~
1
Q.
2
3
PLEASE
GENERALLY
DESCRIBE
ONCOR'S
OPERATIONS ORGANIZATION.
A.
The
Distribution
comprised
organization is
Operations
4
organizational groups:
5
•
Distribution Major Projects;
6
•
Metro East Region Operations;
7
•
Metro/Non-Metro West Region Operations;
8
•
Southeast Region Operations;
9
•
Street Light Maintenance;
10
•
Distribution Services;
11
•
Measurement Services; and
12
•
Environmental, Health, Safety, and Training.
13
This organization is reflected on Exhibit BJP-1.
14
DISTRIBUTION
Q.
of
eight
ARE THERE OTHER ORGANIZATIONS THAT DISTRIBUTION
15
OPERATIONS WORKS CLOSELY WITH THAT DO NOT REPORT TO
16
YOU?
17
A.
18
Yes. Oncor has two Distribution Operating Centers ("DOCs") that are the
nerve centers for all of Distribution Operations' electrical activities. The
20
DOCs have responsibility for directing operations for Oncor's distribution
system and work directly with Oncor's Transmission organization on
21
issues that affect both the distribution system and the transmission
22
system. In general, the DOCs direct Oncor's outage restoration activities,
23
coordinate
24
construction work, track abnormally switched circuits throughout the
25
system, and ensure that Oncor's distribution system is operated within
26
design parameters.
19
29
activities
associated
with
maintenance
and
B. Description of Groups and Services Provided
27
28
switching
Q.
WHAT SERVICES DOES ONCOR'S DISTRIBUTION OPERATIONS
ORGANIZATION PROVIDE?
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Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
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1
•
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•
A.
Oncor's Distribution Operations organization performs numerous activities
2
necessary for the safe and reliable operation of the Company's distribution
3
facilities.
4
maintains the distribution system, which includes service restoration,
5
power delivery, power quality, field engineering design and construction
6
services, maintenance services, and direct customer interface. The eight
7
groups within the Distribution Operations organization that I mentioned
8
above are responsible for providing the services described below:
9
Distribution Maior Projects: This group is managed by Joe Bilbo, who has
10
37 years of experience with the Company in Engineering, Customer
11
Service, Municipal Relations, Contractor Services, New Construction
12
Management, Field Management, and Distribution Operations. This group
13
14
is responsible for field engineering design and construction of major
For example, this group
distribution projects on the Oncor system.
15
designs and constructs the electric facilities for a new subdivision, a new
16
hospital, and major road widenings. They are responsible for managing
17
contract resources that work on the Oncor distribution system. This group
18
is also responsible for construction coordination and scheduling.
19
work of this group is affected by the fast-growing nature of Oncor's service
20
21
area. Over the past five years, Oncor's non-lighting delivery points have
increased by 1.5 percent annually. According to the North American
22
Electric Reliability Corporation ("NERC"), Oncor's service area is also in
23
the United States' highest growth region in electric demand.
24
Metro
25
Operations, and Southeast Region Operations: The Metro East Region
26
Operations group is led by Mike Carter, who has 36 years of experience
27
with the Company in Distribution Operations. The Metro/Non-Metro West
28
Region Operations group is led by Reggie Bonner, who has 30 years of
29
experience with the Company in Measurement Services, Distribution
30
Maintenance and Construction, Engineering, Customer Service, Municipal
First and foremost, Distribution Operations operates and
East
Region
Operations
Metro/Non-Metro
West
The
Region
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
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i
1
Relations, and Distribution Operations. The Southeast Region Operations
2
group is led by Rick Chapman, who has 34 years of experience with the
3
Company in
4
Management, Performance Management, and Distribution Operations.
5
These Operations groups are responsible for electric system operations
6
dispatch response, control, reporting, maintenance, and emergency
7
service restoration. In addition, each of these groups has employees who
8
are utility design engineers that handle the design and construction of
9
smaller projects that are not handled by Distribution Major Projects.
Metering,
Engineering,
Customer
Service,
Field
10
Street Light Maintenance: This group is managed by Michael Navarro,
11
who has 34 years of experience with the Company in the Distribution
12
Construction & Engineering, Transmission, Customer Service, Municipal
13
Relations, and Distribution Operations.
14
performing street light maintenance throughout Oncor's service area.
15
Environmental, Health, Safety, and Training: This group is led by Deborah
16
Boyle,
17
Environmental, Health, Safety, and Training. This group is responsible for
18
providing environmental, health, safety and training services to the Oncor
19
organization through a team of professionals focused on these topics.
20
Distribution Services: This group is managed by Mark Moore, who has 31
21
years of experience with the Company in Customer Service, Municipal
22
Relations, Engineering, New Construction Management, and Distribution
23
Operations. This group is responsible for vegetation management on the
24
Oncor system and management of the contractors hired to perform those
25
services.
26
services and Quality Assurance.
27
Measurement Services:
28
years of metering-related experience and has led this group for 11 years.
29
This group performs meter reading throughout the Company's service
30
area and is responsible for procurement, inspection, testing, calibration,
This group is responsible for
who has 30 years of experience with the Company in
Distribution Services also provides Oncor's Transportation
This group is led by Ron Casey, who has 19
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-8-
•
and installation of meters.
2
sets meter standards and specifications, and evaluates meter technology.
3
Measurement Services also dispatches Field Services technicians as
4
needed to perform the disconnects and reconnects that occur throughout
5
the Company's system as well as other necessa ry services.
6
Q.
7
8
9
•
PLEASE DESCRIBE DISTRIBUTION OPERATIONS' MAINTENANCE
ACTIVITIES.
A.
There are 75 offices strategically located throughout the service territory
that are staffed with highly qualified employees to address maintenance
Monitoring the vital signs of the
10
issues on Oncor's distribution system.
11
distribution system on a daily basis is a key part of the Distribution
12
Operations' reactive distribution maintenance program.
13
within each district, as part of their routine maintenance duties, are given
14
responsibility for several feeder circuits.
15
operational efficiency of these circuits is their responsibility.
16
changes in the behavior of these circuits are quickly detected, and
17
appropriate actions are taken. Reliability repo rts are compiled by feeder,
18
service center, district, region, and system. Interruptions are classified by
19
cause, duration, and frequency. These indicators are utilized to identify
20
trends and to pinpoint where corrective action needs to be taken.
21
•
This group also designs meter installations,
1
Technicians
Monitoring the reliability and
Subtle
Distribution Operations also uses infrared thermography as a part
Thermographic cameras are
22
of our distribution maintenance program.
23
used to detect variations in temperature of our equipment, which allows us
24
to proactively locate defects in material or equipment and identify
25
workmanship issues. By locating and repairing these issues, we are able
26
to reduce maintenance costs by preventing unscheduled outages,
27
increase material and equipment lives, improve our System Average
28
Interruption Duration Index (" SAIDI") and System Average Interruption
29
Frequency Index (" SAIFI"), and enhance the overall operational safety and
30
reliability of the system.
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
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•
•
1
As part of the ongoing proactive maintenance of the distribution
2
system described in Company witness Mr. James A. Greer's direct
3
testimony,
4
maintenance across Oncor's distribution system, targeting the worst
5
performing circuits.
6
vegetation
7
protection, lightning protection, and other hardware inspections for the
8
three-phase mainline portion of circuits. In addition, on repeat worst
9
performing circuits,
Distribution
Operations
also
performs
overhead
circuit
Distribution Operations puts heavy emphasis on
management, pole maintenance, infrared tests, wildlife
Distribution
Operations develops and executes
10
detailed work plans to address the entire circuit. In addition, numerous
11
areas in our system are targeted for underground cable replacement. The
12
finite life of underground electrical cable and the concurrent increased
13
failure rate of that cable with increasing age requires the periodic
14
replacement of electrical cable over long life cycles, typically 20 to 30
15
years. Distribution Operations implemented a rigorous diagnostic testing
16
program to measure cable integrity prior to failure and has, as a result,
17
initiated a long-term cable rehabilitation strategy.
18
has also developed and implemented a comprehensive review and
19
strategic plans for the underground networks serving the downtown
20
business districts of Dallas and Fort Worth.
21
Q.
ARE THE EXPENSES ASSOCIATED WITH THE SERVICES
DESCRIBED ABOVE REASONABLE AND NECESSARY?
22
23
Distribution Operations
A.
Yes.
The processes utilized by Oncor ensure that the expenses
24
associated with the above activities are reasonable and necessary. These
25
are common utility activities that are essential for Oncor to provide service
26
to the public pursuant to its tariffs and the Commission's Substantive
27
Rules.
28
detail, Oncor's current SAIDI and SAIFI performance compares favorably
29
to industry averages. For all electric utilities in Texas that reported their
30
outage statistics to the Commission in 2007, Oncor's SAIDI and SAIFI
As Company witness Mr. Greer's direct testimony describes in
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Pulls - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
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1
were both lower (meaning better) than the average of the other utilities.
2
Oncor's SAIDI for 2007 was 74.81 minutes as compared to the Texas
3
average of 92.12 minutes, and its SAIFI was 0.89 as compared to the
4
Texas average of 1.07.
5
Oncor maintains and operates its distribution facilities in a safe
6
manner that is consistent with good utility practices, and in accordance
7
with both the National Electrical Safety Code ("NESC") and economic
8
practices that are consistent with sound budgeting, procurement, design,
9
and construction principles. In support of these objectives, we continually
10
review our methodologies and practices in order to ensure the safe and
11
reliable operation of our electric delivery system in an efficient and
12
economical manner.
13
Additionally, Oncor has extensive experience and expertise in utility
14
operations, which allows the Company to effectively manage the cost of
15
performing the activities required to achieve its operational objectives.
16
Oncor maintains a continuous focus on improving O&M management in
17
an effort to consistently perform more efficiently and cost effectively. As
18
Mr. Greer describes in more detail, Oncor's expertise in managing O&M
19
and its rigorous focus on cost is reflected in metrics that clearly
20
demonstrate that Oncor's O&M performance is better than most top-
21
performing utilities in the country.
22
Q.
HAVE RECENT CHANGES IN SERVICE LEVEL REQUIREMENTS
23
CAUSED A CHANGE IN EXPENSES ASSOCIATED WITH THE
24
PROVISION OF SERVICES BY DISTRIBUTION OPERATIONS?
25
A.
Yes.
In 2006, the Commission adopted revisions to the Terms and
26
Conditions of Service that apply to all transmission and distribution
27
("T&D") utilities in Texas.
28
effective during the test year, have increased the expenses associated
29
with
30
Previously, Distribution Operations was staffed to meet the average level
the
provision
Those service level changes, which became
of those services by Distribution
•
Operations.
