DTE Electric Company

One Energy Plaza, 688 WCB

Detroit, MI 48226-1279

Andrea Hayden
(313) 235-3813
[email protected]

June 29, 2018

Ms. Kavita Kale

Executive Secretary
Michigan Public Service Commission
7109 West Saginaw Highway
Lansing, Michigan 48917

Re: In the matter, on the Commission’s own motion, of the investigation

into the response of DTE Electric Company to recent storm damage in
its service territory.
MPSC Case No. U-20169

Dear Ms. Kale:

Attached for electronic filing in the above-captioned matter is DTE Electric Company’s Report
in response to the Commission’s May 17, 2018 Order.

Very truly yours,

Andrea
Digitally signed by Andrea Hayden
DN: cn=Andrea Hayden, o=General
Counsel-Regulatory, ou=General
Counsel-Regulatory,

Hayden
Andrea Hayden
[email protected],
c=US
Date: 2018.06.29 14:07:15 -04'00'

AH/lah
Enc.
cc: Service List
 STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

In the matter, on the Commission’s own motion, )

Of the investigation into the response of )
DTE ELECTRIC COMPANY )
To recent storm damage in its service territory ) Case No. U-20169
)

DTE ELECTRIC COMPANY’S MAY 4, 2018 STORM RESPONSE

REPORT
I. Executive Summary ...........................................................................................................2
II. May 4th 2018 Wind Storm (Storm 2018004) ....................................................................4
A. Overview of the event .......................................................................................................4
B. Preparation for the wind storm ..........................................................................................6
C. Impact of the Storm...........................................................................................................7
D. Restoration Performance ...................................................................................................8
E. External Communications ............................................................................................... 11
III. DTE Electric’s Public Protection Program ................................................................. 11
A. Downed wire rules and response protocols ...................................................................... 11
B. DTE Electric’s Safety Training and Quality Program ...................................................... 15
IV. DTE Electric Distribution System Maintenance and Planned Upgrades ................... 16
A. Maintenance Overview ................................................................................................... 16
B. Maintenance Programs .................................................................................................... 17
1. Tree Trimming ............................................................................................................ 17
2. Pole and Pole Top Hardware Program ......................................................................... 18
3. Additional Programs ................................................................................................... 19
C. Upgrades to the 4.8kV Distribution System ..................................................................... 19
1. 4.8kV System Hardening Program .............................................................................. 19
2. kV Conversion and Consolidation Program ................................................................. 20
D. Distribution Design Standards ......................................................................................... 22
V. DTE Electric Compliance with Regulations Identified in the Order ............................. 22
A. DTE Electric Takes Reasonable Precautions to Mitigate Hazards per Rule 460.3801 ...... 23
B. Design and Maintenance Procedures Comply with Rules 460.3501, 3502, 3504, 813 ...... 23
C. The Company Operates and Maintains the Electric System to Comply with Rule
460.721-724 .................................................................................................................... 25
VI. Areas for Improvement ................................................................................................ 28
A. Overview of Areas For Improvement .............................................................................. 28
A. Prevent Downed Wires - Continue to execute and accelerate DTE Electric’s Distribution
System Maintenance and Planned Upgrades .................................................................... 29
B. Education and Communication........................................................................................ 29
C. Improving the effectiveness of the public protection program.......................................... 30

1
 I. EXECUTIVE SUMMARY
The Michigan Public Service Commission issued Order U-20169 on May 17, 2018 and

asked DTE Electric Company (DTE Electric or DTE) to address the following key areas in the

response to the May 4 wind storm: the impact and response to the storm, DTE’s system

maintenance, wire down response practices, and compliance with specific regulations as identified

in the order. This document addresses those questions, along with identified opportunities for

improvement.

On May 4, 2018, a severe wind storm with gusts up to 68 mph impacted southeast

Michigan, toppling trees, knocking down utility poles and power lines and causing over 3,000

reports of downed wires and nearly 255,000 customer outages across the 13 counties in DTE’s

service territory. Given the weather that was experienced in DTE Electric’s service territory, this

impact is consistent with past similar weather events.

In anticipation of the storm, DTE Electric aggressively pursued additional resources to

address downed wires and customer outages, pre-alerted employees who were critical to the storm

response and proactively communicated safety and storm readiness information to the public. As

the weather event unfolded, the Company prioritized downed wires and outages as per its storm

plan.

DTE Electric’s restoration performance exceeded historical standards for storms this size.

In the spirit of continuous improvement, the Company conducts a post-storm assessment after

every large storm event. Opportunities are identified to strengthen processes for restoration, public

protection, single customer outages and further use of advanced metering infrastructure.

DTE Electric has also developed and is implementing a strategy to harden the grid and

make it more resilient to adverse weather events. DTE started developing the Five-Year

2
Investment and Maintenance Plan (Five-Year Plan) in early 2017, and had been working on

refreshing its investment strategy in the years prior to that.

In the draft Five-Year Plan (July 2017) and in the final version (January 2018), DTE

Electric outlines the challenges facing the Company’s infrastructure, and particularly the aging 4.8

kV system. The volume of trouble events in these areas is disproportionately higher compared to

the rest of the service territory as this was the first part of the electrical system to be built in the

early 1900s and now contains many abandoned alleys with overgrown trees. The plan outlines in

detail a prioritized list of projects and programs to address the infrastructure challenges DTE

Electric is facing.

In addition to improving reliability, the upgrades also will address the Company and the

Commission’s concerns around public protection, such as live downed wires. While the

infrastructure upgrades will take many years to implement, the Company has taken steps to

mitigate downed wire hazards through a robust operational protocol, as well as education and

communication with the public across DTE’s service territory.

