HomeMy Public PortalAboutGulf Stream
Renee Basel
From:Susan Schoettle-Gumm <spgumm@mailmt.com>
Sent:Tuesday, April 26, 2011 8:07 PM
To:'Danny Brannon'
Subject:Gulf Stream
Danny - We are planning on meeting with Bill Thrasher at 11 am on Thursday. You did not respond to my email but Bill
Thrasher indicated late today that you are able to come at that time. One of the issues we need to discuss is a schedule for
the remaining Commission actions/hearings. Key to that process is when the "plans & specs" required under Chapter 170
will be available. You indicated last week that you could have them ready whenever they are needed, but I would like
you to have the opportunity to select a reasonable date. Please feel free to give me a call if you have any questions or
would like to discuss anything related to the project. I will be available by cell phone tomorrow (Wed.) and early
Thursday.
Thanks, Susan
Susan Schoettle, PLLC
Phone 941-377-4948 Cell phone 941-320-3054 Fax 941-371-8317 E-mail spgumm@mailmt.com
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FPL
STORM SECURE: FPL'S FIVE -POINT PLAN
TO BUILD A STRONGER GRID FOR THE FUTURE
January 30, 2006
The purpose of this paper is two -fold: to explain the steps that FPL proposes to take to
substantially increase the resistance of its distribution, transmission and substation network to
severe weather impacts; and to identify areas where assistance will be required, either from the
Florida Public Service Commission (FPSC) or from state and local government bodies and
communities.
BACKGROUND
Two extraordinary hurricane seasons have made it clear that significant changes are
required in the way that Florida utilities design, construct and operate their electrical systems.
This is particularly true for FPL, whose service area has experienced the direct hit of five
hurricanes as well as the impact of two others in 2004 and 2005. Standards that have worked
well and provided customers with reliable service in the past will need to be enhanced going
forward. Florida generally, and South Florida in particular, are much more heavily and densely
populated than they were at the time of Hurricane Andrew; customers' expectations have
changed; and there is good evidence that we are in a more active part of a multi -decade hurricane
cycle and can expect more frequent events. Even if 2004 and 2005 were aberrations, as long-
term statistics suggest, we must be prepared for further, significant storm activity in the years
ahead.
The issue is not whether changes should be made, but what those changes should be.
Although no electrical system can be rendered fully resistant to hurricane impacts under the
current state of technology and economics, this paper outlines changes that FPL proposes to
make to benefit our customers and the communities we serve. Our approach to new
construction, system upgrades and maintenance will provide significant improvements in our
system's resiliency to storms and our restoration time after a storm passes. In addition, it will
ensure that a critical mass of providers of basic services that are essential to the health and safety
of our communities will have a reliable supply of electricity as promptly as possible after a
hurricane strike. In developing these proposals, some of which will require FPSC approval, we
have kept in mind the following essential points:
FPL's distribution, transmission and substation systems, as validated by KEMA's
independent analysis, meet or exceed all required safety standards set forth by the
National Electrical Safety Code (NESC) and performed as designed and expected
during recent hurricanes. However, given the severe nature of the 2004 and 2005
hurricane seasons and, as the FPSC has recognized, the fact that meteorological
experts have determined that this is likely part of a long term cycle of increased
hurricane activity, we are proposing many changes to the current standards for our
distribution system.
Significant changes to the resiliency of our system will take many years of
sustained etTort to achieve, Unfortunately, our system is so large and
geographically diverse that it cannot be changed overnight, and all parts of our
extensive service territory are susceptible to hurricane impacts. Therefore, we
must be intelligent in the development of our programs and focus early efforts on
those parts of the system where we can have the greatest impact for a given level
of effort, whether this be by geography or by element of the network,
Substantial improvements to our system's resiliency will have cost implications
(for example, converting the entire grid to underground could double our
customers' rates). We know that would be unacceptable to most customers. That
is why we must focus on spending resources efficiently and wisely.
4. We must avoid focusing excessively on any one aspect of the problem. Electrical
systems are exposed to a variety of different failure modes under the stress of
hurricane conditions and typically each specific failure mode only accounts for a
relatively small proportion of the total problem. For example, FPL and every
other utility experiences pole failures during hurricane conditions. However, even
if FPL had experienced zero pole failures during the 2004 and 2005 storm
seasons, we would still have experienced millions of customer outages.