Pulls - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
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•
The staffing level was sufficient in normal
1
of work for those activities.
2
times, but it did not achieve the service levels now expected in the revised
3
Terms and Conditions. The new service levels require that staffing be
4
increased to near peak work load so that the Company can meet the
5
expected 98% performance level within the required time frame.
6
example of why this increased staffing is necessary relates to the
7
"Standard disconnect and connect" orders.
8
market participants, Oncor targeted 98 percent completion of these orders
9
within 48 hours.
One
Previously, with input from
Under the new service level requirements, standard
10
connect and disconnect orders are expected to be completed on the
11
requested date if they are received two days prior to the requested date,
12
and priority orders are expected to be completed by the end of the day
13
they are received if received by 5 p.m. The volume of priority requests
14
continued to increase from approximately 8 percent to approximately 11
15
percent during the test year.
16
connect orders are typical near the end of the month due to customer
17
movement.
18
needed for Oncor to meet the market requirements during those times of
19
higher volume. The changes in the service levels required in the Terms
20
and Conditions will also affect the expenses associated with other types of
21
service requests, such as requests for service plans, construction
22
estimates,
23
disconnects and reconnects.
Also, higher volumes of disconnect and
Therefore, more Distribution Operations personnel are
outdoor lighting repair and removals, and temporary
24
IV. MANAGEMENT OF DISTRIBUTION CAPITAL
25
A. Types of Distribution Projects Requiring Capital Expenditures
26
Q.
PROJECTS THAT REQUIRE CAPITAL EXPENDITURES.
27
28
29
MS. PULIS, PLEASE DESCRIBE THE TYPES OF DISTRIBUTION
A.
The following is a list of the types of distribution projects that require
capital investment:
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Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
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•
This
2
type of project relates to the installation of the electric distribution
3
facilities needed to provide delivery service to new premises or
4
locations. Such a project could involve onsite and offsite overhead or
5
underground electric facilities.
6
•
Serve
Existing
Customers - Planned System Improvements,
These types of projects relate to installation of
7
Relocation Projects:
8
facilities to address added load on existing facilities, an upgrade of
9
existing facilities, or relocation of existing facilities to accommodate
10
road widening projects or other projects that require the adjustment of
11
our facilities.
•
12
•
Serve New Customers - Residential, Commercial, Multi-Family:
Planned Maintenance Programs - Feeder Maintenance, Cable Rehab,
13
Automated Switches, Pole Replacements: As Mr. Greer describes in
14
his direct testimony, the Company uses several proactive maintenance
15
programs that are designed to anticipate potential maintenance issues
16
and prevent problems from developing, such as replacing cable before
17
it fails as a result of age. The Company has also deployed automated
18
switches that monitor load flow and switch automatically when a fault
19
occurs, as well as automated capacitors that -monitor load and have
20
the capability to be remotely engaged or disengaged.
21
projects associated with these programs usually involve the installation
22
of new facilities, and Distribution Operations is responsible for the
23
installation of those new facilities.
24
•
Thus, the
Streetlights: This type of project includes the street lights installed in
25
conjunction with the Serve New Customers residential projects
26
mentioned above and new roadway lighting projects or requested
27
street light conversions.
28
29
Q.
DOES DISTRIBUTION OPERATIONS MAKE CAPITAL EXPENDITURES
IN CONNECTION WITH ANY OTHER PROJECTS?
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Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
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~ 1 A. Yes. Some maintenance projects require capital expenditures as well.
2
For example, if an existing streetlight is knocked down, the replacement of
3
that pole and streetlight would be classified as capital maintenance and
4
not a new installation, since the new pole and streetlight are replacing a
5
previously existing streetlight. Thus, in some circumstances, Oncor must
6
make capital expenditures to maintain an existing service.
B. Management of Capital Expenditures on Distribution System
7
8
Q.
9
EXPENDITURES ASSOCIATED
10
11
HOW DOES DISTRIBUTION OPERATIONS MANAGE CAPITAL
WITH
ONCOR'S DISTRIBUTION
SYSTEM?
A.
As Company witness Mr. Greer explains, my organization works closely
12
with Asset Management to appropriately manage our capital budget.
13
Distribution Major Projects continually monitors load growth and the actual
14
costs
15
Management in managing and prioritizing funding for additional capital
16
projects.
17
contractors, which allows us to maximize every capital dollar.
18
19
service providers are selected through a sourcing process, which
Distribution
Company witness Mr. Greer describes in more detail.
20
Operations reviews the work of those providers regularly, and an outside
21
auditor rigorously audits contractors' expenses.
22
competitively bids individual projects as appropriate.
23
ensure that contractors are performing consistent with their contracts with
24
the Company and that Oncor is being billed an appropriate amount for
25
contractor services.
26
27
of
planned
capital
improvement projects to assist Asset
We also have strategic alliances with our key vendors and
Those
The Company also
These efforts help
All of these controls help ensure that Distribution Operations'
capital expenditures are appropriate, reasonable, and necessary.
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-14-
•
1
W. MANAGEMENT OF DISTRIBUTION O&M
2
A. Distribution Operations -- Outage Response And
3
Emergency Restoration
4
1. Responsible Group
5
Q.
WHICH
GROUP
WITHIN
DISTRIBUTION
OPERATIONS IS
6
RESPONSIBLE FOR OUTAGE RESPONSE AND EMERGENCY
7
RESTORATION?
8
A.
The three regional Distribution Operations groups are responsible for
9
outage response and emergency restoration, but personnel from
10
Distribution Major Projects and Distribution Services frequently support
11
those regional Distribution Operations groups in helping to restore power
12
to customers. Both Distribution Major Projects and Distribution Services
13
use a large contingent of contract resources on a daily basis and have
14
access to significant additional contractor resources if needed to help the
15
regional Distribution Operations groups in response to large storms or
16
major events.
17
Operations needs help in setting new distribution poles or clearing storm
18
debris,
19
relationships with the appropriate contractors and can mobilize the needed
20
work forces to get the work done as quickly as possible.
For example, if, as a result of a storm, Distribution
Distribution Major Projects and Distribution Services have
2. How Managed
21
22
Q.
ON THE DISTRIBUTION SYSTEM?
23
24
HOW DOES DISTRIBUTION OPERATIONS RESPOND TO OUTAGES
A.
Service interruptions are continuously monitored by the two DOCs that I
As interruptions occur, a strategically placed
25
previously mentioned.
26
workforce of service restoration specialists who are on duty and on call 24
27
hours a day are utilized to make any necessary repairs. In general, the
28
order of priority for restoring electric service is as follows: (1) ensuring
29
public safety, including the safety of those individuals who are working to
30
restore electric service; (2) restoring service to critical end-users, such as
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-15-
1
hospitals; and (3) restoring service to the largest groups of end-users (i.e.,
2
repairing feeders, laterals, and transformers first and then restoring
3
service to individuals). Special conditions arising in a service outage that
4
have the potential for life-threatening or hazardous consequences will be
5
given priority status if expedited restoration at the location is practical. In
6
addition, in the event of, or in anticipation of, widespread service
7
interruptions, the Emergency Restoration Plan is activated in order to re-
8
deploy equipment and personnel throughout the Company to concentrate
9
on service restoration. That Plan is described below.
3. Emergency Restoration Plan
10
11
Q.
PLEASE DESCRIBE THE EMERGENCY RESTORATION PLAN.
12
A.
Emergency restoration
directives,
policies,
and
procedures
are
The Plan includes
13
documented in the Emergency Restoration Plan.
14
detailed position descriptions and associated responsibilities for each
15
special job function created by the Plan, consistent with the Incident
16
Command System as specified in the National Incident Management
17
System.
18
severity. Under the Plan, the severity of the emergency is gauged by the
19
expected damage restoration time, which defines the alert levels and
20
guides the implementation of the Incident Command System. Alert Levels
21
One and Two, which include estimated restoration times of less than 48
22
hours, will be managed under the authority of the Distribution Operations
23
Centers Incident Commander. Alert Levels Three and Four, which include
24
estimated restoration times greater than 48 hours, will fall under the
25
authority of System Emergency Center ("SEC"). The SEC is a dedicated
26
system command facility located in Dallas.
27
involve significant coordination with the Electric Reliability Council of
28
Texas ("ERCOT") and the Commission. If a Level Three or Level Four
29
Alert has not been activated within a given year, a Company-wide .
The Plan prescribes four Emergency Alert Levels based on
These major events also
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-16-
1
Emergency Restoration Plan drill is conducted to ensure employees
2
remain familiar with their roles and responsibilities.
3
Q.
PROGRAM WITH OTHER UTILITIES?
4
5
•
DOES THE COMPANY PARTICIPATE IN THE MUTUAL ASSISTANCE
A.
Yes.
Oncor continues to participate in the mutual assistance program
6
because it is the best way to protect our customers here at home. Should
7
a storm or other disaster hit our service territory that is of such a great
8
magnitude that Oncor alone cannot provide a quick response, then
9
through the mutual assistance program, we have the ability to receive help
This enables us to get power restored to our
10
from other utilities.
11
customers more quickly.
12
restoration on their systems, the costs associated with Oncor's employees
13
being deployed are not borne by Oncor's customers; the utility to which
14
Oncor provides the assistance pays those costs. Thus, participating in the
15
mutual assistance program is the right thing to do for our customers.
16
Q.
DESCRIBE
RECENT EXAMPLES OF EMERGENCY
RESTORATION.
17
18
PLEASE
When we assist other utilities with storm
A.
The Emergency Centers were activated on May 2, 2007, in response to
19
the second most severe storm in the Company's history, in which
20
approximately 624,000 customers were affected. The North Texas area
21
sustained 100 mph winds, heavy rains, and flooding as well as over
22
239,000 lightning strikes. Restoration resources included 698 employees,
23
2,916 contractors, and 120 mutual assistance personnel from CenterPoint
24
Energy and Oklahoma Gas & Electric. In accordance with Oncor's
25
Emergency Restoration Plan, several levels of the Incident Command
26
System were activated, which included the System Emergency Center,
27
the Transmission Emergency Center, the East and West Region Incident
28
Commands, and several District Incident Commands and restoration
29
areas. This coordinated effort resulted in an average restoration rate of
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Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-17-
•
S
I
1
6,567 customers per hour, with the large majority of the 624,000 affected
2
customers being restored within three days.
3
On December 9, 2007 the worst ice storm in Oklahoma's history
4
resulted in over 300,000 outages in Oklahoma Gas & Electric's service
5
area. As part of our Mutual Assistance Agreement with Oklahoma Gas &
6
Electric, Oncor deployed 125 employees and 300 contractors to assist in
7
restoration efforts in the Oklahoma City area for over 10 days in extremely
8
cold and icy conditions.
