Review of systems relating to Code Part 2, Divisions 1 to 4 … · Review of systems relating to...

Network Quality & Reliability of Supply (NQRS) Code Audit

Review of systems relating to Code Part 2, Divisions 1 to 4

INDEPENDENT ASSURANCE REPORT

August 2016


CMPJ0039-02 – Independent Assurance Report - Network Quality & Reliability of Supply (NQRS) Code Audit

i

Mr John Paolino

Senior Compliance Specialist

Regulatory Compliance

Western Power

363 Wellington Street

Perth WA 6000

7 September 2016

Dear John,

Re: 2015/16 Network Quality & Reliability of Supply (NQRS) Code Audit

I am pleased to provide our Independent Assurance Report resulting from the audit on the operation of the

systems that are in place to monitor compliance with Part 2 of the Electricity Industry (Network Quality &

Reliability of Supply) Code 2005 for the 2015/16 financial year.

I confirm my approval of the content of the report, and that it is an accurate presentation of the audit findings

and CutlerMerz’ opinions.

Sincerely,

Ryan Dudley

Principal



ii

Table of Contents

Executive Summary ................................................................................................................... 1

1 Introduction ..................................................................................................................... 3

1.1 Audit objective .................................................................................................................................................... 3

1.2 Western Power’s key systems and procedures .................................................................................................. 3

2 Audit Approach ............................................................................................................... 4

2.1 Audit scope ......................................................................................................................................................... 4

2.2 Audit standard ..................................................................................................................................................... 4

2.3 Audit steps .......................................................................................................................................................... 4

2.4 Audit team ........................................................................................................................................................... 5

2.5 Western Power key staff ..................................................................................................................................... 5

2.6 Audit grades ........................................................................................................................................................ 6

3 Western Power’s response to previous recommendations ......................................... 7

4 Performance summary ................................................................................................... 8

5 Observations ................................................................................................................. 10

6 Recommendations ........................................................................................................ 12

Appendix A Detailed findings ............................................................................................. 13

Appendix B Information provided ...................................................................................... 25



1

Executive Summary

The Electricity Industry (Network Quality & Reliability of Supply) Code 2005 (the “Code”) requires that Western

Power arrange for an independent expert to audit, and report on, the operation of the systems in place for

monitoring compliance with Part 2 of the Code.

CutlerMerz (“we”) have been engaged by Western Power to conduct the independent audit for the 2015/16

financial year. As required by the Code, the objective of the audit is to assess whether Western Power has

adequate controls (Process and Systems) in place to monitor compliance with each obligation under the Code.

We conducted the audit in accordance with the Economic Regulation Authority Western Australia (ERA)

Guidelines for Audit and the Australian Standard on Performance Engagements (ASAE 3500). Accordingly, our

audit report provides reasonable assurance as defined in ASAE 3500.

The key findings, areas for improvement and observations arising from the audit are as follows.

Assessment of the adequacy of controls

► In relation to all but one clause of Part 2 of the Code, we are of the opinion that Western Power has a

strong control environment and have assessed the adequacy of controls as “A – Adequate controls –

no improvement needed”.

► Clause 10(2) requires that Western Power consider whether, in specified circumstances, it should

supply electricity by alternative means to a customer who will be affected by a proposed interruption.

Western Power’s process for monitoring compliance with the requirement for providing alternate power

supplies to mitigate interruptions needs improvement.

Western Power’s process for achieving the Code requirement is through the Electronic Network Access

Request (ENAR) system. The system, which is used to plan outages on the network, prompts the user

to answer either “yes” or “no” as to whether an alternate supply is required during a planned outage. We

found that there is no process that supports the user to determine the “specified circumstances” to be

considered when making this assessment. Further, in the sample reviewed during the audit, the user

had answered “no” for a planned outage where the use of alternate supply would be interpreted as

being appropriate under the Code i.e. an outage was planned for 9.5 hours and the Code requires an

alternate supply be considered for outages exceeding 6 hours (or 4 hours if temperatures are forecast

to exceed 30 degrees Celsius).

We have assessed the adequacy of controls in relation to clause 10(2) to be “B – Generally adequate

controls – improvement needed”. It is recommended that Western Power introduce a process to

ensure that the use of alternate power supplies is considered for planned outages, in view of the

specific circumstances identified in the Code.

Observations

Overall, we consider Western Power’s systems in relation to Part 2 of the Code to be adequate.

Notwithstanding this, we have also made observations in Section 5 of this report that relate to opportunities for

improvement that in our opinion would contribute to better network quality and reliability outcomes, irrespective

of the adequacy of controls:

► Under the requirements of the Code, interruptions arising from weather events are included (without

any exceptions) in determining performance reliability. As a consequence, Western Power consistently

reports a substantial number of breaches against a portion of the Code requirements (which Western

Power advises are predominantly due to outages occurring during extreme weather events). Western



2

Power is also required to make payments to customers where they make a claim against these

breaches.

While we have assessed Western Power’s systems for monitoring reliability performance as being

adequate, we are aware that other jurisdictions (as well as the AER) allow for the exclusion of extreme

weather events for reliability reporting and compliance requirements. This contributes towards:

i. Service providers not being required to invest to reinforce the network to withstand extreme

weather events; and

ii. Underlying performance being more effectively monitored, rather than sustaining unrealistic

reliability targets which include the distortion from extreme weather event anomalies. Effective

monitoring of underlying performance drives tighter focus on achieving the reliability objectives in

general, and particularly in remediating poor performing sections of the network.

We consider that given Western Power’s transition to the national regulatory regime, it may be

appropriate to consider amending the Code to allow for the exclusion of extreme weather events, using

well established principles, from the reliability performance measurements.



