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Community Review Team issues report on BWL and the December 2013 Ice Storm

5/6/2014

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The Community Review Team has released its final report in its entirety.  The Executive Summary is reproduced here for convenience: 

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 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 
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 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 
relationships. 
 
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 
and citizens. 
 
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 
communications. 

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 
additional company. 
 
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 
the components. 
 
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 
box. 
 
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 
power. 
 
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 
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, annual 
objectives, 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 
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 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. 



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Photos used under Creative Commons from wadem, gersonpaes