Mutual Assistance Changing A Paradigm?

1. Mutual AssistanceChanging A Paradigm? California Utilities Emergency Association Annual Meeting, June 6, 2013 B. Jim Reagan NV ENergy

2. Our Discussion Points • Mutual Assistance; A brief History in the West • Notable Events; Assistance from West to East • Recent Events; The Push to Change the Paradigm • What is an RMAG?/RMAG Role in Hurricane Sandy • The Next Step; Multiple RMAGS in National Events • Western RMAG; Where is it now?

3. What Change, and Why? • The Oxford English Dictionary defines the basic meaning of the term paradigm as "a typical example or pattern of something; a pattern or model". • Western Utilities have provided Mutual Assistance for years, and it works just fine • Eastern US Utilities have a different model for large scale Mutual Assistance, RMAGS • Why Should Western Utilities consider a change in in how we manage escalating levels of Mutual Assistance

4. MA in the Western Region

5. MA in the Western Region • 1992 Hurricane Iniki (Hawaii) • 2003 Wildland Fires (Southern California) • 2006 Northwest Storm Damage (Oregon/Washington) • 2007 Wildland Fires (Southern California) • 2008 Storm Damage (Central & Northern California)

6. MA in the Western Region • Joint Powers Act 1952 – CUEA • Written MA Agreements between various utilities since 1980’s • First CUEA Multiple Utility Agreement (Electric) 1994 • Revised and Renegotiated 2005 • Western Region Mutual Assistance Agreement 2003 • Southwest MEMS, WARN Agreement, Gas Agreements, Call Center MA Agreements, multiple inter-utility agreements

7. Resource Strategies • Traditional Mutual Assistance Request Strategies • Phone A Friend – keeping your best hand close to the vest • Fastest Fingers – reach out and get what you can early • The CEO Said So • More Recent Strategies for acquiring resources • Fishing – casting a net until your meet your quota • Broadcasting – casting a big net for any resources you can find

8. Resource Strategies • These Strategies have Worked Very Well in the West . . . So far • Farthest reach (travel miles) for recent Western events; San Diego to New Mexico & Arizona, Seattle to San Diego • Effective in Multiple Utility Resource Requests satisfied • Will these Strategies Work for a Nationally Significant Incident here in the West? • Can we take care of ourselves? • Or will we be reaching across the country for assistance?

9. Assistance from West to East

10. Assistance from West to East Assistance from West to East . . . • 2004 Hurricanes Charley, Frances, Ivan, Jeanne • 2005 Hurricane Katrina • 2012 Hurricane Sandy Recent Events that Push for Change

11. Hurricane Irene – August 2011Snotober – October 2011Derecho – June 2012

12. Hurricane Sandy – October 2012

13. Resource Strategies • Traditional Mutual Assistance Request Strategies • Phone A Friend – keeping your best hand close to the vest • Fastest Fingers – reach out and get what you can early • The CEO Said So • More Recent Strategies for acquiring resources • Fishing – casting a net until your meet your quota • Broadcasting – casting a big net for any resources you can find • National Strategies for identifying multiple resource needs, with resource availability • Regional Communication and Coordination of Resources • Regional Mutual Assistance Groups

14. Great Lakes Mutual Assistance Group American Electric Power Consumers Energy Dayton Power & Light Detroit Energy Duke Energy (Cinergy) Duquesne Energy Exelon (ComEd) First Energy Corporation International Transmission Indianapolis Power & Light E on US N. Indiana Public Service Vectren Energy Delivery We Energies The GLMA group was founded in January of 2005.

15. Mid-Atlantic Mutual Assistance Group Allegheny Energy Baltimore Gas & Electric Co. Duquesne Energy First Energy Corporation Orange & Rockland PECO Energy PHI, Inc. PPL Electric Utilities Public Service Elec. & Gas UGI Utilities The MAMA group was founded in 1999.