3

1 Introduction

CutlerMerz was engaged by Western Power to conduct an independent audit and report on the operation of the

systems that are in place to monitor compliance with Part 2 of the Electricity Industry (Network Quality &

Reliability of Supply) Code 2005 (the “Code”) for the 2015/16 financial year.

The requirement for an audit of these systems relating to Part 2 of the Code is based on clause 26 of Part 4 –

Division 3, which reads as follows:

Part 4 — Duties incidental to the prescribed standards

Division 3 — Performance reporting

26. Annual report on monitoring systems

(1) A transmitter and a distributor must, as required by subsection (2), arrange for an

independent expert to audit, and report on, the operation of the systems that the

transmitter or the distributor has in place for monitoring its compliance with Part 2 or an

instrument made under section 14(3).

(2) An audit under subsection (1) is to be carried out in respect of the operation of such

systems during each year ending on 30 June.

1.1 Audit objective

The objective of the audit is to make an independent assessment of the operation of the systems used by

Western Power for monitoring its compliance with Part 2 of the Code between 1 July 2015 and 30 June 2016.

1.2 Western Power’s key systems and procedures

With regards to compliance with the Code, Western Power has implemented a number of systems and

procedures in order to achieve compliance. The key systems are identified below.

Reliability

PowerOn Fusion (PoF): PoF is a leading industry tool for network control and management. It

integrates call centre, network control, and data capture and removes much of the manual processing

that is traditionally prone to human-error in relation to monitoring customer notifications and network

reliability data. Data is extracted and stored from PoF within the Data Warehouse, and then reliability

data is processed for reporting via the Network Reliability Data Validator (NRDV). Although there is

always room for improvement at data interface and processing points, CutlerMerz considers the PoF /

Data Warehouse / NRDV system to be a strong system for capturing and processing customer and

network information.

Electronic Network Access Request (ENAR): The ENAR system is used to request planned outages

and capture information in relation to the works. It is a functional tool for ensuring compliance with the

code in relation to planned outage requirements.

Power quality

Power quality: Power quality notifications are captured through PoF, before being actioned through

business as usual processes. CutlerMerz considers this to be a generally appropriate system for

managing power quality issues.



4

2 Audit Approach

We assessed Western Power’s compliance with the applicable Code requirements by undertaking the following:

A review of Western Power’s systems designed to meet the compliance requirements;

A review of Western Power’s systems designed to monitor compliance; and

Identifying any opportunities for improvement.

The full approach is summarised as follows (refer to the Audit Plan for further detail):

A risk-based approach to focus the audit on higher risk areas – based on Australian/New Zealand

Standard 31000:2009 (Risk Management – Principles and Guidelines);

Fieldwork to interview Western Power personnel at the head office and operational office. This helped

to gain an appreciation of the control environment, information systems, control procedures, compliance

attitude and outcome compliance;

Sampling procedures in accordance with ASA 500 and ASA 530 (Audit Sampling); and

Reporting in accordance with using the format prescribed in the Authority Guidelines (Guidelines

Section 11), ASAE 3000 and AEAE 3500.

2.1 Audit scope

The scope of the audit covers the systems in place at Western Power to monitor compliance against Part 2 of

the Code, which includes four divisions:

Division 1 - Quality Standards

Division 2 - Standards for the interruption of supply to individual customers

Division 3 - Standards for the duration of interruptions of supply in particular areas

Division 4 - Variations of obligations under this Part

2.2 Audit standard

The audit scope is based on the Audit Guidelines1. An audit plan was developed by the auditor based on the

requirements in the Audit Guidelines, a review of Part 2 of the Code and the auditors experience conducting

reviews and audits of the systems and procedures for monitoring quality and reliability of electricity network

businesses.

The audit report was subsequently reviewed and approved by Western Power.

2.3 Audit steps

The audit steps are summarised in Table 1.

1 Audit and Review Guidelines: Electricity and Gas Licences, April 2014, Economic Regulation Authority Western Australia



5

Table 1: Audit steps

Audit step Tasks

Planning Desktop review of policy and procedures

Prepare audit plan

Field audit

Control room visit Wednesday 20 August

Western Power office Thursday 21 August

Western Power office Friday 22 August

Off-site review and reporting Review supplementary documentation and prepare audit report

2.4 Audit team

The audit team is outlined in Table 2.

Table 2: Audit team

Name Role Responsibility

Ryan Dudley Audit Director and

Lead Auditor

Overall responsibility for the delivery of the audit and participation in field audits

Adam Homan Project Manager

and Auditor

Day-to-day management and delivery of the audit plan, field audits and audit report

2.5 Western Power key staff

The key Western Power staff that have participated in the audit are identified in Table 3.

Table 3: Western Power key staff

Title / Role Key Area(s) of Discussion

Network Operations – Network Operations Development Manager Planned and unplanned outage management

Network Operations – Quality and Compliance Officer Network Operations quality systems and documentation

Network Operations – Network Control Room Manager Planned and unplanned outage management

PowerOn Fusion

Network Operations – Compliance Business Analysts PowerOn Fusion

Customer Service – Complaints & Resolution Team Leader Customer service

Customer Service – Senior Process & Governance Analyst Customer service

Customer Service – Planned Outage Notification Team Leader Customer service

Planned outage management

Customer Service – Access Solutions Manager Customer agreements

Instruments from the Minister

Information & Communications Technology – Senior Information

Consultant

IT systems (including PowerOn Fusion, Data Warehouse, and

Network Reliability Data Validator)

Network Planning – Senior Asset Strategy Engineer Data processing and reporting



6

Title / Role Key Area(s) of Discussion

Network Reliability Data Validator

Works Program and Planning – Scheduling Manager Planned outage management

Works Program Planning – Scheduling & Coordination Team

Leader Planned outage management

Works Program Planning – Outage Coordination & Compliance

Project Support Officer Planned outage management

Strategic Network Planning – Network Planning & Standards Network design to achieve compliance

Remediation of poor performing network elements

Network Planning – Senior Planning Engineer Network design to achieve compliance

Remediation of poor performing network elements

Network Planning – Senior Asset Strategy Engineer Power quality management

Asset Operations, Operational Maintenance – Senior Technical

Officer

Field implementation of power quality investigations

Field implementation of mobile generators (for both planned and

unplanned outages)

Regulatory Compliance – Senior Compliance Specialist General reporting and compliance issues

2.6 Audit grades

The evaluation of compliance was undertaken by adapting the compliance grades outlined in the Audit

Guidelines to assess the adequacy of controls rating only. This is shown in Table 4.

