BWL CRT report

8/10/2019 BWL CRT report

1/144

Report on the Lansing Board ofWater and Lights Response to the

December 2013 Ice Storm

May 5, 2014

Community Review Team


2/144

2

Table of Contents

Executive Summary.....Page 3

I. Introduction....Page 9

II. Planning....Page 20

III. Response and Restoration..Page 42

IV. Recovery and Mitigation........Page 53

Appendix A-CRT Members and Staff......Page 76

Appendix B-CRT Mission Statement...Page 78

Appendix C-Community Concerns....Page 79

Appendix D-Materials Acquired from BWL.Page 96

Appendix E-Transcript of March 10, 2014 Public Hearing..Page 99

Appendix F-Reference Materials...Page 141


3/144

3

Executive Summary

CRT Report on BWL Performance

May 5, 2014

I. The Community Review Team consisted of volunteers, selected by its Chair.All are longstanding community leaders and Board of Water and Light (BWL)customers. The mission of the Community Review Team (CRT) was toconduct an independent, objective and transparent review of the BWL'splanning, preparation, response and recovery prior to, during and after thisdevastating storm event. Our goal was to evaluate the strengths andweaknesses of BWL's performance in order to enhance the BWL's capacity torespond more effectively to their customer's needs and to recover morequickly during future storm events. The CRT goal was to determine if theBWL met industry best practices and, if not, to make recommendations to do

so.

II. The BWL is a municipal utility, owned by the people of the City of Lansing,that provides electric utility services to residential, commercial and industrialcustomers in Lansing, East Lansing, and the Townships of Delta and Windsorin Eaton County and of Dewitt and Watertown, in Clinton County, and Delhi,Meridian, Lansing, and Alaiedon1in Ingham County. Given adequate fuelsources, the BWL can provide sufficient electric power for its customer base,without the need to purchase power. In the Lansing area, BWL is responsiblefor the provision, and for the protection, of water and energy, two of the three

most important sectors of critical infrastructure.

III. Planning and Preparation

a) BWL has not embraced the strategic contingency-planning mindsetnecessary to assure the uninterrupted provision of these essential services.

b) The National Incident Management System is a recognized best practicefor all critical infrastructure owners, including publicly-owned electricalutilities, but the BWL has not adopted the NIMS system.

c) BWL does not have a comprehensive Emergency Operations Plan, just anEmergency Action Plan detailed for certain events. The BWL planning

1A T C P.A. 425 A 1998, J

N L I .


4/144

4

efforts were disjointed. The EAP and other plans need to be replaced by amore comprehensive plan that includes tools for better situationalawareness, and specific plans for response and recovery.

d) BWL does not have Emergency Manager. BWL did not have a distinct

Emergency Operations Center; during electric power outages of anyduration it continues to run operations from their BESOC.

e) There was a failure of communication between the City and the BWL and atotal lack of communication between the BWL and the other localgovernments, representing the BWL customer service area. Assumptionswere made on the transfer of information, rather than the reliance onestablished, tested lines of communication. The CRT discussions with cityand county emergency managers suggest that regional planning activity isnot organized and coordinated in advance of emergency events, butinstead, relies on the experience of the participants and their pre-existingrelationships.

f) Emergency Operations Plans must be coordinated before an emergencyevent or incident, to provide time for training all personnel on the planand for exercising the plan.

g) BWL lacked a communications annex for an Emergency Operations Plan,as well. BWL did not have available the information required due to thefailure of the OMS and the lack of capacity for customer calls. Thesedeficiencies substantially reduced their level of situational awareness andlead to the transmission of information that did not meet the needs ofcustomers and to their inability to determine how they might best respond

to the circumstances.

h) BWL was neither communicating nor coordinating with the Lansing EOCafter December 24, 2013, and many of the other Emergency OperationsCenters were not open, which contributed to the confusion, lack ofaccurate information, and uncertainty experienced by municipal leadersand citizens.

i) The CRT believes that an integrated regional EOP is vitally needed. If aregional EOP, which includes a regional EOC, was operating during therecent event, it would have facilitated the coordination of services between

first responders and with other governmental leaders.


5/144

5

IV. Response and Restoration

a) The confluence of three policies, all under the BWL control, contributed tothe length of the outage: the failure to follow the BWL vegetationmanagement policy, the lack of trained damage assessors, or spotters toimmediately be deployed, and the non-availability of the OutageManagement System were significant causes of the length of the outage.

b) The identification and assessment of the location and cause of outages inthe primary distribution system was a substantial cause of the length oftime for restoration. There were an insufficient number of Spotters,particularly A Spotters. The CRT must emphasize the importance ofhaving sufficient numbers of trained staff including spotters, repair andcentral command sufficient to handle emergencies of this size.

c) BWL concedes that they did not have sufficient mutual aid agreements inplace, and has taken steps to address this deficiency.

d) BWL entered the winter storm season with an OMS system known to beunreliable. The malfunctioning OMS was a critical but missing element inthe response and restoration. They discarded the previous system tooquickly. The system failed during the December outage and had no backupsystem. They accepted assurances that OMS was fully operational withoutfully testing the system. No back-up system or redundancy was apparentlyeven considered, much less implemented.

e) BWL had to discard the OMS by the second or third day of the outage, andthen compile damage assessments and prioritize restoration activities,

using an Excel spreadsheet.

f) If the OMS had been fully operational, then power restoration would havebeen completed at least two days earlier, AND BWL could have moreaccurately advised the public of areas for restoration and date of powerrestoration for each circuit.

g) The CRT experience in obtaining records from the BWL was replete withinstances where records were not forthcoming. There are a variety ofreasons: (1) the BWL senior leadership does not preserve its emails,pursuant to its record retention policy which requires disposal

immediately after use; (2) BWL adheres to a policy of non-distribution ofany records it deems sensitive information; and (3) since there is noinstitutionalized system for communications during emergency eventswith the municipal governments which represent its customer servicearea, neither is there a protocol for preserving the records of thosecommunications.


6/144

6

V. Recovery and Mitigation

a) Vegetation management is essential to reducing storm-induced outages in

the secondary distribution system. The failure to follow their vegetation

management schedule was a key-contributing factor to the magnitude of

the downed lines.

b) BWL is implementing changes to their vegetation management policy,including stricter adherence to the five-year schedule, auditing theperformance of its contracted tree-trimmers, and contracting with anadditional company.

c) BWL reliability is dependent upon the proper maintenance andmanagement of electrical distribution system. The BWL rate ofreplacement is below the rate of replacement based on the expected life ofthe components.

d)A significant portion of the live downed lines were service drops from thedistribution system to customer buildings or damage to distribution linesas a result of service drops being pulled down. The use of service dropsthat unplug from the distribution line when weighted down wouldreduce the number of customer masts damaged or pulled down bycustomer service lines. This solution should be evaluated immediately as itwould seem to be more cost-effective and operationally-sound than othersolutions, such as owning the customer service line through the meterbox.

e) The BWL should undertake a value engineering analysis of its entireprimary distribution system, with the intent to calculate the optimumextent and topology of the primary distribution grid, and the optimumdesign of each segment of its primary distribution grid. This analysisshould consider all aspects of distribution grid performance, butparticularly should include strong consideration of its effects on outageextent and time to service restoration in major storm events.

f) Protection of the secondary distribution system requires more than justvegetation management. Repairs to the secondary distribution system arerelatively easily and quickly done, once the faults are discovered andlocalized. Discovery and localization can be difficult however. The BWL

currently depends on customers to notify them when the customer has lostpower.

g) The CRT believes that the greatest feasible acceleration of repairs to thesecondary distribution system will come from the installation of smartmeters that are able to signal the BWL when they lose power and whenpower is restored, so that the Board will have an instantaneous andcomprehensive view of outages in its system.


