APPENDIX 20
Further Memorandum submitted by the Northern
Ireland Consumer Committee for Electricity
RESPONSE TO A REQUEST FOR FURTHER VIEWS ON
THE NORTHERN IRELAND ELECTRICITY PLC STORM REPORT
INTRODUCTION
The Northern Ireland Consumer Committee for
Electricity (NICCE) welcomes the opportunity to respond to the
Northern Ireland Affairs Committee in relation to the Storm Report
published by Northern Ireland Electricity (NIE).
In this response to the Storm Report the NICCE
will follow the structure of the Report and will comment on matters
arising as necessary.
NICCE welcomes the very serious response by
NIE to the problems which occurred as a consequence of the storms.
NICCE accepts that the storms were of exceptional severity. However,
this is the third year running in which there have been severe
storms at this time of year, and NICCE was assured at its November
1998 meeting that NIE had in place new technology and an effective
strategy to deal with what might arise over the Christmas period.
Lengthy presentations in relation to enhanced communication capacity
were made, and the Committee was assured that there would be no
repeat of the difficulties experienced in 1997. In the event the
situation in 1998 was worse than that in any preceding year.
1. CHAPTER 3—THE
CHARACTERISTICS OF
THE NETWORK
During the first Regulatory Period NIE underspent
on its allowed Capital Expenditure budget by some £97 million.
The statements by NIE in relation to current levels of investment
in the network (paragraph 3.1) are not set in the context of this
very major fact, or of the fact that during the period prior to
privatisation the network was not as old as it is now. Hence the
components of the system would have an anticipated outstanding
lifespan and one would not expect as much work to be required
in terms of refurbishment and maintenance, as are inevitably required
on an ageing system. The fact of the underspend of £97 million
has never been satisfactorily explained and the Committee is of
the view that there is a correlation between capital underspend
and the failure of the network when it comes under strain such
as that imposed by the Christmas Storms. It is not totally relevant
to compare NIE spend in this context with spend by the other Regional
Electricity Companies (RECS) as the necessary capital expenditure
was determined for the regulatory period and NIE underspent approximately
30 per cent of the sum allocated. The NICCE is of the very clear
view that what happened at Christmas is related to the underspend.
CHAPTER 4—DAMAGE
TO THE
NETWORK
The Committee acknowledges that work has been
done on the 11kv network which comprises a very significant part
of the network. The NICCE welcomes the acknowledgement that refurbished
lines suffer noticeably fewer interruptions of supply than unrefurbished
lines (Figure 3). This is as the NICCE would have expected it
to be! However the number of faults arising on the 11kv and 6kv
network were some 856 (approximately 25 per cent of the total).
The 11kv and 6kv network comprises some 23,297 km of line. The
number of faults occurring on the LV system was some 3,000 (almost
75 per cent of all the faults). The most extensive damage therefore
occurred on the LV system. NIE's LV system consists of some 13,564
km of line. Of this 7,231 km are underground and only 6,332 km
are overhead. The majority of the faults are believed to be on
the overhead LV system. It would therefore appear that there was
a very high incidence of failure in this part of the system. This
must be subject to further scrutiny.
The cause of these faults is acknowledged to
be principally wind (approximately 60 per cent) and trees (approximately
30 per cent).
Trees
The tree pruning cycle is stated to be based
on an industry standard of five years. It is also stated that
full protection of the lines would require the removal of very
large numbers of trees. The NICCE is not satisfied with the adequacy
of this response. Anecdotal evidence suggests that trees were
pruned more regularly in the past and that inspection was done
on a more regular basis. Moreover the NICCE is of the opinion
that the particular characteristics of the Northern Ireland transmission
and distribution system are different from some other RECS, and
that what is appropriate to a system with a higher level of undergrounding
and a higher proportion of urban territory may not be appropriate
to a largely rural system.
Poles
The Report states that 1,133 poles were replaced
as a consequence of the Storm. Faulty poles accounted for some
10 per cent of the faults. Consumers are clear that the level
and effectiveness of pole inspection has deteriorated over the
years. Consumers report helicopter inspection of poles, and also
report that there is no systematic pole analysis. NIE state that
there is. The Storm Report does not address this issue in any
detail. Nor does it provide any analysis of the causes of pole
failure, or the age of the affected poles. The NICCE considers
such analysis to be necessary.
Fault Analysis
Whilst there is a table of geographical fault
analysis on the HV system (Table 4) there is no other table of
fault analysis of the whole system. Hence it is not possible to
identify which areas were affected and to what extent they were
affected.
CHAPTER 5—NIE'S
RESPONSE—RESTORATION
OF SUPPLIES
There is no clear evidence as to the effectiveness
of NIE's response to the various faults. The Report states that
management of the field response was devolved to the 13 local
Customer Services Centres. It states that this devolution was
a key factor in the success of the restoration process. NIE has
acknowledged that its radio system and its phone system were subject
to serious failure during the storm period.
It is in this area that the NICCE has grave
reservations as to the content of the Storm Report. The NICCE
has no doubt that engineers and linesmen worked very hard in appalling
circumstances. However there is no indication of what proportion
of the number of technical staff employed on the system were employed
in each part of the system. There is, therefore, no correlation
between geographical fault analysis (even at HV level), and distribution
of technical staff. The NICCE is of the view that it is not possible
to determine the effectiveness of the technical response without
analysis of the areas of loss, the nature of the damage to the
system and the way in which technical staff were deployed. Given
that many customers remained without supply for several days the
NICCE can not be satisfied that the strategic management of the
response by NIE has been shown to be either adequate or appropriate.