Table 4: Audit compliance ratings

Performance audit compliance and controls rating scales (adapted from ERA Audit Guidelines)

Adequacy of Controls (Process and Systems) Rating

Rating Description

A Adequate controls – no improvement needed

B Generally adequate controls – improvement needed

C Inadequate controls – significant improvement required

D No controls evident



7

3 Western Power’s response to previous recommendations

The systems and procedures to ensure compliance against Part 2 of the Code were previously audited by

Deloitte for the 2014-15 period. There were no recommendations made as a result of this audit.



8

4 Performance summary

Table 5 summarises the compliance rating for each Code related licence condition using the rating scale

described in Section 2.6.

As required by the Audit Guidelines, the primary objective of the audit ratings is to provide an independent

assessment of Western Power’s adequacy of controls for monitoring compliance to the Code licence conditions.

The observations supporting the ratings in Table 5 are discussed in Section 5 while the detailed findings for

each licence condition and additional information on the rationale for each of the ratings can be found in

Appendix A.

Table 5: Audit ratings

Compliance

Obligation

Reference No. Licence Reference

Audit

Priority

applied

Adequacy of

Controls Rating

A B C D

462 Electricity Industry (Network Quality and Reliability of Supply) Code 2005 clause 5(1)

A distributor or transmitter must, as far as reasonably practicable, ensure that electricity

supply to a customer’s electrical installations complies with prescribed standards.

4

463 Electricity Industry (Network Quality and Reliability of Supply) Code 2005 clause 8

A distributor or transmitter must, so far as reasonably practicable, disconnect the supply

of electricity to installations or property in specified circumstances, unless it is in the

interest of the customer to maintain the supply.

4

464 Electricity Industry (Network Quality and Reliability of Supply) Code 2005 clause 9

A distributor or transmitter must, as far as reasonably practicable, ensure that the supply

of electricity is maintained and the occurrence and duration of interruptions is kept to a

minimum.

5


A distributor or transmitter must, so far as reasonably practicable, reduce the effect of

any interruption on a customer.

4


A distributor or transmitter must consider whether, in specified circumstances, it should

supply electricity by alternative means to a customer who will be affected by a proposed

interruption.

4


A distributor must take prescribed action in the event of a significant interruption to a

small use customer.

5


A distributor or transmitter must, so far as reasonably practicable, ensure that customers

in specified areas do not have average total lengths of interruptions of supply greater

than specified durations.

4



9

Compliance

Obligation

Reference No. Licence Reference

Audit

Priority

applied

Adequacy of

Controls Rating

A B C D


The average total length of interruptions of supply is to be calculated using the specified

method.

5


A distributor or transmitter must, on request, provide to an affected customer a free copy

of an instrument issued by the Minister and of any notice given under section 14(7) of the

Electricity Industry (Network Quality and Reliability of Supply) Code 2005.

5


A distributor or transmitter that agrees with a customer to exclude or modify certain

provisions must set out the advantages and disadvantages to the customer of doing so in

their agreement.

3



10

5 Observations

All Western Power personnel that participated in the audit process demonstrated an understanding of the Code

and its requirements, and a commitment to effective management of power quality and network reliability by the

business.

Overall, we consider Western Power’s systems in relation to Part 2 of the Code to be adequate. The systems in

effect are generally consistent with those effected by peer businesses, and we have observed some peers with

less robust systems in place.

Notwithstanding the above, we observe that leading peers tend to have a sharper focus on ensuring their

specific requirements are achieved; in terms of the specific requirements being embedded throughout strategic,

tactical and day-to-day decision marking criteria. Based on observations, we consider that there are likely to be

three factors contributing to this, which are linked to the mechanisms of Western Power’s regulatory regime

rather than system capability:

1) The inclusion of extreme weather events in the reporting of reliability metrics has the effect of reducing

emphasis on achieving the requirements, where:

Reporting substantial breaches on an ongoing basis creates an environment where it is acceptable

that breaches are unavoidable; and

The distortion of the metrics by these events masks the underlying performance, which in turn may

reduce focus on monitoring, tracking and remediating these sections of the network.

2) We understand that it is not a requirement for Western Power to be audited on compliance against the

specific performance targets, including a validation of the figures that are captured and reported. We

understand that this audit, which focuses on the operation of the systems that are in place to monitor

compliance, is the only audit required in relation to power quality and reliability. We have observed an

iterative effect within peers that are audited for compliance (including a data accuracy validation

component), where focus on the requirements is continually sharpened.

3) Western Power also has reliability targets prescribed under its access arrangements (Service Standard

Benchmarks – SSB), which are different from those required under the Code. The SSBs are linked to a

performance incentive scheme that has positive/negative financial outcomes. Whilst Western Power’s

documentation considers both the requirements of the Code and the SSBs, we consider that focus will

naturally be sharper on achieving the SSBs which are linked to financial incentives.