7/144

7

h) BWL lacked a comprehensive system to identify all at-risk customers,

including those with medical needs and seniors, who may have greater

need for electrical power and a greater inability to re-locate or make

alternative arrangements during the outage.

i) The CRT believes that that the governmental leaders in the BWL customer

service area should create a Community Resilience Planning Coalition

which would take a broad approach to building community level resilience

to extreme events by participating in the drafting of a regional emergency

response plan, that would include community organizations input on

issues, promote strategies for engaging and organizing the community at

multiple levels and provide a platform for regional sharing of lessons

learned; connecting people, ideas, and resources; and engaging

policymakers and community members in an ongoing conversation about

resilience.

j) Include regional resiliency, including energy self-reliance, as a strategic

goal, and explore the potential for islanding to protect the local electrical

grid, with BWL taking the lead in creating an innovative, strategic

solution.

k) The BWL Board, although appointed in a manner similar to other City

boards, is not an advisory board. Rather, the City Charter granted the

Board full and exclusive management over essential services. The Board

needs to assert greater control over the short-term agenda, annualobjectives, current and emerging issues, and strategic direction of the

BWL.

l) The BWL Board has the authority to appoint a standing committee that

would be a liaison with local communities that hold franchises for services

from the BWL. We strongly believe that the Board Chair should appoint a

standing committee to be a Liaison Committee to Local Units of

Government who hold franchises or agreements for services from the

BWL.

m)The Board lacks the mechanisms to assure that they engage in structured,ongoing and organized dialogue with the other municipal governments

which represent its customer base. This dialogue is vital, both for the

economic health and the security of the region. While a Local Government

Liaison can, and should, be instituted immediately, the long-term

assurance of the regional economic health as well as the health and safety

of its residents compels consideration of the concept of representation on


8/144

8

the Board itself for the local governments which comprise the customer

service area.

n) The Board should hire an "operational auditor" to conduct annual

performance audits of the BWL operations and planning efforts.

o) The BWL should establish a Customer Ombudsman, Chief Customer

Officer or expand the duties of the Director of Governmental Affairs and

Customer Relations, reportable directly to the General Manager.

p) The positions of Strategic Planning, Information Technology, and

Operations should be directly reporting to the General Manager.

q) Consider revision of the 54 Recommendations, using the SMART analysis

to include specific metrics, including the tasks to be performed, the

directorate or section within BWL charged with performance and the time

need for accomplishment. Require staff reports monthly to the Board ofCommissioners on specific actions that have been taken on all of the 54

recommendations made in the Ice Storm Outage Report and that the BWL

post those reports on its website for the next 18-24 months.


9/144

9

Report of the Community Review Teamon the Lansing Board of Water and LightsResponse to the December 2013 Ice Storm

Released May 5, 2014

I. Introduction

On December 21, 2013 a catastrophic ice storm struck the Lansing, Michigan region,

causing more than 34,000 electric customers of the Lansing Board of Water and Light

(BWL) to experience a long-term power outage. Many BWL customers lacked electrical

power for an extended period of time, some reportedly for over 10 days. This problem

was exacerbated by a number of factors including the holiday season, the short days of

daylight, and the freezing temperatures. As the outage continued the BWL had to revise

its estimates on the scope of the outage, on the date when BWL crews would addressneighborhood or individual outages, and on the date for power restoration to the entire

customer base. Public frustration2over the inability to either seek or provide

information with the BWL, as it lacked a functioning Outage Management System and

sufficient number of damage assessors and customer service representatives, turned to

deep concern over the safety of family members and neighbors as the outage period

lengthened without a known date for restoration, and to anger over the unavailability of

senior leadership. As the publics concerns continued after the restoration of power, the

Mayor of Lansing determined that an independent investigation of the BWL response

and restoration was needed.

December 2013 Ice Storm Timeline

December 21st:The National Weather Service warns of ice storm bringing

approximately .5 inch of ice. The storm hits the Lansing, Michigan area during the

afternoon.3

2P BWL . T

BWL . T CRT BWL

, , BWL

.

3 , L S J, (D. 21, 2013) A

://..//20131221/NEWS01/312210017/N

; S R. R E W, T: P T K D I S, BWL

R, L S J (M. 1, 2014) A

://..///A3/20140301/NEWS01/140228003?=1.


10/144

10

December 22nd:At 6 a.m., BWL reports 19,000 customers are without power. Later

that day, about 200 lines are reported down and 25,000 customers are without power.

By 7 p.m., the totals are at 300 downed lines and 34,800 outages. Delta Township

declares a state of emergency.4

December 23rd:BWL reports more than 400 downed lines. At 9 p.m., outages total

19,000. BWL spokesman Steve Serkaian tells the Lansing State Journal that there are

sufficient resources in the field to restore power. All hands are on deck and we asked

people to give up their holiday in order to restore power, he says. General Manager

Peter Lark travels to New York for a vacation. Meridian Township declares a state of

emergency.5 BWL releases a statement at approximately 4 p.m., instructing customers

not to contact the utility to report outages unless you believe your situation is unique

and that BWL is aware of its outage areas. 6

December 24th:At 4 pm, 12,000 customers remain without power.7By late that

evening, BWL reports that 7,500 customer outages remain.8

December 25th:BWL reports that 5,700 customers remain without power. BWL

General Manager Peter Lark returns to Lansing.9

December 26th:The BWL reports at 8 a.m. that they are down to 4,400 households

without power. The City of East Lansing reports, They continue to have many crew

members out working on remaining major circuits and will then be focusing on smaller

pockets where power outages still exist.10BWL General Manager Peter Lark tells

4M H, , , ML, (D. 22, 2013)

://..//./2013/12/.; S R. R

E W, : ,. 22, , L S

J, (M. 1, 2014) A

://..///A3/20140301/NEWS01/140228003?=1.5S R. R E W, : , . 23,

, L S J, (M. 1, 2014) A

://..///A3/20140301/NEWS01/140228003?=1.6: & , N T, WILX, (D. 23, 2013) A

://..///BWLTRDLO237066261..7B H, & 12,000 , ML, (D. 24, 2013) A

://..//./2013/12/..8. (U: B C E, BWL 7,500 .)

9S R. R E W, : , . 25,

, L S J, (M. 1, 2014) A

://..///A3/20140301/NEWS01/140228003?=1.10C E L, 12/26/13(D. 26, 2013) A http://www.cityofeastlansing.com/Home/Departments/Communications/MediaRoom/articleType/ArticleView/articleId/1709/Ice-Storm-Update-from-the-City-of-East-Lansing-122613/.


11/144

11

reporters he cannot predict when power will be restored fully. An East Lansing resident

creates an outage map and posts it to BWL's Facebook page. At 10 p.m., BWL says 3,000

customers are without power. 11

December 27th:3,000 BWL customers were still without power.12Eaton and Clinton

Counties declare emergencies. Ingham County officials report that they do not intend to

declare a state of emergency.13

December 28th:At 8 p.m., BWL says outages have grown to 4,50014, the increase

reportedly caused by thawing trees and additional outages being reported.15BWL

Customers rally at an East Lansing school to protest BWLs performance. Customers

demand restoration of power at a Lansing news conference with Mayor Virg Bernero.16

December 29th: At 5 p.m., BWL lists 3,193 customers lack power on 333 streets and

asks those without power to contact BWL. According to the Lansing State Journal, later

that evening, BWL Spokesman Steve Serkaian texts Lansing Mayor Virg Berneros chief

of staff, saying 100 new streets have been reported by customers without power.17

December 30th:At 9 p.m., BWL reports 700 outages, plus 400 "single-service-

reconnection requests" involving customers who need to repair their connections. BWL

11S R. R E W, : , . 25,

, L S J, (M. 1, 2014) A

://..///A3/20140301/NEWS01/140228003?=1.12

N P, , WLNS (D. 27, 2013) A

://..//24317553/.13

, , ., . , L S J, (D. 27, 2013)

://..//20131227/NEWS01/312270029/CEDTM

T14

S R. R E W, : , . 28,

, L S J (M. 1, 2014) A

://..///A3/20140301/NEWS01/140228003?=1.15L VH,, , L S J

(D. 29, 2013) A ://..//20131228/NEWS01/312280016/A

L.

16.

17S R. R E W, : , . 29,

, L S J, (M. 1, 2014) A

://..///A3/20140301/NEWS01/140228003?=1.


12/144

12

projects power restoration to all customers except single-service reconnections by 11:59

p.m. Dec. 31.18

December 31st:BWL reports that 200 customers are without power at 7 p.m.19

January 1st:BWL reports that all power has been restored at 10 a.m.20

Community Review Team (CRT)

Cooley Law Professor and retired Brigadier General Michael McDaniel was appointed by

Mayor Lansing Virg Bernero on January 8, 2014 to chair the Community Review Team

(CRT).