Finally, the Commission highlighted nine regulations DTE Electric is required to comply

with; as per our response filed annually in March, the Company has been substantially in

compliance for the last five years. DTE’s only variance on this item is specifically driven by large-

scale catastrophic storms where incoming rates for outages and downed wires are several times

greater than normal operations.

DTE recognizes its critical role in the community and is committed to providing safe,

reliable and affordable electric service to all of its customers.

3
II. MAY 4TH 2018 WIND STORM (STORM 2018004)

A. Overview of the Storm

On May 4, 2018, southeastern Michigan experienced a severe wind storm resulting in wide-

spread damage throughout DTE Electric’s service territory. Actual weather conditions exceeded

forecasted conditions (as discussed further below) with isolated wind gusts reported as high as 68

mph (Figure 1) and above 60 mph across a vast part of the DTE Electric service territory (Figure

2 and 3). Sustained winds ranged between 20 mph to 30 mph beginning at 11:00 am and continued

through the late afternoon hours.

Figure 1 – Sustained Wind and Wind Gust

Speed by hour (NOAA)

4
 Figure 2 and 3 – Wind gusts at 1.00 pm on May 4th, 2018 in Michigan and DTE Territory
(Source: https://www.ventusky.com/?p=43.02;-83.46;8&l=gust&t=20180504/17)

The May 4th wind event caused severe damage to DTE Electric’s system and nearly

255,0001 customers, or about 12 percent of the Company’s 2.2 million customers, experienced an

outage. As a result, DTE Electric replaced 542 broken poles, replaced or restrung approximately

400,000 feet of wire, and responded to and investigated more than 3,000 reported wire down

events.

As weather conditions escalated over the course of the day, DTE Electric mobilized and

deployed thousands of employees, contractors, and resources from the Great Lakes Mutual

Assistance (GLMA) to complete a safe, efficient and timely restoration. In all, more than 1,300

DTE Electric employees, 1,000 non-DTE Electric linemen and electricians, and 560 tree trimmers

1
The Company reported 300,000 outages to the media. In a large-scale event, it is normal to have variances
between outages reported real-time and actual outages confirmed after an audit of the Outage Management System

5
assisted with the four and a half-day restoration effort. In addition to field resources, hundreds of

employees across 13 DTE business units performed critical functions such as wire down response,

community and customer outreach, logistical support and others.

It should be noted that the May 4th windstorm occurred only two weeks after a severe ice

storm hit our territory on April 15th. Residual damage from that catastrophic ice storm was still

being remediated, as is normal practice – particularly in large storms – to do temporary repairs to

expedite restoration. Follow-up work and final repairs can take four or more weeks to complete

depending on the extent of the damage.

B. Preparation for the Storm

The May 4th wind storm quickly turned out to be a more impactful event than originally

forecasted. On May 2nd, both DTE Electric’s meteorologist and the National Weather Service

predicted gusty winds ranging from 30 mph to 35 mph for Friday, May 4 th. On May 3rd, at 4 p.m.,

this forecast was revised by both DTE Electric’s meteorologist and the National Weather Service

to increasing the speed of wind gusts to 50 mph. Consumers Energy was also consulted and their

forecasts were generally consistent with DTE’s.

Based on historical correlation of these updated weather conditions, DTE Electric

estimated the impact on May 4th to be a medium to large storm (between 40,000 – 110,000

customer outages). Given this weather forecast, the Company had sufficient resources onsite to

handle the anticipated volume of trouble work. As such, on May 3 rd DTE Electric proceeded with

its pre-specified storm plan which included:

6
 • Alerting Public Protection2 teams to be ready to perform their storm assignment to

respond to downed wires.

• Securing the electric system for the anticipated weather by completing the most critical

open repair and maintenance jobs.

• Requesting an all available canvass for overhead contractors to secure additional

resources to cover trouble work. This process includes the Company’s normal daily

contractors (baseload) as well as linemen working in the non-utility sector (local foreign).

• Hedging for a larger event and the need for additional resources from outstate utilities, a

call with the Great Lakes Mutual Assistance (GLMA) 3 was scheduled for 3:00 pm on

May 4th.

• Alerting customers and media outlets via email on the morning of May 4 th, providing

them with safety and storm preparedness messaging.

C. Impact of the Storm

The high sustained winds and wind gusts, combined with wet conditions, caused trees and

tree limbs to topple onto DTE’s power lines resulting in thousands of downed wire reports and

significant customer outages. DTE Electric initially reported 300,000 customer outages. However,

after the regular review and audit of the Company’s Outage Management System (OMS), data

showed 254,867 actual customer outages. This level of variances between OMS and audited

actuals are normal for a storm of this size.

2
Public Protection is the first responder function to downed wires, it includes field and non-field employees (details
of function explained later in the document)
3
GLMA is the Regional Mutual Assistance Group (RMAG) defined by the Edison Electric Institute (EEI) for the
Great Lakes region utilities

7
 DTE Electric investigated and addressed 27,114 trouble events 4 of which 18,435 were

outage events and responded to 3,016 reported wire downs with 1,811 confirmed in the field. The

outages events and the downed wires were uniformly spread across the entire service territory as

illustrated in the Figure 4 below.

Figure 4: May 4th Wind Storm – Outage and Downed Wire Events Distribution

2,200,000 18,435 1,811

100%

Rest of Service Territory 68% 71%

73%
(4.8kV and 13.2 kV)

4.8 kV in Greater Detroit 32% 29%

27%
(Redford and Caniff)

Customers Outage Confirmed

served events downed wires

D. Restoration Performance

It took four and a half days to restore the 255,000 customers impacted by the wind storm.

