Entergy Services, Inc. ~Entergy

• Entergy Services, Inc. 639 Loyola Avenue 70113-3125 P.O. Box 61000 New Orleans, LA 70161-1000~Entergy Tel 5045766571 Fax 5045765579

Timothy S. Cragin Assislant General Counsel Legal Services - Regulatory

February 28,2014

Via Hand Delivery Honorable Lora W. Jolmson Assistant Clerk of Council Council of the City of New Orleans City Hall, Room 1E09 1300 Perdido Street New Orleans, Louisiana 70112

Re: Entergy New Orleans Inc. Application for Certification ofCosts Related to Hurricane Isaac, andfor Related Relief (CNO Docket No. UD-14- )

Dear Ms. Jolmson:

On behalf of Entergy New Orleans, Inc. ("ENO") please fmd enclosed the original and three copies of Entergy New Orleans, Inc.'s Application for Certification of Costs Related to Hurricane Isaac, and for Related Relief The application ofENO includes the direct testimony of Charles L. Rice, Jr,; Dennis P. Dawsey; Orlando Todd; and Michael A. Herman. Please retain the original and two copies for your files and return a date-stamped copy to our by-hand courier.

Thank you for your assistance with this matter.

Sincerely,

Enclosure cc: Council Members (via electronic mail)

Official Service List UD-12-04 (via electronic mail)

BEFORE THE

COUNCIL OF THE CITY OF NEW ORLEANS

APPLICATION OF ENTERGY NEW ORLEANS, INC. FOR CERTIFICATION OF COSTS RELATED TO HURRICANE ISAAC, AND FOR RELATED RELIEF

) ) ) ) )

DOCKET NO. UD-14-________

APPLICATION OF ENTERGY NEW ORLEANS, INC. FOR CERTIFICATION OF COSTS RELATED TO

HURRICANE ISAAC, AND FOR RELATED RELIEF

Entergy New Orleans, Inc. (“ENO” or the “Company”) respectfully submits this

Application requesting, among other things, that the Council of the City of New Orleans (“CNO”

or the “Council”) certify the costs incurred by the Company to restore its facilities following

Hurricane Isaac as eligible for recovery from its customers.

The Company incurred $47.3 million of Hurricane Isaac storm recovery costs through

December 31, 2013, before adding carrying costs (“Total Storm Recovery Costs”).1 To date,

ENO has withdrawn a total of $17.4 million from the storm reserve escrow account (“Storm

Reserve”). Thus, $29.9 million of Total Storm Recovery Costs, before adding carrying costs,

remains unrecovered.

Through this proceeding, ENO requests entry of a Council order: (1) determining that the

entire amount of ENO’s Total Storm Recovery Costs, $47.3 million, was reasonable and

necessary to rebuild ENO’s electric infrastructure and to restore power to its customers; (2)

certifying ENO’s Total Storm Recovery Costs as eligible for recovery; and (3) authorizing the

Company to recover carrying costs on approved storm recovery costs.

1 Various numbers presented throughout this Application may not sum to totals due to rounding.

2

At an appropriate time following this Application, after working with the Council

Advisors, the Company will request a specific cost-recovery mechanism to recover its remaining

costs not already recovered through the Storm Reserve.

I. EXECUTIVE SUMMARY

Hurricane Isaac was the fourth most destructive hurricane in the Entergy System’s2

history in terms of peak customer outages, exceeded only by Hurricanes Katrina, Rita, and

Gustav. As detailed in both this Application and in the Hurricane Isaac Report filed in Docket

No. UD-12-04, the storm was powerful and brought unprecedented challenges to ENO and its

customers.

On August 28, 2012, Hurricane Isaac made the first of two Louisiana landfalls in

Plaquemines Parish, Louisiana, as a Category 1 hurricane with 80 mph winds. The storm then

re-entered the Gulf of Mexico and made a second landfall near Port Fourchon, Louisiana, on

August 29, 2012. Hurricane Isaac’s tropical-storm-force winds extended roughly 185 nautical

miles from the center in its northeastern quadrant; and hurricane-force winds extended roughly

60 miles from center of the same quadrant. The storm lingered over Louisiana, subjecting the

greater New Orleans area to significant rainfall and tropical-storm-force winds for 54 hours,

which was twice the duration of prior major hurricanes.

Although Hurricane Isaac was a Category 1 hurricane, the storm’s size, slow movement,

and unusual storm track caused an abnormally long duration of tropical-force winds that resulted

in extensive damage to ENO’s distribution and transmission facilities, as well as some damage to

2 The six Entergy Operating Companies (“EOCs”) are Entergy Arkansas, Inc. (“EAI”), Entergy Louisiana, LLC (“ELL”), Entergy Gulf States Louisiana, L.L.C. (“EGSL”), Entergy Mississippi, Inc. (“EMI”), Entergy Texas, Inc. (“ETI”), and ENO. The electric generating resources and bulk transmission facilities of ENO, ELL, EGSL, ETI and EMI are currently operated pursuant to the System Agreement on a single, integrated basis and are referred to collectively as the “Entergy System” or the “System.” In December 2013, EAI terminated its participation in the Entergy System Agreement and currently operates independently of the remaining System Agreement EOCs.

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the Entergy System’s production resources. The storm caused widespread customer outages in

New Orleans, as well as in other areas across Louisiana served by the EOCs. At the peak of

outages in Louisiana, approximately 59% of the combined 1.2 million customers in the

Louisiana EOCs’ service areas were without service, including 163,632 customers in New

Orleans.3

Working with the other EOCs, mutual-assistance utilities and outside contractors, ENO

expended extraordinary efforts to restore service to its customers and to rebuild its electric utility

infrastructure as safely and quickly as possible. Despite the many challenges presented by the

storm, ENO restored service to more than 95% of its customers within five days of the time that

full restoration activities could safely begin, making the Hurricane Isaac restoration the fastest of

all recent major storm restorations affecting the Entergy System.

In this Application, ENO is requesting that the Council certify its Total Storm Recovery

Costs as reasonable, necessary, and recoverable. At a later date, the Company will propose a

specific cost-recovery mechanism regarding the unrecovered costs certified through this

Application, and such subsequent proposal may include a request for alternative financing. The

Company will continue to consult with the Council Advisors to select an economically viable

cost-recovery mechanism.

A. Summary of Storm Recovery Costs

As noted above, ENO is requesting that this Council certify its Total Storm Recovery

Costs, $47.3 million, before adding carrying costs, as reasonable, necessary, and recoverable.

After excluding the $17.4 million already withdrawn from the Storm Reserve for Hurricane Isaac

recovery, $29.9 million of ENO’s Total Storm Recovery Costs remains unrecovered from its

3 This figure includes ELL outages on the Westbank of New Orleans in Algiers.

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customers. Of ENO’s Total Storm Recovery Costs of $47.3 million, $29.7 million are capital

expenditures (e.g., replacement of poles and wires), and approximately $17.6 million are non-

capital costs or deferred operations and maintenance (“Deferred O&M”) costs that have been, or

will be, charged to the Storm Reserve.

At a summary level, the Company presents its storm recovery costs both by “class” of

cost and by “category” of cost. As described in this Application and supporting testimony, a

class of cost is a distinct operational or functional grouping. The four cost classes are

Production, Transmission, Distribution, and Other. A “category” of cost is a subset grouping

that shows the types of activities or services that would be common to each of the classes. The

cost categories are: Contract Work, Employee Expense, Labor, Materials, Other, and

Transportation. The following table shows ENO’s storm recovery costs, by class and category:

Description Distribution Transmission Production Other Total Contract Work 35,235,039 221,903 61,055 488,547 36,006,544 Employee Expenses 2,000,298 3,598 1,163 549 2,005,608 Labor 2,280,947 90,410 130,862 123,154 2,625,373 Materials 3,220,291 34,817 61,427 2,466 3,319,001 Other 2,625,807 265,047 42,979 154,378 3,088,211 Transportation 197,808 7,053 - 12,923 217,784

Total Cost Through 12/31/2013 $45,560,190 $622,828 $297,486 $782,018 $47,262,522

The Company used detailed internal accounting and audit procedures to track and verify

both internal and external storm recovery costs and will make available all documentation

supporting the costs for which it is seeking recovery. The testimony of the Company’s witness

Orlando Todd includes Exhibit OT-3, which contains detailed electronic indices in Microsoft

Excel format to all of the transactions relating to storm recovery costs, exclusive of transactions

that would relate to the estimated costs. With this electronic index, a party can sort the data and

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determine which transactions to audit or review. Parties may determine a statistically relevant

but discrete level of transactions out of the entire set of transactions that they wish to review and

test for accuracy. From these indices, the parties can submit their selected transactions list to

ENO. Based on this list, the Company will then pull all documents underlying those selected

transactions and make them available to the parties. ENO requests that the parties coordinate on

the selection of transactions because it is time intensive to pull the detail supporting a set of

transactions.

In addition to making this information available to parties to this proceeding to review

independently, ENO will also conduct a technical conference, if the parties so request, to further

explain and discuss the costs and documentation included in this Application.

In addition to the Hurricane Isaac storm recovery costs presented herein, this Application

further presents relevant details regarding the specific challenges presented by Hurricane Isaac.

Specifically, Company witnesses provide detailed explanations as to:

Why Hurricane Isaac was so destructive and, thus, costly;

The unique issues faced by the Company during the restoration; and

The systems and practices in place or implemented in response to the

storm to monitor, control, and reduce costs, while also expediting

restoration in a safe and organized manner.

B. Summary of Witnesses

The Company’s Application and associated requests for relief are supported by the

testimony and exhibits of the following four witnesses:

Charles L. Rice, Jr.: President and Chief Executive Officer of ENO. Mr. Rice

provides an overview of the relief ENO seeks in this Application, the damage

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caused by Hurricane Isaac, and the Company’s response to the storm. Mr. Rice

also introduces the other witnesses who support this Application.

Dennis P. Dawsey: Employee of Entergy Services, Inc. (“ESI”) and is the Vice

President of Transmission and Distribution Operations – Louisiana. Mr. Dawsey

oversees the operational aspects of providing safe and reliable electric service to

the Louisiana EOCs’ retail customers and is responsible for the implementation of

the Company’s storm preparation and response plan. His testimony provides an

overview of the Company’s transmission and distribution systems and operations,

and explains ENO’s preparation and training for major storm events. Mr. Dawsey

also discusses the unique challenges presented by Hurricane Isaac, ENO’s pre-

storm preparations, the damages to production, transmission, and distribution

systems, the significant restoration work completed by ENO, and the Company’s

interaction with its customers and stakeholders before, during, and after the storm

made landfall. He also supports the recovery of Production, Transmission,

Distribution, and Other classes of storm recovery costs.

Orlando Todd: Employee of ESI and the Jurisdictional Finance Director for ENO.

Mr. Todd is responsible for financial management, planning, monitoring, and

reporting, as well as providing regulatory support to the Company. Mr. Todd

presents the Total Storm Recovery Costs and describes ENO’s procedures for

approving and accounting for storm recovery costs.

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Michael A. Herman: Partner with PricewaterhouseCoopers LLP. Mr. Herman

discusses the results of an independent attestation examination of ENO’s

summary of storm recovery costs as of January 31, 2013.4

C. The Company’s Summary of Proof

Hurricane Isaac was an intense storm that caused widespread damage to utility property

in Louisiana and brought significant challenges to ENO. The hurricane lingered over the greater

New Orleans area for twice as long as other major hurricanes; and, in many areas of Louisiana,

the water levels resulting from Isaac’s storm surge exceeded those of Hurricanes Katrina and

Gustav. Hurricane Isaac’s destructive winds and storm surge caused approximately 707,000

customer outages in the areas served by the EOCs in Louisiana (including ENO) at the peak of

the storm. At 6:00 a.m. on August 30, 2012, before the restoration effort had begun, peak

customer outages for ENO were approximately 126,955.

Hurricane Isaac’s relentless winds and rainfall caused extensive and widespread damage

to ENO’s transmission and distribution facilities. The storm also caused some damage to the

System’s production resources. Damage to ENO’s transmission and distribution systems

included fallen trees on lines, downed and damaged structures and associated facilities, and

vegetation and other debris that blocked the roads and rights-of-way. As Mr. Dawsey describes,

the storm damaged or destroyed more cross-arms than in any prior storm affecting the Entergy

System. The storm also caused flooding and wind damage to substations.

When electrical power systems experience a major system outage, as was the case here,

production, transmission, and distribution must be restored to service in a careful, coordinated

fashion. To restore service to its distribution system, ENO repaired or replaced distribution

4 Approximately 98% of ENO’s Total Storm Recovery Costs were incurred by January 31, 2013.

8

poles, distribution transformers, and distribution wire. The EOCs also carefully coordinated the

repairs to their transmission system with the repairs made to production facilities in order to

safely and efficiently return power to the Entergy System.

The restoration effort would not have been possible without the team of workers who

helped restore the System following Hurricane Isaac. The EOCs successfully managed a

workforce of over 16,200 restoration personnel at the peak of restoration. Twenty-one mutual

aid companies and 138 pre-contracted companies answered the EOCs’ request for aid. Workers

from 25 states contributed to the Isaac restoration in Louisiana. Mr. Dawsey addresses how the

Company’s restoration efforts were assisted by these workers from affiliated resources, mutual-

aid utilities, and third-party contractors. In particular, Mr. Dawsey describes that without the

contributions from mutual-aid utilities and out-of-state contractor personnel working 16-hour

shifts and weekends, the restoration effort could have taken months.

Mr. Dawsey also discusses the challenges faced by the Company in repairing damages

from Hurricane Isaac. In particular, because Hurricane Isaac had been forecasted to impact the

Florida peninsula after it entered the Gulf of Mexico, many of the resources that would normally

have been acquired by the EOCs were already acquired and deployed to Florida utilities several

days before landfall along the Louisiana coast. When Hurricane Isaac’s path shifted to

Louisiana, thousands of resources that normally would have arrived from their home states in

waves over multiple days instead arrived much closer together. The large influx of workers

caused some congestion in checking-in off-system workers, establishing logistics, and getting

resources allocated to networks. On the other hand, these unique circumstances allowed

resources to be deployed to restoration more quickly when compared to prior storms because of

their availability and close proximity to ENO’s service territory when the storm made landfall.

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As previously mentioned, the Company’s response following Hurricane Isaac is also being

addressed in Docket No. UD-12-04.

The evolving role of technology and social media in informing our customers during the

restoration proved to be another challenge after Hurricane Isaac. Indeed, one of the lessons ENO

learned from Hurricane Isaac is the need to address customer desires for more detailed outage

information. As Mr. Dawsey discusses in his testimony, the Company has taken, and will

continue to take, a number of additional steps to enhance communication to customers during a

major event.

In spite of these and other challenges following Hurricane Isaac, once conditions were

safe to commence restoration efforts, more than 95% of outages in New Orleans had been

restored to service in less than five days after restoration efforts had begun.5 This rate of

restoration exceeded even that of Hurricanes Gustav and Ike, which themselves had established

records for restoration rates. By September 5, 2012, the seventh day of the Hurricane Isaac

restoration, power was restored to 99.8% of the customers in New Orleans. ENO and the other

EOCs extensively planned and prepared their storm response, which guided restoration efforts

after Hurricane Isaac. Mr. Dawsey provides detailed testimony regarding the storm plan

implementation for the transmission, distribution, and production operations, respectively.

