Mr. David McFadden
Chair, Toronto Hydro Ice Storm Inquiry
March 31, 2014
Dear Mr. McFadden,
This submission is emailed to your Gowling email address and also to Toronto Hydro’s consultant (email@example.com). I wrote to the Davies Consulting address previously seeking details on the submission process but never received a reply, so I am unsure as to whether that account is monitored.
I am a customer of Toronto Hydro and experienced an extended outage during the 2014 Ice Storm. In the course of my household’s experience and my reporting for my web site www.tomadamsenergy.com, where this correspondence is also posted, I have identified a number of concerns with respect to Toronto Hydro’s response to the event and also with respect to the inquiry of which you are chair.
On March 6, I made a verbal deputation to the town hall meeting chaired by Mr. Conway. In the course of that deputation I raised three questions that I suggest the citizens of Toronto deserve answers to:
1. Why was it that despite massive spending on the so-called Smart Grid over many years, all the return to service information provided by Toronto Hydro during the ice storm blackout was wildly unreliable, most egregiously on December 22 throughout the day and late on December 23? Notice that the published scope of the inquiry does not include reference to the accuracy of the information provided to the public.
2. What can be done in the near term to improve the utility’s ability to provide consumers with accurate return to service information in the event of another large-scale blackout? The technical issues there relate to the functioning of the Outage Management System/Distribution Management System (OMS/DMS), staffing of the power system controller functions in the control room, and many other near-to-hand improvements.
3. What needs to be done to speed future storm recovery without further increasing Toronto Hydro’s distribution rates, which are already by far the highest of any urban utility in Ontario?
“We’re Winning the War”
Throughout the storm Toronto Hydro’s CEO Anthony Haines issued a stream of unreliable restoration promises. Here is a chronology of some of those false signals. (Reader reviewing this on my site will have seen this chronology already here):
CP24 tweeted at 9:12 pm, 21 Dec 13 “Toronto Hydro says number of outages expected to grow, restoration times are anticipated to be 12 to 16 hours.” (Note that all twitter time references are PST, whereas all other time references in this post are EST.) The utility issued this press release near midnight on the 21 and this press release from 3:21 am on the 22nd repeating the same recovery time.
CP24 tweeted at 8:26 AM, 22 Dec 13 “Toronto Hydro says could be 72 hours before power restored throughout the city. ‘Prepare for the worst,’ says CEO Anthony Haines.” The utility issued this press release at about 8 am repeating this message.
In this press release issued Sunday the 22nd at 4:08 pm Toronto Hydro stated that “the utility hopes to have everyone restored by Wednesday (December 25)”.
CP24 tweeted at 3:39, 23 Dec 13 “Haines said power outages continue to happen as branches continue to fall. Christmas is ‘a very aggressive schedule. Plan for the worst.’”
On December 23 at 1:50 pm, Toronto Hydro issued this press release stating that it expects restoration efforts to continue into the weekend (December 28/9). Later on the 23rd, Haines reassured the public that the utility was “winning the war”. At 7:11 pm on the 23rd, Toronto Hydro issued this press release stating “restoration efforts could continue for the next few days.”
The first time I can find that Toronto Hydro notified customers about the need to repair their own stand pipe/mast was in this press release issued at December 25, 2013 1:02 AM. As the recovery continued, damaged stand pipes/masts became a major factor keeping customers out of power.
CP24 tweeted at 5:06 am 25 Dec 13, “Customers should still be prepared for power restoration to take place over the next few days, Toronto Hydro tells CP24.”
On December 25 at 11:41 pm, Toronto Hydro issued the least informative press release of the emergency pointing out that the restoration effort “takes considerable time.”
At the morning press conference on the 26th, Haines told reporters, “We’re reaching the point that is the hand-to-hand combat of it.” What is the point of that comment?
CP24 tweeted at 8:18 am, 27, Dec 13 “‘Plan for the worst and know that Toronto Hydro will not rest until all power comes back on,’ said Haines.” Again, this statement provided no useful guidance.
In this press release from December 27 at 6:31 pm, the utility’s restoration schedule was “customers who are still without power should be prepared for restoration to continue over the next few days.” The next day at 1:12 pm and then again at 6:05 pm, the utility repeated the same phrase regarding the restoration schedule and here.
On Friday December 27, Haines refused to specify for the Ottawa Citizen when the reconnection work would be complete saying, “it would be ‘irresponsible’ to give residents false hope in such an unpredictable situation.” http://www.ottawacitizen.com/Authorities+warn+storm+related+power+outages+possible/9327889/story.html
CP24 tweeted at 8:07 am, 29 Dec 13 “Toronto Hydro CEO says less than 6,000 customers are now without power. ‘We are almost standing on finish line.’” From the same press conference, the Toronto Star reported Haines promising full power by the end of the 30th. Four days from the end of the crisis, Haines was off by 100% in his time estimate.
In this press release from the 29th at 10:30 pm, the utility informs us that the restoration work is proceeding “as expected”. The full statement is, “As expected, in this final stage, our equipment at many locations has experienced severe damage due to the ice storm, and therefore restoration is taking much longer than would normally be the case.” The whole “as expected” statement is repeated in the next press release from December 30, 2013 10:17 AM.
CP24 tweeted at 5:39 am 30 Dec 13 “Power will be restored to last remaining customers by end of day, mayor says.”