When comparing this storm to others similar in number of outages and type of damage, the

restoration performance was quicker. From the onset of the storm the Company’s objective was to

address all downed wires as quickly as possible. This was accomplished while balancing outage

restoration and utilizing the Public Protection processes detailed later in this report. This improved

restoration was made possible by two strategic initiatives: proactively and aggressively pursuing

and securing resources earlier in the process; and leveraging Advanced Metering Infrastructure

(AMI) data to optimize the use of field resources. DTE Electric restoration resources included:

4
A trouble event is defined as an electric system irregularity requiring intervention, includes single and multiple
outages, low voltages, flickering lights, hazards and others

8
 • 450 Overhead Linemen

• 350 Overhead Contract Linemen

• 100 Electric Field Operations (performing Public Protection and Service Restoration 5)

• 100 Electric Maintenance Journeyman (performing Public Protection and Service

Restoration)

• 144 Public Protection First Responders (Secure First)

• 50 Underground Cable Splicers (performing Public Protection and Service Restoration)

• 560 Tree Trimmers

• 120 Electricians from IBEW Local 58 (performing Public Protection and Service

Restoration)

As the weather developed on May 4th, and actual damage exceeded the anticipated impact,

DTE Electric utilized the scheduled call with GLMA (call at 3:00 pm) to immediately request

additional resources. As the weather was still evolving, all utilities on the call were “holding”

resources due to weather impacting the northern Midwest. Although it’s normal practice to only

have a GLMA call every 12 hours, given the urgency, DTE initiated a second call for 9:00 pm,

after the weather conditions were expected to normalize. Prior to this call DTE Electric’s Senior

Vice President of Distribution Operations reached out to senior leadership at other GLMA

companies and key overhead contracting companies seeking additional resource commitments.

The 9:00 pm GLMA call yielded an immediate availability of 90 linemen and commitment to

reassess conditions and connect again the following morning. On May 5 th, an additional 450

linemen from GLMA were made available to support restoration. This brought the total linemen

(DTE, contractors, GLMA utilities) supporting storm restoration to more than 1,300.

5
Restoration of single customer outages

9
 AMI data allowed DTE to link single customer outages to associated larger level outages,

as well as close outages when the AMI meter communicated good voltage. This helped the

Company to manage the 3,000 single customer outages reported, thus avoiding the dispatch of

valuable resources to customers who had no outage. These improvements were first piloted during

the April 15th ice storm, which also had a significantly better restoration performance when

compared to similar storms.

Once resources were secured, DTE Electric committed to have 90% of the customers

restored by the end of the day Sunday, May 6th. The Company exceeded this target by having 92%

of customers restored by that target time as seen in Figure 5.

Figure 5 - Restoration Rate by Day

255k 34k 99% 100%

92%
115k

58%
86k

13%
17k
0% 3k

Total Storm Restored on Restored on Restored on Restored on Restored on

Outages May 4th May 5th May 6th May 7th May 8th

10
 E. External Communications

DTE Electric also responded to the storm by executing a storm communication plan to

deliver safety messages, manage customer restoration expectations, and keep stakeholders

informed. The following activities were performed:

• 814 radio spots between May 4th and May 6th were run detailing storm restoration

progress and providing wire down and generator safety tips

• Facilitated a press briefing at DTE Corporate Headquarters in Detroit on May 4th

• Provided more than a dozen interviews across TV, radio, and print and responded to more

than 50 media inquiries to the Company’s newsroom

• Sent four media storm alerts and employee updates per day of the storm restoration

• Handled more than 300 customer conversations on Facebook and Twitter and sent four

targeted customer communications

• Launched storm messaging on the Company’s website, mobile app, and social media

channels

In addition to the external communication tactics, Company representatives were in contact

with residential and business customers, as well as community stakeholders through other

traditional channels (call center, marketing representatives etc.) throughout the storm event.

III. DTE ELECTRIC’S PUBLIC PROTECTION PROGRAM

A. Downed wire rules and response protocols

Keeping the public and employees safe is DTE Electric’s most important priority. As

previously noted, more than 3,000 downed lines were reported during the May 4th wind storm,

with an incoming rate that exceeded 100 downed wire events per hour over a 9-hour period (see

11
Figure 6 for details). On an annual basis, DTE responds to approximately 20,000-30,000 downed

wire reports per year. Downed wires are reported to DTE in multiple ways:

a) customer communication via mobile app, web or phone

b) substation ground alarms

c) cases reported by police and fire departments via DTE website or via phone with

a special PIN

For reported downed wires, DTE’s response protocol is well defined in both normal

weather days (Blue Sky) and storm. Wire down reports are received by DTE Electric’s Central

Dispatch, which assigns and dispatches the appropriate crews. During Blue Sky6 conditions, DTE

Electric operates as follows: if an overhead crew is immediately available it is dispatched to the

wire down location to eliminate the hazard through repair or cutting and removing the downed

wire. If an overhead crew is not immediately available, DTE Electric utilizes Electric Field

Operations (EFO) 7 resources as first responders to the site. As first responders, they arrive to the

site and confirm it is a DTE downed wire (as opposed to non-DTE communication wire) and secure

the hazard with yellow barrier tape that specifically indicates “DANGER, LIVE WIRE”.

Additionally, they communicate with the surrounding residents and leave door hangers when in-

person communication is not possible. Before leaving the site, the personnel will determine the

most appropriate overhead resources required to complete the work and update the job in the OMS.