Messrs. Rice, Dawsey and Todd discuss how the Company managed the costs incurred

for contract labor, equipment, and materials, and why those costs were reasonable and necessary.

Mr. Dawsey’s testimony supports ENO’s expenditure of $0.3 million in Production costs, $0.6

million in Transmission costs, $45.6 million in Distribution costs, and $0.8 million in Other costs

incurred through December 31, 2013. All costs will be subject to true-up and reconciliation.

5 Restoration numbers include the customer outages of ELL on the Westbank.

10

In order to ensure that storm recovery costs were appropriate and properly recorded, ENO

maintained a strong system of internal controls, including approvals of costs incurred before

payments were made to suppliers or employees recorded their time and expenses. Invoices for

restoration services and materials were reviewed, and only approved for payment if confirmed to

be accurate. The storm recovery costs were subject to both an internal review and an external

attestation examination, as described by Mr. Herman, to verify that the Company has presented a

complete and accurate representation of valid storm recovery costs. Mr. Todd also describes

ENO’s internal accounting process and the way in which it recorded and tracked the storm

recovery costs in order to ensure the accuracy of the costs.

As of the date of filing of this Application, ENO has not received any insurance proceeds

related to Hurricane Isaac; and, as explained by Mr. Todd in his testimony, it does not expect that

any insurance proceeds will be received. In addition, the Company has not received any funds

from state or federal sources, and there has been no allocation of Community Development

Block Grant funds for the storm recovery costs associated with Hurricane Isaac. The Company

does not anticipate that it will receive any funds from these or other external sources that would

offset the amount of recovery sought in this Application. However, Mr. Todd addresses how the

Company will account for any offsetting funds in the event such funds are received after the

Council issues a resolution in this proceeding.

III. NOTICES

ENO requests that notices, correspondence, and other communications concerning this

Application be directed to the following persons:

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Gary Huntley Entergy New Orleans, Inc. 1600 Perdido Street, L-MAG-505B New Orleans, LA 70112 Telephone: (504) 670-3680 Facsimile: (504) 322-6781 [email protected]

Timothy S. Cragin Entergy Services, Inc. 639 Loyola Avenue New Orleans, LA 70113-3125 Telephone: (504) 576-6571 Facsimile: (504) 576-5579 [email protected]

ENO requests that the foregoing persons be placed on the official service list for this

proceeding, and respectfully request that the Council permit the designation of more than one

person to be placed on the Official Service List for service in this proceeding.

VI. REQUEST FOR WAIVER

Pursuant to Section 158-48, of the New Orleans City Code, the Company requests waiver

of the Minimum Filing Requirements (“MFRs”) set forth in Chapter 158, Division 1, Section

158-41, et seq., of the New Orleans City Code. The Company’s request herein pertains to

extraordinary costs incurred following Hurricane Isaac and should not be subject to the same

MFRs. Additionally and more specifically, the Company requests partial waiver of the

requirements set forth in Sections 158-192 and 158-132 (5) of the New Orleans City Code, to the

extent that those provisions require the Company to provide typical bill comparisons for rate

schedules. At this time, the Company is not requesting regulatory rate treatment for storm

recovery costs, but only that the Council certify ENO’s Total Storm Recovery Costs as eligible

for recovery. Therefore, to the extent that the Company’s filing does not contain information

otherwise required by the MFRs, the Company requests a waiver of the applicability of such

provision.

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V. PRAYER FOR RELIEF

WHEREFORE, for the foregoing reasons, Entergy New Orleans, Inc. respectfully

requests that after due and lawful proceedings are held, its Application be approved. In

particular, ENO requests that the Council:

1. Find ENO’s Total Storm Recovery Costs of $47.3 million incurred through

December 31, 2013 to be reasonable, necessary, and recoverable;

2. Approve and issue a resolution determining the total amount of Hurricane Isaac

storm recovery costs that are eligible for recovery from ENO’s customers,

including the unrecovered amount of $29.9 million;

3. Direct that all notices in this proceeding be sent to Gary Huntley, and Timothy S.

Cragin;

4. Adopt for application in this proceedings its Official Protective Order as set forth

in Resolution R-07-432, or provide for such other appropriate protection for any

confidential information to be produced in this proceeding;

5. Approve ENO’s request for a waiver of the Minimum Filing Requirements set

forth in Chapter 158, Division 1, Section 158-41, et seq., of the New Orleans City

Code.

6. Authorize ENO to recover carrying costs on the approved storm recovery costs at

its weighted average cost of capital, as discussed in the direct testimony of Mr.

Todd and Exhibit OT-5 attached thereto; and

7. Grant such other relief to which ENO shows itself to be entitled.

Respectfully submitted,

r

By: --<,---z=-=--~~~:::::::....--c:o~:...-Kathryn J. Timothy S. in, Bar No.2 3

639 Loyola Avenue, Mail Unit L-ENT-26E

Telephone: (504) 576-6571 Facsimile: (504) 576-5579

Courtney R. Nicholson, Bar No. 32618

New Orleans, Louisiana 70113

ATTORNEYS FOR ENTERGY NEW ORLEANS, INC.

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BEFORE THE



) ) ) ) )


DIRECT TESTIMONY

OF

CHARLES L. RICE, JR.

ON BEHALF OF

ENTERGY NEW ORLEANS, INC.

February 2014

Entergy New Orleans, Inc. Direct Testimony of Charles L. Rice, Jr. CNO Docket No. UD-14-_____

i

TABLE OF CONTENTS

Page

I. INTRODUCTION AND QUALIFICATIONS................................................................. 1

II. SUMMARY OF ENO’S REQUESTS ............................................................................. 3

III. HURRICANE ISAAC ..................................................................................................... 4

A. Damage Caused by the Storm .............................................................................. 4

B. Overview of the ENO’s Response to the Storm .................................................... 7

IV. THE FINANCIAL EFFECTS OF THE STORM ........................................................... 15

V. INTRODUCTION OF WITNESSES ............................................................................. 17

VI. CONCLUSION ............................................................................................................. 18

EXHIBIT LIST

Exhibit CLR-1 Summary of Prior Testimony.


1

I. INTRODUCTION AND QUALIFICATIONS 1

Q1. PLEASE STATE YOUR NAME, TITLE, AND CURRENT BUSINESS 2

ADDRESS. 3

A. My name is Charles L. Rice, Jr. and I am President and Chief Executive Officer 4

(“CEO”) of Entergy New Orleans, Inc. (“ENO” or the “Company”), a position I 5

have held since June 2010. My business address is 1600 Perdido Street, New 6

Orleans, Louisiana 70113. 7

8

Q2. WHAT ARE YOUR CURRENT DUTIES? 9

A. As President and CEO of ENO, I have executive responsibility for the Company, 10

which includes responsibility for the production, transmission, and distribution 11

assets that are used to serve our customers. 12

13

Q3. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND 14

PROFESSIONAL EXPERIENCE. 15

A. I earned a Bachelor of Science degree in Business Administration from Howard 16

University in 1986. Following graduation, I was commissioned as a second 17

lieutenant in the United States Army and served as a military intelligence officer 18

with the 101st Airborne Division (Air Assault). In 1995, I earned a Juris 19

Doctorate from Loyola University New Orleans School of Law. Upon admission 20

to the Louisiana Bar, I began practicing law with the firm of Jones, Walker, 21

Waechter, Poitevent, Carrère & Denègre, LLP. In 2000, I joined the Legal 22

Department of Entergy Services, Inc. (“ESI”), an affiliate of the Entergy 23


2

Operating Companies (“EOCs”)1 that provides engineering, planning, accounting, 1

technical, and regulatory support services to each of the EOCs, including ENO. 2

In ESI’s Legal Department, I held the position of Senior Counsel and was a 3

member of the Casualty Litigation group. Shortly thereafter, I transferred to the 4

Human Resources Department, where I served as Manager of Labor Relations 5

Litigation Support. 6

In 2002, I left ESI to serve in local government as the City Attorney for 7

the City of New Orleans. I later served as Chief Administrative Officer for the 8

City of New Orleans, where I managed 6,000 employees and the City’s $600 9

million budget. In 2004, I returned to private law practice as a partner with the 10

law firm of Barasso, Usdin, Kupperman, Freeman & Sarver, LLC. In 2009, I 11

returned to Entergy to serve as Director of Utility Strategy for ESI. In that role, I 12

was responsible for coordinating regulatory, legislative and communications 13

efforts for Entergy’s regulated utility companies. In early 2010, I transferred to 14

ENO to lead the Regulatory Affairs Department; and, in June 2010, I was 15

promoted to my current position. I also earned an Executive Master of Business 16

Administration degree from Tulane University in 2012. 17

18

1 The six EOCs are Entergy Arkansas, Inc. (“EAI”), Entergy Louisiana, LLC (“ELL”), Entergy Gulf States Louisiana, L.L.C. (“EGSL”), Entergy Mississippi, Inc. (“EMI”), Entergy Texas, Inc. (“ETI”), and ENO. The electric generating resources and bulk transmission facilities of ENO, ELL, EGSL, ETI and EMI are currently operated pursuant to the System Agreement on a single, integrated basis and are referred to collectively as the “Entergy System” or the “System.” In December 2013, EAI terminated its participation in the Entergy System Agreement and currently operates independently of the remaining System Agreement EOCs.


3

Q4. HAVE YOU PREVIOUSLY TESTIFIED IN ANY REGULATORY 1

PROCEEDING? 2

A. Yes. A listing of the cases in which I have previously testified is attached hereto 3

as Exhibit CLR-1. 4

5

Q5. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? 6

A. My testimony provides an overview of the relief sought by ENO associated with 7

the storm damage it sustained as a result of Hurricane Isaac and its subsequent 8

recovery efforts. I also introduce the witnesses who support ENO’s Application. 9

10

II. SUMMARY OF ENO’S REQUESTS 11

Q6. PLEASE DESCRIBE THE RELIEF THAT ENO IS SEEKING IN THIS 12

PROCEEDING. 13

A. Through this proceeding, ENO requests entry of a Council order: (1) determining 14

that the entire amount of ENO’s total storm recovery costs (“Total Storm 15

Recovery Costs”), $47.3 million, was reasonable and necessary to rebuild ENO’s 16

electric infrastructure and to restore power to its customers; (2) certifying ENO’s 17

Total Storm Recovery Costs as eligible for recovery; and (3), authorizing the 18

Company to recover carrying costs on approved storm recovery costs. 19

20


4

Q7. WHAT ARE THE AMOUNTS OF STORM RECOVERY COSTS INCURRED 1

BY ENO FOR WHICH RECOVERY IS SOUGHT? 2

A. ENO is seeking approval for the recovery of its Total Storm Recovery Costs, 3

$47.3 million, before carrying costs. See Exhibits OT-1, attached to the Direct 4

Testimony of Orlando Todd. 5

6

Q8. DOES ENO PROPOSE A SPECIFIC RECOVERY METHOD FOR ITS STORM 7

RECOVERY COSTS IN THIS APPLICATION? 8

A. No, ENO is evaluating several cost-recovery mechanisms and will continue to 9

work with the Council Advisors to determine the best method for recovering its 10

storm recovery costs. At an appropriate time, ENO will request that the Council 11

issue a Resolution authorizing a specific cost recovery mechanism. 12

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III. HURRICANE ISAAC 14

A. Damage Caused by the Storm 15

Q9. PLEASE DESCRIBE HURRICANE ISAAC AND ITS EFFECTS ON AREAS 16

SERVED BY THE LOUISANA EOCS. 17

A. Hurricane Isaac made its first of two Louisiana landfalls at approximately 6:45 18

p.m. CST on August 28, 2012 in Plaquemines Parish, Louisiana, just southwest of 19

the mouth of the Mississippi River, as a Category 1 hurricane with maximum 20

sustained winds of 80 mph. The storm then reentered the Gulf of Mexico and 21

made a second landfall just west of Port Fourchon, Louisiana, at approximately 22

2:15 a.m. CST on August 29, 2012. Hurricane Isaac’s tropical-storm-force winds 23


5

extended roughly 185 nautical miles from the center in the northeastern quadrant, 1

and hurricane-force winds extended roughly 60 nautical miles from the center in 2

the same quadrant. The storm lingered over Louisiana, subjecting the Greater 3

New Orleans area to significant rainfall and sustained winds of over 39 mph 4

(tropical storm force) for 54 hours, twice the duration of prior major hurricanes. 5

As the storm moved through Louisiana, it weakened into a tropical storm and 6

ultimately was downgraded to a tropical depression during the afternoon of 7

August 30, 2012. 8

Although Hurricane Isaac was a Category 1 hurricane, the long duration of 9

tropical force winds, the storm track and slow forward motion, the storm’s size, 10

and significant rainfall occurring at the same time as the maximum storm surge all 11

resulted in large amounts of water being pushed into the coastal areas of the 12

northern Gulf of Mexico. In many areas, water levels exceeded those from 13

Hurricanes Katrina and Gustav. 14

15

Q10. PLEASE PROVIDE A SUMMARY OF THE DAMAGE CAUSED BY 16

HURRICANE ISAAC. 17

A. Hurricane Isaac’s relentless winds caused extensive damage to ENO’s distribution 18

and transmission facilities in New Orleans and also caused some damage to the 19

EOCs’ production resources. The storm caused widespread customer outages 20

across the areas served by the Louisiana EOCs, which include ENO, ELL, and 21

EGSL. At the peak of outages in Louisiana, approximately 59% of the combined 22


6

1.2 million customers in the EOC’s combined service areas (including ENO 1

customers) were without service. 2

Damage to ENO’s transmission and distribution systems included, but was 3

not limited to, fallen trees on lines, downed and damaged structures and 4

associated facilities, vegetation and other debris that blocked the roads and rights-5

of-way, and flood and wind damage to substations. Fortunately, ENO’s 6

production facilities sustained only limited damage. 7

8

Q11. HOW DID THE OUTAGES FROM HURRICANE ISAAC COMPARE TO THE 9

OUTAGES FROM HURRICANES KATRINA AND RITA IN 2005 AND 10

HURRICANES GUSTAV AND IKE IN 2008? 11

A. Hurricane Isaac caused the fourth largest system peak number of outages in the 12

Entergy System’s history, behind only Hurricanes Katrina, Gustav, and Rita. 13

14

Q12. HURRICANE ISAAC WAS RATED A “CATEGORY 1” HURRICANE, DOES 15

THE CATEGORY RATING OF A HURRICANE CORRESPOND DIRECTLY 16

WITH THE TYPE OF DAMAGES THAT IT CAN CAUSE ELECTRICAL 17

INFRASTRUCTURE? 18

A. Not necessarily. The weather conditions associated with Hurricane Isaac were 19

much more damaging than a typical Category 1 wind rating might suggest given a 20

number of factors, as will be discussed further by ENO witness Dennis Dawsey. 21

22


7

B. Overview of the ENO’s Response to the Storm 1

Q13. WHAT IS YOUR ROLE IN THE COMPANY’S RESPONSE TO STORMS 2

SUCH AS HURRICANE ISAAC? 3

A. As President and CEO of ENO, I have oversight responsibility for the 4

coordination of restoration efforts in the ENO Metro Region, including ensuring 5

communications to customers along with key governmental, regulatory, and 6

emergency management contacts. Greg Grillo is the Entergy System Incident 7

Commander, and he is responsible for overall planning and response to storms. 8

ENO’s witness Dennis Dawsey is the State Incident Commander for Louisiana 9

and reports directly to me and the CEO of ELL and EGSL regarding the actions 10

of the Louisiana State Command Center, which oversees the various functions 11

and business units in Louisiana during a storm restoration. 12

13

Q14. WHAT INVOLVEMENT DID YOU HAVE DURING HURRICANE ISAAC? 14

A. Major weather events have many business implications and, as such, I 15

participated in all aspects of Hurricane Isaac preparation and response. I was 16

involved in management calls related to the storm preparation and restoration; I 17

briefed the public through the media, communicated with and updated the city 18

leadership on restoration progress and timelines, and oversaw the execution of the 19

restoration effort in New Orleans. Mr. Dawsey discusses the response in more 20

detail in his testimony. 21

22


8

Q15. HOW DID THE COMPANY PREPARE FOR HURRICANE ISAAC AS IT 1

DEVELOPED AND PROGRESSED THROUGH THE GULF OF MEXICO? 2

A. As discussed by Mr. Dawsey, ENO continuously monitored the progress of the 3

storm. Before the storm entered the Gulf, the Company began its preparations, 4

which continued until landfall. As the storm entered the Gulf, ENO placed all 5

employees, contractors, and support vendors on alert and cancelled all vacations. 6