The investigation and report would be conducted by a team consisting of citizen

representatives from across the BWL service territory and subject matter experts in key

disciplines. Mayor Bernero gave CRT Chair McDaniel the discretion to appoint themembers of the CRT. The CRT chair began by putting out a call for resumes and letters

of interest, which was answered by eighty-five citizens. On January 20, 2014, CRT Chair

Michael McDaniel released the names of the ten appointed individuals who would serve

on the community review team. McDaniel also selected an all-volunteer executive staff.

See Appendix A. All appointed members of the team are BWL customers, and selections

were based on the applicants independence, geographic distribution and expertise.

Those who were not selected were invited to participate actively in the CRT review by

attending public hearings or sending suggestions.

The Mayor and the CRT Chair jointly developed the mission for the CRT. The CRTreleased a mission statement in January 2014, prior to beginning the review. See

Appendix B. The CRTs mission was to conduct an independent, objective and

transparent review of the BWLs planning, preparation, response and recovery prior to,

during and after the devastating December 2013 ice storm. Further, the CRT would

evaluate the strengths and weaknesses of BWLs performance in order to enhance

BWLs capacity to respond more effectively to its customers needs and to recover more

quickly during future storms. Ultimately, the CRTs goal was to release a written report

18.S R. R E W, : , . 30,

, L S J,(M. 1, 2014) A

://..///A3/20140301/NEWS01/140228003?=1.19

.S R. R E W, : , . 31,

, L S J, (M. 1, 2014) A

://..///A3/20140301/NEWS01/140228003?=1.20

S R. R E W, : , . 1,

, L S J, (M. 1, 2014) A

://..///A3/20140301/NEWS01/140228003?=1.


13/144

13

sharing its findings and recommendations. The CRT would make this report available to

the Mayor, City Council, the citys regional partners within the BWL service territory

and the public at large. The report would also be shared with Michigan Public Service

Commission (MPSC) for review.

The CRT conducted public hearings on the evenings of February 6th, 7thand 8thof 2014to address customer concerns and take suggestions from citizens. The hearings were

located in three BWL service areas: East Lansing, Lansing, and Delta Township. Each

hearing allowed citizens to express concerns to the CRT orally or to submit written

comments. The CRT continued to accept written comments by e-mail throughout the

process of the review. The CRT also created a Facebook page and an email address to

communicate with the public. CRT questionnaires were distributed to the public

through groups such as neighborhood associations. The CRT also reviewed the

transcripts of the public hearings conducted by the BWL. See Appendix C for a summary

of citizens concerns, received either by email or at the CRT public hearings.

Working with a representative from the BWL, the CRT submitted two requests for

documents to the BWL. The BWL responded with thousands of pages of documents,

which the CRT reviewed extensively with the assistance of subject matter experts. The

CRT also reviewed and analyzed the BWLs internal report on the December 2013

storm, released on February 19, 2014. Materials received from BWL are listed at

Appendix D. On March 10, 2014, the CRT questioned BWL top executives21during a

five-hour hearing. See Appendix E. The CRT also interviewed city employees and

subject matter experts. After the information-gathering was completed, the CRT began

compiling its findings into recommendations by focusing on three areas of BWL

performance surrounding the December 2013 ice storm: planning and preparation,response and restoration, and recovery and mitigation. The form of this report tracks

those three performance areas.

Board of Water and Light

The Board of Water and Light is a unique entity within the Charter of the City of Lansing

(City). The BWL, unlike all other City advisory boards, commissions or committees,

shall exercise administrative, executive, and policy-making authority over the

21T CRT G M,P L; A G M, S D; D

C, S S; D I T, N B; D E

T D,D B; M E S O, L MK. T

CRT BWL . T G

M, A G M ,


14/144

14

operation of City owned utilities assigned to it.22 Accordingly, the City has granted full

and exclusive management of the water, heat, steam and electric services to the BWL

with the stated duty to provide those services in a manner consistent with the best

practices.23

Although created, funded and owned by the City, the services provided by the BWLextend, mostly by franchise agreement24, to the provision of electrical power to the City

of East Lansing, the Townships of Delta and Windsor in Eaton County and of Dewitt and

Watertown, in Clinton County, and Delhi, Meridian, Lansing, and Alaiedon25in Ingham

County.

The BWL is the 32ndlargest publicly owned utility in the United States serving electrical

customers, according to the American Public Power Association,26with just over 96,000

ultimate customers served. BWL is well regarded nationally for meeting reliability

standards set by the American Public Power Association, receiving a grade of 100% on

the Reliable Public Power Provider standards.27

More importantly, BWL hasdemonstrated strategic vision in two other vital areas: the diversification of sources of

power and the generation of sufficient electrical power to assure its ability to meet

customer demand.

In July 2013, BWL began operating its co-generation plant; this natural gas-fired

electric generating plant emits 50% less greenhouse emissions than a coal fired plant,

and will cut sulfur dioxide and mercury emissions by 99% and nitrogen oxide emissions

22

S 5108.1, C L C C, 2012.://..///LCC/5906

23S 5.201, C C.

24T , 1986

1988, 30 , . O

BWL .

25A T C P.A. 425 A 1998, J

N L I .

26

A P P A, 20132014 A D & S , .PP.. I T 100 1.4

P R C L A 30,000

.

27BWL P R, 25 M 2014,

://../ABWL/N/LBWLRTNR

REO/


15/144

15

by 85%. The design and development of this energy-efficient generation plant and

headquarters resulted in BWL receiving gold certification from the Leadership in Energy

and Environmental Design, the first utility in Michigan to receive this award. BWL also

has contracted with Granger Waste Disposal since 1992 for waste to energy electrical

power28.

BWL has the capacity to generate locally all the electrical power needed by its

customers. BWL has the capacity to generate 440 MW of energy; it provides

approximately 2,200,000 MWh of electricity each year, which equates to approximately

250 MW of energy on average and a peak demand of 500 MW. BWL purchases 11 MW

of power from Granger (waste to energy) and purchases approximately 1.7 MW of

hydro-electricity under a purchase power contract. BWL also has capacity and energy

entitlement to 150 MW from the Belle River generating facility in St. Clair County and

has a small solar array. BWL can truly supply hometown power to its customers. This

is of enormous potential strategic importance. BWL is almost wholly self-reliant for

power; it can generate all the electrical power its customers require. If BWL canmaintain this strategic advantage, rather than have to purchase power off the market, as

do most publicly-owned utilities, it will not only assure the regions energy self-

sufficiency, but will also assure the energy security of the region.

Storm Frequency and Intensity

The ice storm in December 2013 is reported to have caused a higher percentage ofcustomer outages than any previous storm affecting the BWL. (Lansing Board of Waterand Light also claims it is higher than for any utility in Michigan, but comparisons to

utilities with larger territories are not appropriate for some purposes because a stormevent is less likely to affect a large fraction of customers in a larger territory.) The icestorm, however, was not the sole cause of the outage and certainly not of the length ofthe outage. The confluence of three policies, all under the BWL control, contributed tothe length of the outage: the failure to follow the BWL vegetation management policy,the lack of trained damage assessors, or spotters to immediately be deployed, and thenon-availability of the Outage Management System were significant causes of the lengthof the outage.

Lansing Board of Water and Light, and others, may take the view that this was an

exceptional event and evaluate grid hardening measures and restoration capacity on

that basis. While it is likely that this storm had greater consequences than are likely to

28 ://..//.?=G BWL 70,000

75,000 MWH .


16/144

16

recur with great frequency, we must not be guided solely by our past experience as to

storm frequency or to building a resilient system.

A recent report29shows that the level of power outages in the United States due to

weather has been increasing significantly in recent years as illustrated in the following

graph.

The report attributes this increase to both aging grid infrastructure and increasing

storm intensity associated with global climate change. It also notes that:

The Lansing Board of Water and Light must plan as though recent storm frequency and

intensity is normal or even that these types of events will continue to increase.

