TRANSMISSION BUSINESS PERFORMANCE

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1 Filed: September 0, 009 Exhibit A Tab Schedule Page of.0 INTRODUCTION TRANSMISSION BUSINESS PERFORMANCE Hydro One is focused on the strategic goals and performance targets in the area of safety, customer satisfaction, reliability and shareholder value. This Exhibit illustrates the historical business performance of Hydro One s Transmission Business in these areas. A second approach to utility performance assessment, that of comparisons with other utilities, is a priority of the Board and stakeholder community. Accordingly, this Exhibit briefly discusses the issues with such comparisons and provides a comparison to other utilities, where information is available. This comparison utilizes the Canadian Electric Association (CEA) composite performance, which is the average or aggregate performance of CEA participating utilities Since 006, as per the Board s 006 Decision and Order on Hydro One s Distribution rates (RP /EB , dated April, 006), Hydro One has engaged an independent party to develop a list of comparable North American companies with similar business models, and to report accordingly. The results of the most recent independent study for Hydro One s Transmission Business are found in Exhibit A, Tab, Schedule. 6 Also, summary of performance according to the Hydro One Customer Delivery Point Performance (CDPP) Standards is presented within Section. of this exhibit. This standard is described in a document previously filed with the OEB: Customer Delivery Point Performance (CDPP) Standard, EB This document is included in Appendix C for reference. 7

2 Filed: September 0, 009 Exhibit A Tab Schedule Page of.0 PERFORMANCE MEASUREMENT PROCESS 6 As noted previously, the first approach to establish Hydro One Transmission s performance levels entails monitoring actual performance over time. The remainder of this Exhibit provides Hydro One s performance on its targeted areas, utilizing historical data drawn from Hydro One s own records The other approach involves comparison with other transmission utilities, particularly for reliability performance. This is a much more complex undertaking that requires careful consideration of: 6 7 measurement definition, data collection processes which impact on the consistency and accuracy of the reported measures, and variations such as climate, operating environment and system infrastructure between transmission companies that can influence the absolute performance of their transmission systems A way to reduce the effect of these factors is to observe year-over-year performance using consistent and precise measurement definitions. 6 7 Although transmitters each have a slightly different approach when measuring their own reliability performance, the Canadian Electricity Association (CEA) has had success in creating reliability performance definitions of sufficient precision and consistency over the years to permit some degree of multi-jurisdictional transmission performance comparisons. The data, however, are not audited and the comparisons are used only to help identify opportunities for business improvement. Section. of this Exhibit presents

3 Filed: September 0, 009 Exhibit A Tab Schedule Page of Hydro One s performance relative to a CEA composite performance where available. In addition, Hydro One is participating in an analysis with U.S. utilities; the results are presented in Section...0 SAFETY PERFORMANCE Hydro One s number one priority is safety. Hydro One has implemented a managed system allowing the effective management of safety within the work environment. The managed system assesses activities, risks and the effectiveness of control, sets safety objectives and puts in place appropriate programs to manage the risks. As part of this safety program, Hydro One tracks a number of measures. The Company focuses on two leading indicators which are Serious Lost Time Incidents and Serious Incidents. Table shows Hydro One s performance for these indicators since 00. Table Safety Performance (00-007) Serious Lost Time Injuries Serious Incidents Table indicates that Hydro One s safety performance has improved since 00. This has been achieved during a time when the volume of work and the number of staff have increased, the majority of the new staff being either new to the electricity industry or new to the workforce. Hydro One is committed to an accident free workplace and continues to strive toward this goal. The improvement in the safety performance can be attributed to a combination of factors including the further implementation of a Health Safety and Environment Managed System. 6

4 Filed: September 0, 009 Exhibit A Tab Schedule Page of Serious Lost Time Injuries are the number of injuries that resulted in a Hydro One staff member having to take time off. Serious Incidents are events that did not result in an injury but had the potential to result in one. These two measures are related to the following six targeted areas that represent the highest potential risk of injury: electrical incidents falls from different levels falling objects preventable motor vehicle accidents work equipment failure asset equipment failures 6 7 For these two measures discussed above, external comparison data is not available. However, external comparators are available for other safety related measures such as Disabling Injury Frequency Rate and Accident Severity Rate. For both of these measures, Hydro One is in the top quartile (i.e. Q) of Canadian utilities participating in CEA. An example of an external comparison can be found in Figure. 8