The Company conducted frequent conference calls with the State Command 7

Center, the System Command Center, and key leadership in Louisiana. 8

The Company reviewed its storm plans and checklists and also made plans 9

to support neighboring utilities if needed. As ENO’s respective service area 10

became increasingly threatened by the various projected storm paths, the 11

Company along with the other EOCs, responded by setting up staging areas, 12

obtaining fuel and supplies, ramping up logistics support, securing and pre-13

staging outside crews, implementing the equipment evacuation plan, 14

implementing an employee evacuation plan, and identifying front-line 15

management teams with support. ENO also participated in numerous System 16

Resource, Logistics, and Incident Commander Conference Calls with the 17

management of all Business Units and the other EOCs in order to monitor the 18

status of the preparations and make adjustments as deemed necessary. Mr. 19

Dawsey discusses the Company’s preparation in more detail. 20

21


9

Q16. HOW DID THE COMPANY MOBILIZE PERSONNEL PRIOR TO THE 1

STORM MAKING LANDFALL? 2

A. Initially, when the forecasts predicted landfall in Florida, the Company was 3

preparing to send crews to Florida to provide assistance. As the probability tracks 4

moved closer to Louisiana, ENO and the other EOCs activated the State 5

Command Center and Employee Evacuation Plan, and provided contractors with 6

specific instructions and contacts. 7

The Company mobilized Louisiana employees from the potential non-8

affected areas and strategically positioned them throughout the state. The 9

Company also worked closely with the System Command Center and its affiliated 10

Operating Companies in identifying and pre-staging employees, mutual-assistance 11

utilities, and contractors. 12

13

Q17. WHAT ACTIONS DID THE COMPANY TAKE AFTER THE STORM MADE 14

LANDFALL? 15

A. After landfall, the Company performed damage assessments and began the 16

process of repairing and restoring service to customers. ENO also communicated 17

with government officials, customers, emergency personnel, and local media 18

regarding the restoration efforts, safety concerns during the aftermath of the 19

storm, and the Company’s actions to restore service as quickly and safely as 20

possible. 21

22


10

Q18. WERE THERE UNIQUE CHALLENGES FACED BY THE COMPANY IN 1

RESTORING SERVICE FOLLOWING HURRICANE ISAAC? 2

A. Yes. Although every restoration effort following a major storm is challenging 3

and each involves its own unique set of circumstances, the restoration of ENO’s 4

systems after Hurricane Isaac was made even more difficult by the fact that 5

vegetation damage, storm surge flooding, and debris severely restricted access to 6

many of its facilities. Additionally, the slow progress of Hurricane Isaac 7

subjected the Company’s infrastructure to damaging wind and rain for a much 8

longer period than in prior storms. In addition to causing more damage to 9

infrastructure, the prolonged period of winds delayed the time at which the full 10

damage assessment and restoration efforts could safely begin. Also, Hurricane 11

Isaac caused significant flooding in areas that had not previously flooded to the 12

same extent, including Interstate-10 in LaPlace, multiple substations, and an 13

intended check-in site in Slidell. 14

15

Q19. HOW QUICKLY DID THE COMPANY RESTORE SERVICE FOLLOWING 16

HURRICANE ISAAC? 17

A. Despite the challenges presented by Hurricane Isaac, less than five days after it 18

was safe to commence full restoration efforts, 95% of outages in New Orleans had 19

been restored to service, making the Hurricane Isaac restoration faster than all 20

other recent major storms. William Bryan, Deputy Assistant Secretary for 21

Infrastructure Security and Energy Restoration with the U.S. Department of 22


11

Energy’s Office of Electric Reliability and Energy Delivery, publicly commended 1

the Entergy utilities for their response to Hurricane Isaac: 2

The typical benchmark for utility companies is to 3 restore power to 70% of customers within five to 4 seven days. The pace of Entergy’s restoration, 5 restoring power to 90% of its customers in four to 6 five days, is unbelievable. . . . This is one of the best 7 restorations we’ve seen in recent memory and 8 Entergy should be commended. 9

10

Q20. HOW WOULD YOU RESPOND TO THOSE WHO QUESTION THE PACE 11

OF SERVICE RESTORATION FOLLOWING A CATEGORY 1 HURRICANE 12

LIKE ISAAC? 13

A. The facts establish that this was the Company’s fastest restoration following a 14

major storm event. In my opinion, the perception of a slow restoration pace was 15

fueled by the slow movement of the storm, which caused some to be without 16

power for over two days before full scale damage assessment and restoration 17

could even begin. Additionally, because it was a Category 1 storm, there were 18

few government-called evacuations, and many customers chose to shelter in 19

place, perhaps assuming that there would be a limited power interruption. 20

21

Q21. WHY DOES THE COMPANY MAKE EVERY EFFORT TO RESTORE 22

SERVICE AS QUICKLY AS POSSIBLE? 23

A There is a high personal and societal burden when people are without electric 24

service, particularly in the aftermath of devastating storms such as Hurricane 25

Isaac. The availability of electric service following storms is critical to the initial 26

recovery process for the affected areas, including the regional economic recovery, 27


12

particularly in the case of Hurricane Isaac, where there was little to no public 1

evacuation in the affected areas. New Orleans has essential infrastructure that are 2

electric-dependent, such as water, sewage, communications, radio, television, 3

hospitals, the Central Business District, and large industrial customers such as the 4

Air Products facility in New Orleans East and the Port of New Orleans. Any 5

delays in getting these units back in service could have had potentially serious 6

consequences not only to New Orleans but for the regional economy. For these 7

reasons, the importance of restoring service as quickly as possible was reinforced 8

at daily meetings with the Council and its Advisors, the Mayor of New Orleans, 9

and the Governor’s Office of Homeland Security and Emergency Preparedness 10

(“GOHSEP”) personnel. 11

12

Q22. PLEASE PROVIDE AN OVERVIEW OF THE STEPS TAKEN BY THE 13

COMPANY TO EXPEDITE RESTORATION. 14

A. In accordance with its established and well-rehearsed restoration plan, the 15

Company built a restoration workforce with personnel from all of the EOCs, 16

numerous mutual-aid utilities from across the country, and third-party contractors. 17

The Entergy System used over 16,200 personnel in its efforts, including 18

over 12,200 tool workers. The restoration crews worked long shifts and 19

thousands of overtime hours to restore service as quickly as possible. ENO 20

utilized an extensive network of logistical and supply vendors to acquire the 21

necessary food and housing for crews and materials to complete line repairs in an 22

expedited manner. Mr. Dawsey discusses in detail the process employed to 23


13

complete the restoration as quickly as possible, consistent with the Company’s 1

overall goal that the safety of the workers and the public is paramount. As he 2

explains, had ENO not gone to these lengths to expedite the restoration, it would 3

have taken much longer to complete. 4

5

Q23. DOES THE EMPHASIS ON THE SPEED OF THE RESTORATION AFFECT 6

THE TOTAL RECOVERY STORM COSTS? 7

A. Yes. Expediting service restoration increased the costs incurred by the Company 8

due to the overtime payroll expenses and increased level of resources needed to 9

accommodate the large number of line and vegetation crews and other restoration 10

personnel. However, ENO does not incur such costs indiscriminately, but rather 11

manages costs by reassessing the restoration resource plans daily to optimize the 12

Entergy System’s restoration work, relying primarily on providers with whom the 13

Company has pre-existing contracts and business relationships and employing 14

accounting and cost controls, as discussed by Company witnesses Dennis Dawsey 15

and Orlando Todd. The Company implements these procedures and controls 16

during a major restoration to help ensure that the storm recovery costs are 17

prudently incurred for the benefit of customers. 18

19


14

Q24. ARE THE ENTERGY OPERATING COMPANIES KNOWN FOR 1

EXCELLENCE IN STORM RESPONSE? 2

A. Yes. The Entergy System is the only utility group to have received awards from 3

the Edison Electric Institute for restoration excellence every year since the 4

institute established the honor. Mr. Dawsey lists the awards in his testimony. 5

6

Q25. WHAT IS THE STATUS OF THE COMPANY’S RESTORATION EFFORTS? 7

A. As discussed by Mr. Dawsey, power has been restored to customers capable of 8

receiving service in all areas affected by Hurricane Isaac serviced by ENO. 9

10

Q26. HAS THE COMPANY’S STORM PREPAREDNESS AND RESPONSE 11

FOLLOWING HURRICANE ISAAC BEEN REVIEWED BY A THIRD 12

PARTY? 13

A. Yes. As discussed by Mr. Dawsey, Quanta Technology recently issued a report 14

addressing, among other things, ENO’s storm readiness and storm response 15

following Hurricane Isaac. See Exhibit DPD-10, attached to the Direct Testimony 16

of Dennis Dawsey. The report concludes that Entergy has a thorough and 17

comprehensive approach to emergency management that comports with industry 18

standards. The report further concluded that: 19

a. Entergy made efficient and effective use of resources, and results after the 20

storm reflected advance planning and execution of a storm response plan; 21

and 22


15

b. The restoration was by most industry benchmarks very efficient. 1

Restoration of 95% of customers within five days exceeds what is 2

normally considered effective restoration times in major storms. 3

4

IV. THE FINANCIAL EFFECTS OF THE STORM 5

Q27. HOW HAS THE STORM AFFECTED THE COMPANY’S OVERALL 6

FINANCIAL STATUS? 7

A. The cost of restoration can place a serious financial burden on the Company 8

particularly if its storm reserve escrow account (“Storm Reserve”) is not 9

adequately funded. Storm restoration requires the Company to expend large sums 10

very quickly, which can reduce its liquidity and can affect the financial metrics 11

supporting its current credit ratings, which are regularly examined by the 12

investment community. In responding to Hurricane Isaac, the Company withdrew 13

$10 million from the Storm Reserve in November 2012. On June 25, 2013, the 14

Company withdrew another $7.4 million from the Storm Reserve. The total 15

withdrawal of $17.4 million from the Storm Reserve was to offset the deferred 16

operation and maintenance (“Deferred O&M”) costs. As of December 31, 2013 17

the balance of the Storm Reserve was $10.5 million. 18

19

Q28. HAS THE COMPANY REACHED ANY CONCLUSION ON THE 20

PREFERRED MEANS TO FUND THE RECOVERY OF THE COSTS 21

DESCRIBED IN THIS APPLICATION? 22


16

A. No. Not at this time. The Company is evaluating a number of cost-recovery 1

mechanisms for its Hurricane Isaac storm recovery costs, which include 2

traditional recovery consistent with previous treatment for recovering storm costs. 3

In addition, ENO and the Council Advisors have also begun to explore whether 4

financing ENO’s Hurricane Isaac storm recovery costs through issuance of 5

securitized debt might provide a collective benefit to the Company and its 6

customers as an alternative to the Company’s traditional methods of rate recovery. 7

8

Q29. DOES ENO EXPECT TO RECEIVE EXTERNAL SOURCES OF FUNDING 9

FOR ITS STORM COSTS? 10

A. Not at this time. As discussed in prior storm filings, property insurance is not 11

reasonably available for damages to most of the transmission and distribution 12

facilities, which represents the vast majority of damages sustained in Hurricane 13

Isaac. 14

While other property such as buildings and production facilities are 15

insured against wind damage, such coverage is subject to a self-insured retention 16

that was not met in Hurricane Isaac due to the limited damage to those assets. 17

Also, the State of Louisiana has not allocated any Community Development 18

Block Grant (“CDBG”) funds for Hurricane Isaac storm restoration projects by 19

investor-owned utilities. ENO proposes that there be a true-up mechanism 20

established in the approved cost recovery methodology to account for any 21

external sources of funding attributable to its retail jurisdiction. 22

23


17

Q30. DOES THE COMPANY ANTICIPATE RECEIVING ANY REBATES FROM 1

VENDORS AND SUPPLIERS USED DURING HURRICANE ISAAC 2

RESTORATION? 3

A. ENO has received some rebates from vendors, the effects of which are already 4

reflected in its Total Storm Recovery Costs discussed earlier. Additional rebates 5

are not expected at this time. 6

7

V. INTRODUCTION OF WITNESSES 8

Q31. PLEASE INTRODUCE THE WITNESSES WHO ARE FILING TESTIMONY 9

IN SUPPORT OF THE COMPANY’S APPLICATION. 10

A. The following is a list of the other witnesses supporting ENO’s Application and a 11

brief overview of the nature of their testimony. 12

Dennis P. Dawsey – Mr. Dawsey is employed by ESI as the Vice 13

President of Transmission and Distribution Operations – Louisiana. Mr. 14

Dawsey oversees the operational aspects of providing safe and reliable 15

electric service to the retail customers of the three Entergy Operating 16

Companies in Louisiana (ENO, ELL, and EGSL) and is responsible for 17

the implementation of the ENO’s storm preparation and response plan. In 18

his testimony, he provides an overview of the ENO’s transmission and 19

distribution systems and operations and explains how the ENO prepares 20

and trains for major storm events. With respect to Hurricane Isaac, Mr. 21

Dawsey discusses the challenges presented by the storm, pre-storm 22

preparations, the damage to the transmission and distribution systems, the 23


18

significant restoration work completed by ENO, and ENO’s interaction 1

with customers and stakeholders before, during, and after Hurricane Isaac 2

made landfall. He also supports the Production, Transmission, 3

Distribution and Other classes of storm recovery costs. 4

Orlando Todd – Jurisdictional Finance Director for ENO. Mr. Todd is 5

responsible for financial management, planning, monitoring, and 6

reporting, as well as providing regulatory support for ENO. Mr. Todd 7

presents the Hurricane Isaac storm costs on a Council-jurisdictional basis 8

and describes ENO’s procedures for approving and accounting for such 9

costs. 10

Michael A. Herman - Partner with PricewaterhouseCoopers. Mr. Herman 11

discusses the results of an independent attestation examination of ENO’s 12

summary of storm recovery costs as of January 31, 2013.2 13

14

VI. CONCLUSION 15

Q32. WERE THE COSTS INCURRED BY THE COMPANY TO ADDRESS 16

HURRICANE ISAAC REASONABLE AND NECESSARY? 17

A. Yes. The costs were reasonable and necessary to restore service to customers and 18

to reconstruct the transmission and distribution systems promptly and safely in the 19

wake of the damage caused by Hurricane Isaac in the areas served by the 20

Company. While the amounts expended on materials, labor, and the other cost 21

categories were substantial, the public interest required the restoration of service 22 2 Approximately 98% of ENO’s Total Storm Recovery Costs were incurred by January 31, 2013.


