19 4. OBTAINING APPROVAL After establishing a potential resiliency program objective, how a resiliency program can support the pursuit of the objective, how to create a resiliency program, and developing the resiliency program plan, the next step in the Utility Infrastructure Resiliency Playbook (Playbook) is to obtain approval. This step is the most challenging, and success is not guaranteed. Conducting the previous steps in detail and with a focus on crafting a clear objective and establishing the financial or ratepayer benefit from the program is critical. There are multiple examples in Virginia, Florida, Indiana and other states where utilities have crafted legislative routes to support resilience programs including both hardening and undergrounding strategies. Public Utilities Commission (PUC) Versus Legislative Path to Approval Resiliency programs that rely on undergrounding strategies have and will continue to receive significant pushback, largely due to the high upfront cost. Ultimately, a utility wanting to pursue these types of programs for the ratepayer benefits in satisfaction and reliability will have to pick a traditional rate case, rider/surcharge, or legislative action. Regardless, a champion of this concept at the regulatory or legislative body is a necessary path. In addition, city, local or regional government support and ratepayer communications are also required. In the case of a legislative approach, the development of a preliminary bill will require at least one, and preferably a bi-partisan group as a formal sponsor to develop and push the bill. There are examples in Florida (#232), Indiana (see 2013 Senate Bill 560, and 2013 Public Law 133) and Virginia (#50, #188) where a traditional PUC approach was attempted, and then legislative action was ultimately implemented. In each case, additional extreme weather-related outages drove action. Severe Outage History In addition to a champion, a customer satisfaction opportunity and outage history must be present. As is highlighted in Step 3 “DEVELOPING THE PROGRAM PLAN” section, a detailed analysis of outage performance focusing on geography, line, and equipment performance is required. As is highlighted in Exhibit 4.1, a decade of storm analysis demonstrates the normalized duration and scale of storm impact where Exhibit 2.1 and 2.2 visually demonstrate the increasing severity and frequency of weather events. Also, as is pointed out in the previous section, storm frequency and severity over a 10-year cycle is the financial driver of justification of a resilience program that will include undergrounding strategies. In CASE STUDY III – LEGISLATIVE PATH APPROVAL, Florida Power & Light’s (FPL) 2004 hurricane season raised public consciousness and yielded a resiliency program that used hardening and undergrounding strategies. Implemented in 2006, the program generated substantial ratepayer benefit over the next decade. In CASE STUDY IV – GRID MODERNIZATION PLAN PUSHBACK, Duke Energy’s efforts to improve resiliency through a “Targeted Underground Program” (TUG), along with efforts to gain approval of the multi-faceted set of strategies is described. In both cases, the approval process required patience, repetition, and constant pressure to move forward.
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