In Section 6 it is recommended that a process be implemented to ensure relevant factors are duly considered in

determining the circumstances for when mobile generation should be deployed for a planned outage. The three

factors above are likely to have contributed to this process not presently being in effect.

Our observations in relation to the above are as follows (refer to detailed findings on Clause 10(2) in Appendix

A):

The ENAR system requires the originator of the outage request to consider whether mobile

generation is required (in the ENAR guide2 this is in the form of a prompt for a yes/no answer).

However, it does not appear to provide any further guidance on when a mobile generator would be

required. CutlerMerz has not observed a procedural document relating to the use of mobile

generators during planned outages.

2 DM#33995956



11

CutlerMerz has reviewed a sample planned interruption form3 for an outage affecting a life support

equipment (LSE) customer. This outage affected 117 customers over a period from 7am to 4:30pm

(9.5 hours). For this outage the ENAR requestor had answer “no” to the “Generators required?”

prompt and it does not appear that a mobile generator was used for this outage.

Western Power’s scheduling team has advised that they do consider using mobile generators under

the circumstances specified by the Code; however, CutlerMerz has not observed a procedure to

support this practice.

In relation to Clause 15(2), it is noted that Western Power has not entered into any agreements with customers

in relation to where the “prescribed standards” are not met. It may be considered appropriate under the Code for

Western Power to enter into agreements with customers based on the substantial number of breaches being

reported on an ongoing basis. However, in our view, it would be more appropriate to amend the relevant

clauses of the code to exclude extreme weather events. We consider that it would be impractical for Western

Power to enter into an agreement with each customer that may be subject to extreme weather events.

The detailed findings of the audit in relation to each obligation are provided in Appendix A.

3 DM#9431078



12

6 Recommendations

The recommendations from the audit are provided in Table 6.

Table 6: Audit recommendations

Table of Current Audit Non Compliances / Recommendations

A. Resolved during current Audit period

Manual

Ref.

Non Compliance / Controls improvement

(Rating / Legislative Obligation / Details of

Non Compliance or inadequacy of controls)

Date Resolved (&

management action taken) Auditors comments

N/A – there were no non-compliances / recommendations from previous audit (and hence, none that were required to be resolved during the

current audit period).

A. Unresolved at end of current Audit period

Reference

(no. /

year)

Non Compliance / Controls improvement

(Rating / Legislative Obligation / Details of

Non Compliance or inadequacy of controls)

Auditors’ recommendation

Management action

taken by end of audit

period

01/2016 Rating: B

Legislative Obligation: Electricity Industry (Network

Quality and Reliability of Supply) Code 2005 clause 10(2) –

A distributor or transmitter must consider whether, in

specified circumstances, it should supply electricity by

alternative means to a customer who will be affected by a

proposed interruption.

Details of inadequacy of controls: Whilst Western

Power’s ENAR system prompts the planned outage

requestor to state whether or not mobile

generation is required for a planned outage, there

does not appear to be procedural guidance, based

on the requirements of the Code, as to when these

should be deployed. It is noted that Western

Power’s scheduling team has advised that they do

consider using mobile generators under the

circumstances specified by the Code; however,

CutlerMerz has not observed a procedure to

support this practice. CutlerMerz has observed an

outage example of planned outage documentation

where the use of mobile generation may have been

considered appropriate based on the Code; but the

ENAR requestor did not request mobile generation

and it did not appear to be deployed in this

instance.

It is recommended that Western

Power introduce a process to ensure

that the use of alternate power

supplies is considered for planned

outages, in view of the specific

circumstances identified in the Code.

Western Power will review, and

if required improve, its current

processes relating to the use of

alternative power supply for

planned outages in

circumstances identified in

clause 10(2) of the Code.

Due date: 31 December 2016



13

Appendix A Detailed findings

The detailed findings from the audit are provided in Table 7.

Table 7: Detailed findings

NQRS Code, Part 2: Division #

Compliance Obligation and Context Findings

An outline of the criteria for compliance Discussion of the evidence and how the compliance assessment was determined i.e. whether the evidence was sufficient to

demonstrate compliance or not.

Recommendations / Opportunities for Improvement are identified where relevant

Division 1 Compliance obligation reference No: 462

Clause: Electricity Industry (Network Quality and Reliability

of Supply) Code 2005 clause 5(1)

Obligation: A distributor or transmitter must, as far as

reasonably practicable, ensure that electricity supply to a

customer’s electrical installations complies with prescribed

standards.

Context: The “prescribed standards” relates to the

standards for harmonics and voltage fluctuation – refer to

Code 2005, Part 2, Division 1, Clause 6(2) and Clause 7.

CutlerMerz has interviewed personnel responsible for power quality at Western Power, and reviewed relevant information as

appropriate. Based on this consultation, CutlerMerz considers that Western Power has a number of systems, processes and

mechanisms in place to practicably ensure compliance with the standards for harmonics and voltage fluctuations. These relate

to:

The design of the system and connections to the network;

Proactive monitoring of power quality performance; and

Reactive actions where Western Power becomes aware of a power quality issue.

Findings in relation to each of the above are discussed below.

System design

It is understood that Western Power designs its system in accordance with the Australian standards for Electromagnetic

Compatibility (EMC)4. CutlerMerz has reviewed the standards and found them to be effectively consistent with the

requirements of the Code in relation to both harmonics and voltage fluctuation.

4 Standards Australia / Standards New Zealand, Technical Report – Electromagnetic compatibility (EMC) – Part 3.14: Limits–Assessment of emission limits for harmonics, interharmonics, voltage fluctuations and unbalance for the

connection of disturbing installations to LV power systems, SA/SNZ TR IEC 61000.3.14:2013, EC/TR 61000-3-14, Ed.1.0 (2011)



14



CutlerMerz has reviewed the generator connection process5 and confirms that this requires a power quality assessment as

part of the preliminary assessment phase and a review of power quality commissioning results during the commissioning

phase. CutlerMerz understands that the assessments / reviews are based on the requirements of the standards.

