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 to
conduct an independent, objective and transparent review of the BWL's
planning, preparation, response and recovery prior to, during and after this
devastating storm event. Our goal was to evaluate the strengths and
weaknesses of BWL's performance in order to enhance the BWL's capacity to
respond more effectively to their customer's needs and to recover more
quickly during future storm events. The CRT goal was to determine if the
BWL met industry best practices and, if not, to make recommendations to do
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 industrial
customers in Lansing, East Lansing, and the Townships of Delta and Windsor
in Eaton County and of Dewitt and Watertown, in Clinton County, and Delhi,
Meridian, Lansing, and Alaiedon1 in Ingham County. Given adequate fuel
sources, the BWL can provide sufficient electric power for its customer base,
without the need to purchase power. 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 infrastructure.
III. Planning and Preparation
a) BWL has not embraced the strategic contingency-planning mindset
necessary to assure the uninterrupted provision of these essential services.
b) The National Incident Management System is a recognized best practice
for all critical infrastructure owners, including publicly-owned electrical
utilities, but the BWL has not adopted the NIMS system.
c) BWL does not have a comprehensive Emergency Operations Plan, just an
Emergency Action Plan detailed for certain events. The BWL planning
efforts were disjointed. The EAP and other plans need to be replaced by a
more comprehensive plan that includes tools for better situational
awareness, 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 any
duration it continues to run operations from their BESOC.
e) 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, representing the BWL customer service area. Assumptions
were made on the transfer of information, rather than the reliance on
established, tested lines of communication. 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
f) Emergency Operations Plans must be coordinated before an emergency
event or incident, to provide time for training all personnel on the plan
and 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 the
failure of the OMS and the lack of capacity for customer calls. These
deficiencies substantially reduced their level of situational awareness and
lead to the transmission of information that did not meet the needs of
customers and to their inability to determine how they might best respond
to the circumstances.
h) BWL was neither communicating nor coordinating with the Lansing EOC
after December 24, 2013, and many of the other Emergency Operations
Centers were not open, which contributed to the confusion, lack of
accurate information, and uncertainty experienced by municipal leaders
i) 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 between
first responders and with other governmental leaders.
IV. Response and Restoration
a) The confluence of three policies, all under the BWL control, contributed to
the 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 the non-availability of the Outage
Management System were significant causes of the length of the outage.
b) The identification and assessment of the location and cause of outages in
the primary distribution system was a substantial cause of the length of
time for restoration. There were an insufficient number of Spotters,
particularly “A” Spotters. The CRT must emphasize the importance of
having sufficient numbers of trained staff including spotters, repair and
central command sufficient to handle emergencies of this size.
c) BWL concedes that they did not have sufficient mutual aid agreements in
place, and has taken steps to address this deficiency.
d) BWL entered the winter storm season with an OMS system known to be
unreliable. The malfunctioning OMS was a critical but missing element in
the response and restoration. They discarded the previous system too
quickly. The system failed during the December outage and had no backup
system. They accepted assurances that OMS was fully operational without
fully testing the system. No back-up system or redundancy was apparently
even considered, much less implemented.
e) BWL had to discard the OMS by the second or third day of the outage, and
then compile damage assessments and prioritize restoration activities,
using an Excel spreadsheet.
f) If the OMS had been fully operational, then power restoration would have
been completed at least two days earlier, AND BWL could have more
accurately advised the public of areas for restoration and date of power
restoration for each circuit.
g) The CRT experience in obtaining records from the BWL was replete with
instances where records were not forthcoming. There are a variety of
reasons: (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 of
any records it deems “sensitive information”; and (3) since there is no
institutionalized system for communications during emergency events
with the municipal governments which represent its customer service
area, neither is there a protocol for preserving the records of those
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 the
performance of its contracted tree-trimmers, and contracting with an
c) BWL reliability is dependent upon the proper maintenance and
management of electrical distribution system. The BWL rate of
replacement is below the rate of replacement based on the expected life of
d) A significant portion of the live downed lines were service drops from the
distribution system to customer buildings or damage to distribution lines
as a result of service drops being pulled down. The use of service drops
that “unplug” from the distribution line when weighted down would
reduce the number of customer masts damaged or pulled down by
customer service lines. This solution should be evaluated immediately as it
would seem to be more cost-effective and operationally-sound than other
solutions, such as “owning” the customer service line through the meter
e) The BWL should undertake a value engineering analysis of its entire
primary distribution system, with the intent to calculate the optimum
extent and topology of the primary distribution grid, and the optimum
design of each segment of its primary distribution grid. This analysis
should consider all aspects of distribution grid performance, but
particularly should include strong consideration of its effects on outage
extent and time to service restoration in major storm events.
f) Protection of the secondary distribution system requires more than just
vegetation management. Repairs to the secondary distribution system are
relatively easily and quickly done, once the faults are discovered and
localized. Discovery and localization can be difficult however. The BWL
currently depends on customers to notify them when the customer has lost
g) The CRT believes that the greatest feasible acceleration of repairs to the
secondary distribution system will come from the installation of “smart
meters” that are able to signal the BWL when they lose power and when
power is restored, so that the Board will have an instantaneous and
comprehensive view of outages in its system.
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
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
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, annual
objectives, current and emerging issues, and strategic direction of the
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
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
the Board itself for the local governments which comprise the customer
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 of
Commissioners 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.