New York state regulators recently adopted a scorecard for use as a guide in assessing each electric utility’s service restoration programs after significant outages, to assist in holding the utilities accountable to certain performance levels, and to guide utilities as to the regulators’ expectations for their restoration efforts.
The state Public Service Commission (PSC) also said in its order, issued and effective on Dec. 23, that Central Hudson Gas & Electric, New York State Electric and Gas (NYSEG), Rochester Gas and Electric (RG&E), Niagara Mohawk d/b/a National Grid plc subsidiary National Grid USA, and Consolidated Edison (NYSE:ED) subsidiaries Consolidated Edison Company of New York and Orange and Rockland Utilities each is to submit data for the scorecard within 30 days of the completion of customer restoration after, for instance, any outage that lasts for more than three days and any outage for which regulatory staff requests such data.
The provision of safe and reliable electric energy is critical to the health and safety of New Yorkers and a fundamental responsibility assigned by statute to the utilities, the PSC said.
“Our assessment of the importance of this responsibility was reinforced by our recent experiences with Hurricane Irene, Tropical Storm Lee, and Superstorm Sandy,” the PSC said, adding that each of those extreme weather events resulted in the loss of electric service for hundreds of thousands of customers over extended periods of time.
The purpose of the proceeding was to develop a quantitative tool that the utilities and the PSC could apply to assess electric utility performance in restoring electric service during outages that result from a major storm or other outage event.
“Through the use of this guidance tool we come closer to our goal of performance based assessment through which deficient utility practices and decision-making can be identified and disincented and excellent utility performance can be recognized and rewarded,” the PSC added.
The scorecard that the PSC has adopted has been developed to work with the recent amendments to the Public Service Law (PSL), including the new provisions regarding administrative penalties. Those new provisions, among other things, require electric corporations to file emergency plans annually, specify subject areas to be covered in the emergency plans subject to PSC review and approval, the PSC added.
The PSC also noted that the scorecard assigns metrics and points into three categories: preparation, 150 points; operational response, 550 points; and communications, 300 points.
The preparation metrics focus on utility activities in anticipation of a significant outage event, while the operational response category evaluates the utility’s performance as a significant outage event is occurring and during the recovery period after the event until normal service is restored. The communications category assesses the utility’s ability to receive and disseminate information about the outage event and about the recovery process.
Under the preparation category, 15 points are given for participation in all pre-event mutual assistance group calls, for instance. Under the communication category, for example, 30 points are given if municipal calls are held and are highly effective.
The PSC asked for comments by last September on a draft scorecard. In October 2012 comments, the City of New York noted that it and the coalition of investor-owned utilities (IOUs), or the “joint utilities,” separately filed on Sept. 19, 2012, comments on the revised scorecard.
The city said that the joint utilities recommended extensive changes to the revised scorecard that, if adopted as proposed, would diminish the value and effectiveness of the scorecard and ensure that it falls short of becoming the tool that New York Gov. Andrew Cuomo envisioned when he directed the PSC to develop and implement it.
In its order, the PSC said that it understands the concerns expressed by some that the implementation of the scorecard may have unintended consequences and therefore, “the scorecard will be a dynamic and fluid tool subject to periodic review and improvement.”
The scorecard is specific to electric utilities because it is apparent that the most comprehensive and pressing need and, hence, the greatest benefit to customers and the public is from utility performance in that area, the PSC said, adding that as a practical matter, electric utilities have historically been affected more by storms than other regulated services.
Noting that the city recommended that the scorecard be applied to all outages that, for instance, last 24 hours or more, the PSC said that due to the smaller impact expected to result from shorter duration outages, and the utility’s general ability to mobilize personnel to respond to shorter duration outages, the PSC finds that the completion of a scorecard evaluation for shorter duration events would furnish insufficient additional benefit on a statewide basis.
Also, referring to the concern by the joint utilities and the city that there are disparities between the scorecard and the utilities’ emergency plans, the PSC noted that the scorecard is accompanied by a performance guide to provide greater clarity and precision to the metrics being used in the scorecard. Most notably, the PSC added, the performance guide now includes definitions for start of the event, customer restoration, outage duration and start of utility restoration.
While the joint utilities recommended changing the outage duration definition so that the period would begin at the start of utility restoration instead of, as proposed, at the start of the event, and end with the completion of customer restoration, the PSC said that defining outage duration to begin at the start of the event is more appropriate because customers experience an outage when they lose power, not when electric utility personnel begin restoration.
“Therefore, the scorecard will retain the definition of outage duration as the period of time which begins with the start of the storm event,” the PSC added.
The PSC also noted that it understands the joint utilities’ concern that the response to an un-forecast extreme weather event may not include as comprehensive a preparation as would otherwise be the case. Therefore, the PSC has adjusted the scorecard to account for that by recognizing that, for events with limited warning, some of its measures could be impractical to implement. In general, the PSC added, for any metric that staff deems inapplicable, the points for those measures will be excluded and the overall score of the three categories combined will be prorated.
Among other things, the PSC said that regarding communications, the scorecard now consolidates several communication tools, including press releases, text messaging, e-mails and use of social media, into a single measure.
“Utilities will be evaluated on whether messages are provided in a timely manner and whether messages address key components of the restoration, in consideration of the space limitations the joint utilities identified,” the PSC said.
The joint utilities objected to the requirement that an outgoing message on the utility telephone line contain the same information as the press release, the PSC added.
Central Hudson’s holding company is CH Energy Group (NYSE:CHG). NYSEG and RG&E are subsidiaries of Iberdrola USA, which is a subsidiary of Iberdrola S.A.