19

as quickly and safely possible. Had ENO not acquired these resources in the 1

manner that it did, the restoration of the transmission and distribution systems to 2

provide power to essential facilities like water plants, sewage-treatment plants, 3

hospitals, nursing homes, and law enforcement facilities, as well as industries 4

critical to the regional, state, and national economies, would have taken 5

substantially longer, as would the time period for restoring power to other 6

customers throughout New Orleans. Thus, under the circumstances, the costs 7

incurred were reasonable and necessary to restore power safely, timely, and 8

efficiently. 9

10

Q33. IN THE LIGHT OF THE FACTS KNOWN TO ENO AT THE TIME, WAS IT 11

NECESSARY AND REASONABLE TO ACQUIRE AND UTILIZE THE 12

RESOURCES THAT THE COMPANY DID TO COMPLETE RESTORATION 13

OF SERVICE AND RECONSTRUCTION OF ITS FACILITIES? 14

A. Yes. 15

16

Q34. DOES THIS CONCLUDE YOUR DIRECT TESTIMONY? 17

A. Yes. 18

AFFIDAVIT

STATE OF LOUISIANA

PARISH OF ORLEANS

NOW BEFORE ME, the undersigned authority, personally came and

appeared, Charles L. Rice, Jr., who after being duly sworn by me, did depose and say:

That the above and foregoing is his sworn testimony in this proceeding

and that he knows the contents thereof, that the same are true as stated, except as to

matters and things, if any, stated on information and belief, and that as to those matters

and things, he verily believes them to be true.

SWORN TO AND SU~RIBED BEFORE ME THIS GlLtinAY OF ~AAr~--= ,2014.

~({ ~.WLu;,; OTARY PUBLIC

Couttne!J ~ ?lidiJJfson La. Bar. No. 32618

Notary Public State of louisiana

Commission Expires al Death

Previous Testimony of Charles L. RiceTYPE OF TESTIMONY JURISDICTION CLIENT DOCKET Filing Date

Direct Testimony CNO ENO UD-07-03 11/1/2010Supplemental Direct Testimony CNO ENO UD-07-03 1/4/2011Supplemental Direct Testimony CNO ENO UD-07-03 2/1/2011Supplemental Direct Testimony CNO ENO UD-11-01 2/1/2011Supplemental Direct Testimony CNO ENO UD-11-01 3/1/2011Supplemental Direct Testimony CNO ENO UD-07-03 3/1/2011Supplemental Direct Testimony CNO ENO UD-07-03 4/1/2011Supplemental Direct Testimony CNO ENO UD-11-01 4/1/2011Supplemental Direct Testimony CNO ENO UD-07-03 5/2/2011Supplemental Direct Testimony CNO ENO UD-07-03 5/12/2011Supplemental Direct Testimony CNO ENO UD-11-01 5/12/2011Supplemental Direct Testimony CNO ENO UD-07-03 6/1/2011Supplemental Direct Testimony CNO ENO UD-11-01 6/1/2011Supplemental Direct Testimony CNO ENO UD-11-01 7/1/2011Supplemental Direct Testimony CNO ENO UD-11-01 8/1/2011Supplemental Direct Testimony CNO ENO UD-11-01 9/1/2011Supplemental Direct Testimony CNO ENO UD-11-01 10/3/2011Supplemental Direct Testimony CNO ENO UD-11-01 11/1/2011Supplemental Direct Testimony CNO ENO UD-11-01 11/14/2011Supplemental Direct Testimony CNO ENO UD-11-01 12/1/2011Supplemental Direct Testimony CNO ENO UD-11-01 1/3/2012Supplemental Direct Testimony CNO ENO UD-11-01 2/1/2012Supplemental Direct Testimony CNO ENO UD-11-01 3/1/2012Supplemental Direct Testimony CNO ENO UD-11-01 4/2/2012Supplemental Direct Testimony CNO ENO UD-11-01 5/1/2012Supplemental Direct Testimony CNO ENO UD-11-01 6/1/2012Supplemental Direct Testimony CNO ENO UD-11-01 7/1/2012Supplemental Direct Testimony CNO ENO UD-11-01 8/1/2012Supplemental Direct Testimony CNO ENO UD-11-01 9/4/2012Direct Testimony CNO ENO UD-12-01 9/12/2012Supplemental Direct Testimony CNO ENO UD-11-01 10/1/2012Supplemental Direct Testimony CNO ENO UD-11-01 11/1/2012Supplemental Direct Testimony CNO ENO UD-11-01 12/3/2012Supplemental Direct Testimony CNO ENO UD-11-01 1/2/2013Supplemental Direct Testimony CNO ENO UD-11-01 2/4/2013Supplemental Direct Testimony CNO ENO UD-11-01 3/1/2013Supplemental Direct Testimony CNO ENO UD-11-01 4/1/2013Supplemental Direct Testimony CNO ENO UD-11-01 5/1/2013Supplemental Direct Testimony CNO ENO UD-11-01 6/3/2013Rebuttal Testimony CNO ENO UD-12-01 6/12/2013Supplemental Direct Testimony CNO ENO UD-11-01 7/1/2013Supplemental Direct Testimony CNO ENO UD-11-01 8/1/2013

Exhibit CLR-1 CNO Docket No. UD-14-__

Page 1 of 2

Previous Testimony of Charles L. RiceTYPE OF TESTIMONY JURISDICTION CLIENT DOCKET Filing Date

Supplemental Direct Testimony CNO ENO UD-11-01 9/3/2013Supplemental Direct Testimony CNO ENO UD-11-01 10/1/2013Supplemental Direct Testimony CNO ENO UD-11-01 11/1/2013Supplemental Direct Testimony CNO ENO UD-11-01 12/2/2013Supplemental Direct Testimony CNO ENO UD-11-01 1/2/2014Supplemental Direct Testimony CNO ENO UD-11-01 2/3/2014

Exhibit CLR-1 CNO Docket No. UD-14-__

Page 2 of 2

BEFORE THE



) ) ) ) )


DIRECT TESTIMONY

OF

DENNIS P. DAWSEY

ON BEHALF OF


February 2014

Entergy New Orleans, Inc. Direct Testimony of Dennis P. Dawsey CNO Docket No. UD-14-________

i

TABLE OF CONTENTS Page

I. INTRODUCTION AND QUALIFICATIONS................................................................. 1

II. PURPOSE AND SUMMARY OF TESTIMONY ............................................................ 3

III. ENO’S TRANSMISSION AND DISTRIBUTION OPERATIONS ................................. 5

A. Transmission and Distribution Systems in Louisiana ............................................ 5

B. Transmission and Distribution Organization......................................................... 9

C. Storm Restoration Plan ...................................................................................... 18

IV. HURRICANE ISAAC’S IMPACT ON THE COMPANY ............................................. 34

A. Description of Hurricane .................................................................................... 34

B. Damage to the Company’s Infrastructure ........................................................... 42

V. THE RESTORATION WORK ...................................................................................... 45

VI. INTERACTION WITH CUSTOMERS AND STAKEHOLDERS ................................. 61

VII. RESTORATION RESOURCES AND COSTS .............................................................. 70

VIII. CONCLUSION ............................................................................................................. 75


ii

EXHIBIT LIST

Exhibit DPD-1 Map of Louisiana Region Boundaries Exhibit DPD-2 2002 – 2012 SAIFI and SAIDI Results Exhibit DPD-3 Transmission and Distribution Operations Organizational Chart Exhibit DPD-4 System Emergency Operations & Restoration Plan Exhibit DPD-5 Entergy Incident Management System Exhibit DPD-6 Path of Hurricane Isaac Exhibit DPD-7 Hurricane Isaac Transmission Line Outage Report Exhibit DPD-8 Summary of Hurricane Isaac Storm Recovery costs Exhibit DPD-9 Summary of Prior Testimony Exhibit DPD-10 Quanta Technology: Reliability Study of the Electrical System in Orleans Parish


1


Q1. PLEASE STATE YOUR NAME, POSITION, AND BUSINESS ADDRESS. 2

A. My name is Dennis P. Dawsey. I am employed by Entergy Services, Inc. (“ESI”),1 3

and I currently serve as the Vice President of Transmission and Distribution 4

Operations – Louisiana. My business address is 446 North Boulevard, Baton Rouge, 5

Louisiana 70802. 6

7

Q2. ON WHOSE BEHALF ARE YOU TESTIFYING? 8

A. I am testifying on behalf of Entergy New Orleans, Inc. (“ENO” or the “Company”). 9

10

Q3. PLEASE DESCRIBE BRIEFLY YOUR EDUCATIONAL AND BUSINESS 11

BACKGROUND. 12

A. I hold a Bachelor of Science degree in Electrical Engineering from Louisiana State 13

University and a Master’s Degree in Business Administration from Louisiana State 14

University. My career within the Entergy System spans 33 years. I am a registered 15

professional engineer in Louisiana and Texas and a certified project management 16

professional, and I have worked within the Entergy System as a field-design engineer, 17

industrial account representative, substation/relay/supervisory control and data 18

1 ESI is an affiliate of the six Entergy Operating Companies (“EOCs”) and provides administrative and support services to the EOCs. The six EOCs are Entergy Arkansas, Inc. (“EAI”), Entergy Louisiana, LLC (“ELL”), Entergy Gulf States Louisiana, L.L.C. (“EGSL”), Entergy Mississippi, Inc. (“EMI”), Entergy Texas, Inc. (“ETI”), and ENO. The electric generating resources and bulk transmission facilities of ENO, ELL, EGSL, ETI and EMI are currently operated pursuant to the System Agreement on a single, integrated basis and are referred to collectively as the “Entergy System” or the “System.” In December 2013, EAI terminated its participation in the Entergy System Agreement and currently operates independently of the remaining System Agreement EOCs.


2

acquisition design engineer, distribution-planning engineer, transmission-planning 1

engineer, area design manager, and network manager. I also have worked in a 2

system-support role as manager of Systems Development and Management. 3

In 2001, I became Engineering Manager for Louisiana, overseeing distribution 4

design activities for the State. Then, in 2004, I was named Southern Region Manager 5

for ELL; and, in that capacity, I oversaw restoration work in Jefferson Parish 6

following Hurricane Katrina. In 2006, I was promoted to Distribution Operations 7

Director for EMI. I was promoted to my current position in 2008. 8

9

Q4. HAVE YOU PREVIOUSLY TESTIFIED BEFORE THE COUNCIL? 10

A. Yes. A listing of the cases in which I have previously testified is attached hereto as 11

Exhibit DPD-9. 12

13

Q5. WHAT ARE YOUR JOB RESPONSIBILITIES? 14

A. I am responsible for overseeing all aspects of electric service and reliability to well 15

over 1 million retail electric customers in Louisiana that are served in aggregate by 16

ENO, ELL, and EGSL, which are the three EOCs that serve Louisiana customers. 17

My specific responsibilities include, but are not limited to, safety, operations, 18

construction, reliability improvement, engineering, asset planning, distribution 19

dispatching, meter services, contract management, and emergency restoration for 20

each Louisiana EOC’s respective transmission and distribution systems. 21

With respect to emergency restoration, I am the State Incident Commander for 22

Louisiana under Entergy Corporation’s Emergency Operations Plan. During an 23


3

emergency event, I report directly to the Company’s President and CEO and to the 1

System Incident Commander. My duties include, but are not limited to, ensuring 2

incident safety, pre-storm preparation activities, including requesting and 3

coordinating resource needs in preparation for a major event, the evacuation of 4

employees and equipment from flood prone areas along the Louisiana coastal 5

territories, the pre-staging of restoration resources, damage assessment following a 6

storm, the coordination of restoration activities, and effective resource deployment to 7

ensure a safe and prompt restoration for all of ENO, ELL and EGSL’s respective 8

customers. I also perform all roles and responsibilities of the System Incident 9

Commander, as discussed below, when Louisiana is the only area involved in a 10

particular incident and there is no System Command activation. 11

12

II. PURPOSE AND SUMMARY OF TESTIMONY 13

Q6. PLEASE SUMMARIZE THE RELIEF THAT THE COMPANY IS SEEKING IN 14

ITS APPLICATION. 15

A. Through this proceeding, ENO requests entry of a Council order: (1) determining that 16

the entire amount of ENO’s total storm recovery costs (“Total Storm Recovery 17

Costs”), $47.3 million, was reasonable and necessary to rebuild ENO’s electric 18

infrastructure and to restore power to its customers; (2) certifying ENO’s Total Storm 19

Recovery Costs as eligible for recovery; and (3), authorizing the Company to recover 20

carrying costs on approved storm recovery costs. 21


4

1

Q7. WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? 2

A. My testimony supports ENO’s Application in this docket concerning its storm 3

recovery costs for Hurricane Isaac. My testimony covers five main topics. First, I 4

discuss the transmission and distribution systems of ENO and provide details about 5

the EOCs’ storm restoration plan. Second, I review Hurricane Isaac’s impact on 6

ENO. Third, I discuss the significant restoration work done by the Company and 7

describe the challenges associated with this work. Fourth, I discuss the Company’s 8

interaction with customers and stakeholders before, during, and after Hurricane Isaac 9

made landfall. Finally, I provide the costs incurred by the Company as a result of the 10

Hurricane Isaac restoration efforts. In particular, I sponsor the Production, 11

Transmission, Distribution, and Other classes of storm recovery costs incurred by the 12

Company. 13

As discussed in my testimony, the storm recovery costs that the Company 14

incurred after Hurricane Isaac were necessary to repair the damage sustained by the 15

Company’s infrastructure in the most reasonable and expeditious manner possible, 16

and to safely restore service to our customers. 17

18

Q8. DO YOU SPONSOR ANY EXHIBITS? 19

A. Yes. My exhibits are listed in the table of contents to this testimony. 20

21


5

III. ENO’S TRANSMISSION AND DISTRIBUTION OPERATIONS 1

A. Transmission and Distribution Systems in Louisiana 2

Q9. PLEASE DESCRIBE ENO’S TRANSMISSION SYSTEM AND LOAD 3

CHARACTERISTICS IN LOUISIANA. 4

A. ENO owns a transmission system comprised of 158 circuit miles of transmission lines 5

and associated facilities by which it currently provides transmission service pursuant 6

to the Open Access Transmission Tariff (“OATT”) maintained by ESI and on file 7

with the Federal Energy Regulatory Commission (“FERC”). The ENO transmission 8

system is relatively small in comparison to the other EOCs, covering 355 square 9

miles of service area on the east bank of Orleans Parish. The ENO transmission 10

system is composed of 69 kV, 115 kV, 138 kV, 230 kV, and 500 kV transmission 11

lines and substations. The ENO transmission system is only interconnected with the 12

transmission system of ELL. 13

14

Q10. PLEASE DESCRIBE THE COMPANY’S DISTRIBUTION SYSTEMS IN NEW 15

ORLEANS. 16

A. ENO’s distribution systems span over 1,428 line miles to provide retail electric 17

service to the approximately 167,991 electric customers. The predominant operating 18

voltages of the Company’s distribution circuits are 13.2 kV, 13.8 kV, 24kV, and 34.5 19

kV (nominal, phase-to-phase). 20

The Louisiana Distribution Organization operates local service centers within 21

the area served by ENO. These local service centers and the distribution facilities 22

they support are divided among the larger geographic operating region that 23


6

encompasses ENO’s service area on the east bank of Orleans Parish, called the ENO 1

Metro Region. A map of the organization and region is shown on Exhibit DPD-1. 2

3

Q11. PLEASE DESCRIBE THE COMPANY’S INVESTMENT IN AND 4

IMPROVEMENT OF ITS DISTRIBUTION SYSTEM. 5

A. On average, the Company has been investing over $20.5 million annually in capital 6

spending for its distribution systems2 (2007-2012), with adjustments for certain 7

extraordinary items. In addition to the Company’s improvement programs that I 8

address below, a variety of proactive steps have been implemented by each Louisiana 9

EOC after Hurricanes Katrina, Rita, Gustav, and Ike, which proved successful during 10

Hurricane Isaac. Examples of these additional actions, designs, or practices include 11

the following: 12

1. Replacing support circuits crossing interstate highways 13 with steel or concrete structures instead of wood; 14

15 2. Targeting coastal lines with severe or repeat damage for 16 scheduled rebuilds to hardened design levels (double guys and 17 larger class poles); 18 19 3. Using only Class 3 (or larger) poles for three-phase 20 distribution feeder construction for selected circuits (e.g., feeders 21 immediately adjacent to the coast); 22 23 4. Using steel distribution poles for new interstate crossings 24 along major hurricane evacuation routes; 25

26 5. In substations in coastal areas, raising water-sensitive 27 equipment several feet above the flood levels that have been 28 experienced in recent years due to storm surge or erosion; 29

2 The Louisiana EOCs’ T&D Operations are managed on a statewide basis. Therefore, it is possible that a portion of costs spent in ELL may actually benefit ENO, but may not be fully represented in these captured costs.