16. Midwest Mutual Assistance Group Allete/Minnesota Power Alliant Energy Ameren American Electric Power (AEP) Aquila CenterPoint Energy Duke Energy (Cinergy) Commonwealth Edison Empire District Empire District Entergy Indianapolis Power & Light Kansas City Power & Light E on US Madison Gas & Electric MidAmerican Energy Midwest Energy Nebraska Public Power The Midwest MA group was formed around 2000. Texas New Mexico Power TXU Electric Vectren Energy WE Energy Westar Energy XCEL Energy Northern Indiana PSC Northwestern PSC Oklahoma Gas & Elec. Omaha Public Power Otter Tell Power South Carolina Elec. & Gas 19

17. Northeast Mutual Assistance Group ( *Not Shown on Map) Bangor Hydro Central Maine Power Company Central Vermont Public Service Company Green Mountain Power Hydro One, Inc. * Hydro-Quebec * National Grid New Brunswick Power Northeast Utilities NStar United Illuminating Company Unitil NEMAG formed in 2007

18. New York Mutual Assistance Group Central Hudson Gas & Electric Con Edison Energy East (NYSEG & RG&E) FirstEnergy Corporation KeySpan Orange & Rockland National Grid Northeast Utilities NYMAG formed in the early 90s

19. Southeastern Electric Exchange Allegheny Energy American Electric Power Baltimore Gas & Electric Co. CenterPoint Energy Cleco Dominion Duke Energy Entergy Corporation E on US Florida Power & Light Co. Florida Public Utilities Co. Oklahoma Gas & Electric Co. PHI, Inc. Progress Energy South Carolina Elec. & Gas Co. Tampa Electric Co. Southern Company SEE was established in 1933

20. Texas Mutual Assistance Group American Electric Power Austin Energy CenterPoint Energy City Public Service Cleco Entergy Mississippi Power Co. Oklahoma Gas & Electric Texas New Mexico Power TXU Electric The Texas MA group was founded in 1990

21. Wisconsin Utilities Association Mutual Assistance Group Alliant Energy Madison Gas & Elec. Co. We Energies Wisconsin Public Service Corporation Xcel Energy Inc American Transmission Company The WUA Mutual Assistance group was founded in 1993.

22. Western Region Mutual Assistance Members of Western Energy Institute and California Utilities Emergency Association Arizona Public Service Company ATCO Gas Avista Corporation Bonneville Power AdministrationCascade Natural Gas Chelan County PUD No. 1City of Mesa UtilitiesClark Public Utilities El Paso Electric Company ENSTAR Natural Gas Co. *Eugene Water and Electric Board FortisBC* (Terasen)Idaho Power Intermountain Gas CompanyHawaiian Electric Company *Los Angeles Dept. of Water & Power NorthWestern EnergyNV EnergyNorthwest Natural Pacific Gas & Electric CompanyPacifiCorp:  Pacific Power Rocky Mountain Power Portland General ElectricPublic Service Company of New Mexico Puget Sound Energy Questar Gas Company Sacramento Municipal Utility DistrictSalt River Project Seattle City LightSnohomish County PUD Southern California Edison Southwest Gas Corporation The Gas Company, LLC *Tucson Electric Power Company TransCanada GTN (Tuscarora) Anza Electric Cooperative Bear Valley Electric Service Burbank Water and Power Colton Public Utilities Glendale Water & Power Lassen Municipal Utility District Modesto Irrigation District Pasadena Water & Power Plumas-Sierra Rural Electric Cooperative San Diego Gas & Electric Company Southern California Gas Company Truckee-Donner Public Utility District The City of Anaheim The City of Azusa The City of Healdsburg The City of Lompoc The City of Palo Alto The City of Redding The City of Roseville The City of Santa Clara The City of Shasta Lake The City of Ukiah (* Not Shown on Map)

23. How did the RMAGs Work in Hurricane Sandy? • 5 days before landfall – individual utilities were planning and evaluating their need for resources – pre-staging • Utilities in need of Resources communicated up to the RMAG • The RMAG tried to fill the need within it’s own utilities if possible • The RMAG then went to Neighboring RMAGs for Resources • Lessons learned from recent major storm and mutual assistance incidents evolved the EEI Mutual Assistance / Emergency Preparedness Executive Committee, made up of representatives from all 9 RMAGs • EEI and the MA/EP worked directly with DOE and FEMA, then DOD, to coordinate the requesting and movement of resources from all parts of the country, to the affected areas