Based on design and commissioning in accordance with the aforementioned standards, it can be expected that the system

will meet the power quality requirements of the Code upon the commissioning of assets. However, it is noted that power

quality issues arise due to equipment that customers connect to the network (often post-commissioning) – Western

Power’s mechanisms for proactive monitoring of power quality and reactive action are discussed below.

Proactive monitoring:

CutlerMerz considers that proactive monitoring of power quality at all customer connections would not be practical based

on the current metering technology employed within the network. This view is supported by the University of Wollongong

which undertook a National Long Term Power Quality Survey in 2013/14 in conjunction with Power Quality Australia.

Western Power participated in this survey and reviewed the resultant report6. CutlerMerz understands that based on the

survey it was recommended that approximately 350 power quality meters distributed throughout Western Power’s

network would statistically provide a 95% confidence of power quality readings across the network.

It is understood that prior to the 2013-17 regulatory period Western Power had approximately 100 power quality meters

installed on its network. These were capable of monitoring harmonic distortion only. CutlerMerz has reviewed Western

Power’s approved business case7 to install an additional 260 meters throughout the network. It is understood that the new

meters are capable of monitoring both harmonics and voltage fluctuation. It is understood that the 100 (harmonics only)

plus 260 (harmonics plus voltage fluctuation) meters are consistent with the survey outcomes and will provide 95%

confidence level for both harmonics and voltage fluctuation across the network.

CutlerMerz understands that Western Power downloads and analyses the data from the power quality meters once

annually to proactively monitor power quality across the network. It is understood that these reviews are undertaken to

assess compliance with the standards. In addition, Western Power reactively investigates individual power quality cases

where identified by field staff or through customer notification – Western Power’s mechanisms for reactive actions to

address power quality issues are discussed below.

5 DM#11874479 6 PQ Australia and University of Wollongong, National Long Term PQ Survey 2013/14 Participant Results, Western Power 7 DM#8880863



15



Reactive action:

CutlerMerz understands that Western Power has two primary mechanisms for “reactively” identifying power quality issues:

customer notification and when incidentally encountered by operational personnel.

CutlerMerz has reviewed Western Power’s process8 and investigations manual9 for addressing power quality issues that

have been identified. These appear reasonable to ensure that power quality issues that have been identified will be

addressed.

Finding: CutlerMerz considers that Western Power’s systems, processes and mechanisms can be expected to, as far as

reasonably practicable, ensure that electricity supply to a customer’s electrical installations complies with prescribed standards

for power quality.

Compliance obligation reference No: 463


of Supply) Code 2005 clause 8

Obligation: A distributor or transmitter must, so far as

reasonably practicable, disconnect the supply of electricity

to installations or property in specified circumstances,

unless it is in the interest of the customer to maintain the

supply.

Context: The “specified circumstances” are when

compliance with the standards for harmonics and voltage

fluctuation (refer to Code 2005, Part 2, Division 1, Clause

6(2) and Clause 7) cannot be achieved, and this may result

CutlerMerz has interviewed personnel responsible for power quality at Western Power, and reviewed relevant information as

appropriate. The power quality investigation process8 which identifies decision points for customers to be disconnected if:

Harmonics or voltage fluctuation are present that will “damage customer equipment” and the customer agrees with the

disconnection; and

If harmonics or voltage fluctuation are present that will “damage customer equipment” and the customer does not agree

with the disconnection, to disconnect “if there is a safety risk”.

Western Power has advised that during the auditable period there were no disconnections related to harmonics or flicker.

Finding: CutlerMerz considers that Western Power’s systems, processes and mechanisms can be expected to, so far as

reasonably practicable, disconnect the supply of electricity to installations or property in specified circumstances, unless it is in

the interest of the customer to maintain the supply.

8 DM#1165772 9 DM#3494210



16



in damage to a customer’s electrical installations or

property.



of Supply) Code 2005 clause 9

Obligation: A distributor or transmitter must, as far as

reasonably practicable, ensure that the supply of electricity

is maintained and the occurrence and duration of

interruptions is kept to a minimum.

CutlerMerz has interviewed personnel responsible for reliability at Western Power, and reviewed relevant information as


mechanisms in place to practicably ensure that the supply of electricity is maintained and the occurrence and duration of

interruptions is kept to a minimum. These relate to:

Network planning;

Planned works management; and

Unplanned outage management.


Network planning:

CutlerMerz understands that Western Power designs its network in accordance with the Technical Rules prescribed by the

ERA and available on their website. In addition, CutlerMerz has reviewed relevant planning documents such as the planning

guidelines and asset strategy documents.

CutlerMerz understands that Western Power considers reliability as a key factor in prioritisation of maintenance

programmes and defect remediation.

CutlerMerz understands that Western Power has a process for reviewing network sections with poor reliability. The

Network Performance Reliability Strategy document describes how network elements are ranked based on frequency and

duration of interruptions for categories where Western Power exceeds the overall network SSBs (rural), and the worst

performing elements are considered for remedial action.

CutlerMerz considers the network planning processes outlined above to be broadly consistent with Western Powers peers,

and give due consideration to ensuring that the network is designed to minimise the occurrence and duration of

interruptions to customers.

Planned works management:



17



CutlerMerz understands that Western Power’s processes for implementing planned works consider approaches to minimise

the frequency and duration of outages experienced by customers.

CutlerMerz understands that the works scheduling team has visibility of the annual planned works programme. The

scheduling and dispatch process10 requires that both internal and external works are bundled into a consolidated schedule

within the Works Scheduling Management Systems to minimise the impact to customers.

