Mich. PUC Announces Electric Application Involving Northern States Power

LANSING, Michigan, May 4 -- The Michigan Public Service Commission announced the following electric application (Case No. U-21415) on May 3, 2023:

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In the matter of the application of NORTHERN STATES POWER COMPANY, a Wisconsin corporation, and wholly owned subsidiary of Xcel Energy Inc., for a waiver of Rule 460.732(r) for reporting momentary outages.

APPLICATION

NORTHERN STATES POWER COMPANY, a Wisconsin corporation, and wholly owned subsidiary of Xcel Energy Inc. ("NSP-W" or the "Company") files this application with the Michigan Public Service Commission ("Commission") for approval of a waiver of the reporting requirements of Rule 32(r) of the Commission's Service Quality and Reliability Standards for Electric Distribution Systems ("Service Rules"), R 460.732(r). In support of this Application, NSP-W respectfully states the following.

1. NSP-W is a public service corporation organized under the laws of Wisconsin with principal offices located in Eau Claire Wisconsin and Ironwood Michigan. NSP-W is authorized to do business in the State of Michigan.

2. NSP-W is engaged, in part, in the generation, transmission, distribution and sales of electric energy in two counties in the Upper Peninsula of Michigan and thirty-four counties in Wisconsin.

3. NSP-W's retail business is subject to the jurisdiction of the Commission pursuant to 1909 PA 106, as amended, MCL 460.551 et seq.; 1919 PA 419, as amended, MCL 460.51 et seq.; and 1939 PA 3, as amended, MCL./1 et seq. Pursuant to said statutory provisions, the Commission has power and jurisdiction to regulate NSP-W's retail electric rates for service rendered in the State of Michigan.

4. In response to a series of severe thunderstorms that resulted in widespread electric power outages throughout Michigan's Upper and Lower Peninsulas in the summer of 2021, the Commission opened an investigation in Case No U-21122 to review emergency preparedness, planning, and storm response. As a result, the Commission's March 3, 2022, Order in Case No. U211221 required that, "Commission Staff shall work with utilities to hold meetings and collaborate in the development of a reporting template ("Reliability Reporting Template") for the filing of additional information pertaining to distribution system reliability, customer outages, and storm response."

5. In its Order issued on March 24, 2023, in Case No. U-20629/2, the Commission formally adopted updated Service Rules that are to be reported using the Reliability Reporting Template filed in Case No. U-21122 on November 18, 2022/3. The Service Rules include new rules on reporting of momentary interruptions.

6. The Service Rules, under Part 1: General Provisions, R 460.702(o), define momentary interruptions as "the full or partial loss of service to 1 or more customers for less than or equal to 5 minutes, including all reclosing operations that occur within 5 minutes of the first interruption." Furthermore, the Service Rules, under Part 3: Records and Reports, R 460.732(r), require utilities to report the "Number of non-residential customers experiencing momentary interruptions."

7. Pursuant to the Reliability Reporting Template, momentary interruptions should be measured and reported using the IEEE Standard 1366-2012 Momentary Average Interruption Frequency Index ("MAIFI").

8. Supervisory Control and Data Acquisition ("SCADA") performs automatic monitoring, protecting and controlling of various equipment in distribution systems. SCADA on every recloser is necessary in order to accurately measure and report real-time MAIFI. NSP-W does not currently have SCADA on every protective device, including all substations, breakers and reclosers. For devices without SCADA, reclose counters would need to be physically retrieved from the field after each interruption to capture MAIFI for all reclosing operations. In other words, it is not technologically feasible for the Company to measure and report MAIFI at this time.

9. The Company continues to invest in vegetation management and grid hardening efforts to ensure reliability, safety, and customer focus as described in the Company's most recent electric rate case in Case No. U-21097./4 One such effort is to connect SCADA to additional substations and protective devices throughout the Company's distribution system. However, such a project to ensure that every breaker or recloser has SCADA capability is unduly economically burdensome at this time. To ensure full real-time automated MAIFI reporting, the Company would need to connect over 50 reclosers to SCADA in Michigan. Connecting all reclosers to SCADA was not budgeted for or approved in NSP-W's distribution capital investments for 2022 and 2023 as described in Case No. U-21097.