7

1 6. Designing new substations so that water-sensitive 2 equipment will be above those same flood levels; and 3

4 7. Increasing vegetation-management patrols. 5

6

Q12. WHAT RESULTS HAVE BEEN ACHIEVED AS A RESULT OF THE 7

DISTRIBUTION SYSTEM IMPROVEMENTS? 8

A. The Louisiana EOCs’ distribution line reliability metrics have shown significant 9

improvement since 2002. System Average Interruption Frequency Index (“SAIFI”) 10

and System Average Interruption Duration Index (“SAIDI”) targets have consistently 11

outperformed the targets established by the Louisiana Public Service Commission 12

(“LPSC” or the “Commission”). See Exhibit DPD-2, attached to my testimony. 13

14

Q13. HAS THE COMPANY CONSIDERED THE BURIAL OF ITS OVERHEAD 15

DISTRIBUTION LINES AS A MEANS TO FURTHER DECREASE THE 16

VULNERABILITY OF ITS DISTRIBUTION SYSTEMS TO HURRICANES AND 17

OTHER SEVERE WEATHER EVENTS? 18

A. Yes. As was more fully discussed in the Hurricane Isaac Report filed in Docket No. 19

UD-12-04, the EOCs and their respective regulators have evaluated the costs and 20

benefits of large scale replacement of existing overhead electric infrastructure with 21

underground infrastructure (e.g., on a feeder serving a critical care facility such as a 22

hospital), many times. After Hurricane Gustav in 2008, the LPSC opened a 23

rulemaking docket (R-30821) to explore the potential costs and benefits of 24

investments to decrease the vulnerability of electric utility infrastructure to severe 25

weather events. In response to certain questions posed by the Commission regarding 26


8

the potential hardening of distribution facilities through undergrounding, ELL and 1

EGSL noted that there would be a considerable expense to place overhead electric 2

distribution facilities underground. Recovery of this expense would have a 3

significant effect on customer bills. 4

Moreover, burying lines does not fully mitigate the exposure of electric 5

systems to storms and may adversely affect reliability by increasing the duration of 6

outages. In particular, storm damage to source transmission lines and substation 7

facilities will cause outages to the distribution lines fed from these systems even 8

though the distribution facilities may be completely intact. Also, underground 9

distribution facilities still can be damaged by flooding, storm surge, and heavy 10

equipment used to remove storm debris. 11

Among the many conclusions reached by the LPSC Staff in their report 12

was the following: 13

Different weather events create advantage for underground distribution 14 systems versus overhead and vice versa. Clearly, it would not be 15 prudent to install underground distribution systems in areas that are 16 prone to flooding since underground distribution systems are 17 susceptible to damage by flooding. The fact that different terrains and 18 areas present advantages for underground versus overhead distribution 19 systems supports providing utilities with the flexibility to plan their 20 systems in a manner that best meets the needs and environmental 21 factors present. In addition, it supports the idea that a state-wide 22 mandate for underground retrofit should not be enacted by the 23 Commission. Moreover, for the same reasons, a mandate for utilities 24 to implement underground distribution systems on a prospective basis 25 for new construction should not be required either.3 26

27

3 Please see LPSC Docket No. R-30821, Report by Staff dated January 28, 2009.


9

Because of the extremely high cost of converting overhead distribution line facilities 1

to underground facilities, the Company would not recommend such a proposal. 2

Similar conclusions were reached in a post-Isaac study conducted by 3

Quanta Technology concerning the electric systems in Orleans Parish. This report 4

evaluated the systems of ELL and ENO in Orleans Parish to determine whether the 5

public would be better served by placing distribution facilities underground. The 6

Quanta Technology report, which is attached as Exhibit DPD-10, concluded that 7

converting overhead electric lines in Orleans Parish to underground would not be 8

economical. 9

10

B. Transmission and Distribution Organization 11

Q14. HOW IS THE TRANSMISSION AND DISTRIBUTION OPERATIONS GROUP 12

WITHIN LOUISIANA ORGANIZED? 13

A. Exhibit DPD-3 shows the Transmission and Distribution Operations’ organizational 14

chart. As the Vice President of Transmission and Distribution Operations – 15

Louisiana, I report directly to each Louisiana EOC’s President and CEO (Charles 16

Rice and Phillip May). 17

18

Q15. WHAT ARE THE RESPONSIBILITES OF THE TRANSMISSION AND 19

DISTRIBUTION OPERATIONS – LOUISIANA ORGANIZATION? 20

A. This organization, along with Entergy’s Energy Delivery organization, is responsible 21

for operating, planning, designing, constructing, and maintaining the electric 22

distribution and transmission systems that provide electric energy to all of the 23


10

Company’s customers. These responsibilities are carried out through various work 1

groups that provide transmission and distribution operations-related services in the 2

following functional areas: (1) Operations, (2) Planning, (3) Design/Engineering, (4) 3

Construction, and (5) Maintenance of the electrical grid. 4

5

Q16. WHAT ACTIVITIES ARE INCLUDED WITHIN THE FIRST OF THESE FIVE 6

FUNCTIONAL AREAS, THE OPERATIONS AREA? 7

A. My organization manages the day-to-day operations of the electric distribution grid 8

that supplies electric energy to the Company’s customers. The distribution grid is 9

composed of distribution breakers, poles, wires, distribution transformers, and other 10

equipment, all configured to electrically connect rural, urban, and metropolitan 11

communities to each EOC’s electric energy sources from the transmission grid. The 12

Entergy Energy Delivery organization, in turn, is specifically responsible for 13

overseeing the operations of each EOC’s transmission systems. 14

The Operations function monitors the distribution system loads and voltage 15

levels to ensure there is adequate capacity to meet customer needs. In addition, the 16

Operations function handles routine and emergency routing of power to maintain a 17

continuous supply of electricity to customers. 18

19


11

Q17. WHAT ACTIVITIES ARE INCLUDED WITHIN THE SECOND AREA, THE 1

PLANNING AREA? 2

A. The Planning function is responsible for the planning of the transmission and 3

distribution systems, including the coordination of transmission and distribution 4

projects that are required to meet customer needs or growth opportunities. 5

6

Q18. WHAT ACTIVITIES ARE INCLUDED WITHIN THE THIRD AREA, THE 7

DESIGN/ENGINEERING AREA? 8

A. The Design/Engineering work group provides design and engineering services for 9

each EOC’s transmission and distribution assets. For example, substation 10

expansions, such as the addition of distribution transformers or feeders, would be 11

performed within this group. 12

13

Q19. PLEASE DESCRIBE THE ACTIVITIES INCLUDED WITHIN THE THIRD 14

AREA, THE CONSTRUCTION AREA. 15

A. The purpose of the transmission and distribution systems is to deliver a continuous, 16

reliable, safe, and adequate supply of electricity to customers. In order to 17

accommodate new customers and existing customer growth, ENO must sometimes 18

add or upgrade transmission and/or distribution facilities. The Construction Group is 19

responsible for those additions, both major and minor, and its services to the 20

Company include project management, materials and services procurement, 21

regulatory approvals/management, and job closeout. 22

23


12

Q20. PLEASE DESCRIBE THE ACTIVITIES WITHIN THE FINAL AREA, THE 1

MAINTENANCE AREA. 2

A. The Maintenance Area provides the necessary continuous upkeep to preserve the 3

integrity of the Company’s electric transmission and distribution systems and its 4

ability to provide reliable service to customers. Maintenance activities are both 5

preventive and reactive. Examples of preventive maintenance are vegetation 6

management, pole and equipment inspections and maintenance, and the introduction 7

of new maintenance practices to enhance the overall operation and reliability of the 8

transmission and distribution systems. Reactive repairs and upkeep are required 9

when parts of the system fail due to wind, lightning, or other types of damage. 10

11

Q21. PLEASE DESCRIBE THE COMPANY’S VEGETATION PROGRAMS AND 12

PRACTICES. 13

A. To keep rights-of-way in proper condition, all of the Company’s transmission lines 14

undergo at least two aerial patrols each year. A combination of traditional trimming, 15

helicopter side trimming, and herbicides are used to maintain the rights-of-way, and 16

the Company has a program to identify off right-of-way trees that may endanger the 17

conductor zone. 18

For the distribution system, the Company uses several standards and practices 19

to manage its vegetation program. The Company conforms to two industry-accepted 20

standards: (1) ANSI A300 – Tree, Shrub, and Other Woody Plant Maintenance – 21

Standard Practices (Pruning); and (2) ANSI Z133 – Pruning, Repairing, Maintaining, 22

Removing Trees, and Cutting Brush – Safety Requirements. All utilities in Louisiana 23


13

must also perform their vegetation work in accordance with the Louisiana 1

Department of Agriculture and Forestry’s Horticulture Commission Law (La. Rev. 2

Stat. §§ 3:3801-3816) and the Horticulture Commission’s Rules and Regulations. In 3

addition, the Company trims according to the Entergy System specifications, which 4

detail the System’s trimming requirements, including right-of-way widths. Typically, 5

the Entergy System maintains right-of-way widths 10 feet to either side of the 6

conductor and 20 feet of overhang or existing rights-of-way, whichever is greater. 7

Right-of-way widths do vary, however, based on location (e.g., smaller right-of-way 8

widths in predominantly urban areas and larger right-of-way widths in rural areas). 9

Due to New Orleans’ famously beautiful urban canopy, vegetation 10

management in Orleans Parish is somewhat different than the rest of the system. 11

Balancing the desire to protect the beautiful trees in our city against the need to keep 12

vegetation away from the electrical system, requirements of the City of New Orleans 13

limit the clearance at the time of pruning to no more than 4 feet from the primary 14

conductor (or “wires”). Given this limitation, ENO must prune on a more frequent 15

basis to mitigate encroachment by limbs and branches on our facilities. Since 2009, 16

ENO has had an average cycle time of approximately 2.7 years, meaning a given area 17

is addressed less than 3 years on average after the last time it was pruned (~ 64% of 18

scheduled pruning in 2012 was accomplished by August 26th before Hurricane Isaac 19

hit). In more rural areas where the 4 foot clearance rule does not apply, the cycle 20

time is approximately 4.7 years. 21

As far as recent electric reliability is concerned, ENO’s vegetation-related 22

outages are currently the lowest across the four-state Entergy System. As mentioned 23


14

earlier, electric utilities use the SAIFI score as a leading reliability indicator. SAIFI is 1

the average number of interruptions that a customer would experience over a given 2

time period (lower is better). Through the time of the storm, August 2012, ENO’s 3

vegetation-related SAIFI for 2012 was 0.079, which is almost five times better when 4

compared to the Entergy System average SAIFI of 0.351 for the same period. 5

In addition to the maintenance trimming cycles, the Company uses three 6

additional program elements to manage vegetation in the rights-of-way: 7

Overhang Removal Trimming – The Company works to clear as much 8

overhang from the trunk, mainline feeders through an aggressive program to 9

target overhanging vegetation that risks damaging distribution circuits during 10

storm conditions. 11

Danger Tree Program – Removal of damaged or dying trees located outside 12

the right-of-way that might be a danger to the conductors and structures 13

during storm events. This program seeks to remove these trees from private 14

property through negotiations with, and consent of, property owners. 15

Reactive Maintenance – Funding is provided to respond to immediate requests 16

to mitigate tree conditions found during normal day-to-day business. These 17

requests may come from customers or internal employees of the Company. 18

The quality of the vegetation management program is maintained through a 19

100 percent audit of the regular cycle maintenance program and targeted spot audits 20

of the reactive maintenance program to ensure that the contractors are completing the 21

work in accordance with the Company’s specifications. 22


15

From time to time, as required, the Company initiates a focused effort to 1

address areas where the cycle-maintenance vegetation program may not adequately 2

address reliability needs. For example, prior to the 2012 hurricane season, we 3

patrolled and completed identified work on the circuits that had the most vegetation-4

related customer interruptions during the previous year. We also increased danger-5

tree removals and skyline trimming in areas that had been impacted by drought 6

conditions, and we conducted spring and late summer patrols of the trunk sections of 7

circuits to identify mortality of deciduous trees during the winter and summer 8

months, respectively. 9

10

Q22. WAS THE DAMAGE TO THE COMPANY’S TRANSMISSION AND 11

DISTRIBUTION SYSTEMS FROM HURRICANE ISAAC DUE TO 12

INADEQUATE VEGETATION MANAGEMENT? 13

A. No. The Company’s damage assessment observations during Hurricane Isaac did not 14

indicate inadequate vegetation management in its transmission or distribution line 15

rights-of-way. To the contrary, the Company experienced a high degree of 16

vegetation-related damage to its facilities from trees growing outside of the rights-of-17

way. The Company works with its customers to proactively mitigate high-risk trees 18

outside of its rights-of-way; however, obtaining customer consent to trim beyond our 19

rights-of-way is often difficult. 20

21


16

Q23. PLEASE DISCUSS THE COMPANY’S OTHER EFFORTS TO IMPROVE AND 1

MAINTAIN ITS INFRASTRUCTURE. 2

A. Between 2002 and 2011, the Company invested over $19.4 million in non-storm 3

transmission capital spending. Typically, new transmission structures are built to 4

withstand winds of at least 140 mph, with those nearer the coast built to withstand 5

winds of 150 mph.4 The more stringent design standards led to a significantly lower 6

number of transmission structures damaged in Hurricane Isaac compared to prior 7

storms. In addition, the Company’s current transmission inspection program includes 8

sounding wood poles to identify defects and climbing inspections of structures to 9

identify poles or components for structural integrity and mitigate item(s) that may be 10

out of specification. Other programs to maintain and improve transmission reliability 11

include frequent infrared inspections, routine substation inspections, aerial patrols 12

two times per year, transformer oil monitoring and analysis, animal mitigation, relay 13

testing and maintenance cycle, and targeted replacement programs for shield wires 14

and breakers. 15

It is important to note that ENO, given its compact, urbanized service area, 16

has significantly less transmission line miles than other EOCs. As a result, ENO is 17

able to achieve a shorter cycle to inspect its 430 wooden transmission poles. ENO’s 18

current inspection cycle is 3.14 years meaning that each of the current 430 wood 19

poles are inspected approximately every third year. Given this aggressive schedule, 20

the average annual rejection rate for wood transmission poles is 0.62%. 21 4 Since 2002, the minimum design wind speed required by the National Electric Safety Code (“NESC”) for the majority of the Louisiana coastline has been 140 mph. A 150 mph minimum design wind speed is required for the extreme tip of the Louisiana delta.