During storm conditions8, in addition to the field resources discussed above, the Company

activates additional Public Protection resources (Public Protection teams), which are dedicated

teams of Company employees and contractors who are trained to investigate reports of downed

6
Normal day, directionally less than 15,000 customer outages open in the OMS
7
EFO resources perform meter maintenance work; they are Qualified Electric Workers.
8
Storm conditions are defined as more than approximately 20,000 customers impacted by the weather.

12
wires and take appropriate steps to protect the public. The need for these additional resources

during storm is necessary because of the higher volume of events: medium to large storms can

have more than 500 reported downed wires per day, while catastrophic storms can have thousands

of reported wire events per day, and even hundreds per hour as clearly exemplified by the May 4th

2018 storm (See Figure 6). For the May 4th windstorm, DTE responded to over 3,000 reported

downed wires with over 1,800 being DTE equipment, with the balance being false alarms.

Figure 6 – Reported downed wires per hour during May 4th and 5th 2018

450
4-May 405
400
5-May
350
Wire down per hour

300 301
284
250
214
200

150 160
119 112 121
100
64 82
50 62
30 25
19
0
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

Hour of the day

The Company’s Public Protection teams consists of two distinct functions:

• Secure First (SF)– a role that is specially trained to recognize hazardous wires in the

field and identify subtypes (e.g. primary, secondary, services), secure the area through

taping and alerting neighboring residents, and in some cases assessing damage to

support restoration planning. This is an identical process to that employed daily by

EFO, and is currently covered by internal resources (substation electricians,

underground cable splicers, non-field employees, etc.) and external (IBEW Local 58

electricians).

13
 • Wire Guard – a role whose only task is to stand-by confirmed wire down locations

already taped.

EFO and Public Protection Teams typically stand by confirmed downed wires when the

following criteria are met:

Table 1 – Stand-by criteria for normal and catastrophic storms

All Storm other than

Wire Down Location CAT Storms
CAT
Only stand-by when wire is
Wire on or near (<20 feet)
Always stand-by on or near a major road
a road
(mile road)
Wire within 300 feet
Always stand-by until dark Always stand-by until dark
of school
Wire within 300 feet Always stand-by until dark Only stand-by parks with
of park and/or public has vacated high pedestrian traffic
Always stand-by if
Wire on a structure Always stand-by
occupant cannot be notified
Assessed based on above
Police / Fire
stand-by criteria

If the wire down event does not meet the stand-by criteria, the Secure First team is

dispatched to the next reported down wire location after taping and alerting nearby residents

through in person discussions or placing door-hangers when customers are not available. This

process allows Secure First teams to cover more sites in a shorter period of time. For downed wires

reported via substation ground alarms, regardless of weather conditions, DTE Electric will

dispatch an overhead line crew to perform a ground patrol to find the location of the downed wire

on the identified circuit. If the downed wire cannot be identified within 4 hours of dispatch, the

substation breaker is opened to de-energize the entire circuit.

14
 For every reported downed wire, the Company tracks specific process milestones in its

OMS. Milestones that are tracked include, creation of the wire down event, dispatch time, arrival

time, and the action taken by the field resource.

B. DTE Electric’s Safety Training and Quality Program

Secure First resources, which do not already work in the field in their day to day job,

undergo an extensive training program that prepares them for the potential hazards in the field and

for taking appropriate steps to protect the public when addressing a downed wire. Their initial

training is delivered by a qualified, experienced instructor. Candidates are required to pass a test

and to perform 50 hours of supervised field experience paired with a qualified mentor in order to

become fully certified. As of end of May 2018, the Company has more than 500 resources,

including field, non-field and external contractors, that are qualified to be deployed as Secure First

resources.

As discussed above, DTE Electric responded to over 3,000 reports of downed wires during

the May 4th wind storm and over 500 resources were utilized in the field to respond to them. An

opportunity was identified to improve this process by establishing a quality assurance program to

review the activities performed in the field by Public Protection resources. This process utilizes

experienced frontline employees, a detailed checklist, and a process to provide feedback and

coaching. This improvement has been successfully implemented since the May 4th storm and tested

in two subsequent storms.

15
IV. DTE ELECTRIC DISTRIBUTION SYSTEM MAINTENANCE AND PLANNED
UPGRADES

A. Maintenance Overview

DTE Electric has worked to operate and maintain the Company’s existing equipment in a

safe, cost-effective manner for decades. Recently, DTE Electric filed a draft of its Five-Year Plan

with the Michigan Public Service Commission in June 2017 and a final plan in January 2018.

In the plan, DTE Electric described the challenges it faces due to the aging electric

infrastructure, particularly in those areas served by the 4.8 kV system. In many neighborhoods, the

4.8 kV system was constructed in the alley easement at the rear of the customer’s property (rear-

lot). Easy access to the overhead electrical equipment was available through these clear,

maintained alley-ways. Starting in the 1950s, alleys behind homes and businesses were no longer

properly maintained, as some property owners extended rear fence lines to the middle of the alley

and then allowed invasive trees and discarded materials to overcome the once well maintained

alleys. These obstacles present a significant impediment for DTE Electric to trim trees and

efficiently maintain infrastructure. Tree growth in the alley easements previously maintained by

municipalities, coupled with the aging infrastructure, has resulted in the 4.8 kV distribution system

experiencing a disproportionate number of trouble events and downed wires. On a per mile basis,

the number of trouble events per overhead line mile on the entire 4.8 kV system is nearly double

that of the 13.2 kV system.

DTE Electric’s Five-Year Plan discussed in detail a comprehensive set of programs that

are currently being implemented and that are proposed to be implemented to address the aging

infrastructure.