As our nations approach to disaster and emergency planning has matured, there is a

growing belief in the community that catastrophes in the US have intensified in their

effects, as our society has evolved into a complex system of systems which are highlyconnected, optimized and cost-efficient.30Because our systems, including the electrical

29(K, A R, U. 2014. : , .

A ://..//PO.

30L, T G. , . A P, 2011.


17/144

17

transmission and distribution systems are built to be low-cost and efficient, rather than

resilient and secure, they are more brittle, and prone to failure.

The Cumulative Nature of Storm Impact

Some public expectations and some BWL analyses tend to look at grid hardeningmeasures or storm response practices as though they only affect the customers directlyaffected by the avoided fault or accelerated repair. This is incorrect and the BWL shouldapproach its analyses with care on this point. Whether repairs are done by a single ormultiple crews, repairs after a storm are still done more-or-less serially repairing onefault, then on to the next, and the next, etc.. This means that avoiding a fault throughgrid hardening or accelerating a repair has the effect of shortening the time to powerrestoration for all subsequent repairs.

BWL policy, appropriately, dictates that the sequence of repairs in a major outage is to

first restore power to critical facilities, then secure down lines, then repair faults in the

primary distribution system roughly in order of the number of customers affected, thenrepair faults in the secondary distribution system roughly in order of the number of

customers affected. Consequently, grid hardening or accelerated restoration practices

that address critical facilities and secure down lines as a priority benefit all other

customers; grid hardening or accelerated restoration practices that reduce repair time

for the primary distribution system benefit most customers; and grid hardening or

accelerated restoration practices that reduce repair time for the second distribution

system effectively benefit most customers affected by secondary distribution system

faults.

Best Practices

The BWL is charged, by City Charter as follows: The board shall be responsible to the

Mayor and the City Council for the provision of these services in a manner consistent

with the best practices31. As noted in the Mission Statement, the CRT was therefore

tasked with evaluating the BWL response to the ice storm against Best Practices in the

electric utility industry. The CRT has researched and reviewed a number of After Action

Reports published by other utilities, state governors or public utility regulators, which

focus on electrical outages caused by ice or snow storms.

For example,New Hampshire suffered a severe ice storm, resulting in a lengthy outage

of electrical power in December 2008. As a result, the state conducted a similar,although broader investigation, into the response by all utilities in the state. The report

31C C 5201


18/144

18

of that investigation identified the following best practices, which the CRT has used as

a partial template32:

Planning and Preparedness:

1) The utility bases their emergency operations on the concept of the national

incident management system.

2) The utility has a dedicated emergency operations organization and

facilities.

3) At the first indication of a storm, the utility pre-positions its restoration

workforce which includes damage assessors and crews. The initial damage

assessments begin as soon as possible after a storm has passed and the

damage assessments are used to develop initial restoration time estimates.

4) The utility never underestimates the potential damage of a forecastedstorm.

5) The utility has a comprehensive emergency operations plan in place to

communicate with public officials and emergency response agencies. The

plan is distributed to all employees, who are trained in their roles in all

contingencies, and the plan is exercised annually. The plan includes an

integrated annex to assure it opens communications early and maintains

constant communications throughout the storm or event.

6) The utility extensively uses "non-traditional" employee resources,

including cross-training of current employees and retirees.

7) The utility has pre-staged materials which may include such things as

storm trucks or storm boxes.

Response and Restoration:

8) The utility determines the global estimated restoration times and

disseminates that information both within 24 to 48 hours.

32

NEI E P E, , P VII12. T BP CRT A F.


19/144

19

9) The utility has a restoration strategy that targets the restoration of power to

the greatest number of customers in the shortest amount of time.

10) The utility does not limit requests for supplemental crews to the local mutual

aid groups and other local utilities.

11) The utility strives to make sure that all communications are correct and

consistent.

12) The utility implements lessons learned in a timely manner. Implementation

plans that include specific tasks and scheduled completion dates are

developed and tracked.

Mitigation, System Protection and Design:

13) The utility includes 50-year return values for wind and ice loading in their

load cases for designing all line structures.

14) The utility commonly uses automatic distribution line high-speed source

transfer schemes.

15) The utility replaces its traditional electro-mechanical relays with

microprocessor-based protective relays.

16) The utility installs electronically controlled single and three phase reclosers

where appropriate in order to improve system reliability.

17) The utility has an effective outage management system (OMS) that works

even during major outage events.

18) The utility strives for regular inspection of its entire distribution system on a

two-year cycle utilizing a combination of circuit inspection, tree trimming

inspection and pole ground line inspection.

19) Where practical, the utility uses the wire zone-border zone electric ROW

vegetation management practice on sub-transmission lines.

20) The utility utilizes a four-year vegetation management cycle for clearing trees

around power lines.


20/144

20

II. Planning and Preparation

System resilience

Critical Infrastructure is defined as the systems or assets without which our society

cannot function. Discussions of critical infrastructure classify them according to thefunctions or services that are essential to our health, safety and welfare. While bydefinition, they are all critical, the three sectors of Critical Infrastructure that are themost essential, as all other systems of Critical Infrastructure are dependent upon them,are water, information technology and energy. In the Lansing area then, BWL isresponsible for two of the three most essential sectors of Critical Infrastructure. Despiteits role as the sole provider of essential sectors of Critical Infrastructure, the BWLsactivities suggest that the importance of its role in the assurance of the regional healthsafety and welfare was not fully understood. There are a number of key principles to theassurance of critical infrastructure33, but the most important principle is not assuringthe physical security of the infrastructure, but assuring its resiliency34. Resilience resultsfrom a sustained commitment to four factors: Robustness, the ability to continueoperating or stay standing in the face of disaster; Resourcefulness, skillfully managing adisaster once it unfolds; Rapid Recovery, the capacity to get things back to normal asquickly as possible after a disaster; and Learning lessons, having the means to absorbthe new lessons that can be drawn from a catastrophe.

33T P, R, I, P , F

, E : C( R), V T,

.

34

S F, S. A R: D T M N D. F A, 87 (2),28 (2008). M R , F R

R.

R

D

I ,

, .

R

I

P

C

P , N G, A R C,

R R

C

C

M

T

H

L

R

P


21/144

21

Lifeline systems are interdependent, primarily by virtue of physical proximity and

operational interaction35. When a utility is offline and power is disrupted, there is a

cascading effect throughout the community. All other systems of critical infrastructure

rely upon those three systems: water, IT and communications and energy. If electricity

is lost for a significant period (usually defined as over 36 hours), then other key

resources, such as water and wastewater treatment facilities, banks, hospitals and

medical facilities, nursing homes, and other services vital to the community and

industries vital to the regions economy are also offline.

The BWL seems to have underestimated the potential impact of these cascading effects

to other resources. There is little apparent recognition of the dependency of other

systems of critical infrastructure on electrical power, or of the interdependencies across

key sectors and systems of infrastructure. One must recognize the consequences of the

cascading effects across systems and sectors of infrastructure vital to the region. Absent

this recognition, there can be no comprehension of the need for regional preparedness

and planning for major incidents.

All other critical systems and facilities depend on electric power to provide services

essential to public health, safety and welfare. The list includes those facilities needed by

the utility or authorities to carry out response and restoration activities, and includes

key BWL facilities, hospitals, emergency response centers and public safety buildings,

water supply and sewage treatment, and similar facilities whose continued operation is

essential. Some facilities that were critical for the restoration of electrical service after

the storm housed the elderly or disabled or were ultimately used as warming or

community assistance facilities after this storm did not have standby generation

equipment. Some critical facilities lost power during the December 2013 ice storm andrequired restoration work that, by definition, delayed work on service restoration to all

other customers (albeit for only a few hours).

Standby generation is less reliable and often less economically advantageous than the

use of combined heat and power or other nearly continuous on-site generation. Indeed,

the United States Department of Health and Human Services is currently in the rule-

making process to require hospitals receiving Medicare and Medicaid funding to

evaluate the use of combined heat and power for this reason. We note that such use of

combined heat and power at critical facilities throughout the community might also aid

the Board in meeting its power generation capacity requirements.

35OR, T.D., C I, I, R 2007.


22/144

22

Findings:

1) In the Lansing area, BWL is responsible for the provision, and for the

protection, of water and energy, two of the three most important sectors of

critical infrastructure36.

