BEFORE THE WYOMING PUBLIC SERVICE COMMISSION ROCKY MOUNTAIN POWER. Rebuttal Testimony of Paul J. Radakovich

Transcription

1 Docket No ER- Witness: Paul J. Radakovich BEFORE THE WYOMING PUBLIC SERVICE COMMISSION ROCKY MOUNTAIN POWER Rebuttal Testimony of Paul J. Radakovich September 0

2 0 0 Q. Are you the same Paul J. Radakovich who previously submitted direct testimony in this case on behalf of Rocky Mountain Power ( RMP" or the Company")? A. Yes. PURPOSE OF REBUTTAL TESTIMONY Q. What is the purpose of your rebuttal testimony? A. The purpose of my rebuttal testimony is to address issues and concerns raised in the direct testimony filed by the Wyoming Office of Consumer Advocate ( OCA ) witness Denise Parrish. My rebuttal testimony responds to OCA concerns regarding the $. million of additional operations and maintenance funding. My testimony further explains and quantifies the benefits customers will receive from the reliability improvement efforts this additional funding will provide. Q. Do you have any general observations regarding the testimony filed by the OCA? A. Yes. Ms. Parrish testifies that not enough information was provided to show how customers would benefit from the extra expenditures. She also testifies that in her understanding, the 0 System Average Interruption Duration Index ("SAIDI") target may not have been met even if extra funds had been spent since percent of the SAIDI minutes were caused by significant weather event days. My testimony provides additional information to address these concerns. To better explain the targeted reliability improvement effort described in my direct testimony, I first discuss the feeders the Company improved in 0 which were Page Rebuttal Testimony of Paul J. Radakovich

3 0 0 completed consistent with the Natrona County Area Reliability commitment in the Company's 00 general rate case, specifically section.e. of the stipulation (Docket No ER-0, Record No. 0). This information is an example of how we would invest the additional funding in the future. My testimony also shows the reliability improvement outcomes in 0 for those feeders, which clearly benefit the customers that receive their service from those feeders. Lastly, my testimony specifically discusses the work performed on an example feeder in Lander, Wyoming along with the associated performance improvement to demonstrate the level of detailed work undertaken with this effort to derive the benefit for customers. Q. What feeders were improved as part of the targeted reliability effort in 0? A. In 0, RMP spent $,0, of operations and maintenance funding to improve portions of feeders across the service territory. A breakdown of the locations and feeder counts are: Big Piney -, Casper -, Cody -, Cokeville -, Douglas -, Evanston -, LaBarge -, Lander -, Pinedale -, Rawlins -, Riverton -, Rock Springs -, and Worland -. Q. How were these feeders selected? A. The Company uses a number of analysis tools and metrics to identify feeders or Page Rebuttal Testimony of Paul J. Radakovich

4 0 0 more often portions of feeders that are delivering a lower level of reliability. The analysis includes a review of feeder SAIDI, momentary outage counts, outage cause, relay fault information, and the additional metric of Customers Experiencing Multiple Interruptions ("CEMI") to identify the feeder or portion of a feeder to be improved. The effort is intended to target only the portion of the feeder that is under-performing in order to maximize the improvement achieved per dollar spent. The outage causes for those feeders are then reviewed to remove the effect of uncontrollable events like vehicles striking poles, dig-ins, and severe weather events. The remaining circuit portions are candidates for implementing reliability tactics the Company has honed over the past decade. Q. Once a portion of a feeder is identified for improvement, how does the Company determine what work is to be completed? A. A detailed inspection is performed to determine what capital and maintenance work is required to improve reliability. Generally this is an inspection to establish the resilience of the circuit portion and its components. Poles, cross-arms, insulators, pole grounds, and down guys are all inspected. Long spans are reviewed to see if the conductors have slapped together and jumpers are infrared and resistance tested to evaluate their condition. The facilities are also reviewed to determine if any additional animal guarding is required. Lastly, the feeder fuse protection is reviewed and additional fusing or replacement fuse requirements are determined to ensure that if a fault occurs it affects the fewest number of customers as possible. Page Rebuttal Testimony of Paul J. Radakovich