17

With respect to distribution, the Company’s infrastructure is subject to 1

rigorous inspection and maintenance. The LPSC-jurisdictional EOCs (ELL and 2

EGSL) generally inspect their wood poles on a twelve-year cycle. However, over the 3

past few years, pole inspections for ENO have exceeded the pace required to maintain 4

the normal 12-year cycle. An average of over 6,600 poles have been inspected 5

annually (2010, 2011, and 20125) on the East Bank of Orleans Parish, an amount that 6

exceeds by more than 50% the 4,400 annual inspection quantity required for ENO to 7

maintain the normal 12-year cycle. The Company’s distribution wood pole 8

inspection programs include: 9

1. Vendor Inspected Poles – The Company selects an outside vendor specializing 10

in the analysis and inspection of utility poles; one such vendor is Osmose 11

Utilities Services, Inc. These vendors inspect poles from the ground up to 12

detect any decay and any potential deterioration that would impact a wood 13

pole’s strength. These methods include visual inspection, sounding, and boring 14

the wood utility poles. 15

2. Asset Management Program Inspections – The Company’s Asset Management 16

organization has several programs that perform similar inspections on 17

distribution assets including: 18

a. Targeted Circuits – Targeted Circuits is a program designed to address 19

the Company’s devices based on a threshold level of customer 20

interruptions and frequency of outages. This program requires 21

specially-trained lineman to perform a pole to pole inspection of these 22 5 The totals for 2012 include poles inspected up to Hurricane Isaac making landfall.


18

circuits using methods similar to those methods used by pole inspection 1

vendors. 2

b. Backbone Circuits: The Backbone Circuits program is a proactive 3

program designed to inspect a certain number of circuit “backbones” or 4

the trunk section of a circuit to identify and correct any issues that may 5

cause a future outage. The same sets of specially-trained lineman 6

perform these inspections throughout the year. 7

Vendor inspections along with Asset Management programs allow the 8

Company to perform roughly 6,600 pole inspections annually. 9

10

C. Storm Restoration Plan 11

Q24. DESCRIBE THE COMPANY’S GENERAL PLANNING TO ADDRESS MAJOR 12

STORMS. 13

A. The EOCs currently maintain a single, integrated storm plan called the Emergency 14

Operations Plan (“EOP”), which applies to all EOCs and business functions. The 15

EOP provides the basic structure, processes, guidelines, responsibilities, and 16

reference data necessary for appropriate stages of emergency preparedness and 17

response to be followed for orderly transition from routine business operations to 18

emergency operations and restoration in the event of either the threat or impact of 19

severe weather, other natural disasters, and/or security related events that affect 20

normal operations. The EOP focuses primarily on the restoration of transmission and 21

distribution infrastructure and service, and it also addresses coordination with the 22


19

generation, business continuity, and corporate support functions. A copy of the EOP 1

is attached as Exhibit DPD-4 to my testimony. 2

3

Q25. PLEASE DESCRIBE THE ORGANIZATIONAL STRUCTURE EMBEDDED IN 4

THE EMERGENCY OPERATIONS PLAN. 5

A. A successful restoration plan depends on strong leadership and decision-making as 6

well as coordination and cooperation. To ensure clear, coordinated lines of 7

responsibility across all levels of the organization, the EOCs have adopted the 8

Incident Command System (“ICS”) structure that is a key feature of the federal 9

government’s National Incident Management System. Within this structure, the 10

management organization includes the following command functions: (1) Office of 11

Chief Executive (“OCE”); (2) System Incident Commander; (3) State, Business 12

Function, and Support Function Incident Commanders; (4) System Command Center; 13

(5) State Command Center (under the leadership of the respective State Presidents); 14

(6) Business Function (Unit) Command; (7) Emergency Support Function Command; 15

and (8) Business Continuity Command. 16

As these command functions indicate, major incident response often requires 17

management at both the System and State levels. Under the EOP, however, when a 18

single business function or State is the only area involved in a particular incident and 19

there is no System Command activation, Business Function/State Incident 20

Commanders perform all roles of the Incident Commander in their respective 21

organizations.. Both the System Incident Commander and the State Incident 22

Commander receive support from their respective Command Staff and General Staff. 23


20

I attach as Exhibit DPD-5 to my testimony a high-level organizational chart 1

that shows the command structure under the current EOP. 2

3

Q26. WHAT ARE THE RESPONSIBILITIES OF THE SYSTEM INCIDENT 4

COMMANDER? 5

A. The System Incident Commander has the highest level of emergency management 6

responsibility and authority and leads the implementation of the EOP. The System 7

Incident Commander directs the System Command Center (“SCC”) and is responsible 8

for overall incident management, including, but not limited to, activating the SCC, 9

ensuring incident safety, establishing incident command, coordinating activities of the 10

Command Staff and General Staff, coordinating with the Business Continuity 11

Command, which reports to Entergy Corporation’s OCE on support and resource 12

requirements, coordinating with the Nuclear, Fossil, and Gas Operations Business 13

Functions, which have their own EOPs, ensuring appropriate communications with 14

customers, as well as key governmental, regulatory, and emergency management 15

contacts, determining incident objectives and strategies to be followed, approving 16

requests for additional resources or release of resources, approving incident action 17

plans; approving use of auxiliary personnel, ordering demobilization of incident when 18

appropriate, ensuring incident records are maintained and complete, and authorizing 19

information release to media. The System Incident Commander also facilitates 20

overall internal and external resource procurement and allocation among the EOCs 21

and oversees prioritization decisions at the System level to ensure stability of the 22

overall generation and transmission network. 23


21

1

Q27. WHAT IS THE SYSTEM COMMAND CENTER AND WHERE IS IT LOCATED? 2

A. The SCC provides centralized System coordination, management, and support for 3

emergency operations and restoration of transmission and distribution infrastructure 4

and service. The primary location of the SCC is either at the Power House (an 5

Entergy conference facility located in Jackson, Mississippi, that has meeting spaces, a 6

cafeteria, and sleeping facilities) or the Transmission Headquarters Building in 7

Jackson, Mississippi, depending upon the activation level required for a particular 8

event. 9

10

Q28. PLEASE DESCRIBE INCIDENT COMMAND AT THE STATE LEVEL. 11

A. The Entergy System’s transmission and distribution emergency organization is 12

divided into four States and includes six legal entities, three in Louisiana and one 13

each in Arkansas, Mississippi, and Texas. Each EOC is led by a President and Chief 14

Executive Officer and has an Operations VP/Director who performs the State Incident 15

Command responsibilities and provides leadership in the State Command Center. 16

The State Incident Commander leads the restoration efforts within that state and 17

reports to the System Incident Commander. As mentioned earlier in my testimony, I 18

am the State Incident Commander for Louisiana which includes ENO. 19

20

Q29. PLEASE EXPLAIN THE ROLES OF THE COMMAND STAFF. 21

A. The Command Staff is assigned to carry out staff functions needed to support the 22

System and State Incident Commanders. These positions include the Public 23


22

Information Officer, the Customer Experience Officer, the Safety Officer, and the 1

Governmental Liaison Officer. The Public Information Officer is responsible for 2

coordination, development, and communication of response and restoration 3

information with employees, customers, and the media. The Customer Experience 4

Officer works closely with the Public Information Officer and is responsible for 5

ensuring that timely, accurate, and complete information is communicated to 6

customers. The Safety Officer is responsible for overall safety and health activities 7

associated with emergency operations and restoration. The Governmental Liaison 8

Officer is responsible for coordinating emergency issues with various 9

governmental agencies. 10

11

Q30. PLEASE EXPLAIN THE ROLES OF THE GENERAL STAFF. 12

A. The General Staff is responsible for the functional aspects of the incident command 13

structure. The General Staff consists of the Planning, Resource, Logistics, 14

Operations, Administration, and Supply Chain Section Chiefs. Each Section Chief is 15

responsible for the overall function processes, staffing, training and execution for the 16

incident. Each Section Chief reports directly to the System or State Incident 17

Commander. 18

19

Q31. DOES THE COMPANY CURRENTLY CONDUCT STORM PREPAREDNESS 20

AND PLANNING ACTIVITIES? 21

A. Yes. The Company has a robust storm preparedness and planning program that 22

includes training, annual storm drills, and exercise sessions, as well as detailed after 23


23

the fact lessons-learned processes. Storm preparedness is a continual process; 1

preparation for the next storm begins immediately following a major storm or storm 2

threat. 3

4

Q32. PLEASE DESCRIBE THE ANNUAL STORM DRILLS. 5

A. Each year prior to hurricane season (typically in the April – May timeframe), the 6

Company conducts storm preparedness drills that test the storm plan and 7

communication links and include the SCC, the EOCs, Transmission/Energy Delivery 8

and other Business Units, and Corporate support groups. Currently, the Entergy 9

System conducts a System-wide drill (the “SCC Storm Drill”). In addition, each state 10

in which the EOCs operate conducts its own separate drill.6 The drills are developed 11

and facilitated with the guidance of a third-party consultant. They test readiness in 12

the following areas: (1) personnel knowledge of storm roles and responsibilities; 13

(2) personnel familiarity with the System storm response processes; (3) mobilization 14

procedures; (4) logistical preparedness; (5) damage assessment processes; (6) mutual-15

aid and contractor management processes; and (7) overall management and oversight 16

practices. 17

In addition to testing storm readiness, the annual drills also function as a 18

training tool. Participants get “hands-on” experience in emergency response, which 19

provides an opportunity to both practice and improve the performance of emergency 20

response personnel and to test response processes. The drills consist of a hurricane or 21

6 Furthermore, the Gas Operations and Business Function, which operates only in Louisiana, has its own EOP and Incident Commander and conducts its own separate storm drill each year.


24

ice storm simulation with many other days of preparation and post-drill critiquing. 1

The drills begin with activation of the Command Center and then continue with 2

mobilization through notification and activation of key personnel, including 3

operations, logistics, and support teams, with restoration roles and responsibilities. 4

The drills are evaluated by the third-party consultant on a real-time basis and 5

compared to events of similar size and scope. The evaluation is then reviewed, 6

lessons from the drills are compiled, and gaps related to the drill performance are 7

addressed. 8

The Louisiana portion of the 2012 storm drills were held from April 30 to 9

May 3 at the Louisiana EOCs’ State Command Center in Baton Rouge. 10

Representatives from the LPSC and the Louisiana Governor’s Office of Homeland 11

Security and Emergency Preparedness (“GOHSEP”) were among those who attended 12

the 2012 storm drills in addition to EOC personnel. 13

14

Q33. PLEASE DESCRIBE THE LESSONS-LEARNED PROCESS FOLLOWING THE 15

STORM DRILLS. 16

A. Upon completion of the storm drills, evaluators hold a workshop and gather lessons 17

learned from drill participants. The System Section Chiefs then prioritize the items 18

and work with the State Section Chiefs to assign an individual with the responsibility 19

of ensuring that the improvements are incorporated into storm restoration processes. 20

21


25

Q34. HAS THE EXPERIENCE GAINED IN RECOVERING FROM HURRICANE 1

ISAAC ALSO AFFECTED THE COMPANY’S PREPAREDNESS FOR FUTURE 2

HURRICANE SEASONS? 3

A. Yes. In addition to the lessons learned process following the annual storm drill, the 4

Company conducted “lessons learned” sessions after Hurricane Isaac and is 5

implementing improvements and changes to systems and processes in order to 6

respond even better to future major events. 7

8

Q35. PLEASE DESCRIBE THE COMPANY’S LESSONS-LEARNED PROCESS 9

FOLLOWING A STORM EVENT. 10

A. The lessons-learned process starts with a set of meetings shortly after a major storm 11

restoration to identify key lessons learned. Meetings are organized by the leaders of 12

each functional area within the response organization and are conducted at both the 13

State level and the System level. Each operating area and functional support team 14

performs an assessment of the previous storm event or threat, focusing on 15

improvement opportunities and lessons learned from the response and restoration 16

efforts. The summaries are then collected and forwarded to the System level. 17

At the end of the storm season, the System Outage Response (“SOR”) group 18

convenes a one to two-day workshop to review all the lessons learned that have been 19

raised, make any adjustments that are warranted, and prioritize the lessons learned 20

based on their perceived value to future storm restorations. At this workshop, the 21

team agrees on the key improvements that need to be made before the next storm 22

season and assigns individuals to implement the changes. As the process changes 23


26

are designed, the new process is documented, and the SOR team updates the 1

appropriate plans. The SOR group then circulates the plan throughout the 2

organization along with any additional information specific to the improvements. If 3

necessary, training documents are prepared to support the revision to the processes. 4

Examples of lessons learned that came out of the Hurricane Isaac restoration 5

include: 6

Expediting the check-in process, including re-evaluating check-in team 7

processes and equipment; 8

Further refining the damage prediction tool to improve accuracy of resource 9

needs; and 10

As I discuss later in my testimony, improving communication of outage 11

information to customers. 12

13

Q36. HAS ENTERGY RECEIVED RECOGNITION FOR ITS STORM RESPONSE 14

AND IMPLEMENTATION OF ITS STORM PLAN? 15

A. Yes. The EOCs continue to be nationally recognized for their leadership and 16

excellence in utility emergency restoration events. The Entergy System is the only 17

utility group to receive awards from the Edison Electric Institute for response 18

excellence every year since the Institute established the award. In January 2013, 19

Entergy Corporation was honored with the 2012 Emergency Recovery Award for its 20

work in restoring service to customers after Hurricane Isaac. 21


27

Entergy Restoration Awards 1 2

Year Edison Electric Institute (EEI) Emergency Response Award(s) 2013 Emergency Recovery Award, after Hurricane Isaac; Emergency Assistance

Award, PHI, PECO, Public Service Gas & Electric, and Consolidated Edison, after Hurricane Sandy; and Kentucky Power and Appalachian Power, after June 2012 derecho weather event

2012 Emergency Recovery Award, after numerous severe weather events in 2011, including tornadoes, winter storms, river flooding, severe thunderstorms, a drought, and Tropical Storm Lee; Emergency Assistance Award, Atlantic City Electric, after Hurricane Irene

2011 Emergency Assistance Award, American Electric Power Co., after December 2009 snowstorm

2010 Emergency Recovery award, after January 2009 ice storm 2009 Emergency Recovery Award, after Hurricanes Gustav and Ike; Emergency

Assistance Award, AEP Texas, after Hurricane Dolly 2008 Emergency Assistance Award, Public Service of Oklahoma, after severe

winter ice storms 2007 Emergency Assistance Award, Ameren, after back-to-back severe

Midwestern thunderstorms 2006 Emergency Recovery Award, after Tropical Storm Cindy, and Hurricanes

Katrina and Rita; Emergency Assistance Award, Florida Power & Light, after Hurricane Wilma