9
successfully utilized as our command post at three different locations,
10
close to where the crews were working. The tree damage due to ice was
11
devastating, and almost all of the restoration work was performed in walk-
12
in easements and fenced backyards. Even so, our crews were able to
13
restore power to over 10,000 customers before they returned home on
14
December 20, 2007.
The Oncor Mobile Command Center was
15
Although not during the test year, another example of a significant
16
emergency restoration effort happened on April 9 and 10, 2008. A super
17
cell thunderstorm developed in West Texas during the afternoon of April 9.
18
A related intense line of thunderstorms developed in the early morning
19
hours of April 10 southwest of the Metroplex moving through the
20
Metroplex in a broad north and easterly path resulting in the activation of
21
several levels of the Incident Command System including the System
22
Emergency Center, Transmission Emergency Center, the West and East
23
Region Incident Commands, and several District Incident Command and
24
restoration areas. The thunderstorms spawned a total of seven tornados
25
with maximum wind speeds registered at 110 mph, sustained straight-line
26
winds in excess of 75 mph, severe lightning, heavy rainfall and wide-
27
spread flooding with pea-sized to baseball-sized hail across Oncor's
28
service area. The tornados destroyed several 345kV, 138kV, and 69kV
29
structures in Oncor's service area.
30
severe storm in the Company's history, affecting over 488,000 customers.
This event became the third most
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-18-
• 1 Restoration resources included 1,587 employees, 905 construction
2
contractors, and 1,243 tree-trimming contractors. Due to the coordinated
3
effort, the average restoration rate of 5,800 customers per hour was
4
achieved with a majority of affected customers being restored within three
5
days.
6
Q.
7
8
PLEASE DESCRIBE ANY OTHER ELECTRICAL SYSTEM EMERGENCY
PLANS THAT ARE APPLICABLE TO ONCOR.
A.
We also are subject to the following two ERCOT emergency plans:
9
ERCOT Emergency Electric Curtailment Plan ("EECP") (Short Supply):
10
Under an ERCOT protocol, Oncor must be prepared to respond to a
11
system-wide short generation supply situation in ERCOT. The objective of
12
the EECP is to provide for maximum possible continuity of service while
13
maintaining the integrity of the ERCOT transmission grid in order to
14
reduce the chance of cascading outages. The EECP plan is activated in
15
four steps, depending on the severity of the situation and its impact on
16
system frequency. Oncor must respond to ERCOT's requests to reduce
17
load by using distribution voltage reduction management tools and/or to
18
shed firm load. Load Shedding/Rotating Black-outs is accomplished by
19
de-engergizing distribution feeders. In this scenario, Oncor's plan is to
20
rotate these feeders every 15 minutes to minimize disruption to any one
21
group of customers. In addition, ERCOT may request that Oncor issue an
22
appeal through public media for voluntary load reduction.
23
As part of its Short Supply plan, Oncor has 25% of its firm load
24
controlled with underFrequency relays. If the underfrequency feeders trip
25
due to operation of these relays, the Short Supply plan calls for an equal
26
amount of load to be shed from the manual load shed list and the
27
underfrequency feeders reenergized in order to re-arm the system to
28
quickly reduce load if the frequency would again fall below acceptable
29
levels. System operators are trained annually on a simulator to react to
30
this scenario.
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-19-
•
1
The following factors are considered in putting Oncor's load
2
shedding policy into practice: Types of Customers, Registry of Critical
3
Loads, and Curtailment Priorities.
4
analyzed to determine the types of customers each feeder serves. Critical
5
customers must be identified and are defined (in descending order of
6
criticality) as: (1) those whose service is critical to the public health and
7
welfare of the citizens of the community; (2) those who provide major
8
service to the citizens; or (3) those whose unique service is deemed
9
critical to the welfare of the citizens. Critical customers have the highest
10
11
All feeders on Oncor's System are
priority for restoration of service consistent with the ERCOT Guidelines.
This plan is reviewed and updated yearly, and an annual drill is
Oncor has an annual training
12
conducted in coordination with ERCOT.
13
program that includes activation of the emergency centers and simulation
14
of events. In addition, transmission operators spend one week in training
15
every six months and must maintain ERCOT certification through
16
continuing education credits.
17
ERCOT Black Start Emergency Plan: Another ERCOT protocol,
18
called "Black Start," requires Oncor to be prepared to respond effectively
19
to a total blackout in ERCOT. Due to the lack of interconnections between
20
ERCOT and other control areas, ERCOT must maintain its integrity with
21
ERCOT resources and the limited power available through DC ties to
22
other systems.
23
Black Start resources.
24
units designated as Black Start resources would have to be able to start
25
with no external power source, using emergency diesel generators. Each
26
contracted Black Start unit must have readily available and sufficiently
27
detailed current operating procedures to assist in an orderly recovery.
28
Careful coordination is required between ERCOT, Oncor, and generation
29
facilities to balance load and generating capability while maintaining an
30
acceptable system frequency in accordance with these plans. Appropriate
ERCOT conducts an annual bidding process to secure
Should a blackout occur in ERCOT, generation
Pulis - Direct
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2008 Rate Case
PUC Docket No. 35717
-20-
1
voltage levels and reactive control must also be maintained during the
2
restoration.
3
having
4
synchronization facilities,
5
ERCOT coordinating the return to full Automatic Generation Control.
Consideration is given to connecting islands at locations
communications,
control,
and adequate transmission capacity, with
In addition, ERCOT
7
EECP ( Short Supply) training using simulators.
8
conducts annual training for all No rt h Texas market pa rticipants at Oncor's
9
Transmission Grid Management center. The last training for Oncor was
10
conducted in Februa ry 2008. Black Start units must be tested annually.
11
Oncor's emergency communications system is tested eve ry week, and the
12
emergency generators that supply power to the system are tested
13
automatically on a programmed schedule.
14
black sta rt plans must be updated annually and provided to ERCOT.
16
Q.
HOW DOES ONCOR MANAGE ITS COSTS ASSOCIATED WITH
OUTAGE RESPONSE AND EMERGENCY RESTORATION?
17
18
Documentation of system
4. Cost Manaaement
15
•
voltage
control,
Oncor conducts an annual training seminar in concert with the
6
.
frequency
A.
Outages that are not related to storms are handled as part of normal day-
19
to-day service restoration, including restoring interrupted customer service
20
or correcting system failures that present hazardous conditions.
21
example, outages can be caused by an unknown pa rty inadvertently
22
digging into an Oncor underground distribution line, animals contacting
23
energized equipment, or the failure of a transformer.
24
treated as normal operating costs and are recorded as an expense in the
25
appropriate FERC account during the period in which they were incurred.
26
Operating costs for service restorations are recorded to the appropriate
27
expense code and to the restoration sub-activity group. The restoration
28
sub-activity group includes all work that is carried out to diagnose the
29
cause of an outage, sectionalize or isolate the problem, and perform
For
These costs are
Pulls - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-21-
•
temporary repairs, including any vegetation maintenance to restore
1
service or eliminate a hazardous condition.
2
3
Outages related to storms may involve both O&M and capital
4
5
expenditures. The majority of costs associated with smaller storms (less
than $500,000) are typically O&M related. To correctly capture storm
6
costs, O&M related costs are posted to a specific storm project and
7
account, while capital costs associated with property that is damaged is
8
tracked separately to an approved capital work request. Costs associated
9
with major events (damages in excess of $500,000 in O&M expense) are
10
charged to the Company's self-insurance reserve, which is addressed by
11
Company witnesses Messrs. Greer, Robert N. Hughes, and R. Keith
12
Pruett and Ms. Jeanne H. Camp.
5. Reasonableness and Necessity of Expenses
13
14
Q.
RESPONSE AND EMERGENCY RESTORATION REASONABLE AND
15
•
ARE THE DISTRIBUTION EXPENSES RELATED TO OUTAGE
16
NECESSARY?
18
Yes. Oncor continues to build on its long history of providing efficient and
effective outage response and emergency restoration. When an outage
19
occurs, the Company must respond quickly and efficiently to restore
20
service, and we do just that.
21
restoration are critical services that every electric utility must provide to the
22
public pursuant to its Tariffs and the Commission's Substantive Rules.
23
We have reasonable methods in place to track and manage our costs
24
associated with outage response and emergency restoration, and as
25
26
Company witness Mr. Greer explains, the O&M cost we incur per
The
customer compares very favorably with other electric utilities.
27
expenses incurred for outage response and emergency restoration are
28
both reasonable and necessary.
17
A.
Clearly, outage response and emergency
29
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Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-22-
1
B. Distribution Services -- Vegetation Management
2
1. Responsible Group
3
Q.
WITHIN
DISTRIBUTION
OPERATIONS IS
RESPONSIBLE FOR VEGETATION MANAGEMENT?
4
5
GROUP
WHAT
A.
The Vegetation Management work group within the Distribution Services
management
6
group administers the contracts with the vegetation
7
contractors for maintenance of Company T&D rights-of-way. The Asset
8
Management organization plans vegetation management so as to comply
9
with the standards set by the NERC and determines appropriate resource
allocation.
10
11
Q.
ASPECTS OF ITS VEGETATION MANAGEMENT EFFORTS?
12
13
DOES ONCOR USE OUTSIDE SERVICES TO PERFORM ANY
A.
Yes.
Oncor utilizes contract line clearance companies, herbicide
14
applicators, Right-of-Way maintenance contractors, contract foresters, and
15
contract field auditors to help maintain the vegetation on the T&D system.
16
Utilizing contractors for these services is common in the utility industry
17
because it allows utilities to have access to a readily available, trained
18
workforce. In times of great need, such as after a devastating storm,
19
Oncor's contract line clearance companies have the ability to quickly
20
access a very large work force -- a work force that is much larger than
21
Oncor could maintain or access on its own.
2. Implementation
22
23
Q.
MANAGEMENT?
24
25
WHAT IS ONCOR'S OBJECTIVE WITH RESPECT TO VEGETATION
A.
The goals of the vegetation management efforts are to provide safe and
26
reliable energy delivery, prevent damage to Company equipment, and
27
avoid access impairment for the safety of Company employees and
28
contractors.
29
electrical reliability of the T&D system. Oncor's Vegetation Management
30
group manages the rights-of-way for the Company's T&D system and
Vegetation management is critical to maintaining the
~
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
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1
provides
2
approach.