5 Filed: September 0, 009 Exhibit A Tab Schedule Page of Figure Disabling Injury Frequency Rate # of disabling injuries/00,000 hours worked Disabling Injury Frequency Rate CEA Composite Hydro One CUSTOMER SERVICE PERFORMANCE Hydro One is in business to serve its customers and as such, customer satisfaction is a high priority for the company. To gauge satisfaction, the company surveys customers on their satisfaction with the service that they have been receiving. Surveys are administered to both major (i.e. large transmission connected) customers and generators, and survey questions are focused on areas of importance to customers such as reliability, communications, relationships, and responsiveness. Figure illustrates the overall results from surveys that have been conducted in recent years.

6 Filed: September 0, 009 Exhibit A Tab Schedule Page 6 of Figure Customer Satisfaction Customer Satisfaction with Hydro One Major Customers Generator Customers 70 % Satisfied * Note: In 00 there was no satisfaction survey carried out of the Generator Customers due to the Hydro One labour disruption. As evidenced by the results in Figure, Hydro One s major customers are now significantly more satisfied than they were a few years ago. This is a testament to the company s customer focus to meet and/or exceed customer expectations. On the generator side, overall satisfaction with Hydro One is stable from the first survey conducted in 00 through to including the latest 007 survey result.

7 Filed: September 0, 009 Exhibit A Tab Schedule Page 7 of.0 RELIABILITY PERFORMANCE. Transmission Reliability Measures Hydro One defines service quality as a series of measures related to customer reliability and system unavailability. These measures are listed in Table below. Table Transmission Reliability Measures Service Quality Area Reliability Measures Description Customer Reliability System Unavailability Frequency of Delivery Point Interruptions (average # of interruptions per delivery point) Duration of Delivery Point Interruptions (average # of minutes of interruptions per delivery point) Unsupplied Energy (system minutes of energy not supplied) Transmission System Unavailability (Percentage of system not available) The average number of planned, forced and momentary interruptions experienced at customer delivery points The average duration of planned and forced interruptions experienced at customer delivery points Energy not supplied to customers as a result of planned and forced interruptions The extent to which transmission lines are not available for use by market participants due to planned and forced outages on the transmission system Delivery Points are the interface points between Hydro One s transmission system and its load customers. They consist of all (a) Hydro One owned step-down transformer stations low voltage buses, and (b) stations owned by end use transmission customers, including Local Distribution Companies, and other transmitters interfacing at the kv voltage level and above. 6

8 Filed: September 0, 009 Exhibit A Tab Schedule Page 8 of Hydro One uses these measures because: These are commonly used transmission industry measures. As a group, the measures address a broad range of transmission service quality issues important to customers, including the number and duration of interruptions, unsupplied energy, and the availability of the transmission system for use by market participants. Most of the measures have over years of historical data available for assessing performance trends and setting targets. The number of measures keeps tracking and reporting requirements at a manageable and cost-effective level while still covering a broad spectrum of performance relevant to reliable service quality. 6 Refer to Appendix A for additional details on the reliability measures. Refer to Appendix B for additional details on the historical performance of the four reliability measures.. Performance in Canada Using data collected by the CEA, Hydro One is able to compare the reliability performance of its system against the composite performance of other transmission utilities in Canada (that participate in CEA). Hydro One s comparative reliability performance is illustrated in the following Figures, and for frequency of momentary interruptions, frequency of forced sustained interruptions and duration of forced sustained interruptions respectively.