5 0 Q. How does the Company determine if these efforts are successful in delivering the expected reliability improvement benefits for customers? A. The Company sets a 0 percent reliability improvement target, using customer minutes interrupted as the measure, for each targeted feeder that is measured against a baseline established in the previous year. We then measure the actual performance in the year after the work was completed to ensure benefits for customers were achieved. Table shows the cumulative results for the feeders improved in 0. The red bars represent the monthly baseline performance of the feeders in 0. The blue bars represent the targeted improvement of 0 percent from the baseline. The green line represents the actual monthly performance of these feeders in 0. The customers served by these feeders benefited by realizing on average a percent improvement in customer minutes interrupted as measured against the pre-improvement baseline. Table Page Rebuttal Testimony of Paul J. Radakovich

6 0 0 Q. Table represents the cumulative performance of the feeders improved in 0. As an example, can you show the results for one of the feeders and provide information regarding the actual work completed to achieve the results? A. Yes. Table shows the results for Lander feeder H. This feeder is comprised of approximately miles of overhead and underground conductor, of which about 0 percent is overhead. It serves,0 customers, of which about percent are residential, 0 percent are commercial, and one percent are industrial or irrigation. It also serves more than a dozen customer generation locations. The customers served from this feeder realized an percent improvement in 0 against the 0 performance baseline. The work completed to attain this improvement includes: installing four new fused cutouts, replacing 0 porcelain with polymer fused cutouts and applying raptor protection on each, replacing seven deteriorated cross-arms, replacing jumpers at 0 sites, and replacing one failed down guy anchor. A total of $, was spent on labor and material to complete the work. To put this into context this means that by using our reliability improvement tools we were able to examine the data, perform a field inspection, then target repairs appropriately. We determined that for these miles of line, (which includes more than,000 poles, fuse cutouts and transformers) significant improvements could be realized by targeting about / of the cutouts, adding a few new ones and performing other minor but important changes to the circuit. Without these types of efforts to hone in on the under-performing parts of the circuit, the Company could easily have spent multiples of the actually incurred Page Rebuttal Testimony of Paul J. Radakovich

7 cost, but not delivered a commensurate improvement. This process relies upon rapid response to evaluate reliability as performance trends are beginning to emerge. The process serves to limit both the cost and reliability impacts for our customers. Unfortunately these data trends do not lend themselves to protracted planning activities that queue up circuits in multi-year improvement plans. Table 0 Q. Do you have additional comments regarding issues raises in the OCA testimony? A. Yes, Ms. Parrish provides testimony regarding the cost associated with the Company failing to meet reliability targets. She testifies that there are some elements of reliability where a fee is paid for failure to perform within established parameters. She also states that there is nothing in Rule of the Company s tariff that imposes a penalty for failing to meet reliability targets. She is correct on both Page Rebuttal Testimony of Paul J. Radakovich

8 0 0 issues, but I would like to make some additional comments. The Company provides two customer guarantees related to service reliability that provide customers with a $0 credit; one for customers that sustain outages with durations longer than hours and the other for failing to notify customers hours in advance of planned outages. The Company is not requesting the additional funding to avoid fines or penalties. This effort is intended to benefit customers, specifically those served by portions of the network that are performing with a lower level of reliability performance. Ms. Parrish also states that it is her understanding that because the 0 statewide SAIDI measurement of minutes included eight significant event days resulting from weather impacts, animal interference, and loss of supply event the extra funding would not ensure the target of minutes would have been met. Reliability results in any given period are impacted by a variety of factors that cannot be accurately forecast. Weather, human, and animal caused damage can result in dramatically different SAIDI impacts depending where on the network the damage occurs. It is not possible to definitively predict the SAIDI outcome for a future period of time should the additional funding be approved. The 0 improvement depicted in Table for the feeders that were evaluated and improved in 0 represent. minutes in terms of statewide SAIDI. With the benefit of hindsight one could conclude that the 0 statewide metric would have been 0 minutes without the feeder improvement work I have detailed above. The Company is working hard to minimize the cost of service while delivering acceptable reliability performance for our customers and believes the additional $. million of operation and Page Rebuttal Testimony of Paul J. Radakovich

9 maintenance funding is prudent. Q. Does this conclude your rebuttal testimony? A. Yes. Page Rebuttal Testimony of Paul J. Radakovich

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