16
 B. Maintenance Programs

DTE Electric’s Distribution Investment and Maintenance plan includes the Enhanced Tree

Trimming Program (ETTP), Pole and Pole Top Hardware Program, various system improvement

programs and the substation SCADA program. Additionally, DTE Electric is focused on system

analytics, which include Asset Condition Assessments and Failure Analysis to support these

programs.

1. Tree Trimming

Tree trimming is the single largest driver in addressing electric system safety, reliability,

and storm resiliency. Trees and tree-related events are responsible for more than two-thirds of the

time DTE Electric customers are without power and account for approximately one-third of the

outage events. Trimming trees is the most effective way to reduce outages, trouble events, and

downed wires.

Based on extensive benchmarking with other utilities, DTE Electric has taken steps to

enhance its tree trimming practice as the prior practice of trimming did not provide the desired

system reliability. The latest evolution of the tree trimming practice is the Enhanced Tree Trim

Program (ETTP). This was first introduced in 2016 to the MPSC and has since been applied

consistently throughout DTE Electric’s service territory.

Circuits trimmed as part of the ETTP have an annual reduction of approximately 50 percent

in the number of tree-related customer outages and an annual reduction of approximately 80

percent in the time customers are without power. The company’s historic approach was to focus

on mitigating reliability concerns. In late 2017, the Company added downed wire reduction as a

key driver of its circuit prioritization for the ETTP.

17
 DTE Electric remains firmly committed to achieving a best-in-class five-year trimming

cycle on its distribution system and at the current funding level, DTE Electric is able to achieve an

effective cycle of 8.5 years, trimming 11.5 percent of the approximately 31,000 overhead miles in

2017. If a five-year cycle is not achieved, the number of outage events and downed wires will

continue to increase. To address this growing number of trouble events, including downed wires,

on the oldest part of its electrical system, DTE plans to spend over 20 percent of its 2018 tree trim

funding in the City of Detroit, which only represents eight percent of the overhead miles. The

Company also intends to move toward a five-year tree trimming cycle by continuing to improve

the efficiency of the program, and by working through the regulatory process with the MPSC to

implement a funding mechanism for the recommended program.

2. Pole and Pole Top Hardware Program

The Pole and Pole Top Hardware program scope is to identify and reinforce or replace

weakened poles and defective pole top hardware before they fail during service. DTE Electric’s

system is inspected within the MPSC’s recommended 10-12-year cycle as shown in the Table 3

below. DTE Electric’s 4.8 kV system has been inspected in the same cycle as the rest of the system.

In the Pole and Pole Top Hardware program, foot patrols are done on a portion of the system to

inspect poles and pole top hardware. Additionally, DTE Electric monitors and analyzes asset

conditions and asset failures on a continuous basis. The data is collected and subsequent analysis

performed to address any identified asset or system issues and improve customer experience.

18
 Table 3 - Historical Pole Inspection Cycles

2013 2014 2015 2016 2017 Average

Pole
90,433 102,104 83,279 118,211 106,568 100,119
Inspections

Inspection
11.1 9.8 12.0 8.5 9.4 10
Cycle (years)

3. Additional Programs

DTE Electric’s Five-Year Plan detailed a number of additional programs to address system

performance. The CEMI (Customers Experiencing Multiple Interruptions) program has been in

place for over ten years with the purpose to identify customers with recurring outages and then

remediate the underlying issue. The scope of work may consist of reconductoring overhead lines,

adding or strengthening circuit ties, changing design of the circuits, installing sectionalizing

devices, spot tree trimming, or a combination of these actions. The Company’s system resiliency

program was started in 2013 with the purpose of reducing system SAIDI through circuit redesign,

circuit reconfiguration, equipment upgrades, installation of fault indicators, and installing

sectionalizing and switching devices to localize outage events and allow for faster restoration by

restore-before-repair. Technology upgrades at substations and the System Operations Center

improve grid-wide situational awareness and enhance the capability for fault locating, diagnosis

and isolation.

C. Upgrades to the 4.8kV Distribution System

1. 4.8kV System Hardening Program

The 4.8 kV System Hardening Program is a targeted effort, proposed by the Company to

the MPSC in 2017, designed to strengthen and stabilize the 4.8 kV distribution circuits to improve

19
safety, reliability and storm resiliency. Additionally, this program will extend the life of these 4.8

kV circuits until DTE Electric completes the 13.2 kV conversion over the next several decades.

The 4.8 kV System Hardening Program’s scope includes replacing crossarms, replacing or

reinforcing poles as needed, removing overhead wires supplying abandoned homes and businesses,

coordinating with the City of Detroit to remove their abandoned PLD Arc Wires, and tree

trimming. This program will significantly reduce the trouble and wire down events, and improve

customer reliability and storm resiliency for hardened circuits.

Circuits for this program are selected based on prioritization factors that include wire down

events, customer density, tree related outage minutes, overall circuit performance, and number of

dispatched events. Prioritization is coordinated with the Enhanced Tree Trimming Program, Pole

and Pole Top Hardware Program, and 4.8 kV Conversion and Consolidation Program to ensure

program schedules do not conflict and work is executed efficiently.

Based on our prioritization schedule, DTE Electric plans to complete hardening efforts on

all circuits for 12 Detroit area substations by the end of 2020. Initial hardening efforts are underway

on Puritan Substation and Balfour Substation circuits, where work is expected to be completed in

2019. This program will harden a minimum of 50% of the 4.8 kV overhead circuit miles in the

City of Detroit. The remainder of the 4.8 kV system in Detroit will be addressed through 4.8 kV

Conversion and Consolidation Program.