We have used these points as guidelines in assisting us to formulate the initiatives that
follow and in their refinement in the coming months.
BASIS OF OUR PROPOSALS
We have developed our proposals based in part on the extensive analyses that we have
conducted either directly ourselves, or with the aid of external resources such as KEMA, on the
evidence of seven hurricane events that our system has experienced in the last two seasons:
Charley, Frances, Jeanne, Dennis, Katrina, Rita and Wilma,' and also taking into consideration
customer and governmental expectations that have been expressed in the wake of this past storm
'FPL Hurricane Assessment prepared by Davies Consulting, Inc. (February 18.2005); FPL Transmission and
Substation — 2004 Storm Season Report (2005); FPL Hurricane Assessment (January 25, 2005); FPL Infrastructure
Resilience'ream Report on 2004 Hurricanes (2005); FPL Vegetation Management Study (2005); FPL Wilma
Engineering Analysis prepared by KEMA (January 12, 2006).
season. We are happy to provide further background to the Commission and its Staff. However.
we note that we have not by any means completed our analysis and we expect to learn more as
we continue to probe the evidence. In addition, while our proposals have been subjected to a
preliminary and general economic assessment, we are not yet at the point where we can specify
exactly what each element of the program will cost. Accordingly, we expect to refine our
proposed program over time, both by adding elements as we develop new ideas and by adjusting
the timing, level or focus of current elements. FPL is committed to the approach and initiatives
set forth in this paper, subject to FPSC review and approval where needed.
ELEMENTS OF THE PLAN
1. Complete post -hurricane repairs and targeted facility upgrades to rehabilitate and
strengthen the electrical infrastructure in order to prepare for the 2006 hurricane
season.
2. Modify our existing pole inspection, treatment and replacement program to include
a systematic ten-year inspection and treatment cycle for all distribution wood poles,
including those poles owned by other utilities, in order to proactively address any
identified pole deficiencies (consistent with recent FPSC staff recommendations) and
work with other utilities to address joint use issues pertaining to loading.
Harden the electrical infrastructure by (a) adopting NESC extreme wind velocity
zone criteria as the standard for all new distribution construction and system upgrades
(up to 150 mph in certain areas) using construction methods such as undergrounding,
stronger poles (including concrete poles where appropriate), shorter spans, guying,
etc., (b) upgrading existing overhead main lines (feeders) initially targeting those
serving top critical infrastructure facilities and major thoroughfares within the first
five years, with the objective of applying NESC extreme wind -loading criteria where
feasible and practical, and (c) replacing targeted components of remaining
transmission and substation facilities constructed under legacy standards -- all as part
of a comprehensive, detailed ten-year hardening plan for distribution, transmission
and substation infrastructure.
4. Promote undergrounding by (a) investing 25% of the cost of local -government
sponsored overhead -to -underground conversion projects otherwise borne by the
requesting locality, (b) aggressively encouraging local ordinances and legislation
requiring developers to provide underground electrical service for all new
subdivisions, developments and projects, and (c) facilitating local undergrounding
projects by allowing underground conduit and cable, and associated above -ground
transformers and switch cabinets to be placed in road rights-of-way under specific
standards and agreements.
5. Enhance vegetation management initiatives by (a) accelerating mainline (feeder)
clearing to complete 75% of each year's planned line clearing work before the peak
hurricane season, (b) completing line clearing for circuits serving top critical
infrastructure facilities (CIFs) prior to hurricane season 2006 and prior to every
hurricane season thereafter, (c) ensuring a 3 -year line clearing cycle for all main lines
(feeders), (d) aggressively promoting our "Right Tree — Right Place" program to
educate communities and improve shared responsibility with customers regarding the
placement, removal, species and type of trees in proximity to power lines, and (e)
supporting legislation that would regulate and enforce the species, type, placement
and removal of trees and vegetation in proximity to electric facilities, and enhance
utility rights of access to property to clear lines through local code enforcement
assistance.
We are confident that these initiatives will ultimately result in fewer outages during
severe weather events. When outages do occur, service will be restored faster, particularly to
critical infrastructure facilities and to main thoroughfares where businesses that provide basic
necessities such as gas stations and grocery stores are located. Our plan clearly demonstrates that
just as Florida's weather is changing, so are we.