CutlerMerz has reviewed the use of the Electronic Network Access Request (ENAR) user guide, and samples of ENAR forms

and has observed processes for the use of mobile generators to minimise outages to customers (i.e. completed ENAR form).

CutlerMerz has not observed a procedural document relating to the use of mobile generators during planned outages.

CutlerMerz has observed the identification of outage areas though the ENAR system and resultant switching schedules and

observed that Western Power has processes to ensure that outages to enable planned works are confined to network areas

to minimise the number of customers affected.

Unplanned outage management:

CutlerMerz understands that Western Power has several processes in place to minimise the duration and number of

customers affected during an unplanned outage. These relate to both control room procedures and procedures for field

personnel.

It is noted that whilst field personnel make decisions on the ground regarding how to repair the network following a fault,

access to the network and all switching operations (both those performed remotely from the control room and those

performed by field switching operators) are executed under direction from the control room operator. CutlerMerz has

reviewed the procedures for fault restoration11 and priority restoration guideline12. These documents demonstrate that

Western Power has processes in place to prudently restore power in a way that minimises the duration and number of

customers affected.

CutlerMerz understands that Western Power uses a “priority response” approach for unplanned outage management in the

field, which is aimed to make the network safe and restore power as soon as possible, and leaving major repair works to be

10 High Level In-depth S&D Work Flow Process 11 DM#1530872 12 DM#8482502



18



scheduled for regular maintenance crews. CutlerMerz has reviewed the dispatch procedures13 which demonstrates the

priority dispatch process.

CutlerMerz understands that Western Power uses mobile generators during unplanned outages to minimise the outage

duration and customers affected. CutlerMerz has reviewed Western Power’s procedural document14 which details the

process for the deployment of generators during unplanned outages.


reasonably practicable, ensure that the supply of electricity is maintained and the occurrence and duration of interruptions is

kept to a minimum.





reasonably practicable, reduce the effect of any

interruption on a customer.



mechanisms in place to practicably reduce the effect of any interruption on a customer. These relate to:

Reducing the frequency and duration of outages in general;

Communication with customers in relation to outages; and

Special consideration and prioritisation of customers likely to be most affected by an outage.


General measures for reducing the frequency and duration of outages:

Refer to discussion in relation to clause 9 above.

Customer communication:

CutlerMerz understands that Western Power has two primary mechanisms for communicating planned outages with customers

– posting letters in the mail and card drops. CutlerMerz has reviewed the process for notifying customers for planned outages15

13 DM#1531117 14 DM#2123938 15 DM#8224570



19



which details the process. It is noted that through this process the identification of customers to be notified relies on PowerOn

Fusion (PoF) and the ENAR systems (refer to Section 2).

Customers likely to be most affected:

Western Power places increased effort on manging customers who are likely to be more adversely affected, or where an

outage these to these customers will adversely affect the community more broadly. These customers include:

Life support equipment (LSE) customers;

Utilities and essential services (e.g. Main Roads, traffic lights); and

Sensitive load customers (e.g. hospitals).

CutlerMerz has reviewed the procedural documents for customer notifications15, fault restoration11, the priority restoration

guideline12, the priority dispatch procedures13, and procedures for the deployment of generators during unplanned outages14 –

these procedures all give consideration to “sensitive” customers in some capacity.


reasonably practicable, reduce the effect of any interruption on a customer.




Obligation: A distributor or transmitter must consider

whether, in specified circumstances, it should supply

electricity by alternative means to a customer who will be

affected by a proposed interruption.

CutlerMerz has interviewed personnel responsible for mobile generator dispatch at Western Power, and reviewed relevant

information as appropriate. Based on this consultation, CutlerMerz considers that Western Power has a number of systems,

processes and mechanisms in place to supply electricity by alternative means to a customer who will be affected by a proposed

interruption. These relate to:

Planned outages; and

Unplanned outages.


Planned outages:



20



Context: The “specified circumstances” are when:

The interruption is expected to exceed 6 hours, or 4

hours if forecast maximum temperatures are expected

to be greater than 30 degrees Celsius (as issued by the

Bureau of Meteorology in Perth);

The effect of the interruption on the customers’

business is likely to be substantial; or

The interruption will affect a person with life support

needs and requires electricity for the operation of

equipment that caters to those needs.

The ENAR system requires the originator of the outage request to consider whether mobile generation is required (in the ENAR

guide16 this is in the form of a prompt for a yes/no answer). However, it does not appear to provide any further guidance on

when a mobile generator would be required. CutlerMerz has not observed a procedural document relating to the use of mobile

generators during planned outages. CutlerMerz has reviewed a sample planned interruption form17 for an outage affecting a

life support equipment (LSE) customer. This outage affected 117 customers over a period from 7am to 4:30pm (9.5 hours). For

this outage the ENAR requestor had answer “no” to the Generators required?” prompt and it does not appear that a mobile

generator was used for this outage. Western Power’s scheduling team has advised that they do consider using mobile

generators under the circumstances specified by the Code; however, CutlerMerz has not observed a procedure to support this

practice.

Unplanned outages:

It is noted that the Code refers to “proposed interruption[s]”. Notwithstanding, Western Power’s process for the use of mobile

generators14 during unplanned outages outlines that mobile generation should be considered if the estimated “fix time” is less

than 6 hours.

Finding: Whilst Western Power’s ENAR system prompts the planned outage requestor to state whether or not mobile

generation is required for a planned outage, there does not appear to be procedural guidance, based on the requirements of

the Code, as to when these should be deployed. It is noted that Western Power’s scheduling team has advised that they do

consider using mobile generators under the circumstances specified by the Code; however, CutlerMerz has not observed a

procedure to support this practice. CutlerMerz has observed an outage example of planned outage documentation where the

use of mobile generation may have been considered appropriate based on the Code; but the ENAR requestor did not request

mobile generation and it did not appear to be deployed in this instance.





appropriate.

