By Jessica Hendricks, AAE's State Policy Director
Turns out, Louisiana’s electric utility grid needs to step it up to address resilience and reliability, yet untangling the two has become a bit messy.
The Louisiana Public Service Commission (LPSC) has FOUR open dockets to figure out how to keep the lights on. If there’s a silver lining here it’s that at least our elected officials are aware of the problem. While there is overlap between customer benefits and potential solutions, setting parameters on the intent of each proceeding is crucial if we want to get anything done.
Let’s start with resilience. The LPSC has an open rulemaking aimed to mandate resilience planning among utilities. Common resilience measures include grid hardening, solar + storage, back-up batteries and microgrids. This would help keep the lights on during an extreme weather event, get the lights on quicker following an outage from an extreme weather event, and mitigate the potential for unsafe conditions during a power outage. Other states and federal regulators have also included efforts to address extreme heat and cold, which have led to outages and high costs in recent years. The current LPSC draft does require consideration of non-wire alternatives like microgrids and solar + storage, but it falls short in requiring the inclusion of those alternatives nor does it create a pathway for other stakeholders to propose solutions (i.e. Community Lighthouse). In the Alliance’s opinion, this rule as currently drafted, falls short of robust, transparent, and collaborative resilience planning.
Coincidentally, Entergy Louisiana (ELL) has jumped ahead of the Commission’s rulemaking and has already filed an application for resilience upgrades on their system, with Phase I proposing a whopping $5 Billion over the first five years, followed by an additional $5 Billion in spending The problem is their plan is mostly poles & wire grid hardening, which they would be eligible to earn a rate of return on. While it does consider non-wire alternatives, those solutions are not included in Phase I. While we fully recognize the need for utility investments in their share of the electric grid, the metrics used to identify the best investments lack transparency and ELL is not forthcoming with pertinent information. Approving ELL’s $5B plan as is would be a dangerous exercise in trust in ELL, to put it nicely. Similarly, Entergy New Orleans has filed a request to spend up to $1.3 Billion on their resilience plans in Orleans Parish, which the City Council has yet to approve or deny.
Next, there’s reliability. This is about keeping the lights on during normal weather and often measured using System Average Interruption Duration Index (SAIDI), how long the power is out; and System Average Interruption Frequency Index (SAIFI). New Orleans just created their SAIDI and SAIFI requirements last February! The LPSC has had standards in place since 1998 that utilities in Louisiana, including Entergy and SWEPCO, have failed to meet in recent years, leading to Louisiana’s status as the least reliable utility grid in the country. The LPSC has two open dockets aiming to improve reliability with better tracking of the status of the electric grid and better coordination between utility pole owners and pole attachers. These two rules are good starts, but we think another crucial step is to strengthen the basic reliability standards and enforcement. After all, basic blue-sky reliability is foundational to greater resilience when the weather turns bad. It wouldn’t make much sense to put brand new “resilient” technologies at the top of a rotting pole.
Go look at your closest utility pole. Can you tell who owns it? Can you tell which wires have been attached by the electric utility and which ones have been attached by a telecom utility? Who do you call if one of those wires is down? Maybe it is an AT&T wire that’s down but when they come to reattach it, they determine the pole, owned by ELL is not usable, in which case the wire stays hanging in place until the pole falls down leaving two restaurants and a school without power on a sunny day, leaving a bunch of people out of work because the restaurants had to close, and parents had to leave work to pick up their kids. Better tracking and a coordinated effort could have fixed the problem when it was first reported. The two open dockets aimed to address reliability include transparent reporting requirements, a clear customer complaint process, a tracking database and even a “Lessons Learned’ working group to share new technologies and cutting edge practices.
Sounds great, and should have been done 10 years ago! But it wasn’t. Which is a big part of why we’re in this resilience/reliability regulatory mess.
Without knowing what shape our electric grid is in, regulators and stakeholders have no way of knowing if those investments are needed for resilience or reliability. If a pole is at a 45 degree angle with termites, replacing it will improve both resilience and reliability, the problem is much of reliability is paid for through standard Operations & Maintenance (O&M), and we’ve already paid for it.
Ultimately this leaves a big regulatory mess, and the excuse I’m using for why I look like I’ve been buried in utility filings for weeks now.
So how do we move forward? That is literally the $5B question. At least.
The Alliance is an intervenor in all of these proceedings, and we will continue to urge regulators and utilities to be transparent and find affordable ways to keep the lights on.