3
Our goal is to utilize the latest technology and best utility work
4
practices in our vegetation management. Oncor is a recognized Tree Line
5
USA recipient for the seventh consecutive year. This is an award given by
6
the Texas Forest Service and National Arbor Day Foundation recognizing
7
that the Company has met the goals set by these two organizations in
8
order to be recognized nationally. The Vegetation Management group has
9
degreed foresters who have Arborist ce rtifications from the International
The foresters also have Texas Department of
10
Society of Arboriculture.
11
Agriculture Non-Commercial Applicators licenses. These certifications,
12
licensing,
13
Vegetation Management group abreast of the latest technologies and
14
work practices in the utility indust ry.
15
•
support by using an integrated vegetation management
Q.
ONCOR'S
DESCRIBE
INTEGRATED
VEGETATION
MANAGEMENT APPROACH.
16
17
PLEASE
and continuing education requirements help keep the
A.
Oncor looks at the performance of its distribution feeders to determine
18
which feeders would likely benefit from vegetation management. In
19
addition,
20
distribution feeders, visually inspect those feeders, and issue an order for
21
vegetation management if needed.
22
transmission lines and conduct aerial inspections to determine where line
23
clearance maintenance activities are needed. Once we have determined
24
which lines need attention, we use best management practices to actually
25
manage the vegetation, including using mechanical, manual, and chemical
26
controls. This approach comprises our Integrated Vegetation Management
27
program.
Distribution
Operations technicians monitor their assigned
28
29
30
We also routinely patrol our
3. Cost Management
Q.
HOW DOES ONCOR MANAGE AND CONTROL VEGETATION
MANAGEMENT COSTS?
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-24-
~
1
A.
2
management, including evaluated firm price bids, and time and material
3
pricing.
4
perform quality assurance and controls on the contractors performing
5
vegetation management across the system. Oncor maintains a herbicide
6
program to reduce future stem count and reduce more costly mechanical
7
and manual line clearance activities.
8
electronic invoicing system also contains a system of checks that verify
9
billing accuracy for the individual work types.
10
Q.
12
A.
WHAT COSTS DID ONCOR INCUR IN THE TEST YEAR FOR
Total Vegetation
Management costs, excluding property insurance
4. Reasonableness and Necessity of Expenses
14
Q.
WERE THE VEGETATION MANAGEMENT EXPENSES DESCRIBED
16
ABOVE REASONABLE AND NECESSARY FOR THE PROVISION OF
17
SERVICE TO THE PUBLIC?
18
i
The Vegetation Management
reserve-related storms, were $60,535,929.
13
15
Oncor utilizes third-party forestry management contractors to
VEGETATION MANAGEMENT?
11
•
Oncor uses various methods for obtaining resources to perform vegetation
A.
Yes. Oncor recognizes the critical need and importance of this program.
19
The Vegetation Management activities described above are essential to
20
maintaining the safety and reliability of the Oncor T&D system. In
21
addition, the blackout in the northeastern United States in 2003 has
22
caused a heightened awareness of, and focus on, this issue. The NERC
23
has become increasingly more involved in monitoring and establishing
24
standards on how we maintain and operate our transmission facilities for
25
the safe and reliable distribution of high voltage electricity in the
26
Company's footprint, and the interaction of our system to surrounding
27
transmission owners.
28
monitoring the operation of our transmission system.
29
voltages, the Commission monitors Oncor's service reliability annually to
30
ensure areas with service quality issues are addressed.
ERCOT has also become more involved in
For distribution
Market pricing
Pulls - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-25-
~
1
comparisons are routinely performed to ensure generally accepted
2
industry costs are obtained. Accordingly, the expenses associated with
3
such vegetation management effo rts are reasonable and necessa ry.
4
C. Measurement Services -- Field Services
5
1. Services Provided
6
•
Q.
7
MEASUREMENT SERVICES
8
OPERATIONS.
9
A.
GROUP
WITHIN
DISTRIBUTION
Field services include: ( 1) connecting and disconnecting service
10
and providing meter readings associated with move-in and move-out
11
activities; (2) disconnecting and reconnecting service associated with non-
12
payment; and (3) out-of-cycle meter readings for retailer switch requests.
13
In 2007, those field service technicians performed 2.4 million disconnects
14
and reconnects on the Oncor distribution system.
15
important to our ability to serve retail electric providers ("REPs") and to
16
comply with the Commission's approved Terms and Conditions of Service.
17
Field service technicians also investigate potential diversion and meter
18
tampering.
20
These activities are
2. Impact of Advanced Metering Deployment
19
Q.
PLEASE DESCRIBE THE IMPACT THAT THE DEPLOYMENT OF
21
ADVANCED METERING EQUIPMENT ON ONCOR'S DISTRIBUTION
22
SYSTEM WILL HAVE ON THE MEASUREMENT SERVICES PROVIDED
23
BY DISTRIBUTION OPERATIONS.
24
!
PLEASE DESCRIBE THE FIELD SERVICES PROVIDED BY THE
A.
We expect that once the deployment of advanced metering on our system
25
is complete, the current costs associated with manual meter reading will
26
be essentially eliminated. We also expect, however, that the deployment
27
of advanced metering will cause us to engage in some new activities that
28
are not included in the meter reading expenses for 2007. As described in
29
Oncor's Request for an AMS Surcharge proceeding, Oncor's deployment
30
of advanced metering will include the deployment of two sophisticated
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-26-
• 1 communication networks. Oncor will also operate and maintain the
back-office
operating
systems
and the Meter Data
2
supporting
3
Management System ("MDMS"), which is discussed in the direct testimony
4
of Company witness Mr. Walter M. Carpenter.
5
personnel to ensure that we have sufficiently skilled resources to maintain
6
and operate those communication networks and the supporting back-
7
office operating systems and MDMS. The proposed AMS Surcharge does
8
not include any costs that are included in this rate case filing, and this rate
9
case filing does not include any of the estimated costs that the Company
We will also need to add
is seeking to recover in the AMS Surcharge.
10
3. How Managed
11
12
Q.
HOW IS THE PROVISION OF MEASUREMENT SERVICES MANAGED?
13
A.
We manage the provision of measurement services, including installing,
14
testing, maintaining, and collecting data from meters both manually and by
15
using advanced meter systems. Normal connections and disconnections
16
are handled through our service centers that are spread throughout our
17
service area.
18
manually or through automated meter reading systems where automated
19
meters are installed. The management of manual meter readings is done
based on the geographic areas that need to be covered. The automated
20
Normal monthly meter reads are done two ways, either
22
meter readings are handled through our computer systems, which are
managed by Measurement Support within the Measurement Services
23
group. Requests for out-of-cycle meter reads are performed by the same
24
employees who handle disconnects and reconnects. Meter test requests
25
by customers and REPs are performed by meter technicians who are
26
assigned across the service area.
21
4. Cost Management
27
28
29
Q.
HOW DOES DISTRIBUTION OPERATIONS MANAGE THE COSTS
ASSOCIATED WITH FIELD SERVICES?
~
Pulls - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-27-
• 1 A.
Field service costs are managed by efficiently matching required skills to
2
the services to be performed and locating personnel across the service
3
area. Field service personnel and meter reading personnel are co-located
4
and supervised in non-metro areas of the service territory. Service orders
5
are routed to individuals in the field by a centralized dispatch group via a
6
mobile workforce management system, which reduces the drive time
7
between service orders to the extent possible.
5. Reasonableness and Necessity of Expenses
8
9
Q.
MEASUREMENT SERVICES REASONABLE AND NECESSARY?
10
11
ARE THE EXPENSES ASSOCIATED WITH THE PROVISION OF
A.
Yes. The functional organization and work management are organized to
12
support efficient delivery of services in accordance with customer and
13
market requirements. The expenses are necessary to ensure the integrity
14
and accuracy of measurement and reporting of energy delivery and
15
provision of associated field services required by customers and REPs.
16
Q.
HAVE INCREASES IN SERVICE LEVEL REQUIREMENTS CAUSED A
17
CHANGE IN THE EXPENSES ASSOCIATED WITH THE PROVISION OF
18
MEASUREMENT SERVICES?
19
A.
Yes.
As I previously mentioned, the Commission recently adopted
20
changes to the standard Terms and Conditions that must be adhered to by
21
22
electric utilities. Those changes to the service level requirements in the
Terms and Conditions require increased service levels for several utility
23
services. Those increased service levels have caused Oncor's expenses
24
associated with the provision of measurement services to increase.
25
Previously, Oncor staffed its measurement services function to meet the
26
average level of work.
27
operations, but it did not achieve the compressed timeframes now
28
required.
29
increase its staffing so that it can meet the new expected 98%
30
performance level within the required time frame.
That staffing level was sufficient during normal
Thus, to meet the new increased service levels, Oncor must
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-28-
1
"
For
example,
previously
Oncor
was required to complete
2
reconnect after disconnect for non pay" service requests by the end of the
3
next field operations day. Now, completion of that type of service request
4
is required on the same day if the request is received by 2 p.m. and on the
5
next day if the request is received after 2 p.m., and the same day if
6
received by 5 p.m. for priorities. Standard connect and disconnect orders
7
are expected to be completed on the requested date if received 2 days
8
prior to the requested date. Oncor experiences higher volumes of connect
9
and disconnect orders near the end of the month because customers
10
frequently relocate at that time. Additionally, there has been an increase
11
in priority requests during the test year from approximately 8 percent to
12
approximately 11 percent of the total volume. If these orders are received
13
by 5 p.m., they are to be completed the same day. Therefore, more field
14
service personnel are required for Oncor to meet the new increased
15
service levels during those times of higher volume.
• 16 Q. IS ONCOR PROPOSING ANY KNOWN AND MEASURABLE CHANGES
17
TO ITS TEST YEAR O&M EXPENSES RELATED TO THESE CHANGES
18
IN SERVICE LEVEL REQUIREMENTS?
19
A.
Yes. Oncor is requesting that its O&M expenses related to Measurement
20
Services be increased by $1,911,387. Because of the changes to service
21
level requirements in the revised standard Terms and Conditions
22
described above, Oncor has had increased expenses for Field Services in
23
the Measurement Services organization, and those increased expenses
24
will continue to be incurred.
25
incurred by the Company with respect to the increased service level
26
requirements were $159,282. When that expense amount is annualized,
27
the total additional O&M expenses requested are $1,911,387. Because
28
these additional expenses are both known and measurable, Oncor
29
requests their addition to the Company's test year O&M expenses.
For March 2008, the additional expenses
~
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-29-
•
1
Oncor is still
making
process improvements to
maximize
2
productivity before adding additional resources to meet the increased
3
service level requirements.