By December 30, 2013 10:42 PM, Toronto Hydro’s excuse making was at full power. “As expected, our equipment at many locations has experienced severe damage due to the ice storm and there is also a great deal of forestry work and clean up required. As a result, power restoration, is taking much longer than would normally be the case.” If this was all expected, why did the utility claim on the 22nd that full power was coming in 72 hours?
Even late in the day on December 31, blacked out customers were reporting on Twitter and through the media that they could not get a statement from Toronto Hydro as to when their service would be restored. What were the Customer Service Representatives doing at this point if not providing reconnection information to customers?
January 1, 2014 at 8:25 pm Toronto time, Toronto Hydro issued this press release declaring an end to the emergency.
The inquiry members should determine what information Mr. Haines was relying on in making each of these statements. Was he simply making things up when he said 72 hours until full power? Early on in the event, it appears that workers inside Toronto Hydro had no confidence in the restoration estimates issued by the CEO.
As it became obvious that the information being issued by Mr. Haines on restoration was nonsense, the company started warning the public to not speak with field staff. Here is a report to that effect published in National Post December 27th. The inquiry’s consultant might be able to answer whether other utilities issue similar warnings claiming it is unsafe to speak to utility crews. With crews well trained and equipped to maintain safe workplaces, it appears that the warning to the public might have had a non-safety purpose. The apparent purpose of Mr. Haines telling the public to not speak to workers appears to have been to prevent the public from gaining access to more accurate information than they were receiving from Mr. Haines through the media.
All of the statements issued by the utility with respect to masts should be catalogued and reviewed. Many customers have complained about receiving inaccurate, untimely, and sometimes even contradictory information about damaged masts. It also appears that at some point during the storm response, utility workers were told to disconnect slightly damaged masts, thereby significantly delaying restoration times for those customers. At other times, slightly damaged but serviceable masts were left in place, allowing customers faster return to service and orderly, scheduled, less costly mast repairs rather than emergency repairs.
Adequacy of Planning and Control
I have also received substantial information indicating confused behaviour within the utility. The problems appear arise from poor planning for an event of this kind and also on disorderly distribution system control functions.
The amount of ice deposition during the event — 30 mm or about 1/7 of the most serious ice deposition during 1998 Eastern North America ice storm — appears to be something that can be expected in future and could have been reasonably anticipated as a credible scenario in advance. However, the utility did not appear to be prepared.
It appears as if all staff available to work in, or in support of, the control functions of the utility were not deployed efficiently from the beginning of the storm. The deployment of qualified staff in the functions related to distribution system control needs to be thoroughly documented.
Despite the fact that he storm’s arrival was forecast accurately far in advance, it appears that Toronto Hydro had not called in extra staff to be on hand when the storm hit. If true, this would be a repeat of Toronto Hydro’s performance during Hurricane Sandy, where the utility vastly underperformed its peers in response to that storm. Here is a more complete review of Toronto Hydro’s failure to respond effectively to Hurricane Sandy. I suggest that inquiry should undertake a detailed comparison of the utility’s performance on Sandy and Ice Storm 2013.
Once Local Incident Command Centres (LICC) were established, they appeared to issue ineffective and inefficient directions to field staff.
In some cases, directions to field staff appears to have violated safety protocols. I believe that there were several incidents where crews were dispatched to areas where they were told local circuits were not energized, only to discover that lines were actually energized. If true, this would indicate a severe infraction of safety protocols. This issue must be investigated thoroughly. This investigation must examine actual practices in the control room or controlling LICC, particularly any interference in the proper operation of the control function or other disorder in the control function.
Anecdotal evidence suggests that inadequate replacement hardware stocks slowed the restoration response. A cost-effective solution for this might be some form of stock sharing with other utilities.
The deployment of available forestry staff also appears to have been inefficient.
Independence of the Inquiry
The inquiry’s independence appears impaired by the following:
It appears that Toronto Hydro selected or influenced the selection of the inquiry members, funds the inquiry, sets or influences the mandate for the inquiry, and selected and funded a consultant of its choice for the inquiry.
In his work at Gowlings, inquiry appointee Mr. Conway ultimately reports to the inquiry chair. This fact is not disclosed in any of the promotional material released by the inquiry’s sponsors.
In January, you Mr. McFadden joined the board of the Ontario Energy Association, which represents Toronto Hydro.
You Mr. McFadden have had various roles in promoting and directing the Ontario government’s Smart Grid agenda. With the failure of Toronto Hydro’s Smart Grid investments to support accurate return to service information for customers, it appears that the performance of the Smart Grid would benefit from independent assessment.
The inquiry’s promotional material providing inquiry member bios focuses on Mr. Conway’s relationship with Ryerson University’s Centre for Urban Energy (CUE), an institution that receives substantial funding from Toronto Hydro. The full amount of that funding does not appear to be accessible through the public record, although one element is known — a $2.5 million payment from Toronto Hydro in 2010. There also appears to have been substantial funding since, although CUE’s annual report does not provide financial data and CUE has not responded to my inquiries for such data.
It appears that Toronto Hydro provided direction to the Centre for Urban Energy on ice storm findings at a private conference on February 13.
If this press report is accurate, Davies was selected by Toronto Hydro for the ice storm inquiry but was directly involved in developing the current tree trimming program used by the utility. Since tree trimming is directly associated with the damage incurred, Davies Consulting would appear to be inquiring into their own work.
I suggest that it is incumbent upon the inquiry to report on all connections its members and the inquiry consultant have with Toronto Hydro.
Post Script: Davies Consulting acknowledged receipt of this letter on April 2.