CHAPTER 6—NIE'S
RESPONSE TO
CUSTOMERS AND
THE MEDIA
By any standards, NIE's response to customers
was woefully inadequate. The NICCE has already cited in its supplementary
response to the Northern Ireland Affairs Committee the fact that
during 26 and 27 December some 650,000 calls were made to NIE,
and that only 13,650 consumers were able to get through to call
centre staff.
The telephone system
NIE state that the volume of attempted calls
was unprecedented. This must be largely a product of the fact
that people were unable to contact NIE and made repeated attempts
to do so, over many, many hours. Had there been an initial response,
it is the NICCE's view that there would not have been such a volume
of calls. The NICCE considers that this element of NIE's response
can only be described as a catastrophic failure. The NICCE is
gravely disappointed at the inadequacy of the response. This inadequacy
was, we think, compounded by the fact that communications between
customer service centres and management and technical staff do
not seem to have been in any way satisfactory. The inability of
various sections of NIE to communicate with each other is not
investigated in the report, and the NICCE considers that it would
have been necessary to conduct an analysis of the aspect of the
situation.
The fault on the BT Message Link facility
There is no explanation of the nature of the
fault on the Message Link facility, no indication of what might
be done to prevent a recurrence of the situation, and no analysis
of the impact of the fault on communications. The Report identifies
a fault on the evening of 26 December which was not resolved until
late afternoon the following day. However consumers identified
difficulties with the Message Link situation over a much longer
period than 24 hours. The NICCE is of the view that more information
is required in relation to the operation of the Message Link system.
The NICCE is aware that in parts of England a similar system was
updated half-hourly and provided an adequate and effective response
to consumer information needs.
Customer care
NIE have identified the need to revisit the
operation of the customer care systems as a consequence of the
experience of the Storm. The NICCE welcomes this and will assist
NIE in every way possible to ensure the identification of customers
at risk and an appropriate caring response to them.
Vital services
A number of consumers lost their water supply
in addition to their electricity supply as a consequence of the
storm. This was caused by a failure of whatever emergency generation
arrangements had been made by the Water Agency in the context
of its responsibilities to provide a water supply. This should
not have happened, and the NICCE welcomes the commitment to formalising
arrangements in respect of vital service providers. Obviously
such arrangements must be tested at regular intervals, and we
look forward to hearing more of the substance of these proposals.
Goodwill payments
NIE involved the NICCE from the earliest stage
of this crisis in its goodwill response. The NICCE welcomes this
opportunity to acknowledge that involvement and to state its appreciation
of the efforts made by staff in this context. However the NICCE
is disappointed that the Report does not indicate any intention
to formalise these policies, and considers that this is a notable
deficiency.
CHAPTER 7—NIE'S
SYSTEMS
Much of what is stated above in relation to
NIE's response to customers is relevant to this Chapter. The scale
of the failure of these systems was so extensive that NIE have
committed themselves to extensive work in this context. We welcome
the proposals but with the caveat that we received similar assurances
last year. Such assurances proved to be groundless. We will therefore
monitor this matter constantly. The NICCE is to visit the new
IVR system during April to review the effectiveness of the new
system. Obviously there is a need, once the telecommunications
system has been installed, to revisit the issue of information
flow in crisis situations.
CHAPTER 8—RECOMMENDATIONS
During the post-storm period the NICCE have
had repeated meetings with NIE in relation to the content and
progress of the recommendations contained in the Report. We have
received extensive information on the progress of some 150 remedial
actions being undertaken by NIE. We welcome this level of involvement
and the obvious determination on the part of the customer services
managers to ensure, as far as they can, that there is a genuine
improvement in relation to all aspects affecting customers' enjoyment
of electricity supply.
Recommendation 8.1
The NICCE is of the view that contact with those
on the medical support equipment register must be made within
a much shorter period than the 24 hours proposed in the Report.
Similarly the commitment to a further 12 hour period for contact
with the emergency services is too long. The NICCE is of the opinion
that further emergency planning is required in this context.
The NICCE welcomes the remainder of the recommendation,
and is pleased that NIE is setting itself targets in relation
to information supply.
Recommendation 8.2
Whilst welcoming these proposals, the NICCE
is of the view that more rigorous analysis of what happened this
year is necessary in order to achieve the necessary outcomes.
Recommendations 8.3
The NICCE welcomes NIE's commitment to augmentation
and refocussing of the capital expenditure programme. However
the NICCE would like to remind all concerned that what is being
spent here is no more than would have been spent anyway, and that
NIE is always required to review its proposals to secure the best
possible outcome for consumers. The money being spent is paid
for by customers not shareholders. It is not new money. The Committee
will monitor the implementation of this proposal rigorously. We
are of the view that these plans are critical to an improvement
in the level of customer supply.
Conclusion
There is much useful information in this Report.
However there are significant gaps in the analysis and in the
information provided. The NICCE has identified many of these gaps
in the course of this response. Effective action by NIE can only
occur in the light of complete information. The Report does not
indicate the existence of such information, although the NICCE
accepts that there will be more information available to NIE than
is contained in this report. The NICCE welcomes the positive action
which is currently under way at NIE, will continue to monitor
the situation and to articulate the consumer interest.
29 March 1999
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