Other DNSPs commented that a MED is not limited to weather events, and they will have to examine each MED to ensure it is related to a weather event. Further, there could be severe weather events that do not reach the required MED threshold but incur a significant amount of expenditure. While it may be difficult for all DNSPs to report costs associated with individual MEDs, we consider it necessary to understand the costs of these 'extreme events' and exclude them from the everyday operational costs in order to examine underlying trends in emergency response opex. In response to DNSPs' concerns and difficulties in collecting the data, we have inserted instructions in the RIN regarding the reporting of MED costs via the following processes: reporting of MED costs via direct cost capture reporting (i.e. specific allocated cost code) if available reporting of MED costs via capturing operating and maintenance (O&M) costs that were booked to the O&M codes on those days. While it may not capture all costs caused by the major events on those MED days, this will provide a good approximation. Customer outage minutes In addition to the data requirement on major storms and MEDs, we will use data on customer outage minutes for each regulatory year. These data will be used to assess the annual emergency response expenditure of each DNSP. These data are collected in template 6.3 of the regulatory templates. Outage data can be used to establish an emergency response workload-cost correlation model, which can serve as an alternative solution if DNSPs fail to provide good quality MED cost data, or it can be used to verify DNSPs' emergency response cost data estimates.
Other DNSPs commented that a MED is not limited to weather events, and they will have to examine each MED to ensure it is related to a weather event. Further, there could be severe weather events that do not reach the required MED threshold but incur a significant amount of expenditure. While it may be difficult for all DNSPs to report costs associated with individual MEDs, we consider it necessary to understand the costs of these 'extreme events' and exclude them from the everyday operational costs in order to examine underlying trends in emergency response opex. In response to DNSPs' concerns and difficulties in collecting the data, we have inserted instructions in the RIN regarding the reporting of MED costs via the following processes: reporting of MED costs via direct cost capture reporting (i.e. specific allocated cost code) if available reporting of MED costs via capturing operating and maintenance (O&M) costs that were booked to the O&M codes on those days. While it may not capture all costs caused by the major events on those MED days, this will provide a good approximation. Customer outage minutes In addition to the data requirement on major storms and MEDs, we will use data on customer outage minutes for each regulatory year. These data will be used to assess the annual emergency response expenditure of each DNSP. These data are collected in template 6.3 of the regulatory templates. Outage data can be used to establish an emergency response workload-cost correlation model, which can serve as an alternative solution if DNSPs fail to provide good quality MED cost data, or it can be used to verify DNSPs' emergency response cost data estimates.
AER%20explanatory%20statement%20-%20final%20category%20analysis%20RINs.DOCX