2) BWL has not embraced the necessary strategic contingency-planning mindset

for these essential services.

3) BWL appropriately first focused its restoration efforts on those critical

systems and facilities vital to public, health safety and welfare.

4) The Order of Restoration used by the BWL was outdated and did not include

all critical facilities.

The CRT recommends that the BWL:

1) Working jointly with local emergency planners and municipal

governments, update the inventory of critical facilities, as part of a Regional

Emergency Operations Plan.

2) Assist all units of government representing its customer base with

identifying Special Needs Facilities for power restoration efforts, including

assisted care facilities, elder care facilities, water and sewer plants, food

warehouses, Capital City airport and key industry.

3) Undertake a program of technical assistance to critical facilities in its

service area to determine the feasibility and net benefits of implementing amicro-grid at each such facility, using combined heat and power or renewable

generation and storage.

4) Explore various options to participate financially in implementing micro

grids at critical facilities where they are feasible and beneficial, including

power purchase agreements, joint ventures, and Board ownership.

36T CRT BWL , , C

R BWL ,

, .


23/144

23

National Incident Management System Implementation & Training

The National Incident Management System (NIMS) is a comprehensive, systematic

approach to incident management which grew out of the Incident Command System

developed by the Fire Community for inter-agency firefighting decades ago and, post-

9/11, has been adopted by all levels of government. NIMS provides a unified approach toincident management, creates standard command and management structures, and

emphasizes preparedness and mutual aid. The Federal Emergency Management Agency

(FEMA) and the Office of Infrastructure Preparedness, in the U.S. department of

Homeland Security, have consistently encouraged all owners and operators of privately-

owned critical infrastructure to adopt NIMS and to train their staff in its application.

Public Works and water and power utilities have long been considered an essential

discipline in Emergency Management. FEMA has even designed a customized version of

the ICS course, Introduction to ICS for the Public Works community37. The National

Response Framework38, the broad national outline for coordinated response to all

disasters between all levels of government details the interrelationship with essentialsectors of critical infrastructure in some of the 15 Annexes to the Framework, detailing

the requisite Emergency Support Functions (ESFs). Annex 12, known as ESF 12- Energy

Annex39, describes the roles of FEMA and other federal, state and local officials to assist

the owners and operators of utilities during a Stafford Act event. To be able to

appropriately function and communicate during an emergency, the utility owners and

operators must be trained in the National Incident Management System.

NIMS compliance is a prerequisite for eligibility for Federal Preparedness Awards under

Homeland Security Presidential Directive (HSPD)-5,Managing Domestic Incidents.

Personnel must attend training based on their ICS role40.

Most utilities, including public-owned utilities, are cognizant of this requirement and

have incorporated it into their emergency planning and training regimens. The APPA

newsletter, for example, promoted NIMS implementation (while objecting to the NIMS

37IS100.PWB: I I C S (ICS 100) P W;

://../EMIW/IS/O.?=IS100.

38://..////32230?=7371

39://..//201307261921250454796/12201305011.

40S, ://..//


24/144

24

Integration Centers proposal for credentialing line workers as cumbersome given

mutual aid agreements), as far back as 200741.

The APPA endorses required NIMS training for key personnel42. Given the need to

cross-train employees to assure that BWL has a depth to its roster, has experienced

employees that can be transferred to emergency duties as contingencies demand, andthe need to coordinate response and restoration efforts with government EM officials

from the city, state and other governments in its customer service area, NIMS training is

vital to all BWL staff.

Findings:

1) NIMS is a recognized best practice for all critical infrastructure owners,

including publicly-owned electrical utilities.

2) BWL has not adopted the NIMS system.

3) The BWL had several Emergency Plans, but did not have a coordinated

Emergency Plan. In response to CRT questions, the BWL indicated that

training did not occur with all personnel involved, in the same training

program, at the same time.


Recognize its role to assist Regional, City and Township Emergency Management in

disaster response by implementing all of the following:

41 APPA P P M , ND 2007,

://../M//AD.?IN=20451 "A FEMA

NIMS , ,

, M H, , , A P P

A.S , . O

APPA NIMS , IOU .

42F APPA , C T NIMS

I C S. T

, , I C S

ICS NIMS. O

. I

. A (NIMS700: N I M S I)

, , NIMS. I

, ,

, NIMS ,

.


25/144

25

a) During anyevent where the City EOC is activated, including during major

widespread outages, a trained and experienced BWL Liaison Officer must be

deployed to the City EOC.

b) Participate in all EM exercises sponsored by any units of government

representing its customer base

c) Assure that all operations employees receive basic NIMS training, at a

minimum the two introductory courses: FEMA IS-700,NIMS An

Introduction; IS-100.PW-B,Introduction to the Incident Command System

(ICS 100) for Public Works; that all first-line supervisors take those courses,

plus ICS-200, Basic ICS; that all senior management officials take those 3

courses, plus ICS-400, Advanced ICS.

d) 2) Participate in After-Action Reviews with all units of government

representing its customer base, not just post-exercise, but after every major

outage, disaster and emergency

e) Develop and maintain good working relationships with the first-responder

community for all units of government representing its customer base

Contingency Planning, Training and Exercises

The hearing on 10 March 2014 with BWL officials left the impression that its leadership

had not yet recognized the need for the integration of planning for the likelihood of a

catastrophic or extreme weather event into its overall strategic planning. Despite the

daily reports of extreme weather, and the warnings to utility operators of the potentialimpacts of climate change, the BWL leadership seemed to discount the possibility that

BWL could confront an event ever resulting in greater than the 40% customer outage

experienced last December. The BWL electric operations chief commented during the 5-

hour interview with senior leadership that because BWL had never experienced an

outage of greater than 20%, they assumed that that was the upper limit for which they

should prepare. Similarly, the General Manager declared at the 10 March hearing no

utility has ever been hit with a storm of these dimensions. To the contrary, however,

utilities, like emergency planners for government agencies and other sectors of critical

infrastructure, are routinely criticized for the lack of imaginative planning43, for the

43W R, 1314: C L P

. T CL&P ,

. CL&P 100,000

, '. I , , 810, 000 1,2

. T 25 ,

, CL&P


26/144

26

inability to envision potential natural or man-made actions that can degrade or destroy

their continuing operations.

The North American Electric Reliability Corporation (NERC) and the U.S. Department

of Energy (DOE) partnered in July of 2009 on an effort to address High-Impact, Low-

Frequency risks to the North American bulk power system44. As stated in the report,Examples of these events include a pandemic illness, coordinated cyber, physical, or

blended attack on the system, extreme solar weather, and the high-altitude detonation

of a nuclear weapon. While some of these events have never occurred and the

probability of future occurrence and impact is difficult to measure, government and

industry are working to evaluate and, where necessary, enhance current planning and

operating practices to address these risks in a systematic and comprehensive fashion.

In addition the risk assessments conducted by States in the identification of critical

infrastructure were asked by the DHS to use a worst case scenario to conduct this

assessment.

The focus of emergency management planning, then, is to imagine the unlikely and

then prepare for it45. A common catch-phrase of emergency planners is to Prepare for

the worst, and everything else is a lesser included contingency.

The BWL, in response to requests from the CRT, provided a number of differentemergency plans46. At the March 10, 2014, hearing, BWL indicated that its 2014Emergency Action Plan (EAP) was the plan implemented during the ice storm. This plan

. A

NWS

"" "" .

44://..//CI/R/D/HILFR.

45T 9/11 C N

,

. S , :

, MJ B, GB S , T I J: T P S I J, V

13(3), 2008, 4 (2008); MC, A. D, L. (2006). T M I? P

P C. J C C M, 14: 5970. : 10.1111/.1468

5973.2006.00482.; M, L., & S, S. (2008). A : T D H S' . S P, 12(3), 281296.

46T 2014 L B W & L E A P O 28, 2013 (

D 2013 , ); T L B W & L E

P M; T L B W L T O P E

O P (T O P (TOP))., L B W L E

O P (EOP).