2. 4.8 kV Conversion and Consolidation Program

For those circuits selected, the program scope is to replace the aging 4.8 kV equipment

with modern 13.2 kV equipment for the selected circuits. Prioritization of the 4.8 kV Conversion

and Consolidation projects are driven by the need to serve new load returning to the City of Detroit

and DTE Electric’s commitment to not expand the aging 4.8kV system because of its limited

20
capacity and age. These projects are expected to bring multi-faceted benefits of safety

improvements, load relief, substation failure risk reduction, reliability improvements, technology

modernization and operational cost reduction.

Converting circuits from 4.8 kV to 13.2 kV requires a complete rebuild of the existing

infrastructure. Rebuilds are designed based on current NESC (National Electric Safety Code)

factors and industry best practices. The structural upgrades to Grade B Construction Standards

include armless construction or stronger fiberglass crossarms, larger and stronger conductors

(standardizing on 1/0 ACSR and 636 ACSR), polymer insulators that are four times stronger than

pin insulators, and poles that are one and a half times stronger. DTE will also remove any unused

electric infrastructure supplying abandoned homes and businesses.

As part of the 4.8 kV conversion and consolidation program, DTE Electric also evaluates

various design and construction alternatives including relocation of overhead infrastructure from

rear lot to front lot, extension of overhead primary wires and removal of overhead secondary wires,

and conversion of overhead to underground services. It is important to understand that these

alternatives often present execution challenges such as obtaining rights-of-way or easements,

getting community approvals, maintaining clearances, and space limitation in co-locating with

other utility underground infrastructures. DTE Electric strives to develop and identify the best

infrastructure design that balances considerations on reliability, constructability, accessibility and

affordability for customers. The detailed plan on 4.8 kV Conversion and Consolidation program

can be found in the Five-Year Plan DTE Electric submitted in January 2018 in Case No. U-18014.

A copy of the plan was also e-filed in Case U-20147 by the Commission Secretary pursuant to an

April 12, 2018 Commission order.

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 D. Distribution Design Standards

DTE Electric construction standards adhere to the 2017 National Electric Safety Code

(NESC) as mandated by the MPSC. Furthermore, DTE maintains a comprehensive set of

Distribution Design Standards (DDS) that are the basis for the electrical system design and

construction. These standards meet or exceed the NESC and are reviewed for compliance to any

revisions to the NESC. In addition, the DDS also incorporate industry best practices gained from

DTE Electric’s involvement in the Edison Electric Institute (EEI), Electric Power Research

Institute (EPRI) and Institute of Electrical and Electronics Engineers (IEEE). The DDS are

reviewed and updated based on new equipment or technologies, developments in the industry,

NESC updates, system performance and field experience. The DDS are the “single design source

of knowledge” that is mandated throughout DTE Electric.

Over the years, the Company has increased the minimum standards for construction to

further harden the system and better sustain impacts from inclement weather and tree interference.

These structural upgrades are intended to standardize overhead construction materials and

specifications to significantly streamline the design and construction of overhead facilities, and to

increase the structural strength to improve system reliability and storm resiliency. In addition,

circuit design standards are established to improve circuit configuration and allow crews to more

quickly restore customers during outage events.

V. DTE ELECTRIC COMPLIANCE WITH REGULATIONS IDENTIFIED IN THE

ORDER

The Commission’s May 17, 2018 Order in this case requested an analysis of the Company’s

compliance with various Commission Rules related to system design and maintenance (R

460.3801, R 460.3501, R 460.3504, R 460.3502 and R 460.813) as well as public protection and

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operational response (R 460.721-724) and with the Company’s own internal policies. The sections

below summarize the Company’s compliance with each cited rule.

A. DTE Electric Takes Reasonable Precautions to Mitigate Hazards per Rule

460.3801

Rule 460.3801 requires a utility to “exercise reasonable care to reduce the hazards to which

its employees, its customers, and the general public may be subjected.” To comply with this rule,

the Company has implemented proactive programs to maintain its distribution system as well as

responsive programs to address hazards that occur due to downed wires, outages, and other trouble

events. The Company’s maintenance programs and polices include regular system inspections,

the ETTP, Pole and Pole Top Hardware Program, various system improvement programs,

substation SCADA program, and improved system analytics, which include Asset Condition

Assessments and Failure Analysis to support these programs. Details regarding these programs

were provided in previous sections. Implementing systematic maintenance programs such as these

reduces hazards to which employees, customers, and the general public could be exposed.

When a hazardous condition arises, DTE Electric’s wire down response protocols and

Public Protection program is in place for responding to reports of hazardous conditions.

Implementation of DTE Electric’s wire down response policies ensure that the Company is

reasonably mitigating potential hazards to its employees, contractors, and the general public.

B. Design and Maintenance Procedures Comply with Rules 460.3501, 460.3502,

460.3504, and 460.813

Commission Rules 460.3501 and 460.3504 set forth requirements for the design and

maintenance and operation of a utility’s plant and distribution system. Rule 460.3501 states that

“[t]he electric plant of the utility shall be constructed, installed, maintained, and operated pursuant

to accepted good engineering practice in the electric industry to assure, as far as reasonably

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possible, continuity of service, uniformity in the quality of service furnished, and the safety of

persons and property.” Rule 460.3504 sets forth the specific requirement that a utility “adopt a

program of inspection of its electric plant to ensure safe and reliable operation. The frequency of

the various inspections shall be based on the utility's experience and accepted good practice.”

Commission Rules 460.3502 and 460.813 set forth specific requirements for utilities to “…apply

the standards of accepted good practice in the National Electric Safety Code, 2017 edition (ANSI-

C2-2017)”.