9 Filed: September 0, 009 Exhibit A Tab Schedule Page 9 of Hydro One data in Figures through 7 exclude the impact of the 00 blackout. Figure Performance of Frequency of Momentary Interruptions Frequency of Delivery Point Interruptions Momentaries Ave. # of interruptions per DP CEA Composite Hydro One 00 00* *results exclude impact of the 00 Blackout Figure Performance of Frequency of Forced Sustained Interruptions Ave. # of interruptions per DP Frequency of Delivery Point Interruptions Forced Sustained CEA Composite 00 00* *results exclude impact of the 00 Blackout Hydro One

10 Filed: September 0, 009 Exhibit A Tab Schedule Page of 6 In 006, ice storms and electric storms significantly impacted the performance of the Hydro One grid. These events contributed to the reliability measures as follows, the frequency of delivery point interruptions of forced sustained would be 0.7 interruptions per delivery point (Figure ). The duration of delivery point interruptions of forced sustained (BES) would be at 6. minutes per delivery point (Figure ) and the unsupplied energy (Figure 6) would be 6.8 system minutes Figure Performance of Duration of Forced Sustained Interruptions Duration of Delivery Point Interruptions Forced Sustained (BES) Ave. minutes of interruption CEA Composite Hydro One (Caledonia Excluded) Hydro One 00 00* *results exclude impact of the 00 Blackout Note: The Caledonia Event in 006 contributed 8. minutes to the Duration of Delivery Point Interruption measure as shown in Figure above. 6 7 The following charts in Figures 6 and 7 illustrate historical performance pertaining to Unsupplied Energy and System Unavailability respectively. These are indices that Hydro One tracks in addition to the frequency and duration of interruptions. Both measures 8 include planned and unplanned interruptions. Comparison to CEA composite is not 9 available for these measures as they are not tracked by CEA.

11 Exhibit A Tab Schedule Page of Figure 6 Performance of Unsupplied Energy Measure Unsupplied Energy System Minutes 0 0 Hydro One (Caledonia Excluded) Hydro One 00 00* *results exclude impact of the 00 Blackout Note: The Caledonia Event in 006 contributed. system minutes to the system Unsupplied Energy measure as shown in Figure 6 above Figure 7 Performance of System Unavailability Measure System Unavailability % of System Unavailability.%.0%.%.0% 0.% 0.0% Hydro One 00 00* *results exclude impact of the 00 Blackout

12 Exhibit A Tab Schedule Page of The System Unavailability measure represents the extent to which the transmission system is not available for use by electricity market participants. The detailed description of this measure is provided in Appendix A. Figure 7 illustrates an increase in the System Unavailability measure in 007. This was due to an increase in planned line outage work compared to previous years. [Refer to Exhibit D, Tab, Schedule for related investment program details]. The increase in System Unavailability was not detrimental to the delivery performance to load customers as evidenced in Figures,, and 6. 9 Hydro One undertakes an annual detailed assessment of the performance of all the above mentioned measures. This assessment is taken into account along with other factors such as asset condition when establishing and prioritizing operating, maintenance and capital programs.. Performance Relative to Utilities in the USA Hydro One is also participating in a statistical and comparative study of transmission reliability in U.S., administered by SGS, a utility consultancy. A summary of the results from the 008 study are presented in Table, which are the average performance levels over a three-year period (00-007). The results include Hydro One s relative quartile performance of delivery point reliability compared to other transmission companies that participated in the SGS study. Although there are some inconsistencies in both definitions and reporting practices within the study, the results are considered accurate enough for broad, system performance comparisons. The measures are system averages for frequency and duration and include non-planned interruptions to transmission delivery points. The study includes delivery point interruptions by transmission line outages only. Other transmission system failures at sub-stations or line terminals that have affected delivery points are not included in these results. 8

13 Exhibit A Tab Schedule Page of Table Summary of Delivery Point ( DP ) Analysis: SGS 008 Study 0-6kV >=0kV Frequency Measures T-SAIFI Q Q T-SAIFI-M Q Q T-SAIFI-S Q Q DP Outages per 0mi Q Q DP Sustained Outages per 0mi Q Q Duration Measures T-SAIDI Q Q DP Minutes per 0mi Q Q Notes () The Top Quartile (Q) is a point at or above which the best-performing % of systems perform. The quartile positions reported in this are provided by the study results. () Measures are system averages for frequency and duration and include non-planned interruptions to transmission delivery points due to circuit outages. The results indicate that for 0kV and above systems, Hydro One is in either first or second quartile depending on the metric used, and for systems in the 0-6kV range, Hydro One is in the third or fourth quartile depending on the metric used. The results for Hydro One s kv system are expected due to the nature of this system, which is typically rural, with longer radial circuits than most of its comparator transmission companies Delivery Point Performance Outliers 9 0 Hydro One tracks reliability performance at its load delivery points according to the standard that Hydro One developed and filed with the OEB. The performance standard is used as a trigger by Hydro One to initiate assessment and follow up with affected customers including to: Customer Delivery Point Performance (CDPP) Standard, EB-00-0