It is noted that Western Power has reported a substantial number of incidents where the “prescribed standards” have not been

met in previous years (for both outage duration and number of interruptions standards); and Western Power advises the same

outcome in 2015/16. It is understood that these cases are predominantly due to extreme weather events. CutlerMerz considers

16 DM#33995956 17 DM#9431078



21



Obligation: A distributor must take prescribed action in the

event of a significant interruption to a small use customer.

Context:

The “prescribed actions” are:

To remedy the cause or causes of the interruption so

that the prescribed standard is met; or

Enter into an agreement to the small use customer’s

satisfaction for the supply of electricity to the

customer.

The “prescribed standard” is the supply of electricity for 9

years in every 10 without the interruption of supply

exceeding:

An interruption of more than 12 hours continuously; or

9 interruptions in Perth CBD and urban areas, or 16 in

other areas (in the preceding year).

The definition of “significant interruption” is not meeting

the prescribed standard.

it impractical for Western Power to meet the prescribed standards during extreme weather events. It is noted that in other

Australian jurisdictions such events would be excluded, which would allow the underlying performance to be monitored. In

CutlerMerz’ view, it would be appropriate to amend this clause of the code to exclude extreme weather events.

Notwithstanding the above, it is understood that Western Power has a process for reviewing poor performing sections of the

network (referred to as “hot spots”). CutlerMerz has reviewed Western Power’s Network Reliability Performance Strategy18,

which details how Western Power considers both its Service Standard Benchmarks (SSB) applicable under its Access

Arrangement, and the requirements of the Code; the strategy then forms a considered position on remediating “hot spots”.

Western Power has advised that they have not entered into any agreements with small use customers in relation to providing

lower than the prescribed standards.

Finding: CutlerMerz notes that Western Power consistently reports a substantial number of incidents where the “prescribed

standards” are not met. This appears to be predominantly due to extreme weather events. In CutlerMerz’ view, it would be

appropriate to amend this clause of the code to exclude extreme weather events. It is also noted that Western Power has not

entered into any agreements with small use customers in relation to providing lower than the prescribed standards; further to

the above, CutlerMerz considers that it would be impractical for Western Power to enter into an agreement with each

customer that may be subject to extreme weather events.

Notwithstanding the above, CutlerMerz considers that Western Power’s systems, processes and mechanisms can be expected

to, so far as reasonably practicable, remedy sections of the network with poor reliability.





appropriate. The findings on Western Power’s processes and systems to ensure compliance with reliability obligations are

detailed within the findings relating to Division 2. It is noted that Western Power’s network planning and outage management

processes consistently consider risk factors in terms of reliability and customers affected, which naturally leads to greater focus

on reducing higher density areas i.e. Perth CBD, then other areas, then the remainder of the network (assuming greater

18 DM#12596515



22




reasonably practicable, ensure that customers in specified

areas do not have average total lengths of interruptions of

supply greater than specified durations.

Context:

The overall “specified durations” are:

Perth CBD: 30 minutes

Urban (other than Perth CBD): 160 minutes

Other areas: 290 minutes

number of customers per feeder in higher density areas). The SSBs also drive focus in this area. Further, Western Power’s

Network Reliability Performance Strategy18 details how Western Power considers both its Service Standard Benchmarks (SSB)

applicable under its Access Arrangement, and the requirements of the Code; the strategy then forms a considered position on

remediating “hot spots”.

As per Division 2 - clause 12(3), CutlerMerz notes that the Code does not allow for the exclusion of extreme weather events,

which is understood to have resulted in Western Power not meeting its overall targets. Again, CutlerMerz considers that this is

due to impracticality of the Code (i.e. in not excluding extreme weather events) rather than due to inappropriateness of

Western Power’s processes and systems.

Finding: As per Division 2 - clause 12(3), CutlerMerz notes that Western Power consistently reports not meeting the “specified

durations”. This appears to be predominantly due to extreme weather events. Again, CutlerMerz’ considers it would be

appropriate to amend this clause of the Code to exclude extreme weather events.

Notwithstanding the above, CutlerMerz considers that Western Power’s systems, processes and mechanisms can be expected

to, ensure that customers in specified areas do not have average total lengths of interruptions of supply greater than specified

durations.




Obligation: The average total length of interruptions of

supply is to be calculated using the specified method.

Context:

The overall “specified method” is to be calculated as at 30

June in each year:

by taking the average total length, in minutes, of

interruptions of supply to customer premises in an area

CutlerMerz has interviewed personnel responsible for reliability systems and calculations at Western Power, and reviewed

relevant information as appropriate.

Western Power calculates the average total length of interruptions using its Network Reliability Data Validator (NRDV) system.

The NRDV system is configured to run Structured Query Language (SQL) to interrogate the Data Warehouse (which captures

and stores reliability data generated by PowerOn Fusion). CutlerMerz has observed the queries being run in NRDV to produce

the reliability calculations and considers this to be an appropriate system to generate the required reports. It should be noted

that CutlerMerz has not reviewed the SQL coding or attempted to reproduce the calculations to verify their accuracy.


reasonably practicable, calculate the average total length of interruptions using the specified method.



23



during each year of the period of 4 years ending on that

day; and

by then taking the average of the 4 annual figures

determined above.




Obligation: A distributor or transmitter must, on request,

provide to an affected customer a free copy of an

instrument issued by the Minister and of any notice given

under section 14(7) of the Electricity Industry (Network

Quality and Reliability of Supply) Code 2005.

