Westchester has been hit hard in the past two years by tropical storms, hurricanes, and superstorms. After each of these events, residents and elected officials have expressed dissatisfaction with power utilities’ response, communication, and preparation. But other than registering a complaint with Con Ed, there has been little chance for citizens to bring about positive change in advance of the next storm.

Last fall, Governor Cuomo established a commission under the Moreland Act to investigate power utilities throughout the state. Today that commission is holding a hearing at SUNY Purchase for the purpose of collecting testimony from residents of Westchester, Rockland, and Putnam counties.

Although Noam is not able to attend the hearing in person today, his experience as Mayor of New Rochelle during these recent storms compels him to offer written comments to the commission, which you can read below.

Submission to the Moreland Commission

Noam Bramson, Mayor of New Rochelle

January 24, 2013

I regret that I am unable to attend today’s hearing in person, but welcome this opportunity to submit testimony to the Moreland Commission.

Hurricane Sandy disrupted electrical service for approximately three-quarters of the residents of the City of New Rochelle, many of whom lacked power for ten days or more. While the unprecedented scale of the damage from Sandy would have posed a challenge to even the most robust emergency response process, the pace of repairs was clearly compromised by Con Edison’s inadequate initial deployment of field resources, chaotic command and control procedures, substandard coordination with municipal service providers, and poor provision of public information.

To improve the preparation for and efficient response to future storms, the following specific suggestions are offered for your consideration:

Determine Initial Field Resource Requirements: There is at present no objective, measurable standard of storm preparation for which Con Edison can be held accountable. Indeed, according to Con Edison, the initial deployment of field resources is typically calibrated to address routine repair needs, rather than sweeping emergency conditions. As a result, repair efforts are significantly constrained prior to the arrival of mutual aid crews. Con Edison must have a larger standing army at its disposal and/or a swifter means of calling up reserves, based on objective standards that are determined in advance by public authorities. The following is one possible standard: prior to the onset of a predicted storm event, Con Edison should have field resources prepared for action that are sufficient in quantity and capability to restore power to every critical institution within 48 hours after the conclusion of the storm event.

Pre-Define Critical Institutions: State or regional authorities, such as County OEMs, should promulgate uniform, consistent standards that define critical institutions, considering facilities such as schools, nursing homes, government centers, senior housing, essential infrastructure, etc. Each community should work in partnership with a State or regional authority to identify the critical institutions within its borders and prepare a comprehensive checklist, including addresses and any other necessary identifying information or special considerations. Copies of these community lists should be maintained in each municipal hall and EOC, at County OEMs, and at Con Edison. County OEMs should survey communities annually to determine whether any changes should be made.

Coordinate Efforts for Road Clearance: In addition to field resources aimed at restoring power for critical institutions, Con Edison should have municipal crews whose sole purpose is to assist Public Works Departments with the clearance of roads. During the initial period of storm response, perhaps 48 hours, such crews should be self-sufficient, with the capacity to remove trees and branches and to restore power, with specific locations chosen in concert with municipal leaders. After this initial response period, once obstructions of major roadways and intersections have been cleared, such full-service crews should be redeployed from road clearance to power restoration, but a cadre of individual Con Edison linemen should be assigned to accompany municipal DPW crews to certify that lines are dead, thereby allowing municipal crews to undertake any additional secondary and tertiary road clearance. The number of full-service crews available for this purpose prior to a storm event should be based on a uniform population or land area standard, determined in advance, with specific assignments subsequently determined by the scope and pattern of need.

Track Activities with Greater Consistency: Con Edison should implement procedures for informing municipal leaders of the locations and work assignments of all resources operating within their communities. At a minimum, there should be a morning briefing, email or bulletin outlining daily projects. Ideally, it should be possible for municipal leaders to track the whereabouts of crews in real time.

Provide Circuit Maps to Municipal Officials: Con Edison should prepare books of circuit maps for each community, including lines that straddle municipal boundaries, and provide copies of these maps to each municipality, as well as a full set for County OEMs. Alternatively, municipal leaders and County OEMs should be provided with web access to circuit maps.

Develop Written Power Restoration Protocols: Con Edison should prepare clear, straightforward written protocols that describe its general operating procedures, prioritization methods, and work standards. These written protocols should include, at a minimum, descriptions of: power restoration priorities; the division of labor between Con Edison and municipalities regarding such matters as downed trees and wires; system-wide resource allocation standards; and the method by which Con Edison tracks power outages. The protocols should be phrased and presented in a fashion suitable for distribution to the general public.

Provide Accurate Public Information: The written protocols referenced above should be posted prominently on Con Edison’s website and placed squarely in front of every customer service representative who accepts calls from the public. All site safety representatives should be provided with printed copies of these protocols and should reply to all public inquiries in the field by distributing this information.

In addition to advancing the foregoing operational improvements, it is my hope that you will also act to reform public oversight of utility companies, such as Con Edison, to ensure a greater level of accountability for performance prior to, during and after emergencies.

Before closing, let me note that Con Edison is fortunate to benefit from the work of many dedicated and capable professionals. My concerns relate to the performance of the organization as a whole, and should not be regarded as critical of specific individuals, many of whom demonstrated great dedication and competence during and after Hurricane Sandy.

Thank you for your consideration.