2005 Emergency Assistance Award, numerous Florida-based utilities, after Hurricanes Charley, Frances, Ivan, and Jeanne

2004 Emergency Assistance Award, Dominion Virginia and Baltimore Gas & Electric, after Hurricane Isabel

2003 Emergency Assistance Award, Kansas City Power & Light and Oklahoma Gas & Light, after an ice storm

2002 Emergency Recovery Award, after Entergy’s 2000 ice storm 2001 Emergency Assistance Award, Florida Power & Light, after Hurricane Irene 2000 Emergency Assistance Award, Florida Power & Light, after Hurricane Floyd 1999 Emergency Recovery Award, after Hurricane Georges

3

Q37. HOW DOES THE COMPANY DETERMINE ITS PERSONNEL AND RESOURCE 4

NEEDS AFTER A MAJOR STORM? 5

A. The Company employs damage prediction models as a first step in determining the 6

personnel and resources that will be necessary following a storm. Using the 7

forecasted track and intensity of the storm, these assessments approximate the 8


28

damage that a storm may cause to the Company’s infrastructure, including poles, 1

transformers, spans of wire, and cross arms. Based upon that estimate, the numbers 2

of transmission, distribution, and vegetation workers required for the restoration are 3

determined. Those model outputs are compared against past operational experience, 4

which includes comparisons to previous storms with similar characteristics, and the 5

estimated number and type of line and vegetation crews are determined and presented 6

at a System Resource conference call prior to the storm’s impact. 7

Actual damage assessment begins as soon as the weather safely permits after 8

landfall or impact, and distribution and transmission personnel are dispatched in 9

vehicles to perform preliminary assessments of the damage to the system. As weather 10

conditions improve, helicopters are mobilized to expedite the damage assessment 11

process. On the distribution system, scouts first patrol backbone feeders serving 12

critical customers, followed by the rest of the feeder backbones. Major branches of 13

each circuit are inspected next, followed by laterals, with individual customer service 14

lines being assessed last. The scouts document on circuit maps the repair needs that 15

they observe at each location. The process for assessing damage to the transmission 16

system is similar, but it mainly uses aerial patrols in order to cover large amounts of 17

territory as efficiently as possible. 18

Data from the ground and aerial patrols is collected, and the Planning Section 19

at the System Command Center, with input from the State Command Centers, quickly 20

assesses the extent of the damage and the most expeditious restoration plan needed to 21

establish a stable generation, transmission, and distribution network. The damage 22


29

assessments also provide a basis with which to adjust resource allocations among 1

regions or networks or to request additional resources. 2

3

Q38. HOW DOES THE COMPANY ACQUIRE RESOURCES TO RESTORE SERVICE 4

TO ITS CUSTOMERS? 5

A. The Company recognizes the importance of restoring service as safely and quickly as 6

possible for the health, safety, and needs of their customers, and also for the sake of 7

the regional and national economy. Thus, the Company pre-arranges for a variety of 8

logistical and specialized equipment resources that are staged throughout the 9

potentially affected service areas so that restoration can begin safely as soon as a 10

storm passes. 11

The support from many ESI employees is critical to restoration efforts. Other 12

EOCs that are not impacted directly by a storm also support restoration efforts by 13

supplying line crews, management teams, logistical personnel, safety specialists, call 14

center personnel, scouts, material supply chain personnel, and dispatching personnel, 15

as well as material and equipment. The Company also partners with mutual-16

assistance utilities and have pre-negotiated contracts with third-party contractors to 17

obtain materials and services at reasonable rates. 18

19

Q39. TO WHAT EXTENT DOES THE COMPANY RELY ON OTHER UTILITIES TO 20

PROVIDE ASSISTANCE FOR RESTORATION? 21

A. To obtain assistance in responding to major events, the Company is an active 22

participant in several mutual-assistance groups, including EEI, the Southeastern 23


30

Electric Exchange (“SEE”), the Texas Mutual Assistance Group, and the Midwest 1

Mutual Assistance Group. The various mutual-assistance arrangements generally 2

provide that the assisting utility will furnish labor and materials on a not-for-profit 3

basis. Therefore, when the Company requires assistance, it pays the actual charges 4

for the assisting utility’s crews, at the same rates the assisting utility pays its crews. 5

Labor rates, transportation charges, labor overhead, and corporate overhead are 6

reimbursed at the same rates that the assisting utility accounts for these charges in its 7

normal course of business. The Company reimburses actual expenses for lodging, 8

meals, fuel, and consumable materials. The assisting utility makes no profit and 9

suffers no loss. This arrangement is reciprocal, as the same rules apply when the 10

Company is assisting other utilities outside of the Entergy System footprint. 11

12

Q40. TO WHAT EXTENT DOES THE COMPANY RELY ON THIRD-PARTY 13

CONTRACTORS TO ADDRESS RESTORATION NEEDS? 14

A. The Company relies on third-party contractors year-round for routine distribution and 15

transmission line construction and maintenance, as well as vegetation management 16

activities. For storm restoration, the Company draws on internal maintenance and 17

capital construction “base load” crews before requesting mutual assistance from other 18

utilities and/or additional third-party contract crews. 19

20


31

Q41. HOW DOES THE COMPANY MANAGE AND ALLOCATE INCOMING OFF-1

SYSTEM RESOURCES? 2

A. Standardized check-in procedures help the Region and Network Commands ensure 3

that incoming crews understand safe work practices and the Company’s distribution 4

system, and that the condition of the crews’ equipment will not endanger the public, 5

themselves, or other restoration workers. After checking-in, off-system crews are 6

given a safety orientation and provided with important area-specific information. The 7

Company also initiates electronic tracking of detailed off-system crew information, 8

including inventorying the equipment that these crews have brought with them and 9

the identity of each crew member present. 10

In addition to the initial safety orientation, a more specific safety meeting is 11

conducted once a storm crew arrives at the local network office. Particulars about the 12

local area, system, hospitals, contact points, and safe work practices are provided and 13

reviewed by storm crew members. During this time, the local network also 14

disseminates local emergency response information and acquires information 15

regarding the storm crew’s skill set and equipment in stock in order to make an in-16

network restoration assignment to the crew. A storm crew not requiring rest time due 17

to traveling to the service area will begin restoration activities immediately. Crews 18

needing rest are directed to lodging facilities to begin an 8-hour rest period and 19

preparation for the next work day. As a guideline, employees and contractors follow 20

a work schedule of 16 hours followed by 8 hours of rest during emergency restoration 21

operations after hurricanes, ice storms, and other types of emergency conditions. 22

This schedule is designed to deliver maximum restoration productivity while also 23


32

providing a safe work environment for individuals engaged in restoration efforts. 1

Other factors, such as heat, humidity, mental fatigue, and restoration-effort duration 2

may necessitate additional rest periods. 3

The Company assigns a Crew Leader to each storm crew to direct storm crew 4

restoration efforts and maintain continuous interface with the storm crew until it is 5

reassigned or released. This ensures that restoration personnel understand safe work 6

practices, working hours, work assignments and location, records management 7

requirements, system configurations and voltages, switching procedures, 8

communication protocols, and the logistics surrounding food, lodging, fuel, and 9

material. Crew Leaders address the storm crew’s questions/concerns should they 10

have any or forward them along to the appropriate person to address them 11

accordingly. At the distribution level, work is generally dispatched to storm crews to 12

repair damage to equipment affecting the greatest amount of customers, starting with 13

substations, feeder trunk circuits, lateral and sub-lateral circuits, transformers, and 14

service drops, all in accordance with the following established priorities: 15

Priority Zero (0) – Facilities important to the Company’s restoration process 16

(supporting supply lines to generation units, supporting our centralized dispatch 17

centers, emergency response centers such as Network/Region/State Command 18

Centers, customer information centers); 19

Priority One (1) – Facilities that impact the risk to public safety or public health 20

(primary feeds to hospitals, local emergency preparedness centers, police/fire 21

stations, major sewer/water systems, Red Cross or other housing facilities such as 22

churches); 23


33

Priority Two (2) – Facilities that impact civil defense (military facilities, radio/TV 1

stations, airports, major land line and cell phone communications systems, major 2

government facilities, oil/gas facilities that have national impact); 3

Priority Three (3) – Facilities that impact customers on the Company’s medical 4

assistance list, nursing homes, assisted living facilities, after hours care facilities; 5

and 6

Priority Four (4) – Facilities serving all other customers. 7

When no longer needed for restoration activities in the area assigned, the off-system 8

storm crew is reassigned to a different crew leader, network, or region, or it is 9

released. 10

11

Q42. DOES THE COMPANY MAINTAIN INVENTORIES THAT ARE SUFFICIENT 12

TO ADDRESS DAMAGE RESULTING FROM STORMS OF THE MAGNITUDE 13

OF HURRICANE ISAAC? 14

A. No. It would not be cost effective for the Company to maintain inventories of 15

materials large enough to address the extent of damage caused by Hurricane Isaac or 16

other major storms because of the quantities of materials that would have to be stored. 17

However, the Company usually keeps stores and inventories ample enough to handle 18

normal construction and repair needs without calling for additional supplies from 19

outside vendors. Prior to hurricane season, the Company also increases its 20

inventories of critical materials so that restoration can begin as soon as it is safe to do 21

so after a storm passes. Because a major restoration will exhaust those inventories 22

quickly, the Company’s supply chain organization manages strategic contracts with 23


34

vendors to allow for quick response to match critical inventories and lead times to 1

damage estimates. Both before and after a storm, the Company places those materials 2

in strategic sites to facilitate restoration. 3

4

IV. HURRICANE ISAAC’S IMPACT ON THE COMPANY 5

A. Description of Hurricane 6

Q43. PLEASE DESCRIBE HURRICANE ISAAC. 7

A. Hurricane Isaac formed from a tropic wave that moved westward from the coast of 8

Africa on August 17, 2012. The wave continued westward across the tropical 9

Atlantic, and, on August 21, the disturbance was upgraded to a tropical storm. On 10

August 26, the center of the storm entered the southeastern Gulf of Mexico, reaching 11

hurricane strength the morning of August 28. 12

Hurricane Isaac made its first of two Louisiana landfalls at approximately 13

6:45 p.m. CST on August 28 in Plaquemines Parish, Louisiana, just southwest of the 14

mouth of the Mississippi River, as a Category 1 hurricane with maximum sustained 15

winds of 80 mph. The storm then reentered the Gulf of Mexico and made a second 16

landfall just west of Port Fourchon, Louisiana, at approximately 2:15 a.m. CST on 17

August 29. Hurricane Isaac’s tropical-storm-force winds extended roughly 185 18

nautical miles from the center in the northeastern quadrant, and hurricane-force winds 19

extended roughly 60 nautical miles from the center in the same quadrant. The storm 20

lingered over Louisiana, subjecting the greater New Orleans area to significant 21

rainfall and sustained winds of over 39 mph (tropical storm force) for 54 hours, twice 22

the duration of prior major hurricanes. The hurricane weakened to a tropical storm 23


35

and ultimately was downgraded to a tropical depression during the afternoon of 1

August 30. 2

Although Hurricane Isaac was a Category 1 hurricane, the long duration of 3

tropical force winds, the storm track and slow forward motion, the storm’s size, and 4

significant rainfall occurring at the same time as the maximum storm surge all 5

resulted in large amounts of water being pushed into the coastal areas of the northern 6

Gulf of Mexico. In many areas, water levels exceeded those from Hurricanes Katrina 7

and Gustav. Storm surges of 12-13 feet occurred along the Louisiana coast in the 8

Mississippi Delta southeast of New Orleans.7 Storm rainfall totals from Hurricane 9

Isaac of 8-12 inches, with amounts reaching over 20 inches in some areas of eastern 10

Louisiana, caused numerous rivers to exceed major flood stage and added to the 11

flooding caused by storm surge. 12

In several locations around the state, including Slidell, Mandeville, 13

Madisonville, LaPlace, Braithwaite, and Lafitte, storm surge and waves overtopped 14

levees, causing substantial and widespread flooding. The decision was made by state 15

officials to intentionally breach a levee in Plaquemines Parish that was trapping more 16

than twelve feet of flood waters within the city of Braithwaite and surrounding areas. 17

Likewise, state crews breached a levee in the town of Lafitte, Louisiana, to help drain 18

devastated areas of Lower Jefferson Parish. 19

Hurricane Isaac’s relentless winds caused extensive damage to the Company’s 20

distribution and transmission facilities. The storm caused widespread customer 21

7 As an example of the storm’s extreme force, the U.S. Geological Survey documented that Hurricane Isaac’s strong winds and storm surge caused a backward flow of the Mississippi River.


36

outages across the area served by ENO, as well as the areas served by ELL and 1

EGSL. At the peak of outages in Louisiana, approximately 59% of the combined 1.2 2

million customers in the Louisiana EOC’s service area were without service. 3

Including ELL-Algiers, peak outages in New Orleans occurred on the night of 4

Wednesday, August 29th reaching 163,632 customers without power.8 5

Exhibit DPD-6 depicts the pathway of Hurricane Isaac. 6

7

Q44. HOW DID THE COMPANY PREPARE FOR HURRICANE ISAAC AS IT 8

DEVELOPED IN THE GULF OF MEXICO? 9

A. Before the storm system entered the Gulf, the Company began its preparations, which 10

continued until landfall. In addition to forecasts provided by the National Hurricane 11

Center (“NHC”), the Company utilized Impact Weather of Houston to keep the 12

Company apprised of developing weather situations, thus offering two different 13

perspectives and varying expertise. 14

The SOR team began monitoring a tropical disturbance on Saturday, August 15

18, 2012, that eventually became Hurricane Isaac. On Monday, August 20, the 16

System Incident Commander was notified of a potential event. Starting Tuesday, 17

August 21, the EOCs began daily communications updates to potentially affected 18

employees. On the same day, the System Incident Commander began to 19

conditionally offer resources to Florida utilities that were requesting assistance in 20

anticipation of being impacted by Hurricane Isaac, subject to the understanding that 21

those resources would be held until it was certain that the Entergy region was clear of 22 8 Peak outages in New Orleans occurred on the night of Wednesday, August 29, 2012.