INITIATIVES
I. Post -Hurricane Repairs and Targeted Facility Upgrades to Prepare FPL's System
for the 2006 Hurricane Season
Our restoration process has two components — the initial restoration phase, when all
customers affected by storm -related outages are restored; and the recovery phase, when facilities
affected by hurricane are restored to pre -storm condition. As a result of the 2005 hurricane
season, a comprehensive field assessment of all distribution, transmission and substation
facilities was initiated. Follow-up work to our system is ongoing to repair and restore
distribution, transmission and substation facilities that were damaged and left weakened during
the 2005 hurricane season, and to replace facilities where necessary. Additionally, certain near-
term work is being performed to strengthen targeted facilities prior to the onset of the 2006
hurricane season. Our action plan includes the following:
Distribution Follow -Up Work on Poles
- Replace damaged poles, including those braced during restoration
- Straighten leaning poles
- Remove pole stubs
Other Distribution Follow -Up Work
- Replace damaged lightning arrestors
- Replace or repair capacitor banks
- Replace or repair switches
- Address various other components of electrical infrastructure damaged during
last year's hurricane season
- Distribution Facility Strengthening
Replace conductor along targeted main lines (feeders) serving critical
infrastructure facilities (e.g., Port Everglades)
Complete Thermovision inspections and follow-up repairs to identified 500
main lines (feeders) to proactively address potential causes of interruptions
Transmission Line Follow -Up Work and Targeted Facility Strengthening
- Rebuild seven miles of the Conservation -Corbett 500kV transmission line that
experienced structural damage
Inspect all 500kV lines within the impacted area of Hurricane Wilma and
make hurricane -related repairs as identified
Relocate the wood pole line off the berm of Lake Okeechobee and rebuild
with concrete poles
Replace existing ceramic post insulators with better performing polymer post
insulators on facilities with the highest customer impacts
Substation Facility Strengthening
Accelerate replacement of silicon carbide arrestors to better performing
arrestors on transformers with the highest customer impact
Harden selected equipment assemblies at 500 kV substations and bus
connections at 15 substations
As we complete our follow-up work on facilities during this recovery phase, it should be
noted that we are also often replacing identified facilities with ones that meet current, higher
standards than those in place at the time of initial installation, which will improve the overall
robustness of FPL's system.
The above initiatives help to address the immediate operating viability and reliability of
our infrastructure prior to the onset of the 2006 hurricane season. The initiatives that follow are
more comprehensive in nature and address the longer-term strength and resiliency of our
electrical system.
II. Pole Inspection, Treatment and Replacement
FPL's distribution poles are currently designed to meet NESC standards, and most poles
are designed 50% stronger than NESC minimum requirements. FPL's distribution poles are
inspected as part of a three -pronged approach: (1) a Thermovision program that visually inspects
all.main line (feeder) poles; (2) a targeted wood -pole inspect and treat program; and (3) pole
inspections that are done as part of daily work activities. FPL's transmission poles have been
designed to meet extreme wind -loading criteria at the time of construction, and are currently
inspected, treated and replaced as necessary on a 3, 4 or 8 -year cycle, depending on material and
customer count.
The failure rate of FPL's distribution poles during the 2004 and 2005 hurricanes was low.
With respect to Hurricane Wilma, KEMA determined that of the distribution poles that
experienced hurricane force winds, the distribution pole failure rate (1.46% of the total
population of distribution poles that were exposed to hurricane -force winds) was consistent with
the failure rate that would have otherwise been expected for a hurricane of that storm's size and
strength. KEMA concluded that wind was the predominant root cause of pole breakage.
Notwithstanding the low distribution pole failure rate, given the expectation that Florida is
experiencing a heightened cycle of increased hurricane activity, FPL is taking the following
action:
Modify the existing pole inspection and treatment program to establish a systematic
inspection and treatment cycle of ten (10) years for all distribution wood poles,
including those poles carrying FPL facilities that are owned by other utilities
(consistent with recent FPSC staff recommendations)
Prioritize inspection of creosote -treated wood poles (the oldest type of pole within
distribution system) by the onset of the 2006 hurricane season
Replace as necessary those poles identified as having deficiencies
Report findings to the FPSC of such inspections, treatment and replacement on an
annual basis
Work with other utilities (e.g., telephone, cable) to address joint use issues pertaining
to loading and their own inspection programs
III. Hardening the Electrical Infrastructure
New Construction
All of FPL's distribution facilities meet or exceed NESC standards. However, given the
severe nature of the 2004 and 2005 hurricane seasons and, as the FPSC has recognized,
the fact that meteorological experts have determined that Florida is in a long-term cycle
of increased hurricane activity. FPL proposes to take the following action:
Adopt the NESC extreme wind -loading criteria as the standard for all new
distribution construction (up to 150 mph in certain areas). This standard will be
applied as specified by established NESC extreme wind velocity zones (see Exhibit
A), and may be achieved using construction methods such as undergrounding,
stronger poles (including concrete poles where appropriate), shorter spans, guying,
etc.