27/144

27

was an update to the July 2012 EAP. The Electrical Transmission and Distribution alsorelied on a separate, pre-existing Order of Restoration which, although part of anearlier plan, remained in use. The 2o14 EAP has an effective date of December 1, 2013. Itwas produced by the Risk Management Department. There was some confusion at thehearing of the definition of a catastrophe which would trigger the deployment of the

plan47

.

Although it is an update of a pre-existing plan, we have substantial concerns, including:

a) The existence of multiple plans can lead to operational disconnects during anevent, as staff will need to verify that they are following the proper plan,

b) There was no company-wide system for planning, plans were developed on anad hocbasis,

c) There was not sufficient time to train staff on the EAP,

d) There appeared to be conflicting directions in the multiple plans, and

e) There was not clear direction on the trigger for deployment of the plan.

The CRT discussions with city and county emergency managers suggested that regionalplanning activity is not organized and coordinated in advance of emergency events, butinstead, relies on the experience of the participants and their pre-existing relationships.While that experience was evident during the ice storm response, there are somedifficulties with this approach. First, experience works only so far as that event, or asimilar event has been encountered and overcome. A properly trained EM cadre,working for a common and comprehensive Emergency Operations Plan, will adapt to

the contingency confronted. Second, as noted elsewhere herein, when the entire EMsystem is reliant on a pre-existing relationship for the trusted flow of information, thatrelationship becomes a chokepoint in the information stream. Third, there is nogovernment entity that encompasses the entire BWL customer service area, whichstretches across three counties.

Continuity of Operations

Continuity of Operations Planning (or Business Continuity Planning in the private

sector) is the concept of strategic-level planning to assure that government departments

and essential services, whether privately-owned or public, are able to continue operation

of their essential functions under a broad range of circumstances including all-hazardemergencies as well as natural, man-made, and technological threats and national

security emergencies48. Thus, emergency plan developers include continuity of

47S, , 39, M 10, 2014 , A.E.

48://../


28/144

28

operations either within the plan, as an annex to the plan, or as an integrated

accompanying plan. Strategic planners for the agency or business must work closely

with all departments of senior leadership to develop a Business Impact Analysis, a

detailed assessment of the possible consequences of disruption of an essential function

and collects information needed to develop recovery strategies to quickly resume

operations. The business continuity plan is designed to assure sustained operation of the

agency or business essential functions. It is a collection of resources, procedures, and

information that is developed, tested, and held in readiness for a major disruption of

operations. Business Continuity Planning helps prepare the agency or business to

maintain mission-critical operations after any emergency or disaster. Some important

aspects of a business continuity plan include:

a) Identification of essential services;

b) Thorough risk assessment;

c) Plans for evacuation of personnel from affected work sites;

d) Designation of alternative locations for senior management and key staff;

e) Selection of alternative sources of key supplies, materials and resources and

contingency contracts to assure their availability; and

f) True IT operations back up.

Findings:

1) The BWL planning efforts were disjointed. The EAP and other plans need tobe replaced by a more comprehensive plan that includes tools for better

situational awareness, and specific plans for response and recovery.

2) There was not a concerted response effort or coordinated communications

between the BWL and the City, and none between BWL and the local

governments which represent the rest of their consumer base. The CRT

discussions with city and county emergency managers suggest that regional

planning activity is not organized and coordinated in advance of emergency

events, but instead, relies on the experience of the participants and their pre-

existing relationships. While that experience was evident during the ice stormresponse, there are some difficulties with this approach. Experience works

only so far as that event or a similar event has been encountered and

overcome.

3) There was an over reliance on pre-existing personal relationships between

personnel at BWL with the City and elsewhere.


29/144

29

4) Emergency Operations Plans must be coordinated before an emergency event

or incident, to provide time for training all personnel on the plan and

exercising the plan.

5) The BWL lacks a Business Continuity Plan, although some necessary aspects,

such as evacuation of personnel, are contained in the 2014 Emergency ActionPlan.


1) Consolidate its multiple emergency response plans within the City andRegional plan, (see below) and then test that plan by scheduling a full staffcoordinated table top exercise49at a minimum of every 12 months.

2) BWL Staff and upper management should participate in the exercises and

receive training on these plans and regular refresher training. BWL staff with

emergency responsibilities should be required to have training on these plansand their role and responsibilities and the role and responsibilities of others

that will be involved with any emergency response.

3) Together with the communities in the greater Lansing area (not just the BWL

service area), undertake a regional planning effort to be better prepared and

coordinated and assure that emergency communication protocols are agreed

to and followed. The mayors and township supervisors of our communities

must lead and encourage this effort and provide the necessary resources. This

planning effort50should be done in coordination with the State Police

EMHSD District 1 Coordinator.

4) Include Business Continuity Planning in its development of a comprehensive

Emergency Operations Plan.

Inter-agency Communications and Emergency Operations Center

At the CRT public hearing on 10 March 2014, the BWL was questioned on the use of an

Emergency Operations Center and on the communications between the BWL and the

City EOC. The BWL suggested to the CRT that they did not need an EOC , as the current

operations center, known as the BESOC, provided sufficient capability to manage

49T EOP,

.

50T M P S C L E A P

.


30/144

30

operations during the outage. BWL advised that, in any event, there was not a need for

EOC activation.

The primary role of an EOC is to provide strategic direction and support for the actual

response organizations. An equally important role is to coordinate the response, so that

all entities are working cohesively and coherently to address the multiple nuanced issuesthat will arise in an event. The EOC acts as the center of gravity for senior level decision-

making and thus, links horizontally to other municipal governments and vertically to

higher-order government agencies. The EOC assures that the senior officials all have the

same set of data, the common operating picture so that when decisions are made, each

senior official, whether with that government agency or a linked government, will know

and understand the basis for the decision. When the senior officials are in the EOC, then

the decisions are emanating to the public and others from a common location. Because

of the potential impact on the personnel and equipment needed for daily governmental

services, during an event, the coordination or reconfiguration of day-to-day (i.e.,

normal) services to the remainder of the affected municipality, state, is commonlyaccomplished through the EOC. Similarly, since senior-level decision-making is

facilitated through the EOC to assure, among other reasons, that the public, like the

government officials, are all receiving the same information and at the same time,

emergency public information is coordinated and disseminated through the EOC.

An EOC is vital to assure that a number of capabilities are present and shared between

all participating agencies and units of government. Those capabilities include:

1) Assurance that EOC internal operations are organized and based on NIMS/ICS

concepts and principles.

2) Provision of a Common Operating Picture (and, usually, a more sophisticated

communication system) and greater communications reach to key officials.

3) Use of dedicated software and other tools (CAD, GIS, WebEOC) to assure the

preservation of information, data and communications for further analysis.

4) Provides a platform for contingency decision-making, horizontally, and often

vertically, by the inclusion of senior and key agency or organization members officials that have the jurisdiction or authority to speak on behalf of their

municipality, agency or corporation to other orders of government and

participants and that have the political, legal, or financial authority to commit

extraordinary funds and resources. Other participants include those with

needed subject-matter expertise or resources.


31/144

31

5) Missions that should be coordinated through the EOC include:

- Damage assessment, consequence analysis, interdependencies impacts

and situational awareness to support decision-making and resource

allocations for response and recovery

- Coordination with member communities for Emergency Response

- Communications with elected or appointed officials

- Warming Centers coordination

- Health and Safety Checks on residents

Medical, weather or other alerts to the cities and townships.

The BWL advised that they followed their Emergency Action Plan. That plan includes a

process for the activation of the Command and Communications Center, providingthat, [i]n a catastrophic event, the Unified Command Team, charged with managing the

BWLs emergency response, will determine whether or not the situation warrants

activation of the CCC.

BWL published its Crisis Communications Plan in March 2014, in response to criticisms

of its inability to communicate with the public during the ice storm and outage. The

stated purpose of that plan is to assure a constant and consistent line of reliable

information from the BWL to its customers. That plan lists the members of its Crisis

Communications Command Team as the General Manager, Assistant General Manager,

the Director of Communications and the Director of Governmental and CommunityServices.

The Unified Command Team and the Crisis Communications Team identify differing

personnel for crisis leadership. It seems apparent that the Emergency Action Plan and

the Crisis Communications Plan were developed and drafted independently of each

other, with no consideration for the potential overlap in planning, processes, and

personnel. This is only one example of why comprehensive unified plans are needed.

