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direct testimony of the capital expenditures, reliability, and - nyseg

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Case 09-E-____; Case 09-G-____ (NYSEG)DIRECT TESTIMONY OF THE CAPITAL EXPENDITURES,RELIABILITY, AND OPERATIONS PANEL12345678910111213141516171819202122density <strong>and</strong> proximity to energized conductors that can be achieved with periodic,scheduled clearing, <strong>and</strong> <strong>the</strong> reduction in h<strong>and</strong>ling costs for <strong>the</strong> large trees removedduring <strong>the</strong> first cycle can mitigate <strong>the</strong> cost <strong>of</strong> subsequent clearing cycles. Fur<strong>the</strong>r,a comprehensive cycle program would allow for even more efficient planning <strong>and</strong>contracting <strong>of</strong> clearing work, reducing per-mile maintenance costs. Cyclical lineclearance also helps improve customer satisfaction. Customers are moreamenable to frequent cutting <strong>of</strong> small limbs <strong>and</strong> trees, <strong>and</strong> generally view this asacceptable. During <strong>the</strong> first cycle, however, customer satisfaction may beexpected to decrease as ROW is reclaimed. The incremental annual cost is $25.3million <strong>and</strong> <strong>the</strong> total annual cost for this program would be $36.19 million.Q. Has <strong>the</strong> Company utilized a partial clearing cycle in <strong>the</strong> past?A. Yes. Distribution line clearance has been funded to achieve established <strong>reliability</strong>targets. This has resulted in <strong>the</strong> implementation <strong>of</strong> a partial clearing cycle.Transition to a full cycle clearing program has multiple benefits as described in<strong>the</strong> previous response.Q. Is <strong>the</strong> Company proposing a change in accounting treatment?A. Yes. The cost to perform full cycle distribution line clearance is significantlygreater than <strong>the</strong> present spend. Additionally, costs for line clearance can varybased on market conditions <strong>and</strong> <strong>the</strong> expected volume <strong>of</strong> work per mile. TheCompany proposes that costs to achieve full cycle distribution line clearance bereconciled as part <strong>of</strong> <strong>the</strong> deferral recovery mechanism surcharge or surcreditmechanism that is discussed in detail by <strong>the</strong> Revenue Requirements Panel.55

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