4
those process improvements, additional resources in Measurement
5
Services and Distribution Operations will be necessa ry to meet those
6
requirements beyond the known and measurable change we are
7
requesting here. We are not, however, requesting an increase for those
8
additional resources because they are not sufficiently quantifiable at this
9
time.
However, Oncor is certain that even with
10
D. Street Light Maintenance -- Street Lights
11
1. Responsible Group
12
Q.
GROUP
WITHIN
DISTRIBUTION
OPERATIONS IS
RESPONSIBLE FOR THE STREET LIGHT MAINTENANCE PROGRAM?
13
14
WHICH
A.
The Street Light Maintenance Group.
2. Overview of Street Light Program
15
16
Q.
PLEASE DESCRIBE ONCOR'S STREET LIGHT PROGRAM.
17
A.
Oncor provides street lights, including a variety of fiberglass, aluminum,
18
steel, and wood poles, as well as a variety of fixtures and arms, that are
19
designed to meet the costs and aesthetic desires of any governmental
20
entity.
21
Oncor provides the necessa ry materials for connecting a street
light to Oncor's system and supplies a point for energy delivery. Oncor
22
also provides maintenance service for street lights available under its
23
Tariff for Retail Delive ry Service (the "Tariff").
24
Q.
WHAT ARE THE GOALS OF ONCOR'S STREET LIGHT PROGRAM?
25
A.
26
The goals are to: ( 1) provide requested street lighting services in
accordance with Oncor's approved Tariff; ( 2) meet or exceed the
27
Commission's standards for maintaining street lights and the related
28
standard reflected in the Commission's Order in Docket No. 34077; (3)
29
add and remove street lights as requested and in a timely manner; and (4)
30
accurately bill REPs for street lighting services.
~
Pulls - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-30-
•
1
Q.
HOW MANY STREET LIGHTS ARE ON ONCOR'S SYSTEM?
2
A.
Oncor provides street light services to approximately 400,000 unmetered
3
street lights system-wide. These street lights are located in 356 cities and
4
in some unincorporated areas. Oncor owns and maintains approximately
5
310,000 street lights.
6
owned. In addition, Oncor provides maintenance of customer-owned
7
street lights on an as-requested basis pursuant to our Tariff.
8
Q.
DOES ONCOR PROVIDE METERED STREET LIGHT SERVICE?
9
A.
Yes.
However, the Tariff provides that metered street lights must be
10
customer-owned. For those lights, Oncor provides only a point of delive ry
11
through one meter. These metered street lights are not part of the street
12
light program I described above. Therefore, all future references to, and
13
discussion of, street lights in this direct testimony are referring to
14
unmetered street lights only.
15
Q.
17
HOW MANY STREET LIGHTS ARE ADDED TO ONCOR'S SYSTEM
EACH YEAR?
16
0
The remainder of the street lights are customer-
A.
18
The number of street lights added to the Oncor system between 2002 and
2007 averaged 6,000 per year.
19
Q.
WHAT TYPES OF STREET LIGHTS DOES ONCOR PROVIDE?
20
A.
Oncor provides several different types of lights at different wattages.
21
Oncor's Tariff currently provides for multiple combinations of light type and
22
23
wattage. In addition, there are numerous types of fixtures (e.g., decorative
and ornamental) available. Oncor previously provided mercu ry vapor
24
lights. However, because of a change in the law under the Energy Policy
25
Act of 2005, Oncor no longer offers mercu ry vapor lights as an option for
26
new street lighting. The Tariff proposed herein, and discussed in detail in
27
Company witness Mr. J. Michael Sherburne's direct testimony, provides a
28
revised schedule for street light services.
29
Q.
WHAT STANDARDS ARE USED FOR STREET LIGHT INSTALLATION?
30
A.
Oncor complies with NESC standards.
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-31 -
•
1
Q.
2
3
ONCOR?
A.
Under Oncor's Tariff, street light service is available to REPs for service to
4
governmental entities in areas that are served by Oncor. Governmental
5
entities receiving street light service from Oncor include incorporated
6
cities, counties, municipal utility districts, and the Texas Department of
7
Transportation.
8
Q.
9
10
DOES ONCOR PROVIDE STREET LIGHT SERVICE TO ANY NONGOVERNMENTAL ENTITIES?
A.
Yes, Oncor still honors historical obligations that it had under prior Tariff
11
requirements for existing street light service to ce rtain non-governmental
12
customers, such as homeowners associations. However, new street light
13
service is not available to non-governmental entities.
14
3. Street Light Maintenance
15
•
WHO IS ELIGIBLE TO RECEIVE STREET LIGHT SERVICE FROM
Q.
16
17
PLEASE DESCRIBE ONCOR'S RESPONSIBILITIES ONCE A STREET
LIGHT IS INSTALLED.
A.
As I previously mentioned, Oncor is currently responsible for maintenance
Approximately
18
of approximately 310,000 Company-owned street lights.
19
200,000 of these lights are located in the Dallas/Fo rt Worth Metroplex and
20
the nine surrounding counties. In addition to Oncor's own street lights,
21
Oncor also maintains a small number of street light facilities for the Texas
22
Depa rtment
23
developments, businesses, and cities on an as-requested basis.
24
Q.
25
26
of
Transpo rtation,
homeowner associations,
private
WHAT SERVICES ARE INCLUDED IN THE MAINTENANCE OF
STREET LIGHTS?
A.
Maintenance includes the replacement or repair of any component
27
associated with the pole or fixture that allows the facility to operate safely
28
and effectively.
29
Q.
HOW DOES ONCOR IDENTIFY STREET LIGHT OUTAGES?
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-32-
~ 1 A. In the Dallas/Fort Worth Metroplex, Oncor performs street patrols five
2
nights a week checking streetlights. The proximity of the cities in the
3
Metroplex allows Oncor to systematically patrol major thoroughfares in
4
each city at least once per quarter. In the rural areas outside of the
5
Metroplex, where cities are further apart and there are fewer street light
6
facilities, Oncor's distribution crews and contractors working in those
7
areas are used to report and repair outages.
8
municipalities and the general public report street light outages. In fact,
9
the majority of street light outages are identified based on reports received
10
from the general public. The general public includes not only individual
11
citizens, but also reports from city officials, including police officer reports.
12
Q.
13
14
And, of course,
HOW DOES A MUNICIPALITY OR A MEMBER OF THE GENERAL
PUBLIC REPORT A STREET LIGHT OUTAGE?
A.
Oncor receives outage information in many different ways, including
15
through its public website, through its call center, and through direct faxes
16
or e-mails.
17
accessible on its public website to assist customers in reporting street light
18
outages. During 2007, an average of 153 reports per day were received
19
using this particular method.
20
council members and local residents to educate them on the various ways
21
to report a street light outage, and the importance of doing so.
22
Q.
23
24
Since 2003, Oncor has had an electronic form that is
Oncor works with city governments, city
ONCE ONCOR RECEIVES A REPORT OF AN OUTAGE, WHAT
HAPPENS NEXT?
A.
To maintain consistency and to facilitate the flow of information across the
25
system, all street light reports are entered into the Oncor outage reporting
26
system, known as Computer Assisted Trouble System ("CATS"). Every
27
street light outage reported through CATS generates a "ticket" and is
28
recorded. Each ticket is assigned a specific trouble code and printed to
29
the appropriate service center representative or contractor, who inspects
30
and evaluates the street light to determine what, if any, repairs are
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-33-
•
1
needed. If possible, the serviceman will repair an outage on site; if not,
2
the serviceman will schedule additional repairs or replacement.
3
Q.
DO ONCOR PERSONNEL PERFORM THE REPAIRS?
4
A.
Oncor hires contractors to make standard street light repairs. Since the
5
majority of all street lights are located in the Metroplex, the use of
6
contractors allows Oncor to focus these contracted resources solely on
7
street light maintenance and repair.
8
conducted by a limited number of Oncor employees who are responsible
9
for other distribution system work and contractors who are solely
responsible for street light maintenance and repair.
10
11
Q.
12
13
Repairs in rural areas are currently
WHAT SITUATIONS CREATE A
NEED
FOR STREET LIGHT
MAINTENANCE?
A.
There are three types of events that most often create a need for street
14
light maintenance:
15
1.
Routine repairs, which include bulb replacement;
16
2.
Circuit repairs, which may require Oncor to access underground
17
facilities; and
18
3.
Knockdowns, which are not repairs, but rather require the entire
19
replacement of a street light. Knockdowns are street lights that are
20
physically damaged or destroyed by impacts related to weather,
21
construction, traffic accidents, etc.
22
Q.
HOW LONG DOES IT TAKE TO REPAIR STREET LIGHTS?
23
A.
The average repair of a routine outage due to component failure (lamps,
24
photocells, ballasts, starter boards, etc.) is approximately five business
25
days. In 2007, 92% of all repairs were considered " routine." Repairs that
26
require more extensive construction or installation activities (for example,
27
underground cable failures) often take considerably more time to
28
complete. In 2007, circuit repairs were made in an average of 11 calendar
29
days.
~
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-34-
•
1
Also, some street lights requested by customers are non-standard
2
street lights that are decorative or unique in some way. It can take
3
additional time to procure parts for those non-standard lights.
4
Oncor maintains a full inventory of different styles of commonly-used
5
standard street lights and associated parts to support new construction
6
and facilitate repair or replacement of damaged facilities, it does not, and
7
effectively cannot, keep on hand all parts for every possible light that a
8
customer may choose.
9
Q.
10
11
•
While
WHY DOES IT TAKE SO MUCH LONGER TO COMPLETE CIRCUIT
REPAIRS?
A.
Circuit failures often require construction work in a public right-of-way,
12
which requires additional time to obtain required city permits, contact the
13
Texas Excavation Safety System as required by law, physically locate the
14
underground line in need of repair, and get a traffic control plan from the
15
city, which may require work during off-peak hours.
16
construction is also dependent on favorable weather conditions.
Underground
17
Q.
HOW DOES THE COMPANY TREAT KNOCKDOWNS?
18
A.
As I mentioned earlier, knockdowns are not related to typical wear and
Therefore, knockdowns are not
19
tear of a street light's components.
20
treated as repairs.
21
street light. In 2007, the average time for replacement of knockdowns was
22
27 calendar days.
23
construction work in public rights-of-way, which creates the delays
24
described above. In addition, there are often pending insurance claims
25
related to the accident that caused the pole to be knocked down, and the
26
affected city or citizen requests that the knocked down pole not be
27
removed until appropriate inspections or evaluations can be conducted.
28
29
Q.