10. Xcel Energy is currently implementing Advanced Metering Infrastructure ("AMI") throughout the jurisdictions that it serves. However, there are supply chain constraints impacting the pace of current state deployments which limits opportunities to accelerate the deployment within Michigan. Deployment in Michigan is currently scheduled to begin in the year 2024 or after. As Xcel Energy deploys AMI in its other jurisdictions, we have committed to developing momentary outage tracking and reporting capabilities that can be utilized when AMI is deployed in Michigan.

11. Although AMI will aid in reporting momentary outages, early review of AMI meter manufacturer specifications indicates that there may be limitations with AMI meters that would only allow for calculation and reporting of momentary events ("MAIFIE"). The speed of the reclose attempts of the Company's protective devices, the inability to configure the power down settings of the meters, and the length of the reboot time of the meters, could limit capturing all momentary interruptions. The Company predicts that MAIFI could be calculated from MAIFIE but would not account for real-time system contingency conditions. It also would only include devices with SCADA where the Company could capture the count of reclose attempts. Calculating MAIFI in this manner would provide partial and incomplete data which would misrepresent results reported.

12. The Service Rules, under Part 5: Waivers and Exceptions, R 460.751(1) of the Commission's Service Rules permit an electric utility to "petition the commission for a permanent or temporary waiver or exception from these rules when specific circumstances beyond the control of the electric utility or cooperative render compliance impossible or when compliance would be unduly economically burdensome or technologically infeasible" and under R 460.751(2) which says "An electric utility or cooperative may request a temporary waiver in order to have sufficient time to implement procedures and systems to comply with these rules"

13. As stated above because compliance is both unduly economically burdensome and technologically infeasible at this time, NSP-W requests the Commission grant approval of a waiver of the reporting requirements in R 460.732(r) for number of non-residential customers experiencing momentary interruptions. The Company requests that AMI be fully deployed throughout NSP-W's Michigan service territory for a full calendar year before reporting momentary outages. Likely, the earliest the Company could produce meaningful momentary outage reports using AMI data would be in the year 2026 or after. Therefore, the Company is seeking a waiver of the reporting requirements of R 460.732(r) until a full-calendar year after AMI is fully deployed in NSP-W's Michigan jurisdiction.

14. Furthermore, to ensure the Company reports real-time and complete data, the Company requests that when reporting commences as described in paragraph 13 herein, that the Company report on momentary events (MAIFIE) rather than momentary interruptions (MAIFI).

15. Approval of the relief requested in this Application will not increase rates or charges for any customer. NSP-W respectfully requests the Commission approve the relief requested on an ex parte basis without the time and expense of a public hearing.

WHEREFORE, Northern States Power Company respectfully requests that the Commission:

A. Accept this Application for filing;

B. Issue an Order approving the request to waive the reporting requirements for nonresidential customers experiencing momentary interruptions until a full-calendar year after AMI is fully deployed in NSP-W's Michigan jurisdiction;

C. Issue an Order approving the request to report MAIFIE rather than MAIFI.

D. Determine that the relief requested herein should be granted ex parte without the time and expense of a public hearing; and

E. Grant such other relief as is lawful and appropriate.

Respectfully submitted,

NORTHERN STATES POWER COMPANY, A WISCONSIN CORPORATION

Dated: May 3, 2023

By:

Its Attorney

Sherri A. Wellman (P38989)

MILLER, CANFIELD, PADDOCK & STONE, P.L.C.

One Michigan Avenue, Suite 900

Lansing, MI 48933

(517) 487-2070

Attorneys for NORTHERN STATES POWER COMPANY - WISCONSIN

And by:

Tyrel Zich, Regional Vice President, Regulatory Policy

Northern States Power Company - Wisconsin

1414 W. Hamilton Ave

P.O. Box 8

Eau Claire, WI 54702

612-216-5682

Tyrel.Zich@xcelenergy.com

Mara Ascheman, Regional Vice President, Rates and Regulatory Affairs

Northern States Power Company - Wisconsin

1414 W. Hamilton Ave

P.O. Box 8

Eau Claire, WI 54702

612-215-4605

Mara.K.Ascheman@xcelenergy.com

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Footnotes:

1/ Case No. U-21122-0067

2/ Case No. U-21122-0074

3/ Case No. U-21122-0069

4/ Case No. U-21097-0003, Direct Testimony of William J. Rauckman, p. 33-58.

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Original text here: https://mi-psc.force.com/sfc/servlet.shepherd/version/download/0688y000007ggUsAAI