, New York State, said in a June 24 statement provided to TransmissionHub. “We were very well prepared for these storms and were pleased to see several of our storm procedures and community outreach efforts cited as best practices. At the same time, we will work with the governor’s office and others to address the many concerns cited in the report in order to make the necessary investments and further improve the service we provide to our customers.”
National Grid USA, which operates in several states including New York and Massachusetts, is a subsidiary of National Grid plc.
According to the governor’s statement, among its recommendations, the commission said utilities should improve the development and issuance of localized and individual ETRs while managing customers’ expectations regarding the reliability of the first mandated ETR.
Utilities should also review existing staffing levels and evaluate the impacts of an aging workforce on their abilities to effectively respond to major storms.
Recommendations for utility-specific improvements call for Con Edison to formalize in its corporate coastal storm plan actions taken to resolve resource concerns and coordinate with government to identify critical infrastructure locations.
For Consolidated Edison’s Orange and Rockland (O&R), there is a need for a formalized procedure for allocating resources between O&R and its sister company, Con Edison.
NYSEG, a subsidiary of Iberdrola USA, which is a subsidiary of Iberdrola, S.A., should improve the functionality of storm centers, such as the Brewster service center, and ensure the centers have sufficient communication capabilities.
The statement also noted that the commission recommended that National Grid take steps to bolster the oversight of its emergency planning function, including through the possible addition of other staff members to the emergency planning team.