14 Exhibit A Tab Schedule Page of Determine the root cause of unreliability Technical and financial evaluations Decide on remedial action to improve reliability Table includes a summary of the transmission load delivery point performance outliers for each of the Group and Individual CDPP Standard criteria in years 006 and 007. Note that Outliers due to Group and Individual CDPP Standard criteria are not mutually exclusive. The proportion of Hydro One transmission load delivery points that are determined to be performance outliers are determined separately for Group and Individual CDPP Standard criteria, and a composite result is also provided. Table Transmission Load Delivery Point Performance Outliers (006 & 007) Number and Proportion of Performance Standard Criterion Customer Delivery Point Performance Outliers Population of Tx Delivery Points Group CDPP Standards 98 % of Hydro One Delivery Points Considered Outliers by Group Criteria % %. Individual CDPP Standards 6 6 % of Hydro One Delivery Points Considered Outliers by Individual Criteria 7% 7% Total (Mutually Exclusive Composite Result) % of Hydro One Delivery Points Considered Outliers (Mutually Exclusive Composite Result) 0 % 6% 6 7 The delivery points found to be outliers according to the standard are assessed for incorporation into future investment programs. Hydro One endeavours to keep the number of outliers to % or less of the total population of its load delivery points. This

15 Exhibit A Tab Schedule Page of 6 7 will not always be the case as some delivery points are flagged as performance outliers even though they would normally experience better reliability performance than standard. One or two interruptions caused by isolated events may affect the performance result in a particular year. Reliability performance at these delivery points would typically be better than standard again the following year with no incremental investment. Hydro One takes this into consideration in its assessments. Please refer to Section. of Exhibit D, Tab, Schedule, for a fuller discussion of the work undertaken to address outlier performance SHAREHOLDER PERFORMANCE Delivering shareholder value is a key objective of any business and as such, Hydro One monitors related measures. A key measure in this area is the company s credit rating. Currently the company has a credit rating of A, which is in line with other large transmission companies in Canada. The goal is to maintain this credit rating in order to ensure ready access to long-term financing at reasonable rates, as Hydro One does not have access to equity markets and must use debt to fund capital requirements and investments. Table below contains Hydro One s credit rating in recent years. Table Hydro One s Credit Rating (00-007) S&P Rating A A- A A A A Maintaining a good credit rating allows Hydro One to borrow at attractive interest rates, which benefits customers by minimizing the cost of capital.

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17 Exhibit A-- Appendix A Page of 6 APPENDIX A DESCRIPTIONS OF THE RELIABILITY MEASURES Frequency of Delivery Point Interruptions Frequency of Delivery Point Interruptions is an indicator of customer reliability related to interruptions, that is, outages on the transmission system that interrupt the supply of energy to transmission customers. This indicator measures the number of interruptions to the supply of power to customer delivery points. It is expressed mathematically as: Frequency of Delivery Point Interruptions N i= = ( M + S ) i N i Where: M i is the total number of Momentary Interruptions experienced at Delivery Point i over a one year period. S i is the total number of Sustained Interruptions (caused by either forced or planned outages) experienced at Delivery Point i over a one year period. N is the total number of Delivery Points at the end of the reporting period The frequency of power supply interruptions has long been a concern to customers, and indicators that track such events are almost universally used in some form in other Delivery Points are the interface points between Hydro One s transmission system and its load customers. They consist of all (a) Hydro One owned step-down transformer stations low voltage buses and (b) stations owned by end use transmission customers, including Local Distribution Companies, and other transmitters interfacing at the kv voltage level and above. Momentary interruptions are defined as interruptions lasting less than one minute. Sustained interruptions are those lasting one minute or longer.