24. Mutual Assistance Process

25. Mutual Assistance Process Used In Sandy Individual Utilities

26. Results of RMAG Coordination • This event was bigger than any other movement of utility and contract resources in history • Unlike previous events, the Utility Industry demonstrated that We Can be Fully Effective in Responding to National Events • The Industry can Effectively coordinate with State and Federal Agencies in response • Industry Associations provide Invaluable Assistance and Coordination for their Utility Members • There is No Need for 3rd party regulation of Mutual Assistance • The Utility Industry can identify needed improvements, develop solutions, and be better prepared for future events

27. What’s Next • The EEI member CEO’s established a task force to identify improvements in RMAG Coordination and Configuration, Materials and Equipment, and Contractor Outreach • EEI is continuing development of RMAGS, and how they coordinate with each other, their effectiveness, and best practices in Mutual Assistance • EEI will represent the Electric Utility Industry with Federal Agencies in the integration of utility response in large events • EEI will reach out to Utility Associations to continue process improvements in Mutual Assistance and Emergency Response • WHY EEI???

29. National Response Event (NRE):The Case for Action & Proposed Approach5/22/2013

30. Case for Action We need to enhance the existing mutual assistance process for national events because: We want our customers, who have increasing expectations and electricity dependence, to see the mutual assistance process as efficient, transparent and equitable As an industry, we are the leaders in emergency response. Failure of any individual utility or regional mutual assistance group (RMAG) affects the entire industry We want to demonstrate that we are prepared for significant events so as to reduce unnecessary interference from 3rd parties. More efficient resource allocation would improve public safety, accelerate restoration and avoid economic consequences

31. Level of Events • Level 1 – Local Area (resources come from within your company including sister companies) • Level 2 – Local Region (resources come from 1 RMAG and potentially neighboring utilities) • Level 3 – Regional (resources come from more than one RMAG) • Level 4 – National Response Event (NRE) (impacts a significant population and requires resources from multiple RMAGs or sources)

32. Industry’s Vision for Allocating Resources in a National Response Event “When an NRE is declared then all available resources (including contractors) will be pooled and allocated to individual companies in an efficient, transparent and equitable manner based on a set of industry accepted evaluation criteria in order to do what is right for all customers and communities.”

33. Guiding Principles Governing National Response Event Safety First:Whether providing or receiving assistance, personnel safety will be the preeminent objective and responsibility of all participants. companies should work together to minimize safety risk to all parties. Voluntary Participation: Utility participation should remain voluntary and should not undermine a utilities’ ability to retain local control of respective operations while benefiting from outside support. Responding company may recall its resources at any point to address another event on its territory. Full and Reciprocal Participation:Utilities requesting mutual assistance during a storm event should offer assistance in future events proportional to their size and abilities, recognizing that great geographical separation may limit opportunities to share in all but the most catastrophic events. There will be a standing offer that each company will set and which will be available for support unless that company is threatened. Removing Regulatory Barriers: Companies will act in good faith to reduce legal and regulatory barriers to their respective full and reciprocal participation pursuant to these principles. Resource Transparency: Requesting company will disclose all available resources including their own line personnel, full-time on-site contractors, parent/sister company resources and any other resources secured in the reported mutual assistance resource counts. Efficient and Equitable Restoration:In an NRE the industry should have the organizational ability and resources to be responsive to members during major disaster and allocate available resources efficiently and equitably to meet all affected member company needs to restore power in a timely fashion. Companies agree that, in general, resources will be allocated on the basis of severity of need based upon predicted and/or actual impact (percentage/degree of system loss and estimated time customers have been without power), storm timing (i.e., which company will be impacted first), travel time, availability of non-RMAG member controlled resources. Coordinate Release of Resources:Companies agree not to release or dispatch any resource (contract or native) unless committed to and confirmed by the requesting member company. It is understood that the responding member company’s territories must be free from significant threat before resources (company and contractor) can be committed and dispatched. Situational Awareness:Companies should communicate to responding companies’ personnel regarding the degree of devastation in the emergency restoration work area and expected working conditions. Requesting companies should communicate general guidelines with responding companies, such as labor contractual issues, safety issues, contact personnel, vehicle fueling arrangements, typical standard construction, meal and lodging arrangements, etc. Timely and Fair Reimbursement:Utilities should provide assistance on a not-for-profit basis and requesting companies should provide timely reimbursement to responding companies for all expenses incurred in providing assistance. Responsibility of Requesting Companies: Utilities should request only those resources they can effectively assign and support. Following Existing Principles: EEI members agree to operate in accordance with the existing EEI Governing Principles covering Emergency Assistance