Knockdowns require Oncor to completely replace a
As with circuit repairs, knockdowns often require
HAS THE COMPANY COMMITTED TO ANY PERFORMANCE
STANDARDS RELATED TO STREET LIGHTS?
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-35-
1
A.
Yes. In Docket No. 34077, Oncor agreed to street light performance
2
standards that are to apply from January 1, 2008 until December 31,
3
2012.
4
agreements with Cities, those standards are as follows:
5
•
6
To the extent that they are not inconsistent with existing
Routine repairs (bulbs, photocells, ballasts) - 90% complete in 5
calendar days;
7
•
8
Circuit repairs (overhead/underground cable repairs) - 80% complete
in 15 calendar days;
9
•
10
Knockdowns (not repairs, require the replacement of the entire light) 80% complete in 30 calendar days
11
These metrics will be exempt from force majeure events, including, but not
12
limited to, major storms, cities whose ordinances or approvals impact
13
Oncor's ability to meet these metrics, and mutual assistance to other
14
utilities.
15
pre-determined work schedules, and noise ordinances. All non-standard
Examples of qualifying City ordinances include lane closures,
• 16 lights, such as antique or historical lights are exempt from this requirement
17
since they are not readily available in Oncor's stock or from the
18
manufacturer.
19
year if the standards are not achieved, to be paid to the customers
20
affected as contained in a plan filed by Oncor with the Commission for
21
approval. This plan was filed on April 7, 2008.
22
Q.
23
24
Oncor agreed to a maximum payment of $1 million per
WILL THIS NEW STANDARD REQUIRE CHANGES IN ONCOR'S
STREET LIGHT MAINTENANCE PROGRAM?
A.
Yes. Currently, our Tariff provides that Oncor will repair any street light or
25
security light within 15 calendar days of receipt of a repair request. Due to
26
the reduced timelines in the new standard I described above, Oncor will
27
need to increase resources to perform street light maintenance. In
28
addition, Oncor is required to make information technology system
29
modifications so that necessary metrics required by the new standard can
• 30 be tracked and reported.
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-36-
• 1 Q. IS ONCOR PROPOSING A KNOWN AND MEASURABLE CHANGE TO
2
ITS TEST YEAR O&M EXPENSES RELATED TO STREET LIGHT
3
MAINTENANCE?
4
A.
Yes. Oncor is requesting that its O&M related to street light maintenance
5
be increased by $534,197. During the test year, Oncor was charged $.66
6
per light per month pursuant to its contract with its street light maintenance
7
contractor for maintaining 204,952 street lights in the Dallas-Fort Worth
8
Metroplex. In 2008, that contractor raised its charge to Oncor to $.87 per
9
light per month. This increase will cost Oncor an additional $534,197 over
Because these additional
10
the amount it incurred during the test year.
11
costs are both known and measurable, Oncor requests their addition to
12
the Company's test year O&M expenses.
4. Operational Challenges
13
14
Q.
DISCUSS WITH REGARD TO STREET LIGHT MAINTENANCE?
15
~ 16
ARE THERE ANY OTHER CHALLENGES THAT YOU WOULD LIKE TO
A.
Yes. In pa rticular, Oncor has been actively working to address cities'
17
expectations regarding street light services. In 2004, several cities, as
18
pa rt of the Steering Committee of Cities Served by Oncor ("Steering
19
Committee"), initiated some rate inquiries, including a complaint that street
20
light rates were too high. The Steering Committee and Oncor agreed to
21
establish a Street Light Task Force to work on several issues, including
22
timeliness of street light maintenance and development of a process to
23
assign street lights an identifiable geographic location.
24
Q.
25
26
DID ONCOR TAKE ANY ADDITIONAL STEPS TO FOCUS ATTENTION
ON THE STREET LIGHT PROGRAM?
A.
Yes.
Oncor has met with members of the Steering Commi ttee several
27
times to discuss these and other issues, and to provide the Steering
28
Committee updates on the actions it has taken. In addition, Oncor has
29
recently made some organizational changes to further focus attention and
30
resources on the street light program.
Oncor has defined specific
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-37-
1
organizational responsibilities and designated several full-time personnel
2
whose time is solely dedicated to street lights, including managing the
3
maintenance of street lights and handling customer service and billing
4
issues for street lights.
5
In addition, one of the concerns that cities raise with Oncor is how
6
to improve "customer feedback" when outage reports are made. Oncor is
7
currently reviewing a number of options to provide appropriate feedback
8
so that the public can be certain that street light outages are being timely
9
addressed.
10
Q.
LIGHTS YOU WOULD LIKE TO DISCUSS?
11
12
ARE THERE ANY OTHER CHALLENGES REGARDING STREET
A.
Oncor has been challenged to timely repair and replace street lights
13
because of the high incidence of theft of cables and other facilities that
14
contain high-value metals. Although it is a problem not just for the street
15
light program, it does have a significant negative effect on Oncor's ability
16
to maintain street lights as effectively as it would like.
17
18
E. Other Activities
Q.
ENGAGE IN?
19
20
WHAT OTHER ACTIVITIES DOES DISTRIBUTION OPERATIONS
A.
Employees of Distribution Operations are responsible for performing
21
several additional activities that are required for the Company to be able to
22
provide safe and reliable delivery of electricity.
23
Operations'
24
responsible for providing environmental, health, safety, and training
25
services to the Oncor organization through a team of professionals
26
focused on these topics.
27
within the Distribution Services group is responsible for ensuring that both
28
Distribution Operations and Transmission & System Operations have the
29
transportation needed to provide service to customers.
30
Customer Service Support group within the Distribution Operations group
Environmental,
Health,
Safety,
First,
and Training
Distribution
group is
Second, the Transportation Services group
Third, the
•
Pulls - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-38-
• 1 is responsible for working with end-use customers directly when
necessa ry , such as notifying the customer of a necessa ry power outage.
2
3
Q.
PLEASE
DESCRIBE IN MORE DETAIL WHAT ACTIVITIES THE
4
ENVIRONMENTAL,
5
ENGAGE IN.
6
A.
HEALTH, SAFETY, AND TRAINING GROUP
Oncor is commi tt ed to protecting the air, land, and water by meeting or
7
exceeding environmental standards. This group provides comprehensive
8
environmental services, including the following: site assessments;
9
environmental permit development, submittal, and performance tracking;
10
proactive engagement in regulatory review, assessment, comment, and
11
program development; interactions with all state, federal, and local
12
environmental regulatory agencies; compliance support and audits;
13
regulatory filings development, review, and submittal; comprehensive
14
assessment, transportation, disposal, and recycling of system waste; and
15
proactive interface with stakeholders on environmental issues of concern.
• 16
Because safety is our top priority at Oncor, this group has
17
implemented a consistent process to improve employee safety training
18
and accident prevention.
19
coursework each year, and they are equipped with the training, tools, and
20
personal protective equipment to help ensure on-the-job safety.
21
safety and training professionals in this group provide the following:
22
regulatory interface with local, state, and federal agencies; regulatory
23
review, assessment, comment, and program development; compliance
24
assurance with all safety and Department of Transportation regulations;
25
comprehensive Craft Advancement Progression Skills training for lineman;
26
and other safety training on such topics as ergonomics, driver safety,
27
Occupational Safety and Health Administration compliance, medic first
28
aide and blood borne pathogens, Automatic External Defibrillation, and
29
meter base disconnects and reconnects.
30
delivering occupational health and wellness services to our employees
Employees receive numerous hours of
The
Oncor actively engages in
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-39-
with a focus on disease and injury prevention.
2
Department of Homeland Security and NERC, we have developed a
3
Pandemic Readiness Plan, proactively engaging our vendors; our local,
4
state, and federal regulators; and our employees and their families in this
5
process.
6
Q.
ARE THE COSTS ASSOCIATED WITH THE ENVIRONMENTAL,
7
HEALTH, SAFETY, AND TRAINING GROUP REASONABLE AND
8
NECESSARY?
9
A.
Yes. Obviously, we must comply with all applicable laws and regulations
10
governing the environment and the health and safety of our workers. Our
11
priority on safety is integral to our operational mindset and a fundamental
12
principle of the way we do business. In addition, all of the activities
13
performed by the Environmental, Health, Safety, and Training Group are
14
critical to our ability to provide safe and reliable electricity to customers.
15
•
At the urging of the
1
Q.
TRANSPORTATION SERVICES GROUP ENGAGE IN.
16
17
PLEASE DESCRIBE IN MORE DETAIL WHAT ACTIVITIES THE
A.
As one would expect, Oncor must have transportation capability in order
The
18
to provide the necessary service to customers on its system.
19
Transportation Services group handles the procurement, registration,
20
maintenance, and disposal of all of the Company's transportation fleet.
21
This organization represents Oncor with our vendors, suppliers, and peer
22
utilities in the fleet industry.
23
group represents Oncor as a member of the Hybrid Truck Users Forum.
24
As a member, we were one of fourteen utilities that participated in the
25
national pilot program to test a hybrid powered (diesel-electric) truck in our
26
fleet under real operating conditions.
27
powered bucket trucks were placed in service at the fourteen utility
28
companies across the U.S. and Canada to evaluate this technology and
29
determine ways to improve the hybrid system. Oncor has a hybrid bucket
For example, the Transportation Services
A total of twenty-four hybrid
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-40-
•
1
truck that has been in service since June 2006 and has two additional
2
hybrid bucket trucks on order.
3
We also participate in the confidential Utilimarc Benchmark Survey
4
with 48 other utilities. The basic fleet statistics and actual fleet expense
5
numbers are furnished to the Utilimarc group, and they analyze each fleet
6
to determine the best manner to compare the operation of the various
7
fleets in a format that levels the playing field. The Oncor fleet has been in
8
the top quartile in Annual Cost per Vehicle every year since the survey
9
began in 2001.
10
Q.
11
12
•
ARE THE COSTS ASSOCIATED WITH THE TRANSPORTATION
SERVICES GROUP REASONABLE AND NECESSARY?
A.
Yes.
The services provided by the Transportation Services group are
13
clearly necessary to Oncor's ability to provide service to customers, and
14
the costs associated with those services are reasonable, particularly in
15
light of Oncor's performance in this area when compared to other utilities.
16
Q.
CUSTOMER SERVICES SUPPORT GROUP ENGAGE IN.
17
18
PLEASE DESCRIBE IN MORE DETAIL WHAT ACTIVITIES THE
A.
The Customer Service Support group provides service to customers on
This group is responsible for interfacing with
19
the distribution system.