As discussed above, DTE Electric adheres to the 2017 NESC design standards as required

by the Commission. Additionally, the Company’s own design standards meet or exceed the NESC

and are reviewed for compliance to any revisions to the NESC. DTE Electric’s design standards

also incorporate industry best practices gained from the Company’s involvement in EEI, EPRI and

IEEE. The DDS are reviewed and updated based on new equipment or technologies, as dictated

by developments in the industry, on system performance and field experience.

DTE Electric also performs maintenance on system assets when a need is identified through

the Company’s monthly asset condition assessments. Through these programs, the Company

identifies necessary infrastructure repairs or replacements. Targeted maintenance is also performed

based on the Company’s monitoring of trouble events and as further described above. The

Company’s design standards and the Company’s maintenance program are designed to comply

with Rules 460.3501, 460.3502, 460.3504 and 460.813.

As required by Rule 460.3504, DTE Electric also conducts overhead system inspections

every 10 to 12 years as recommended by Commission guidelines, with foot patrols performed to

inspect poles and pole top hardware for integrity, damage, or deterioration. Identified items are

flagged for repair or replacement. A subset of the poles is further tested based on a schedule

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determined by pole age, type, treatment, and location. Based on the inspection and testing results,

poles that do not have the required strength remaining are flagged for either replacement or

reinforcement.

C. The Company Operates and Maintains the Electric System to Comply with Rule
460.721-724

The Commission’s Order asked for compliance observations with respect to Rule 460.721,

which requires an electric utility to “operate and maintain its distribution system in a manner that

will permit it to provide service to its customers without experiencing an unacceptable level of

performance as defined by these rules.” The Commission Order then specifically references Rule

460.723, which states that “[i]t is an unacceptable level of performance for an electric utility to fail

to respond to a request for relief of a non-utility employee guarded downed wire at a location in a

metropolitan statistical area within 240 minutes after notification at least 90% of the time under

all conditions.”

The Company files an annual report with the Commission documenting its compliance

with Rule 460.721. The report filed on March 8, 2018 in docket No. U-12016 documented DTE

Electric’s 2017 performance with the standards referenced in Rule 460.721. With respect to Rule

460.723, the Company tracks compliance on an annual basis. Table 4 summarizes the Company’s

performance in 2017. For the metropolitan area, performance was 84% with an average response

time of 148 minutes. This is 92 minutes quicker than the 240 minutes required by the Rule.

Excluding the March 2017 storm, the urban performance was 92% with an average response time

of 95 minutes, 145 minutes quicker than the 240 minutes defined in the standard. For the rural

area, the Company’s performance was 76% with an average response time of 309 minutes, 51

minutes quicker than the 360 minutes defined in the standard. Excluding the March storm, the

rural Wire Down Police/Fire Standing By performance remained at 76% but with an average

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response time lowered to 297 minutes, 63 minutes quicker than the 360 minutes defined in the

standard. In 2017, less than three percent of all Wire Down Police/Fire Standing By were in the

non-metropolitan area and the number of cases not meeting the non-metropolitan standard

represents less than six tenths of one percent of all the wire down cases in 2017.

Table 4 – DTE 2017 Compliance with Rule 460.723

Performance Metric /
Measure: Wire Down Relief MPSC Target Results
Police/Fire Standing By
All Year data:
240 minutes - Metro Area ≥ 90% 84%
360 minutes - non-Metro Area ≥ 90% 76%

Excluding March Storm

240 minutes - Metro Area ≥ 90% 92%
360 minutes - non-Metro Area ≥ 90% 76%

Rule 460.721 also refers to Rules 460.722, 460.723 and 460.724 to define acceptable levels

of performance. Rule 460.722 (Unacceptable levels of performance during service interruptions)

requires an electric utility to restore service within 36 hours to not less than 90% of customers

within 36 hours. DTE Electric’s performance in 2017 was 89% within 36 hours, off by 1%.

Excluding just the first day of the March 2017 storm, DTE Electric’s performance increases to

98% within 36 hours which well exceeds the required restoration timeframe under Rule 460.722.

Rule 460.722(b) establishes targets for service restoration under catastrophic conditions at

not less than 90% of customers within 60 hours. For the May 4th wind storm the Company’s

restoration performance was 92% within 60 hours which is compliant with the standard. DTE

Electric’s performance in 2017 was 77% within 60 hours as it took 84 hours to achieve 90%

restoration. Excluding just the first day of the March 2017 storm, DTE Electric’s performance

improves to 90% within 60 hours, which would be compliant with the standard.

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 Under Rule 460.722(c) the target for service restoration under normal conditions is not less

than 90% of customers within 8 hours and DTE Electric was on target in 2017 with a performance

of 90%.

Rule 460.722(d) establishes criteria for repetitive interruptions, and requires that an electric

utility shall not experience five or more interruptions within a 12-month period for on more than

5% of circuits. In 2017, DTE Electric was compliant at 4%.