34. Triggering a Level 4 National Response Event • When multiple RMAGs cannot adequately support the resource requirements of the requesting utilities, the CEOs (or designated officers) of the requesting utilities may initiate the NRE process • A National Event: • Significantly impacts the energy infrastructure resulting in widespread power outages, telecommunications outages and fuel shortages • Impacts life, property and security of a significant population • Requires resources that exceed the capacity of the impacted and adjacent regions, in terms of level and capability • Requires coordination of the Federal, State and Local response

35. Structure for Allocating Resources During a National Response Event • Establish an NRE Executive Oversight Committee, consisting of Executives (VP or above) representing all regions of the US to oversee the process for resource allocation during an NRE, that • Owns the process and criteria for allocation of resources during NREs • Interface with EEI around communications and messaging for the industry (Public Information Officer – PIO) • Is responsible for conducting after-action reviews and commissioning periodic drills of the NRE process • Consists of the executives representing utility companies • Drives preparation and readiness of the Allocation Team for the NRE through training and drills • Ensure adherence the guiding principles and manage the appeal process during the event

36. Structure for Allocating Resources During a National Response Event • Create a NRE Mutual Assistance Allocation Team that will execute the process once the NRE is triggered • Assigned representatives who are drawn from the leaders (chairs) of the regional mutual assistance groups • Use the pre-defined criteria for resource allocation and facilitate agreement among requesting utilities • Analytic Support that will (the Allocation Team to define who will provide analytic support): • Compile the information on resource requests and resources available • Maintain the spreadsheets and methodology documentation for allocation

37. Process for Allocating Resources During a National Response Event • Once the NRE process is activated: • The allocations of the available resources will be allocated to requesting companies without regard to the existing RMAG boundaries • Available resources will be the total of all resources (company and contractor) available from all member companies and providers of resources • Requested resources will include all of the remaining unfilled resources by each company looking for assistance (initial request net of the resources that the company has already secured or has received commitments to receive) • The allocations will be based on pre-defined criteria and other situational considerations made transparent to all requesting utilities • Other requirements: • Resources will be applied to NRE consistent with good utility industry practices, including that the requesting utility must develop their resource request based on the needs of the event, not their worst case scenario. • Utilities will work together to address the impact of other day-to-day performance requirements that may be compromised as a result of support they are providing • Develop a contingency plan to address a secondary event that may impact a responding utility(ies)

38. Evaluation Criteria for National Response Event • There are a number of factors that should to be considered in the allocation, including but not limited to the following examples: • Number of trouble locations (actual or forecasted) • By type of damage • Damage location and type of terrain • Wires down • Total customers out and customers restored • Total and % of customers affected • Weather forecast (potential vs. actual outages, timing of the impact, potential secondary events, etc.) • Forecasted restoration time • Travel time • Geographic proximity • Pre-existing relationships with contractors • Skills of the resources required for restoration • Mutual Assistance/Emergency Preparedness Executive Committee will define the allocation criteria

39. Transparency of Resources • To promote transparency for all levels of events the utility requesting resources will identify, by type of resource, the following: • Company resources • Company contractor resources • Intra parent company/sister company resources and contractors • Resources obtained from outside allRMAGs • Resources obtained within RMAG • In many cases this information is already being provided to Governors and Regulators

40. Equity of the Process • In an NRE while there may not be sufficient mutual assistance resources to meet all companies’ needs (based on predicted or actual damage), the available resources will be allocated proportionally based on those companies with the greatest need receiving the highest proportion of resources using the agreed upon allocation process

41. Proposed Follow-up Actions with Contractors • Continue to partner with contractors to find solutions to resource allocation process challenges • Improve contractors’ understanding of mutual assistance process • Recognize contractor constraints in the allocation process (e.g., existing customer relationships, storm contracts and union/non-union agreements) • Enhance communications with contractors during early stages of response to understand the commitment and timing of resource releases • Have principles and practices recognize the event as an emergency and understand that provided resources may not be all the same but should meet basic qualifications