18 Exhibit A-- Appendix A Page of 6 regulatory jurisdictions. Transmission providers in Alberta, Australia, the UK, New Zealand and Sweden use an interruption frequency indicator. Additionally, the Canadian Electric Association (CEA) tracks the frequency of delivery point interruptions for most Canadian transmission providers. This indicator includes all forced and planned interruptions, both momentary and sustained. Including forced interruptions in this measure promotes prudent levels of maintenance and capital expenditures when the goal is to maintain historical levels of reliability performance. Including planned interruptions is a driver for minimizing the number of disruptions to customers by co-ordinating all planned work. Momentary interruptions are included because they can have a significant impact on the quality of supply to transmission customers. Duration of Delivery Point Interruptions Duration of Delivery Point Interruptions is an indicator of customer reliability related to the duration of interruptions, that is, the time for which supply of energy is interrupted for customers supplied from the transmission system. This indicator measures the duration of interruptions to customer delivery points. It is expressed mathematically as: Duration of Delivery Point Interruptions N ( ) Di i= = N Delivery Points are the interface points between Hydro One s transmission system and its load customers. They consist of all (a) Hydro One owned step-down transformer stations low voltage buses and (b) stations owned by end use transmission customers, including Local Distribution Companies, and other transmitters interfacing at the kv voltage level and above.

19 Exhibit A-- Appendix A Page of 6 Where: D i is the total effective interruption duration 6 of Sustained Interruptions (caused by either forced or planned outages) experienced at Delivery Point i over a one year period. N is the total number of Delivery Points at year-end of the reporting period Like frequency, the duration of power supply interruptions has long been a concern to customers, and indicators that track such events are almost universally used in some form in other regulatory jurisdictions. Transmission providers in Alberta, Australia, the UK, New Zealand and Sweden use an interruption duration indicator. Additionally, the Canadian Electric Association (CEA) tracks the duration of delivery point interruptions for most Canadian transmission providers. Unsupplied Energy Unsupplied Energy is an indicator of customer reliability that combines the duration of interruptions to a customer s power supply with the energy not supplied as a result of the interruption. It is expressed mathematically as: Unsupplied Energy = N i= U i x 60 min/hr Pk 6 This is the effective length of the interruption taking into account the partial restoration of load. For example, the interruption of a 0 MW load where 90% of the load is restored in five minutes and the remaining % of load is restored minutes later would have an effective duration of six minutes (0% of load unavailable x min. + % of load unavailable x min.). Another way of expressing effective duration is total unsupplied energy/total MW (0 MW x min. + MW x min.)/0 MW = 6 min.).

20 Exhibit A-- Appendix A Page of 6 Where: U i is the total unsupplied energy, expressed in MWh, at Delivery Point i over a one year period. Pk is the current year s system peak, expressed in MW. N is the total number of Delivery Points at the end of the reporting period. Unsupplied energy is normalized by the peak demand for energy to account for the changes in the volume of power delivered by the transmission system and allow a better assessment of changes in performance. The unit of measure for unsupplied energy is expressed in "system minutes". This represents the total energy that is not supplied to the customers normalized by the peak demand of the system (that occurred during the measurement period). The indicator includes both forced and planned sustained interruptions. Including forced events maintains Hydro One s direction to restore the supply of power to customers as quickly as possible following an unscheduled interruption. Planned events are included to minimize the length of planned interruptions and to schedule interruptions at a time that is least impactive to the customer. Momentary events are not included, since they do not contribute appreciably to unsupplied energy, particularly when compared to the impact from sustained events. Transmission companies in Australia, the UK, New Zealand, Sweden, and the U.S. use indicators of this type to track performance.

21 Exhibit A-- Appendix A Page of 6 Transmission System Unavailability Transmission System Unavailability captures the impact of all outages on transmission lines, not just the outages that interrupt customers. Outages on transmission lines impact both end use customers and energy suppliers by limiting their ability to use the transmission system to its full extent. This indicator is expressed mathematically as: N ( Fi + Pi ) i Transmission SystemUnavailability = = x 0% 8760 x N Where: F i is the annual forced outage duration in hours for transmission line circuit i. P i is the annual planned outage duration in hours for transmission line circuit i. N is the total number of declared in-service transmission line circuits is the number of hours in a year. The indicator tracks the extent to which the transmission system, including load and generation connection lines and interconnection lines, is not available for use by electricity market participants. The impact of both forced and planned sustained outages on transmission lines are included to ensure continued efforts to minimize the duration of all outage events. This indicator is focused on the aspect of transmission service within Hydro One s control that most contributes to overall system performance that is, keeping the transmission system available for market participants to use. It also puts the impact of outages in context with the availability of the transmission system as a whole and expresses the impact of outages in a single, easily understood indicator.