Compliance with service quality metrics as outlined in Regulation R 460.724 for 2017 is

summarized below:

• The MPSC target for Call Blockage Factor is less than 5%. DTE Electric was

compliant with a result of 0%

• The MPSC target for Complaint Response Factor of 90% of customer complaints

forwarded by the MPSC responded within 3 business days is higher than 90%. DTE

Electric was compliant with a result of 91%

• The MPSC target for Average Customer Call Answer Time is to answer customer

phone calls in less than 90 seconds. DTE Electric was compliant with an average of

29 seconds

• The MPSC target for Meter Reading Factor is to have more than 85% of the meters

read within the billing period. DTE Electric was compliant with a result of 98%

• The MPSC target on New Service Installation Factor is to have 90% or more of new

services installed within 15 days. DTE Electric was compliant with a result of 96%

As previously reported, and as discussed above, DTE Electric is compliant with the

Commission rules cited in the May 17, 2018 Order with minimal deviation from Rule 460.723 due

to the unprecedented nature of the March 2017 windstorm. DTE Electric’s current internal safety

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and maintenance protocols align with the Commission rules and provide reasonable measures to

protect the public and the Company’s customers and employees. The Company has determined

that the downed wire response protocols will be re-evaluated. DTE Electric’s belief is that the

electric utility industry can learn from the gas industry with the parallel response process to

hazardous gas leaks. DTE Electric has begun an extensive benchmarking initiative with DTE Gas

and their leak emergency response process. DTE Electric would welcome the MPSC Staff’s

participation in this effort and is willing to lead a State-wide initiative involving all electric utilities

to jointly improve the overall downed wire response process.

VI. AREAS FOR IMPROVEMENT

A. Overview of Areas for Improvement

The areas for improvement that DTE has identified are summarized across three areas:

1. Prevention of downed wires and outages is best accomplished through the solutions

detailed in the Five-Year Plan and summarized in this document. Continuing to

execute and accelerate this plan around tree trimming and infrastructure

improvements will provide for much improved safety and reliability.

2. Further education and communication to all stakeholders regarding the dangers of

downed wires.

3. Advance, through the use of new technologies, the responsiveness of the public

protection program to even more quickly address reported downed wires especially

during major storms.

Each of these three areas is summarized below.

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 A. Prevent Downed Wires - Continue to execute and accelerate DTE Electric’s
Distribution System Maintenance and Planned Upgrades

As previously discussed and detailed in the 5-year investment plan DTE has developed

solutions to address the aging 4.8 kV infrastructure and associated downed wires. The execution

of this plan including the Enhanced Tree Trimming Program and the 4.8 kV System Hardening,

Conversion and Consolidation will be the main drivers for the prevention of downed wires.

B. Education and Communication

Ramp up already existing education efforts to the public on the risks of downed wires.

Additionally, continue to communicate to the public when impending weather is approaching and

could create potential conditions for downed wires.

Over the last 12 months DTE has met with the Fire Chiefs of the City of Detroit and most

major municipalities in our service territory. During these meetings, DTE reviewed and gained

valuable feedback about the existing process for police and fire departments to report downed

wires and other hazards. DTE Electric plans to hold these meetings on a routine basis to ensure the

Company receives continuous feedback and is available to answer questions. In 2018 DTE Electric

also had two opportunities to share our restoration practices with Michigan legislators: the

Company provided an update in Lansing in January 2018 and hosted a delegation at the Detroit

headquarters in April 2018.

It is standard practice to send email communication to our customers and post alerts on

social media ahead of anticipated major storm events. This communication emphasizes safety

messages and serves as a reminder of our standard restoration practices (see Figure 7 below).

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 Figure 7 – Storm Alert which is sent to customers prior to adverse weather impacting DTE’s
service territory

With the start of the new school year in September, DTE Electric will provide an

educational program on safety and downed power lines with schools. DTE Electric believes that

this program will further educate some of the most vulnerable segments of the population (young

children) who can potentially be exposed to downed power lines while playing outdoors.

DTE will also initiate discussion with Consumers Energy regarding sharing of best

practices and investigate opportunities around mutual assistance targeting downed wires.

C. Improving the Effectiveness of the Public Protection Program

The effectiveness of our public protection program depends on three key factors: (a)

the efficient dispatch of the first responder resource, (b) the capability to scale operations

depending on the volume of downed wires at any given time, (c) the increased real-time visibility

to ensure that DTE Electric first responders are dispatched efficiently and that those first

responders are taking appropriate steps to protect the public. DTE Electric is actively working

across all these three areas.

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 In the first area, DTE Electric has focused primarily on reducing the time between the

opening of a new event in the system and arriving on the scene. DTE Electric has recently

developed a technology solution for our Secure First resources that allows DTE Electric to

efficiently assign these resources to the nearest wire down and eliminates the dispatching

bottleneck in the process. DTE Electric is in the process of benchmarking other utilities to assess

whether there are additional best practices to adopt.

In the second area, DTE Electric has taken steps to increase the pool of resources available

for Secure First during storms, when the volume of downed wire events exceeds the number of

resources available to respond. Starting in April 2018, DTE Electric has trained and utilized IBEW

Local 58 contractors as DTE first responders. These contractors are not only qualified to take

appropriate steps to protect the public but can also accurately assess damage to DTE’s system

given their training and experience. DTE has launched discussions with other vendor partners

regarding including more resources to support our public protection program. This includes

investigating the use of our nearly 800 tree trimmers who could be used at the onset of the storm

to investigate downed wires. DTE also intends to train additional DTE resources who work outside

of the Electric utility but are trained to protect the public when situations arise associated with their

work.

For the third and final area, DTE is reviewing various technologies to track and assess the

efficiency of Public Protection crews in the field in real-time, which has the potential to vastly

reduce or eliminate duplicate efforts (e.g. dispatching to locations already taped).

Additionally, DTE Electric is expanding its quality audit program to help ensure that its

Public Protection teams are taking appropriate steps in the field to protect the public. This is

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accomplished by having field supervisors and experienced employees randomly audit the field

work of Secure First teams to detect and immediately address any concerns.

DTE Electric’s plan is to pilot these newer initiatives discussed above throughout the 2018

storm season. During the pilot, DTE Electric will capture the feedback and improvement

opportunities and will make process improvements that will be implemented by the end of the third

quarter this year.

Respectfully submitted,

DTE ELECTRIC COMPANY

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