Of greater concern, the March 2014 Crisis Communications Plan, although expressly

detailing the forms of response for specific contingencies, does not reference any

emergency operations plan nor does it connect with any city or regional plan.

As detailed elsewhere herein, the CRT received thousands of pages of documents from

the BWL in response to their requests. Despite asking repeatedly, BWL has apparently

not preserved any records from the BESOC nor elsewhere in Electrical Operations, on

its actions in response to the ice storm nor in the restoration process. No

documentation equals no lessons learned. There apparently was no organization-wide


32/144

32

process for retention of key documents for subsequent analysis to determine what

worked and what did not. In answer to a question about the lack of organization-wide

exercises, BWL pointed out that every event is an exercise, that they had a windstorm in

November 2013, which downed 3000 lines and that there were lessons learned from

that event. Yet, there is apparently no documentation of any of the steps taken, nor of

the overall process used, to recover from the worst outage ever to affect the BWL

customer area.

CRT Planning and Response Working Group members met with City of Lansing

Emergency Management (EM) and Fire Department personnel. The City EM personnel

detailed their efforts to open and maintain the City Emergency Operations Center and to

assure a common operating picture for City leaders. The City EOC was in operation from

December 21 through January 3. It remained in operation to coordinate the response to

the heavy snowfall that would occur later that week. The state EOC was partially

activated on January 5, 201451. The City willingly provided the CRT with copies of the

City EOC records, emails with the BWL, and CAD maps created during the outage,based on a verbal promise from the CRT Chair to Chief Trent Atkins that we would not

distribute them.

There is a substantial discrepancy between the accounts provided by the BWL Senior

Leadership and the City Emergency Management Office, describing the flow and volume

of communications between the BWL and the City during the ice storm and restoration

efforts between December 21, 2013 and January 3, 2014.

The BWL advised the CRT, both at the March 10th public hearing and again during an

April 10th tour of the BESOC, that BWL Operations officials called in to the City EOC,every day, for the EOC conference calls. The BWL also advised that they had a

representative in the EOC during the outage.

In contrast, Lansing EM stated to the CRT Working Group that the BWL stopped

communicating with the city on or about Day 3 or Day 4 of the outage. Further, that

there was not a BWL representative in the EOC until 30 December. As noted, BWL was

asked to explain the discrepancy on April 10, 2014, and suggested that their phone

presence continued throughout. Yet, the communications log from the EOC indicates

that many calls to the BESOC went unanswered or unreturned. The City EOC hosted 1- 3

conference calls each day, staring on December 22, 2013 and ending on January 3, 2014.BWL was fully engaged with the City on 22-23 December. From the 0800 hrs

conference call on December 24ththrough the 0800 hrs conference call on December

51://..///PR1401054438997.


33/144

33

29th, however, there was no participation from BWL; the log indicating, Invited. No one

on call. As noted below, the EOC communications log indicates that there was sporadic

communication from BWL between December 23rdand 28th, 2013.


34/144

34

Further, the emails provided by the City EM only evidence email communications between the

EOC and BWL for the period from December 26ththrough January 3rd, and almost all concern

the routing of reports of outages from other sources to the BWL and their acknowledgment by

BWL. There are no emails between the BWL and the EOC prior to December 26th. The BWL

did not have a representative stationed in the EOC until December 30thand never had a

representative in the EOC with operational expertise or decision-making authority, other than

when the General Manager or other officials visited during the first two days of the outage.

Note: The CRT strongly asserts that this failure of communications cannot be attributed tothe Director of Electric Systems Operations. Electric Operations in the BESOC wasattempting to conduct restoration and emergency operations with the tools used duringnormal operations. The lack of a cohesive and comprehensive emergency operations planincluded the lack of a system for scalable management staffing. Emergency operationssubstantially increase the duties of the Operations section, including the need for contingencyscenario planning and implementation, recordkeeping and communications. Utility powerrestoration, like many disaster responses, requires an influx of personnel to restore services.

The deployment of spotters, linemen and tree crews through Mutual Assistance Agreementsand contingency contracts necessitates an increased management capability for directionand coordination. With 3 times the workforce on the ground than normal operation, to beefficiently directed according to the order of restoration and evolving exigencies, requiredmanagement staffing that had not been planned for nor exercised prior to the outage. Theplan must therefore anticipate scalable management operations for the significantlyincreased workforce and the increased duties of BWL management.

Findings:

1) Despite the recent weather events, there is a lack of urgency of the need for

integration with the city EOC and with the regional community.

2) The CRT believes that an integrated regional EOP is vitally needed. If a regional

EOP, which includes a regional EOC, was operating during the recent event, it

would have facilitated the coordination of services with first responders in

conducting well-checks and other services, and reduced the frustration of out-

county and other governmental leaders who were unable to get accurate

information, from BWL.

3) As discussed above, BWL does not have a comprehensive Emergency Operations

Plan, just an Emergency Action Plan detailed for certain events. BWL does not

have Emergency Manager. BWL did not have a distinct Emergency Operations

Center; during electric power outages of any duration it continues to run

operations from their BESOC.

4) BWL Emergency Operations are not coordinated with the City of Lansing, nor

with any other municipal government that represents its customer base.


35/144

35


1) Develop a comprehensive EOP, in coordination with the City EM officials, that is

an Annex to the City EOP, consistent with MCL 30.410 (1) (a)

2) Working jointly with the City of Lansing and other regional governments, develop

a regional EOP which includes a process for siting, supporting and sustaining a

regional EOC.

3) Develop, in coordination with the governments representing its customer base,

an Energy Annex to a Regional Emergency Operations Plan.

4) Collaborate with Lansing Emergency Management, Lansing Police Department's

Neighborhood Watch, Lansing Neighborhood Council, East Lansing

neighborhood associations and similar groups in all townships in the

development of a program supporting block level emergency response plans.

This effort would build upon the well-developed social infrastructure of Lansing's186 organized neighborhood groups and prepare them to play an important role

in planning for, responding to, and recovering from extreme weather events.

BWL Crisis Communications

Extensive public comments were received by both the BWL and the CRT on the lack of

communications with BWL, both the inability of its customers to report downed lines,

discussed in the section on the Outage Management System, and on the lack of current, and

detailed information on the restoration efforts. The lack of knowledge of expected restoration

has an effect increasing geometrically, as it continued for some customers to the fifth, sixth,seventh, eighth, ninth and tenth date without power, coupled with the BWL public statements

of 90% restoration. Those remaining customers felt overlooked and forgotten by the utility, as

they coped without power and heat for the holidays, discarded spoiled food, imposed on

families or neighbors and, in cases where they were able to find rooms at local hotels, returned

daily to their homes, to determine of power had been restored.

As noted in the Introduction, BWL did issue press releases three times per day, but the

information was limited to providing the number of customers without power and in most

releases, also provided the number of downed lines. Later releases added the location of line

crews and the expected location of line crews. The BWL spokesperson also had press

conferences twice daily. BWL senior officials acknowledged that they had no crisis

communications plan in place to manage messages to customers and other audiences. BWL

focused on their communications failings in their Outage Report: 19 of 54 recommendations

discuss Customer Communications and 9 additional recommendations discuss External

Communications. BWL commissioned an outside consultant to develop a Crisis

Communications Plan. A plan was issued in March 2014.


36/144

36

Findings:

1) BWL efforts were not sufficient to communicate needed information to a

community of the size of Capital region;

2) BWL did not have available the information required due to the failure of the

OMS and the lack of capacity for customer calls.

3) These deficiencies substantially reduced their level of situational awareness. The

lack of situational awareness and the lack of a coherent communications plan or

annex, lead to the transmission of information that did not meet the needs of

customers and the resultant inability of its customers to determine how they

might best respond to the circumstances. While there was daily communications,

the issue was that the quality and content of these communications was not

resulting in the messaging that the public and emergency managers needed.

4) BWL must create a long-term strategic communications plan to rebuild its trustwith its customers and community.


1) Create a robust social media presence for its customers this work is already

underway internally, but must become a priority for its communications

operations, as consumers are primarily using digital communication tools to

learn about outages and other service issues.