22 Exhibit A-- Appendix A Page 6 of 6 Transmission providers in the UK track System Unavailability, while the inverse, System Availability 7, is currently tracked by some Australian utilities and has been proposed by the Australian regulator for use by all transmission companies in Australia. Although not part of a performance based regulation ("PBR") plan, TransPower of New Zealand also reports on the unavailability of their transmission system. 7 Calculated as one minus the Unavailability.

23 Exhibit A-- Appendix B Page of APPENDIX B RELIABILITY MEASURES HISTORICAL PERFORMANCE The latest years of performance for the four reliability measures is provided in the figures below. Figure B Historical Performance of Frequency of Delivery Point Interruptions Average Interruption Frequency # of interruptions per DP * * *Results exclude the impact of the 998 ice storm, 00 Blackout

24 Exhibit A-- Appendix B Page of Figure B Historical Performance of Duration of Delivery Point Interruptions Average Interruption Duration Minutes of interruptions per DP ** * * *Results exclude the impact of the 998 ice storm, 00 Blackout ** Result is 60. excluding the impact of the Caledonia Event in 006 Figure B Historical Performance of Unsupplied Energy Unsupplied Energy System Minutes ** * * *Results exclude the impact of the 998 ice storm, 00 Blackout ** Result is.8 excluding the impact of the Caledonia Event in 006

25 Exhibit A-- Appendix B Page of Figure B Historical Performance of Transmission System Unavailability Transmission System Unavailability.0%.6%.7% % Unavailability.%.0%.%.0% 0.%.9%.%.%.0%.7%.6%.%.% 0.0% 998* * *Results exclude the impact of the 998 ice storm, 00 Blackout

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27 Exhibit A-- Appendix C Page of 8 APPENDIX C CUSTOMER DELIVERY POINT PERFORMANCE STANDARDS.0 INTRODUCTION The Transmission System Code (TSC) requires transmitters to develop performance standards at the customer delivery point ( CDPP ) level, consistent with system wide standards, that: reflect typical transmission system configurations that take into account the historical development of the transmission system at the customer delivery point level; reflect historical performance at the customer delivery point level; establish acceptable bands of performance at the customer delivery point level for the transmission system configurations, geographic area, load, and capacity levels; establish triggers that would initiate technical and financial evaluations by the transmitter and its customers regarding performance standards at the customer delivery point level, as well as the circumstances in which any such triggering event will not require the initiation of a technical or economic evaluation; establish the steps to be taken based on the results of any evaluation that has been so triggered, as well as the circumstances in which such steps need not be taken; establish any circumstances in which the performance standards will not apply. On May, 00, Hydro One filed proposed Customer Delivery Point Performance Standards to meet the requirements of the TSC with the OEB for review and approval. Subsequently, on September 8, 00, as a result of stakeholder comments received, Hydro One filed amendments to its original CDPP Standards submission. On July, 00, the OEB issued its Decision and Order (RP /EB-00-0) which approved Hydro One s proposed CDPP Standards subject to a number of changes directed by the Board. A Delivery Point is defined as a point of connection between a transmitter s transmission facilities and a customer s facilities.