20
customers directly on numerous distribution issues, such as when a
21
customer's power must be disconnected in the course of providing a repair
22
or upgrade to the distribution system. This group also provides support in
23
communicating with and assisting critical and life support customers
24
during storms and major outage events, and serves as Oncor's customer
25
interface in resolving access issues when fences, barriers, or other
26
obstacles block Oncor's access to electrical equipment. This group also
27
assists in resolving meter access issues for Measurement Services,
28
assists in resolving vegetation management tree trim refusals and other
29
vegetation management issues, and supports Distribution Operations in
~
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-41-
•
1
maintaining
2
3
customer premise information within
Oncor's
customer information system.
Q.
ARE THE COSTS ASSOCIATED WITH THE CUSTOMER SERVICE
SUPPORT GROUP REASONABLE AND NECESSARY?
4
5
accurate
A.
Yes. The services provided by the Customer Services Suppo rt group are
6
clearly necessa ry to Oncor's ability to provide safe and reliable service to
7
customers, and the costs associated with those services are reasonable.
VI. CONCLUSION
8
9
Q.
PLEASE SUMMARIZE YOUR DIRECT TESTIMONY.
10
A.
In summa ry, the conclusions of my direct testimony are as follows:
11
•
Oncor's capital investment in its distribution system as included in
12
the rate filing package (" RFP") is used and useful and reasonable
13
and necessary for the safe and reliable operation of the Oncor
14
distribution system and the provision of service to the public.
15
•
Oncor's O&M expenses as described in my direct testimony and
16
included in the Company's RFP for system maintenance, outage
17
response
18
measurement services, street lights, and other services are
19
reasonable and necessa ry for the provision of service to the public.
20
21
Q.
A.
and
storm
restoration,
vegetation
management,
DOES THIS CONCLUDE YOUR DIRECT TESTIMONY?
Yes.
•
Pulis - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-42-
•
§
§
§
STATE OF TEXAS
COUNTY OF DALLAS
BEFORE ME, the undersigned authority, on this day personally appeared
Brenda J. Pulis, who, having been placed under oath by me, did depose as
follows:
My name is Brenda J. Pulis. I am of legal age and a resident of the State
of Texas. The foregoing direct testimony and the attached exhibits offered by me
are true and correct, and the opinions stated therein are, to the best of my
knowledge and belief, accurate, true and correct.
XK'd.g
g
Qtectt~ R~lis
•
SUBS RIBED AND SWORN TO BEFORE ME by the said Brenda J. Pulis this
a ~day of June, 2008.
Notary Public, Stake of Texas
i.~.~.ri.
TERI SMART
My CommIsMon Expires
November 13, 200d
Ra+~
Pulls - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
❑
-43-
EXHIBIT BJP-1
Page 1 of 1
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-44-
•
INDEX TO THE DIRECT TESTIMONY
OF WESLEY SPEED, WITNESS FOR
ONCOR ELECTRIC DELIVERY COMPANY LLC
1.
POSITION AND QUALIFICATIONS ................................................................2
II.
PURPOSE OF DIRECT TESTIMONY ........................................................... ..3
III.
ONCOR TRANSMISSION SYSTEM AND ORGANIZATION ......................... ..4
IV.
TRANSMISSION AND LOAD SERVING SUBSTATION OPERATION AND
MAINTENANCE ACTIVITIES ........................................................................ 11
A. Introduction ............................................................................................... 11
B. Activity Discussion .................................................................................... 11
V.
DESCRIPTION OF CAPITAL INVESTMENT ................................................ 14
A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
B. Categories of Projects Included in Rate Base .......................................... 18
C. Project Selection Process ........................................................................ 19
•
VI.
INVENTORY AND WORKING CAPITAL ALLOWANCE ................................21
VII.
PLANT HELD FOR FUTURE USE ................................................................23
VIII. CONCLUSION ............................................................................................... 24
•
IX.
AFFIDAVIT .................................................................................................... 26
X.
EXHIBITS ...................................................................................................... 27
EXHIBIT WS-1
CCN Proceedings
EXHIBIT WS-2
Dallas-Fort Worth Area Transmission Construction Map
EXHIBIT WS-3
Transmission Capital Expenditures by Year
EXHIBIT WS-4
TCOS Filings Listing of Projects
EXHIBIT WS-5
New Generation Connected to Oncor Grid
EXHIBIT WS-6
Circuit Miles of Transmission
EXHIBIT WS-7
Substation Utilization/Net Added Substation Capacity
EXHIBIT WS-8
Transmission Autotransformer Capacity Added
Speed - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-1-
•
1
DIRECT TESTIMONY OF WESLEY SPEED
2
I. POSITION AND QUALIFICATIONS
3
Q.
4
5
•
EMPLOYMENT POSITION.
A.
My name is Wesley Speed.
My business address is 115 West Seventh
6
Street, Fort Worth, Texas 76102. I am currently the Senior Director of
7
Engineering for Oncor Electric
8
"Company").
Delivery
Company LLC ("Oncor" or
9
Q.
WHAT ARE YOUR RESPONSIBILITIES IN YOUR CURRENT POSITION?
10
A.
I
am responsible for the engineering standards, system protection,
11
automation programs, maintenance criteria, certificates of convenience and
12
necessity ("CCN"), station siting, and transmission right-of-way ("ROW")
13
acquisition, all relating to Oncor's construction, ownership and operation of
14
its high voltage electricity transmission system and related substations.
15
Q.
17
PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND
PROFESSIONAL EXPERIENCE.
16
•
PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND CURRENT
A.
I graduated from Texas A&M University in 1990 with a Bachelor of Science
In 1990, I began my career as an
18
degree in Electrical Engineering.
19
associate
20
Engineering at TU Electric, a predecessor of Oncor.
21
substation design and project management experience I transferred to a field
22
operations support manager role. In 1999, I became the Relay Support
23
Manager in Transmission System Protection. In early 2004, I became the
24
Dallas Transmission Manager involving the construction, operations, and
25
maintenance of transmission lines and substations. In early 2006, I became
26
the Director of System Protection, and in late 2007 1 became the Senior
27
Director of Engineering for Oncor.
engineer in the substation design area of Transmission
After 6 years of
Speed - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-2-
•
1
I am a Professional Engineer in the State of Texas ( License Number 80684)
2
and an active member of the Institute of Electrical and Electronics Engineers
3
("IEEE").
4
Q.
UTILITY COMMISSION OF TEXAS ("COMMISSION")?
5
6
HAVE YOU EVER SUBMITTED TESTIMONY BEFORE THE PUBLIC
A.
No.
II. PURPOSE OF DIRECT TESTIMONY
7
8
Q.
WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY?
9
A.
The purpose of my direct testimony is as follows:
10
•
I provide an overview of Oncor's transmission facilities and operations;
11
•
I describe Oncor's transmission system, including the transmission
12
portion of the Company's total net plant in service balance, as
13
summarized in RFP Schedule II-B;
14
•
•
15
Oncor's invested capital and explain why each category of projects is
16
necessa ry in order for Oncor to provide service to the public;
17
•
I explain how the investment made in transmission facilities since the
Company's last rate case is used and useful;
18
19
•
I describe the transmission organization within Oncor;
20
•
I describe the transmission operations and maintenance activities and
demonstrate how such expenses are reasonable and necessa ry ;
21
23
I describe how the Company manages its transmission materials and
supplies invento ry, explain why it is reasonable and necessa ry , and
24
explain why the transmission portion of the Company's average balance
25
of such inventory should be included in rates;
22
•
27
I describe the Plant Held For Future Use by the Company and explain
how such plant is reasonable and necessa ry, benefits customers, and
28
why such resources should be included in rates; and
26
•
I describe the categories of transmission projects that are included in
•
Speed - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-3-
•
1
•
2
test year and support the reasonableness and necessity and used and
3
useful nature of Oncor's transmission capital investment.
4
III. ONCOR TRANSMISSION SYSTEM AND ORGANIZATION
5
Q.
PLEASE GENERALLY DESCRIBE ONCOR'S TRANSMISSION SYSTEM.
6
A.
As of December, 31, 2007, Oncor's transmission facilities and substation
7
facilities included approximately 14,600 miles of 345 kV, 138 kV, and 69 kV
8
transmission lines and supporting structures, 970 substations and switching
9
stations, 173 autotransformers, 1,541 power transformers, and 6,097 circuit
10
breakers.
11
As of December 31, 2007, the Company employed almost 600 people
12
performing a variety of transmission services from planning to operations.
13
Highly skilled Oncor personnel are located at multiple, existing service
14
centers located throughout the Company's existing transmission grid. These
15
district office employees perform routine maintenance, first response to
16
storms, and provide field switching services.
17
transmission grid management organization ("TGM") to operate its extensive
18
transmission -system, which consists of sixty-one additional employees
19
including managers, supervisors, engineers, technicians, specialists, and
20
other support personnel. Using sophisticated applications, TGM is able not
21
only to detect and respond to any out-of-limit alarms, but also to identify next
22
contingency event outcomes that would violate security criteria established
23
to maintain system reliability and to determine remedial actions or plans that
24
will prevent, correct, or mitigate these contingency events.
25
Q.
27
28
The Company maintains a
HAS ONCOR INVESTED SIGNIFICANTLY IN ITS TRANSMISSION
SYSTEM IN RECENT YEARS?
26
•
I present the Company's transmission capital investment at the end of the
A.
Yes. Oncor invested an average of approximately $260,000,000 per year in
transmission facilities and load-serving substations between January 1, 1999
Speed - Direct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-4-
•
1
and December 31, 2007. During that time, Oncor added about 830 circuit
2
miles of new transmission lines, over 5500 MVA of substation capacity, over
3
9600 MVA of autotransformer capacity, and connected more than 12,500
4
megawatts of new generation capacity. This investment was necessary in
5
order to interconnect new generation, to accommodate power flow from
6
these new generation facilities, to reduce congestion on the Electric
7
Reliability Council of Texas ("ERCOT") grid, to address load growth and
8
equipment replacement issues, and generally to allow Oncor to fulfill its
9
obligations pursuant to the Public Utility Regulatory Act ("PURA"), the
Commission's Substantive Rules, and its Commission-approved tariffs.
10
11
Q.
WHICH REQUIRED CCNS APPROVED BY THE COMMISSION?
12
13
WERE THE TRANSMISSION PROJECTS UNDERTAKEN BY ONCOR
A.
Yes.
Since January 1, 1999, Oncor has applied for and received
14
Commission approval to construct and operate more than 20 transmission
• 15
projects including approximately 300 miles of new 345 kV transmission lines.
16
Oncor has a proven record of completing these projects in a timely fashion.