Context:

If, having regard to the advice of the Authority, the

Minister is satisfied that it is appropriate to do so, the

Minister may by “Instrument”:

Exempt the transmitter or distributor from compliance

with the provision concerned; and

Attach to the exemption a condition that another

provision, in place of the provision for which an

exemption is granted, is to be complied with by the

transmitter or distributor in the supply of electricity.

CutlerMerz has interviewed personnel responsible for customer services at Western Power, and reviewed relevant information

as appropriate.

Western Power has advised that no “instruments” have been issued by the Minister during the audit period, and nor are there

any previously issued instruments that are applicable within the audit period.

Interaction with the Minister is through Western Power’s Government Relations division, and interactions with customers is

through Western Power’s Customer Services division. CutlerMerz considers that this would be an appropriate structure to

provide to an affected customer a free copy of an instrument issued by the Minister (should the Minister issue a notice in

future and a customer then request a copy of the instrument.


reasonably practicable, provide to an affected customer a free copy of an instrument issued by the Minister upon request.



24



“Section 14(7)”- The Minister may at any time, after

obtaining the advice of the Authority, by notice in writing

to the transmitter or distributor revoke or vary an

instrument above including by imposing any further

condition to be complied with by the transmitter or

distributor.




Obligation: A distributor or transmitter that agrees with a

customer to exclude or modify certain provisions must set

out the advantages and disadvantages to the customer of

doing so in their agreement.

CutlerMerz has interviewed personnel responsible for customer services at Western Power, and reviewed relevant information

as appropriate.

Western Power has advised that no “agreements” are in place with customers to exclude or modify certain provisions of Part 2

of the Code. As noted in relation to Division 2 – clause 12(3), Western Power consistently reports a substantial number of

incidents where the “prescribed standards” are not met (which appears to be predominantly due to extreme weather events).

Finding: It may be considered appropriate under the Code for Western Power to enter into agreements with customers where

the “prescribed standards” are not met. However, in CutlerMerz’ view, it would be more appropriate to amend the relevant

clauses of the code to exclude extreme weather events. CutlerMerz considers that it would be impractical for Western Power

to enter into an agreement with each customer that may be subject to extreme weather events.



25

Appendix B Information provided

The information provided during the audit is provided in Table 8. It should be noted that Western Power also

responded directly via email and provided document hard-copies throughout the fieldwork – these items are not

included in Table 8.

Table 8: Information provided

Document name Reference No.

Annual Reliability and Power Quality Report – For

the period 1 July 2014 to 30 June 2015

DM#13019660

eNAR User Guideline DM#33995956

Dispatching Fault Jobs DM#1531117

Restoration of Feeders and Reclosers DM#1530872

Review of the Use of Emergency Response

Generators

DM#:12950187

Emergency Response Generators (LV) DM#2123938

Quality of Supply Resolution DM#1531190

Prioritising Network Restoration Guideline DM#8482502

Technical Report, Electromagnetic compatibility

(EMC), Part 3.14: Limits—Assessment of

emission limits for harmonics, interharmonics,

voltage fluctuations and unbalance for the

connection of disturbing installations to LV power

systems

SA/SNZ TR IEC 61000.3.14:2013

National Long Term PQ Survey 2013/2014

Participant Results, Western Power

PQ Australia, University of Wollongong

Power Quality Investigations Manual DMS#3494210

DRAFT*****PPG Connection Process. 0-10 MW

generators connected at 33kV or less, excluding

0-30kVA inverter and PV. Refers to full installed

capacity at one lot or connection point.****DRAFT

DM#11874479v1

Power Quality / TVI Complaint Handling Process

DMS#1165772 v5A

LV Power Quality Management – (AA3) 2012/13

to 2016/17

DM#8880863

Identification and Notification of Customers for

Planned Interruptions

DM:8224570 v37A

LSE Daily Audit – Archive 2015_09 Sept.xlsm Spreadsheet

Copy of Customer Assist - LSE Daily Audit

(9131948)_.xlsm

Spreadsheet

Copy of Notification Working Document_.xlsm Spreadsheet

Customer Service Planned Outage Audit &

Approval Procedure

DM#9847816



26

Document name Reference No.

Outage Coordination & Compliance Team

Checklist 5, 1 Day Prior to the Interruption – Final

checklist

eNAR Number: 279636

Access Offer Template No reference number

Electricity Transfer Access Contract (template) No reference number

Data Warehouse TCS Subject Area Data Flow

Chart

No reference number

ENMAc, SOAP Interface, SOAP Interface

Architecture

P118-01-01 v1.2

WR2667 – Reporting Strategy – ENMAC TCS No reference number

Conductor Clashing Mitigation Strategy DM#6034312

Summary Strategy for Mitigating Distribution

Overhead Conductor Clashing

DM#11829820

Distribution Automation Strategy DMS#3127544

Distribution Automation – Guideline #01, Recloser

Placement Strategies – Metro

No reference number

Rural Protection Settings Guidelines

For Feeder CB, Reclosers, Sectionalisers, and

Fuses

DMS# 1068147v5

Recloser Placement Formula No reference number

Network Reliability Performance – Strategy DM#12596515

Risk Based Renewal Methodology –

Distribution Overhead

No reference number

Distribution Network Planning Guidelines: An

Interpretation of the Technical Rules

DM#4880519

Transmission Planning Guidelines: Interpretation

of the Technical Rules

DM#8494654

High Level In-depth S&D Work Flow Process 13775228

Planned Interruption Form DM#9431078



27

Review of systems relating to Code Part 2, Divisions 1 to 4 … · Review of systems relating to...

Documents

Transcript of Review of systems relating to Code Part 2, Divisions 1 to 4 … · Review of systems relating to...