2) Require all communications staff and senior leadership to undergo certified

NIMS communications training in order to understand best communicationspractices during crisis situations, with associated training events and tabletop

exercises to ensure coordination of communications functions with regional

governments.

3) Further refine the March 2014 plan. The plan must contain greater detail on how

to address the need for timely and accurate information; customer information

must be consistently explained in a way that effectively meets customer

expectations; and the plan must assure the provision of information sufficient to

allow the public to make informed decisions on how they may best respond.

There is a considerable body of studies on this subject that should be drawn uponin the development of such a plan. Once this plan is completed the BWL

management and employees must be trained on, periodically exercise, and follow

the plan.

4) The crisis communications plan must be an annex to the Emergency Operations

Plan and should be guided by a qualified communications professional certified

through the NIMS protocols.


37/144

37

City Emergency Planning & the Collaborative Planning Process

The Michigan Emergency Management Act, MCL 30.409 (2), emphasizes the need for acoordinated, but locally developed and initiated plan of emergency response, naming themayor or his designee as the City Emergency Management Coordinator, pursuant to a processto be detailed in the city charter.

The City Charter provides a broad foundation of authority to the mayor and city council to act

during emergencies and disasters: "[t]he City shall take such action, and adopt such

ordinances, as shall be necessary to provide for the public peace and health and for the safety

of persons and property within the City52." The Charter also provides the City Council power

to enact time-limited emergency ordinances53. The Lansing City Charter says "the Mayor shall

be a conservator of the peace. The Mayor may exercise within the City the powers

conferred upon sheriffs to suppress disorder and enforce the laws of the State and the

ordinances and regulations of the City.54"

Pursuant to Charter section 3-310, the City enacted the Lansing Emergency ManagementOrdinance, Chapter 234, which sets forth a scheme for developing a coordinated city-wide plan

for response to emergencies or disasters, akin to the process created by the Legislature in the

Michigan Emergency Management Act, which it expressly references. The city ordinance

envisions that the Mayor, through his designee, the Emergency Management Director, shall

develop both a comprehensive plan and an ongoing program to provide for the mitigation,

preparedness, response and recovery from natural and human-made disasters. More than

that, of course, the city ordinance cloaks the Mayor with increased, albeit temporary, authority

as the guarantor of public health safety and welfare within the City55.

The Emergency Management Ordinanceexpressly expands the powers of the Mayor during anemergency, to include the authority to Relieve City employees of normal duties and

temporarily reassign them to other duties This requirement is quite common in legislative

52S 3310, C C.

53S 3308, C C

54S 4102.1. T L C C . T C C

S, , " , , ,

."(E ). N, ,

. T M S A K C

S T E 50 S

. S ://..//T%20O%20%20S%20%20E.

55S, C, 234.05 234.07.


38/144

38

delegations of temporary, emergency authority to the executive branch and the need is

obvious: the contingencies arising during disasters or emergencies frequently demand greater

deployment of personnel for temporary duties, including those duties commonly fulfilled by

fewer employees, such as clearing roads and streets and those uncommon duties, including

clearing storm debris or emplacing sandbags. Further, such events often require streamlined

command and control systems within a government, to assure a rapid, agile and flexible

response to the crisis.

While the BWL is a creation of the City Charter, its employees, unlike the General Manager,

and although fulfilling a vital public function, are not considered municipal employees.

During the ice storm, the BWL employees acted independently from the City of Lansing

command structure and sometimes without communication or coordination. It is a truism that

strong disaster response requires strong partnerships. There was no evidence of such a

partnership between the BWL and the City EM during the ice storm outage. When questioned

about communications with other governments, BWL advised that they assumed that theirdiscussions with the City EOC would be passed on to the other units of government.

Both the City and BWL personnel spoke positively of the personal relationships they have with

officials in the other organization and some suggested that those relationships assured

sufficient communications during the outage. And the City EOC staff also stated they had

relationships and communications with some of the other communities emergency personnel

during the December outage. The same assertion was made concerning emergency operations

plans, that while there had been no coordination of emergency operations prior to

implementation, the personal relationships would assure that the mutual trust between

experienced operators would assure that a solution could be identified, agreed upon, andexecuted, timely.

Such an assertion, however, is contrary to facts determined during the investigation, and to

expected protocols and best practices in the Emergency Management discipline. An over-

reliance on personal relationships creates its own chokepoint to information flow. When that

communication link between individuals, say between an electrical distribution operator in the

BWL BESOC and a first responder in the City EOC is interrupted (by shift change, fatigue,

injury, overwhelmed by other duties, etc.) then the link between agencies is lost. Further, no

formal communication plan had been established for information flow during emergency

events between the Lansing City EOC and other communities emergency personnel, otherthan the City of East Lansing.

During emergencies, there must be a clear and clean command structure. This need is directly

stated in the Michigan Emergency Management Act which provides that the state Director of

Emergency Management shall assume complete command of the emergency operations,


39/144

39

including by employees of other state agencies, when expressly directed by the Governor56. The

Act also provides the Governor with temporary authority to commandeer private property, as

needed and subject to proper compensation.57Within that spectrum of emergency authorities,

could reside the ability of the Mayor to direct the employees of the BWL during an event.

Findings:

1) As discussed above, there is critical need for a regional EOC, or minimally, a plan

to ensure a coordinated response for emergencies and disasters across

governmental boundaries.

2) There was a failure of communication between the City and the BWL and a total

lack of communication between the BWL and the other local governments which

represent the BWL customer service area. Assumptions were made on the

transfer of information, rather than the reliance on established, tested lines of

communication.

3) Municipal and township first responders and officials and BWL employees were

often engaged in redundant tasks, or tasks that could have been more efficiently

performed by other EM officials or responders within the region, such as the City

EOC designing outage maps of traffic lights, multiple warming centers and

information centers, the disorganized exchange of outage information by emails.

4) BWL was neither communicating nor coordinating with Lansing EOC after

December 24, 2013, and many of the other Emergency Operations Centers were

not open contributed to the confusion, lack of accurate information, and

uncertainty experienced by municipal leaders and citizens.

The CRT recommends that the City:

1) Consider amendment of the City Charter to clarify the powers of the Mayor andto provide the Mayor executive authority over the BWL during disasters oremergencies

2) Emergency Management Director, working with all other member communities,including Ingham, Clinton and Eaton Counties, create a regional emergencyoperations plan (EOP).

56MCL.30.407(1).

57MCL 30.405(1)().


40/144

40

3) Work with BWL Operations and Senior Leadership to integrate their BESOC andCrisis Command Center, using the NIMS framework, with the City EOC.

4) Consider fully integrating BWL employees into the City EM structure.

5) Recommend appropriate emergency management training for BWL leadership,including Commissioners, on how best to build in resilience and ensure fullresponse capability to storms that are increasing in severity and frequency.

6) Sponsor or encourage a full scale training exercise, involving emergencymanagement staff of all units of government and BWL in the tri-county region, totake place annually.

Emergency Declarations

Neither Ingham County, nor the Cities of Lansing or East Lansing, declared an emergency

during the ice storm or outage. Eaton and Clinton Counties declared emergencies on 27

December. Shiawassee County, immediately to the north of the BWL customer area, declared a

state of emergency, almost immediately after the storm hit.58. In April 2014, the Governor

issued separate emergency declarations for Marquette County, and for Newaygo and Osceola

Counties, to permit state resources to assist the counties in recovering from the effects of the

harsh winter59. Although the Michigan Legislature recently appropriated monies for ice storm

clean-up.60, without the pre-requisite of a gubernatorial declaration, that eventuality was

unknown in December.

While, in the publics perception, the need for state or federal resources is the prompt for an

emergency declaration, the judicious pro-active use of the declaration is an essential tool for

municipal governments. An emergency was declared by the State and the City, less than one

week later, in anticipation of the heavy snowstorm61. A similar anticipatory declaration would

have provided the Mayor with the authority to deploy city employees as needed, including to

assure full door-to-door, health and welfare checks of the neighborhoods, and to assist in

damage assessments and debris-clearing.

While Lansing is used as the example, this recommendation applies to all county, city and

township governments within the BWL customer servi

BWL CRT report

Documents

Transcript of BWL CRT report