42. Proposed Material and Equipment • Post Hurricane Sandy, questions were raised regarding material and equipment shortages that may have delayed restoration • EEI Industry Survey: • The Material and Equipment Team conducted a survey to determine if there were shortages • Thirty-Nine utilities responded to the survey • Conclusion: • With some minor exceptions there were no shortages of material and equipment • The existing relationships with vendors and other utilities (or groups) have ensured that shortages typically do not occur in emergencies • Individual states may institute their own rules dealing with materials during emergencies • Association of Edison Illuminating Companies (AEIC) best practice report provides recommendations to avoid material shortages

43. Proposed Material and Equipment Follow-up Actions • Work with the EEI Mutual Assistance/Emergency Preparedness (MA/EP) Executive Committee to develop a formal mutual assistance logistics, material and equipment process for the NRE and each RMAG • Make AEIC best practices report available to all EEI members (to be finalized) • Develop a position paper that defines a material “shortage” and describes the process used by utilities to obtain material and equipment during major events without delaying restoration

44. Issues to be Addressed • Restoration Strategy: Resource allocation process needs to allow for different restoration strategies • Common Language: Need to continue to build a common language to be used across all events and RMAGs • Evaluation Criteria: Once developed the criteria can be applied for all events by individual RMAGs to ensure consistency • State Interventions: Governors and regulators are making state-specific decisions and demands on resources that are in conflict with the NRE

45. Public Policy Initiatives • Utilities will commit to pursue discussions with their respective regulators and legislators to educate them about the unintended consequences of decisions to limit the movement of restoration resources during emergencies • Develop a document that describes the NRE process to support the discussions with the external stakeholders (including Federal and state regulators and legislators) • Establish a process for communicating with stakeholders during major events to provide an industry perspective on resource needs and allocations • Avoid comparisons of resource acquisitions among individual utilities but focus on regional allocation as an indicator of readiness • Develop pre-messaging and communication strategy for each event • Use EEI Communications group as the Public Information Officer (PIO) for the events and align communications process with the Incident Command System (ICS)

46. RMAG Configuration • Some RMAGs could be more effective with increased geography and resources • Current size of individual RMAGs in Mid-Atlantic and Northeast may not provide sufficient geographic diversity and resources to address regional events • There is a significant overlap in membership among several RMAGs across the country • Individual Utilities may belong to one or multiple RMAGs

47. Summary of Recommendations • Implement a National Response Event (NRE) approach as defined in this document • Develop and execute an industry public policy strategy to educate the third party stakeholders on the NRE • Evaluate the benefits of consolidation of certain RMAGs, such as: • Mid-Atlantic Mutual Assistance (MAMA), New York Mutual Assistance Group (NYMAG) and New England Mutual Assistance Group (NEMAG) • Northern portion of the Midwest Mutual Assistance (MMA) • Southeastern Exchange (SEE) and Texas Mutual Assistance

48. Remaining Action Items (post Board Meeting) • Ensure that there is full support for the NRE across IOUs • Develop the specific criteria for resource allocation during NRE • Initial allocation to be based on quantitative criteria • Process for finalizing allocation criteria based on qualitative requirements (utility and contractor) • CEOs to assign NRE Executive Oversight Committee • Establish the document governing the NRE Executive Oversight Committee activities • Develop and implement a table top exercise for the NRE • Conduct an outreach to municipal and coop utilities to engage in mutual assistance in NREs

49. Where is the Western RMAG? • Initially represented to EEI as the combination of 2 major Mutual Assistance Agreements (each with EEI members), which include California Utilities Emergency Association Mutual Assistance Agreement, and the Western Region Mutual Assistance Agreement • Hurricane Sandy accelerated the interest in formalizing a Western Region Mutual Assistance Group • Initial meeting April 15th at WEI meeting in Seattle • Attending utilities agreed in principal to move forward with the development of the WRMAG • A Core Workgroup representing 7 electric utilities and 2 industry associations have begun development of the Guiding Principals and Concept of Operations for WRMAG

50. Western RMAG Concepts • Provide Value and Competence in assisting it’s members in medium to large assistance activations • Governance Structure that will provide leadership and continuity moving forward • Is Voluntary, Transparent, with minimal or no fee structure • Incorporates Industry Associations and their members • Incorporates Municipal, Rural, and Co-op utilities • Scalable to provide level of coordination in line with the event • Clear simple activation guidelines, and processes • Allows for existing Agreements to remain, and provide alternatives for agreements on demand • Provide planning coordination for WRMAA being the REQUESTING organization