Changes in new construction standards for transmission and substation facilities are not
indicated or recommended! That said, we are taking proactive action as follows:
2 FPL', transmission and substation facilities are designed in accordance with NESC extreme wind loading criteria
applicable at the time of design. During the 2004 and 2005 hurricanes, the transmission lines built to the current
standard of concrete poles and polymer insulators performed well. During Hurricane Wilma, a total of 345
transmission line sections were interrupted; of these 65% had no damage. (Note that countermeasures to address the
35% of transmission line sections that were damaged are included in the "Hardening the Electrical Infrastructure"
section of this paper). The most probable cause of the interruption of those undamaged transmission lines was wind-
blown debris including trees, branches and vegetative material from outside FPL's easements and rights-of-way,
which likely self -cleared the impacted facilities. In total, these 345 line sections disrupted service to 241 substations,
of which only 8 had damage requiring repairs prior to restoring service.
Enhance our current standards for substation fences and control house roofs where
appropriate (Note: Although this damage did not cause any outages, substation roof
and fence damage was found at 26 locations after Hurricane Wilma.)
System UnQrades
System upgrades are generally described as projects aimed at substantially
changing the current state of existing facilities, through programs such as system
expansion, relocations and major maintenance/rebuild projects. FPL intends to take the
following action with respect to system upgrades:
- Apply NESC extreme wind velocity zone criteria in those instances when mainlines
(feeders) have to be relocated along road rights-of-way or are being substantially
upgraded due to increased electrical demand
Long -Term Hardening of Tartzeted Facilities
In addition to new construction and system upgrades, a targeted, long-term
approach to systematically increasing the strength and resiliency of existing electrical
infrastructure that serves critical infrastructure facilities (C1Fs) and major thoroughfares is
necessary. To accomplish this, long-term retrofit projects will be undertaken with the
sole purpose of hardening identified facilities. The following proactive hardening plans
are being initiated:
Develop a comprehensive, detailed ten-year hardening plan for distribution
infrastructure based on additional independent and internal analyses, including
recommendations for infrastructure hardening developed with assistance from KEMA
Upgrade existing overhead main lines (feeders), initially targeting those serving top
critical infrastructure facilities and major thoroughfares (with gas stations, grocery
stores, etc.) within the first five years, with the objective of applying NESC extreme
wind -loading criteria where feasible and practical
Initiate a long-term plan to replace remaining transmission line ceramic post
insulators, single -pole unguyed wood transmission structures, and substation
transformer surge arresters constructed under legacy standards
This will be the first time that any electric utility operating in the United States has
adopted the NESC extreme wind -loading criteria for distribution facilities. This will,
undoubtedly, have profound long-term benefits to all our customers and the communities we
serve.