28 Exhibit A-- Appendix C Page of 8 The approved CDPP Standards apply to all existing transmission load customers (including customers that have signed a connection cost recovery agreement prior to market opening). For new or expanding customer loads, the delivery point performance requirements will be specified and paid for by the customer based on their connection needs and negotiated as part of the connection cost recovery agreement..0 DELIVERY POINT RELIABILITY STANDARDS The approved CDPP Standards consist of two components () Group CDPP Standards that relate the reliability of supply to the size of load being served at the delivery point; and () Individual CDPP Standards that maintain a customer s individual historical delivery point performance. Triggers for each component are used to identify performance outliers to initiate technical and financial evaluations to determine the root cause of unreliability and remedial action required to improve reliability. The CDPP Standards and triggers for each component are summarized below.. Performance Standards Based on Size of Load Being Served: Group CDPP Standards In this component, the CDPP Standards and the associated triggers are based on the size of load being served. For this purpose, the load is the delivery point s total average station gross load as measured in megawatts. The CDPP Standards vary with the size of the load in groups or bands of 0 to MW, greater than up to 0 MW, greater than 0 up to 80 MW and greater than 80 MW, as shown in Table below. Total Average Station Gross Load (MW) = (Total Energy Delivered to the Station (MWh) + Total Energy Generated at the Station Site (MWh)) / 8760 hours.

29 Table Filed: September 0, 008 Exhibit A-- Appendix C Page of 8 Customer Delivery Point Performance Standards Based on Load Size Performance Measure Customer Delivery Point Performance Standards (Based on a Delivery Point s Total Average Station Load) 0- MW > - 0 MW >0-80 MW >80 MW Standard (Average Performance) Minimum Standard of Performance Standard (Average Performance) Minimum Standard of Performance Standard (Average Performance) Minimum Standard of Performance Standard (Average Performance) Minimum Standard of Performance DP Frequency of Interruptions (Outages/yr) DP I nterruption Duration (min/yr) These CDPP Standards are based on historical performance, as measured by the frequency and duration of all momentary and sustained interruptions caused by forced outages, excluding outages resulting from extraordinary events that have had excessive impact on the transmission system and that, in Hydro One s assessment, strongly skew the historical performance. Included in this category of excluded events are the 998 ice storm and the 00 blackout. Momentary interruption is any forced interruption to a delivery point lasting less than minute and a sustained interruption is any interruption to a delivery point lasting minute or longer. A delivery point is interrupted whenever its requisite supply is interrupted as a result of a forced outage of one or more Hydro One components causing load loss. Interruptions caused by Hydro One s customers are recorded but not charged against Hydro One s reliability performance for the customer initiating the interruption, but are charged against Hydro One s reliability performance for other interrupted customers.

30 Exhibit A-- Appendix C Page of 8.. Criteria for Minimum Standard Performance to Identify Performance Outliers for Group CDPP Standards The minimum CDPP standards of performance, for each of the four load groups or bands, are to be used as triggers by Hydro One. The trigger occurs when the three-year rolling average of the delivery point performance falls below the minimum CDPP Standard for the delivery point of the load size group or band (referred to as a performance outlier or outlier) or when a delivery point customer indicates that analysis is required. When an outlier is identified, it is considered a candidate for remedial action. In such cases, Hydro One will initiate technical and financial evaluations with affected customers to determine the root cause of the unreliability and any remedial action required to improve the reliability.. Performance Standards to Maintain Historical Delivery Point Performance: Individual CDPP Standards In this component, the CDPP Standards are intended to maintain the historical reliability performance levels at each customer delivery point. This is done by identifying customer delivery points with deteriorating trends in reliability performance, irrespective of whether they are satisfactory performers under the Group CDPP Standards (Section. above). In order to identify customer delivery points with deteriorating trends in reliability performance, a performance baseline trigger for the frequency and duration of forced (momentary and sustained) interruptions is established for each delivery point based on that delivery point s historical average performance, plus one standard deviation (the historical baseline ). The historical baselines exclude outages resulting from extraordinary events that have had excessive impact on the transmission system and that, in Hydro One s assessment, strongly skew the historical trend of the measure (such as the 998 ice storm and the 00 blackout). Also, for delivery points that