17
For example, between April 1999 and December 2001, the Company sought
18
and obtained approval from the Commission to construct four significant
19
critical constraint relief projects.
20
before the end of-2002. Thus, in a little over three and a half years, the
21
Company certificated and constructed four separate projects involving over
22
200 miles of critical constraint relief 345 kV transmission lines.
23
applying for approval in late 2004 and early 2005, Oncor completed the
24
construction of over 80 miles of additional 345 kV transmission capacity by
25
the end of 2006.
26
January 1999 through December 2007.
27
28
is
Q.
All four were constructed and in-service
Since
My Exhibit WS-1 shows the list of CCN projects filed from
WHAT OTHER TRANSMISSION PROJECTS HAS ONCOR UNDERTAKEN
SINCE JANUARY 1, 1999?
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Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
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•
•
1
Another significant capital expenditure activity that occurred since
2
January 1, 1999, is the re-build of a significant amount of the existing
3
transmission facilities in the Dallas-Fort-Worth Metroplex.
4
transmission lines in the Dallas-Fort-Worth area had to be rebuilt to
5
accommodate generation being imported to the region to replace generation
6
being retired in the Metroplex. Exhibit WS-2 shows the generation facilities
7
that were retired in the Metroplex and the transmission line reconstruction
8
and new additions in the Metroplex from January 1, 1999 through December
9
31, 2007. This construction replaced many of the transmission structures in
10
the region with new, larger structures to accommodate larger conductors that
11
move more power along existing transmission corridors. This activity was
12
more intense in the 2003 through 2006 period and had a peak in activity in
13
2005.
14
rebuild activities required extensive planning and coordination, well beyond
15
that typically required for a non-urban project.
16
crews had to work at night, and in and around congested areas of the
17
Metroplex, which increases the time and expense required to complete these
18
urban rebuild projects successfully. Urban rebuild projects are still ongoing,
19
and they will continue to be necessary in the future.
Due to the urban nature of these important rebuilds, much of the
Very often, construction
20
In summary, the Company's investment in transmission facilities in
21
Texas from January 1, 1999 through December 31, 2007 represents one of
22
the largest utility construction efforts in the United States during this period of
23
time.
24
Q.
26
HOW DOES ONCOR OPERATE AND MAINTAIN ITS TRANSMISSION
FACILITIES?
25
•
Many of the
A.
Oncor maintains and operates its facilities consistent with good utility
27
practices and in accord with economic practices that are consistent with
28
sound budgeting and procurement principles. In support of these objectives,
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Oncor Electric Delivery
2008 Rate Case
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•
•
•
1
the Company reviews its methodologies and practices in order to ensure the
2
safe and reliable operation of its electric delivery system in an efficient and
3
economical manner.
4
Additionally, Oncor has extensive experience and expertise in utility
5
operations that allow the Company to effectively manage the cost of
6
performing the activities required to achieve its operational objectives.
7
Oncor is focused on constantly improving operations and maintenance
8
("O&M") management in an effort to consistently perform more efficiently and
9
cost-effectively.
O&M expenses include those expenses necessary to
10
operate, monitor, and switch the system and to maintain the equipment
11
necessary to deliver power in a safe and reliable manner.
12
In addition, Oncor strives to improve the O&M of its system. In recent
13
years, Oncor has made operational and systems improvements designed to
14
allow it to thoroughly investigate outage events so as to identify and mitigate
15
issues, through enhanced monitoring technologies and equipment history
16
profiles.
17
operational and safety performance.
18
received formal certifications from both the North American Electric
19
Reliability Corporation ("NERC") and ERCOT.
Oncor also investigates potential system problems to improve
Oncor system operators have also
20
From a maintenance perspective, Oncor implemented an Integrated
21
Maintenance Program ("IMP") that is a condition-based maintenance
22
program that factors in information from facility operation, conditions found
23
during
24
misoperation events, and information obtained from other companies. This
25
program targets both what is done to facilities and how often it is done in a
26
programmatic manner. Those systems and facilities with a higher probability
27
of misoperation, and those with a higher consequence of misoperation, are
28
given a higher level of focus than those with lower levels.
maintenance, information
discovered
during investigation
of
Specific
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Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
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•
1
modification, inspection, and maintenance programs are directed towards
2
those facilities that warrant attention based on the factors considered above.
3
There is also a time-based component on some maintenance and inspection
4
program activities. These intervals are reviewed as appropriate.
The IMP, coupled with a variety of on-line non-invasive diagnostics
5
6
and off-line non-invasive equipment testing, has allowed Oncor to better
7
prioritize and sequence its transmission maintenance activities.
8
Q.
•
•
DESCRIBE
ONCOR'S
TRANSMISSION
AND SYSTEM
OPERATIONS ORGANIZATION.
9
10
PLEASE
A.
As Oncor witnesses Messrs. Rob D. Trimble and James A. Greer explain in
11
their respective direct testimonies, the Transmission & System Operations
12
organization is one of the two organizations that make up the T&D
13
Operations
14
organization is further composed of the following groups that engage in the
15
following activities:
16
•
17
This organization is led by Michael Quinn who has over 19 years of
18
experience in Generation, Transmission Operations, and System Protection.
19
This organization is accountable for grid operations.
20
controls the Company's transmission and substation facilities.
21
directs and controls on a real-time basis the transmission grid operations as
22
part of the Company's responsibility for grid reliability in compliance with the
23
Commission's
24
obligations. Finally, when necessary, TSO is responsible for implementing
25
ERCOT emergency operations as directed by the ERCOT Control Area
26
Authority.
27
necessary maintenance and construction.
organization.
The Transmission
& System Operations
Transmission System Operations ("TSO")
Substantive
Rules
and
TSO monitors and
TSO also
NERC and ERCOT security
TSO also supports the grid by coordinating facility outages for
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Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
-8-
•
•
•
Transmission Operations
1
•
2
The Transmission Operations organization is lead by Don Cole with over 25
3
years of experience in transmission field operations, maintenance and
4
construction.
5
construction, maintenance, and field operations of Oncor's transmission and
6
substation facilities and provides the operational interface with merchant
7
generating plants and other utilities connected to Oncor's transmission grid.
8
Transmission Operations performs: preventive and reactive maintenance;
9
operational
This group is accountable for the safe, timely, and reliable
and functional testing;
diagnostic testing
and
periodic
10
observation of electrical facilities, including summer preparedness; and
11
ERCOT and/or NERC mandated, service bulletin, and programmatic work
12
orders.
13
construction of transmission lines, switching stations, and substations,
14
including commissioning and acceptance testing of equipment, functional
15
and in-service tests, and ensuring all changes to the grid are appropriately
16
documented. Transmission Operations provides first responders for outages
17
to transmission lines and facilities including emergency response and Black
18
Start.
19
reliability and power quality associated with the operation of the transmission
20
grid, switching stations, and substations in all types of weather extremes and
21
grid configurations.
22
•
23
This organization is led by Phillip McCrory who has over 35 years of
24
experience in Transmission Planning, Transmission and Generation
25
operations, and the Transmission Management System (SCADA and
26
Network Applications). T&D Services includes the installation, maintenance,
27
monitoring, troubleshooting, and repair of hardware and software utilized to
28
monitor and operate the transmission system. This group also supports the
Transmission Operations is also accountable for the physical
Transmission Operations is also accountable to ensure service
Transmission Management System ("TMS")
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2008 Rate Case
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•
,
The
1
Oncor Electric Delivery implementation of SmartGrid systems.
2
SmartGrid
3
(Measurement
4
Services), DSCADA and Distribution Network Applications.
5
•
6
The Transmission Services organization is lead by Jeff Herring with over 34
7
years of experience primarily in interfacing with generators, utilities, rural
8
electric cooperatives, municipal utilities, and large retail customers who are
9
seeking to establish or upgrade interconnections with the Oncor
system
will
Mobile
incorporate
Services),
Outage
Workforce
Management
Management System (Distribution
Transmission Services
system.
Transmission
Services prepares and secures
10
transmission
11
contractual arrangements with the above entities, including those associated
12
with interconnections and wholesale transmission service.
13
•
14
Transmission Engineering is led by Carlos Isaac who has over 33 years of
15
experience in T&D engineering, construction, operations and standards.
16
This group is primarily accountable for planning, organizing, directing, and
17
managing the engineering design, requisitioning of material and equipment,
18
and construction support of transmission lines, switching stations, and
19
substation facilities.
20
engineering drawings and documentation for the transmission infrastructure
21
in
22
interconnections and points of delivery consistent with all applicable
23
standards.
24
Strategy group in the creation, tracking, prioritization, and forecasting of
25
capital budgets and makes project priority recommendations when capital
26
spending targets change.
27
28
Transmission Engineering
the
Transmission Engineering creates and maintains
Oncor system.
The group also establishes generation
Transmission Engineering supports the Asset Investment
The Transmission & System Operations organization also includes a
small Reliability Standards Compliance group.
Company witness Ms.
S pee d - Di re ct
Oncor Electric Delivery
2008 Rate Case
PUC Docket No. 35717
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• 1 Brenda Pulis discusses the Distribution System Operations group in her
2
direct testimony.
3
IV. TRANSMISSION AND LOAD-SERVING SUBSTATION
4
OPERATION AND MAINTENANCE ACTIVITIES
5
A. Introduction
6
Q.
SUBSTATION SYSTEM THAT ONCOR OPERATES AND MAINTAINS.
7
8
PLEASE DESCRIBE THE TRANSMISSION AND LOAD-SERVING
A.
As I previously explained, as of December, 31, 2007, Oncor operates and
9
maintains approximately 14,600 miles of 345 kV, 138 kV, and 69 kV
10
transmission lines and supporting structures; 970 substations and switching
11
stations; 173 autotransformers; 1,541 power transformers; and 6,097 circuit
12
breakers.
B. Activity Discussion
13
14
Q.
ACTIVITIES.
• 15
16
•
PLEASE DISCUSS THE MAJOR OPERATIONS AND MAINTENANCE
A.
The major operations and maintenance activities can be grouped into district
17
work, equipment support, the transmission management system and grid
18
operations process, and vegetation management.
19
The district work organization performs direct switching; routine
20
maintenance, inspection, testing and calibration of station equipment for the
21
purpose of maintaining performance; keeps station logs and records; and
22
prepares reports on station operation. In addition this group patrols lines
23
and stations and more specifically maintains, inspects, and tests
24
transmission lines, transformers, switching equipment, protection and control
25
systems, and other equipment necessary for safe and reliable service. This
26
group also performs work associated with establishing clearances for
27
construction, maintenance, tests and emergency purposes.
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2008 Rate Case
PUC Docket No. 35717
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