IV. Undergrounding
Currently 37% of FPL's distribution infrastructure is underground. FPL's current policy
is to install underground facilities in high density areas where multiple power lines are required
to serve customers, or where local ordinances require underground construction for new
residential subdivisions. Pursuant to FPSC rule, FPL's customers pay the differential cost
between overhead and underground pursuant to existing tariff. There are specific applications
under which underground service is less desirable than overhead service for reasons of site
engineering or due to extended outages after storm surge or flooding. However, analysis from
the 2004 hurricanes and Hurricane Katrina which impacted FPL's service area indicated that
underground facilities incurred fewer main line (feeder) interruptions during each hurricane. In
addition, we recognize that many communities have expressed an interest in pursuing conversion
from overhead to underground. Therefore, FPL intends to take the following actions:
- Promote the conversion of electric distribution facilities from overhead to
underground by offering to invest 25% of the cost of local government-sponsored
conversion projects otherwise borne by the requesting locality, with the FPSC
recognizing such investment as new plant in service
o All property located within any area designated by the locality for conversion
would be required to convert from overhead to underground service in order to
ensure that the potential benefits to the new underground area's robustness are not
compromised by interceding overhead facilities that are exposed to causes of
overhead outages
- Aggressively enhance existing efforts with local governments to strongly encourage
ordinances requiring developers to provide underground electrical service for all new
subdivisions, developments and projects
- Support legislation that would require developers throughout the state to provide
underground electrical service for all new subdivisions, developments and projects
- Support and assist efforts of communities to obtain funding assistance from federal
and state agencies to defray costs of underground conversion projects
- Facilitate local undergrounding projects by allowing underground conduit and cable,
and associated above -ground transformers and switch cabinets to be placed in road
rights-of-way under specific standards and agreements
V. Vegetation Management
Evidence and analysis from the 2004 and 2005 hurricane seasons shows that trees and
vegetation interfering, damaging or breaking poles, lines and other facilities were the greatest
cause of hurricane -related outages. FPL's current line clearing practice is to clear distribution
lines on a 3 -year average cycle (an average of 4,600 feeder miles annually). Our line clearing
practices, which include directional pruning methods, meet ANSI A-300 and NESC tree
trimming standards and follow the guidelines recommended by both the international Society of
Arboriculture and the National Arborist Association.
That said, vegetation management is an area that FPL cannot unilaterally control. Our
forensic team's analysis of tree -related distribution feeder and lateral outages from Hurricanes
Katrina and Wilma in 2005 concluded that 81% of tree -related outages were not preventable by
FPL; that is, no trimming standard or work performed by FPL would have prevented these
outages from occurring. These outages were caused by damage to FPL facilities from trees
located off rights-of-way or outside of FPL's property or its casements which toppled into FPL's
poles, lines and other facilities, or by limbs breaking off from trees and vegetative material
located outside of FPL's trim zone. In addition, FPL's transmission system had 22 trees located
outside of FPL's transmission rights-of-way that impacted facilities. As previously indicated, no
damage was observed on the vast majority of transmission line sections interrupted by Hurricane
Wilma, indicating that these facilities were impacted by flying debris, including tree branches
and other vegetative material from outside FPL's easements and rights-of-way, that likely self -
cleared from the impacted lines. For its part, to mitigate the prospect of outages caused by trees
and vegetation interfering with, damaging or breaking electrical facilities, FPL is taking the
following action:
Accelerate main line (feeder) clearing to complete 75% of each year's planned line
clearing work before the peak hurricane season
Complete line clearing for circuits serving top critical infrastructure facilities (CIFs)
prior to hurricane season 2006 and prior to every hurricane season thereafter
Ensure a 3 -year line clearing cycle for all main lines (feeders)
Aggressively promote "Right Tree — Right Place" program to heighten community
education and shared responsibility between FPL, communities and customers for tree
species, type, location and proximity to power lines
Support legislation that would regulate and enforce the species, type, placement and
removal of trees and vegetation in proximity to electric facilities, and also enhance
utility rights of access to property to clear lines through local code enforcement
assistance
CONCLUSION
We have all experienced firsthand the significant impact of recent hurricanes in our state.
No utility has had to respond to as many direct hits by hurricanes in recent years as FPL. We
recognize that if the recent cycle of increased hurricanes activity is the new storm paradigm for
our state, FPL's service area and its customers will undoubtedly be impacted. Without
fundamental and significant changes in the way we prepare for storms and harden our
infrastructure to prevent outages, we believe that the level of disruptions to our electrical system
may well continue into the future. That is unacceptable to FPL, as it is unacceptable to our
customers.
However, it is a reality that, regardless of the initiatives that we set forth above, when
hurricanes and severe weather events impact our state, outages will occur. It is our intention,
however, to take the steps necessary to mitigate such impact. The tactical and strategic initiatives
we have outlined not only address the resiliency of our system to future severe weather events,
but also provide for an increased level of day-to-day reliability for our customers. In addition to
the initiatives outlined above, FPL intends to make further refinements to this action plan based
on additional input and analyses, and will include such refinements as part of our 10 -year
hardening plan. We expect this plan to provide a clear roadmap to improving the long-term
resiliency of our electric infrastructure, and will submit it to you later this year. Furthermore, we
will include localized hardening plans that we will share with respective community leaders and
local emergency managers.
Rd