31 Exhibit A-- Appendix C Page of 8 came into service after 99, the in-service year is to be the first year of the -year period used to determine the performance baseline... Criteria for Minimum Standard Performance to Identify Performance Outliers for Individual CDPP Standards Delivery point performance that is worse than the historical baseline (for either frequency or duration) in two consecutive years is considered a performance outlier and a candidate for remedial action. In such cases, Hydro One will initiate technical and financial evaluations with affected customers to determine the root cause of the unreliability and the remedial measures required to restore the historical reliability of the delivery point s performance.. Remedial Costs to Address Group and Individual Performance Outliers For Group and Individual Performance outliers, Hydro One will cover the remedial costs of restoring and sustaining the inherent reliability performance of the existing assets to what was designed originally. These costs include appropriate asset sustainment costs, on-going maintenance costs and costs associated with asset refurbishment or replacement. Historically, Hydro One has spent approximately $700 million per year on OM&A and Capital expenditures on the transmission system. About half of these expenditures are related to sustainment work to ensure that transmission assets are in good working order and able to perform as intended. These expenditures are made on an ongoing basis consistent with good utility practices, irrespective of actual delivery point performance or of whether a delivery point is a performance outlier. No customer contribution formula is required for these normal sustainment expenditures. For Individual Performance outliers, Hydro One will restore the delivery point to the historical level of performance. Hydro One s remedial work will not include capital

32 Exhibit A-- Appendix C Page 6 of 8 reliability improvements that significantly enhance the reliability of supply relative to the reliability that was inherent in the original system design or configuration of supply. For Group Performance outliers, Hydro One s level of incremental investment for improving the performance of an outlier beyond what was designed originally will be limited to the present value of three years worth of transformation and/or transmission line connection revenue associated with the delivery point. Any funding shortfalls for improving delivery point reliability performance will be made up by affected delivery point customers. In cases where specific transmission facilities are serving two or more customers in common with outlier performance, Hydro One will approach all affected customers to determine their willingness to contribute jointly to the reliability improvements. Cost responsibility for these investments is to be consistent with the TSC, specifically: (i) Hydro One will not attribute the costs associated with network investment to any customer and any variance from this approach requires a determination by the Board; (ii) the costs of preparing the final estimate for reliability improvements required to address performance outliers is the only portion of the technical and financial evaluation that is to be included as part of the cost of the remedial work; and (iii) where a customer contribution is required to improve or expand the transmission system to correct outlier performance, the customer will be given contracting privileges consistent with those applicable to contestability for new customer connections. In addition, affected delivery point customers are responsible for all of the costs associated with any new or modified facilities required on lines and stations they own to improve reliability. These financial and cost sharing arrangements are to be detailed in a connection and cost recovery agreement with the affected customers. In the special case where a delivery point pays only network tariffs, transmission line connection tariffs are to be used as a proxy in the revenue calculation.

33 Exhibit A-- Appendix C Page 7 of 8. Process Timelines to Address Performance Outliers The process and associated timelines that will be followed to address performance outliers both for Group and Individual outliers - and determine the preferred course of action are provided below Time = 0: Hydro One identifies, annually, delivery point performance outliers for both Group and Individual standards. Hydro One will notify customers that are supplied from these performance outlier delivery points and solicit their feedback/issues/concerns on their reliability of supply.. Within months: Hydro One will determine the root causes of unreliability associated with each performance outlier identified in () Within month: Hydro One will develop solutions to address performance outliers, including, (i) the work to restore and sustain the inherent reliability performance of the existing assets to what was designed originally; and (ii) for Group Performance outliers, the additional capital improvements required to improve the performance of an outlier to within standard and beyond what was designed originally. Hydro One will discuss the proposed solutions with affected customers.

34 Exhibit A-- Appendix C Page 8 of Within month: Hydro One will determine the costs and assess the risks of the solutions, including any customer capital contributions required for option (ii) above. Hydro One will present these costs to customers for their review and assessment.. Within months: Hydro One and customers select the preferred option and where appropriate customers state their intention on whether to proceed with capital improvements that involve customer contributions identified in option (ii) above. 6. Within months: Hydro One and customers obtain the necessary approvals to proceed with the preferred solutions to address performance outliers Hydro One will integrate the solutions into its work programs and implement them according to a mutually agreed schedule. 6 7 When Hydro One completes work to restore delivery point performance to standard, it continues to monitor the delivery point the year after the work is completed. If future performance suggests that the standard has not been met, then Hydro One will review the work that has taken place and will identify corrective action. Hydro One will not as a practice wait another years and start a new technical and financial evaluation. Hydro One reviews and identifies customer delivery point performance annually, regardless of the investment history. 8