37

the storm’s path. On Thursday, August 23, the path of Isaac shifted westward, with 1

the NHC putting the metro New Orleans area within the westernmost boundary of the 2

forecast zone for the first time. As of August 24, however, the Florida Panhandle was 3

still projected as the impact zone. On that same day, Entergy’s Incident Commander 4

Steering Committee held a call establishing a State of Alert, triggering response 5

personnel to activate, begin working the storm checklists, and prepare to be donors to 6

the mutual assistance program. 7

The NHC’s early morning forecast on Sunday, August 26, still projected the 8

storm’s landfall to be near Pensacola, Florida, with only the westernmost boundary of 9

the forecast cone even approaching the Louisiana-Mississippi border: 10

11

Later that same morning, the impact zone shifted westward, placing New Orleans in 12

the forecast zone, but with landfall projected at Mobile, Alabama. By that evening, 13


38

Isaac’s path had shifted even further west with the NHC forecast cone now centered 1

on the Louisiana-Mississippi border. 2

The decision was made to fully activate the Entergy SCC effective Monday, 3

August 27 at 9:00 a.m. The Louisiana State Command Center was fully activated as 4

of 12:00 noon that same day and we began to activate the staging sites. Our efforts 5

included reviewing storm plans, reviewing and implementing checklist action items, 6

stockpiling materials, pre-staging contractors, placing employees on alert, and 7

moving equipment from possible flood areas. The Company continued to monitor the 8

storm’s forecast and reevaluate predictive damages and resource requirements as the 9

storm unexpectedly slowed in approach and threatened a much longer duration of 10

impact than originally forecasted. This resulted in additional requests and acquisition 11

of resources consistent with the predictive damage assessments and latest storm 12

forecast. 13

We also took necessary steps to communicate with the public, government 14

officials, parish and State emergency operations centers, and others to help them 15

understand our plans for safely and quickly returning our communities and customers 16

to normal operation, what would be involved in emergency-power restoration, public 17

safety messages, and how to contact us after the storm. 18

19

Q45. HOW DID THE COMPANY DETERMINE THE NUMBER OF OUTSIDE 20

RESOURCES THAT WERE NECESSARY FOR THE RESTORATION EFFORT? 21

A. As the Company monitored Hurricane Isaac’s approach, the storm’s projected path 22

shifted from Florida to Louisiana. As that path shift occurred, from the perspective of 23


39

resources, the Louisiana utilities shifted from being potential donor utilities to being 1

receiving utilities. At various stages, modeled damage prediction estimates fluctuated 2

from low resource needs to high, then back down. In order to manage this significant 3

uncertainty, several decisions were made as Hurricane Isaac moved into the Gulf of 4

Mexico and west toward Louisiana. 5

Based on early predictive damage models and storm forecasts, Louisiana 6

initially requested 3,853 restoration workers (including scouts, vegetation, and 7

transmission and distribution line personnel) to arrive over 3 days beginning August 8

27 (meaning a planned, staged arrival over Monday, Tuesday, and Wednesday for 9

that first wave). As the storm’s movement slowed and models predicted the need for 10

more resources, Louisiana requested two additional waves of approximately 3,000 11

off-system resources each as shown in the table below. This brought the total number 12

of tool workers either committed or requested for the Louisiana State Command to 13

10,033 as of August 29, 2012. 14

Wave Date Committed/ Requested

Resources D-Line

T-Line

D-Vegetation

T- Vegetation

Scout Safety Total

1 27-Aug

Committed Incumbent 600 65 400 50 60 8 Incremental 1,600 160 700 - 190 20

Total 2,200 225 1,100 50 250 28 3,853 2 29-

Aug Committed Incremental 2,000 1,000 40 3,040

Total Committed to Louisiana 4,200 225 2,100 50 290 28 6,893 3** 29-

Aug Request Incremental 2,000 100 1,000 40 3,140

Total Resources 6,200 325 3,100 50 330 28 10,033 **Wave 3 request was based on damage assessment findings and crew availability. 15

16

Twenty-one mutual aid companies and 138 pre-contracted companies answered the 17

request for aid. Workers from 25 states provided restoration assets to the Isaac 18


40

restoration in New Orleans and the rest of Louisiana.9 In addition to the mutual aid 1

companies and contractors with existing contracts, the EOCs also contracted with 21 2

additional companies that were being released from Florida utilities. As the 3

additional contractors were en route to Louisiana, the Company negotiated and 4

executed contracts, with all but one contract completed before arrival. 5

Resources from the first wave largely arrived as planned and were well-6

positioned to begin restoration when it was safe to do so. An early arrival of waves 2 7

and 3 brought some challenges, but proved to be critical to the success of the 8

restorations, as discussed later. Because restoration resources had previously 9

mobilized to Florida based on Isaac’s early forecast track, the geographic proximity 10

of waves 2 and 3 resulted in those resources arriving at the same times on Thursday 11

and Friday. While this caused congestion at some check-in sites, it did not affect the 12

overall pace of restoration because those crews arrived sooner than would normally 13

be expected had they travelled from their home states. 14

In total, the EOCs employed over 12,200 field tool workers for Hurricane 15

Isaac.10 This work force included ENO employees, employees from other EOCs, 16

workers from mutual-assistance utilities, line contractors, and vegetation workers. 17

Logistical support personnel and restoration support personnel totaled an additional 18

9 States providing restoration (tool) workers included: Alabama, Arkansas, Connecticut, Florida, Georgia, Illinois, Indiana, Kansas, Kentucky, Louisiana, Massachusetts, Maryland, Mississippi, Missouri, North Carolina, New Jersey, New York, Ohio, Oklahoma, Pennsylvania, South Carolina, Tennessee, Texas, Virginia, and Wisconsin. This includes mutual-assistance and off-system resources that were acquired from contractors and through our memberships and contacts with the SEE, EEI Mutual Assistance, Midwest Mutual Assistance, and Texas Mutual Assistance Association. 10 At peak, 1,886 tool workers and additional support personnel engaged in restoration on the East Bank of Orleans Parish.


41

4,000 workers, which included EOC employees as well as off-system resources, 1

bringing the total amount of workers engaged in the restoration to over 16,200. 2

3

Q46. PLEASE EXPLAIN THE COMPANY’S ACTIVITIES ONCE THE STORM MADE 4

LANDFALL. 5

A. By the time the storm made landfall, we had completed the items mentioned above, 6

and our first priority after landfall was to establish communication links with the 7

Louisiana Regional Command Centers to ensure all Core Teams were safe. 8

The allocation of scouting and repair crews was made based on pre-landfall 9

damage estimates, with adjustments made as early damage assessments became 10

available. Even though aerial bucket truck restoration could not commence until 11

winds fell below 30 mph, early damage assessments were made by circuit bosses 12

doing ground patrols even while winds were well above 30 mph. The preliminary 13

assessments required us to make some adjustments to the allocation of scouts and 14

repair crews to various regions. 15

As assessments came in, I reviewed preliminary damage reports to understand 16

the condition of our transmission and distribution grids. I monitored the daily 17

damage assessments and restoration progress along with the deployment of resources 18

to ensure all areas had adequate material and restoration workers. I also made field 19

visits to personally observe the level of damage from the storm and assess the field 20

restoration progress, as well as the effectiveness of my management team’s plan and 21

its execution. I also kept senior management informed throughout the restoration 22

process. 23


42

1

Q47. HOW DID HURRICANE ISAAC COMPARE TO PREVIOUS STORMS THAT 2

AFFECTED LOUISIANA IN TERMS OF CUSTOMER OUTAGES? 3

A. As summarized in the table below, Hurricane Isaac caused the fourth largest amount 4

of system peak customer outages in the Entergy System’s history. 5

Storm System Peak Outages Hurricane Katrina 1,100,000 Hurricane Gustav 964,000

Hurricane Rita 800,000 Hurricane Isaac 787,000

6

The storm’s destructive winds and storm surge caused over 707,000 customer outages 7

for the EOCs in Louisiana (including ENO) at the peak of the storm. Peak outages in 8

New Orleans occurred on the night of Wednesday, August 29th with 163,632 9

customer outages. By the next morning, Thursday August 30th, before it was safe to 10

begin “bucket truck” restoration efforts, the total outages had dropped slightly to 11

158,134. 12

13

B. Damage to the Company’s Infrastructure 14

Q48. PLEASE SUMMARIZE THE DAMAGE TO THE COMPANY’S DISTRIBUTION 15

SYSTEMS AS A RESULT OF HURRICANE ISAAC. 16

A. Although Hurricane Isaac was classified as a Category 1 hurricane, it was a powerful 17

and damaging storm that subjected the Company’s infrastructure to strong winds for 18

twice the duration of prior major hurricanes. Indeed, the severity rating of Hurricane 19

Isaac (15 out of 50) was comparable to Hurricane Gustav (20 out of 50). Hurricane 20


43

Isaac caused extensive damage to the Company’s distribution infrastructure, resulting 1

in numerous broken poles and many more leaning poles. When possible, leaning 2

poles were straightened (as opposed to replaced) in order to promptly restore service. 3

ENO replaced approximately 167 distribution poles and approximately 173 4

distribution transformers. In addition, Orleans Parish together had 142 feeder lines 5

experience an outage on at least a portion of the circuit during the Isaac event (124 for 6

ENO Metro and 18 for ELL Algiers).11 Other damage inflicted to ENO’s distribution 7

system required the repair or replacement of approximately 174 Conductor-miles, 8

917,474 Conductor (lbs.), and 9,152 Insulators. The storm also damaged or destroyed 9

approximately 3,301 cross-arms for ENO and a total of approximately 11,572 cross-10

arms for the System, which is more than in any prior storm affecting the Entergy 11

region. 12

13

Q49. PLEASE SUMMARIZE THE DAMAGE TO THE COMPANY’S TRANSMISSION 14

SYSTEMS AS A RESULT OF HURRICANE ISAAC. 15

A. Hurricane Isaac did not cause the level of transmission-system damage that the 16

Company experienced during Hurricane Gustav in 2008. But, again, Hurricane Isaac 17

was a powerful storm that brought unique challenges. 18

19

11 These figures represent feeders that were out of service for greater than five minutes.


44

Q50. PLEASE SUMMARIZE THE DAMAGE TO THE COMPANY’S PRODUCTION 1

FACILITIES. 2

A. The Company’s production facilities sustained no damage and its sister EOCs 3

received only limited damage to their generation facilities. 4

5

Q51. DID THE COMPANY SUSTAIN ANY DAMAGE TO FACILITIES THAT FALL 6

WITHIN THE “OTHER” CLASS OF COSTS? 7

A. Yes. The Company also sustained other damage to facilities that are not strictly 8

classified as Production, Transmission, or Distribution. The costs included in the 9

Other class concern general facilities that are owned, leased, and/or operated by ENO 10

and other support costs that benefit the various functional groups, such as repairing 11

damage to service-center sites. The other support costs also include fees paid for 12

external auditing of storm costs and legal fees. 13

14

Q52. WAS THE DAMAGE TO THE COMPANY’S INFRASTRUCTURE CONSISTENT 15

WITH OTHER INDICATORS OF HURRICANE ISAAC’S LONG DURATION? 16

A. Yes. In particular, Hurricane Isaac’s long duration over the greater New Orleans area 17

resulted in significant storm debris. Two weeks after Hurricane Isaac made landfall, 18

hurricane debris still clogged the streets of Jefferson Parish, and, as late as three 19

weeks after landfall, piles of leaves, branches, and black bags were still on many 20

curbs throughout Orleans Parish. 21

22


45

V. THE RESTORATION WORK 1

Q53. HOW QUICKLY WAS ENO ABLE TO RESTORE SERVICE TO ITS 2

CUSTOMERS AFTER HURRICANE ISAAC? 3

A. Once conditions after Isaac were safe to commence aerial bucket truck restoration, 4

crews safely restored power to more than 85% of Louisiana customers within 5 days 5

(92% across all of the EOCs). Customers in New Orleans fared better still; less than 6

five days after the restoration had begun, 95% of outages in New Orleans had been 7

restored to service. Given that certain members of the public and media suggested 8

that the Hurricane Isaac restoration was progressing slower than would be expected 9

from a Category 1 storm event, it is helpful to gain perspective by comparing the 10

restoration progress during Hurricane Isaac with other events. As shown in the chart 11

below, it took 7 days to reach the 85% restoration level for Hurricane Ike in 2008, 8 12

days for Gustav in 2008, 13 days after Rita in 2005, and 16 days following Katrina in 13

2005, excluding extended restoration customers (Hurricane Katrina, in particular, left 14

over 122,000 customers incapable of taking electric service). 15


46

1

As this chart indicates, the EOCs restored service to more customers faster 2

after Hurricane Isaac than after any other major storm affecting the Entergy service 3

territory. William Bryan, Deputy Assistant Secretary for Infrastructure Security and 4

Energy Restoration with the U.S. Department of Energy’s Office of Electric 5

Reliability and Energy Delivery, publicly commended the Entergy utilities for their 6

response to Hurricane Isaac: 7

“The typical benchmark for utility companies is to 8 restore power to 70% of customers within five to seven 9 days. The pace of Entergy’s restoration, restoring 10 power to 90% of its customers in four to five days, is 11 unbelievable . . . . This is one of the best restorations 12 we’ve seen in recent memory and Entergy should be 13 commended.” 14

15 16


47

Q54. WHAT WERE THE SPECIFIC TIME FRAMES FOR RESTORATION OF 1

SERVICE FOLLOWING HURRICANE ISAAC? 2

A. Across all of the affected EOCs, of the customers who could be restored (i.e., did not 3

require reconstruction of their personal property), 61% were restored by the 3rd day; 4

80% were restored by the 4th day, 92% were restored by the 5th day, and 99% were 5

restored by the 6th day. The following chart summarizes the restoration progress: 6

7

Again, the Hurricane Isaac restoration was the fastest restoration in the Entergy 8

System’s history when compared with other major storms affecting each EOC’s 9

service territory. By September 5, the seventh day of the Hurricane Isaac restoration, 10

power was restored to 99.8% of customers in New Orleans. The pace of the 11

Company’s restoration highlights the importance that the Company places on quickly 12

restoring service to protect the health and safety of its customers. 13

14

Isaac Restoration Progress by Day

The Isaac customer outages and percent customers restored include customers of the following Operating Companies: ELL, EGSL, ENO, EMI, and EAI.


48

Q55. WHAT IS THE STATUS OF THE COMPANY’S RESTORATION EFFORTS? 1

A. Power-restoration efforts are complete in all areas affected by Hurricane Isaac in the 2

Company’s service area. 3

4

Q56. PLEASE DESCRIBE HOW THE COMPANY MANAGED AND IMPLEMENTED 5

THE CHECKING-IN OF CREWS ARRIVING FROM OUTSIDE OF LOUISIANA. 6

A. As I briefly discussed earlier, Hurricane Isaac’s early forecast tracks caused mutual 7

assistance utilities to mobilize to Florida, and Entergy’s utilities were prepared to 8

send crews to Florida as well. As the forecast tracks gradually shifted to the West, 9

many crews released from Florida were two days closer to the EOCs’ service areas 10

than the normal drive from their home states. 11

Ultimately, about 60% of responding resources came from coastal states east 12

of Louisiana, arriving through the I-10 corridor into New Orleans East. In addition to 13

this influx of resources from the East, further resources from areas farther northeast 14

were also arriving through the I-10 corridor into New Orleans East, which required us 15

to rapidly modify the “Gateway” check-in process that we had used in prior storms, 16

which process utilized multiple check-in sites spread across the state. In order to 17

accommodate the large influx of resources that were arriving through one entryway 18

along the I-10 corridor, we decided to activate two stand-alone check-in sites on the 19

East side of the service area: Bullard Road in New Orleans East and the Northshore 20

Harbor Center in Slidell. On Thursday morning, August 30, the Slidell check-in site 21

began to flood, ultimately resulting in the access road from I-10 being closed. 22


49

Incoming crews were re-routed to the Bullard Road site and there was an 1

additional check-in site in New Orleans East that was operational on Friday morning. 2

Considering that the entryway from the west was closed the next day due to flooding 3

at I-10 and Highway 51 in LaPlace, having this volume of restoration workers 4

checking-in in New Orleans East ultimately proved to be a critical success factor in 5

restoration efforts. Had these crews checked-in outside of the affected service areas, 6

they could have been stranded and not available for an additional 24 to 48 hours. 7

8

Q57. DESCRIBE THE WORK DONE BY THE EOCS TO RESTORE SERVICE TO 9

CUSTOMERS AS QUICKLY AND SAFELY AS POSSIBLE. 10

A. The following is a summary of the significant areas of transmission and distribution- 11

related activity: 12

1. The EOCs worked to secure outside resources in a safe and timely manner in 13

order to mobilize the workforce required to effectively execute the restoration. 14

Over several days, the EOCs added over 9 times the number of tool workers 15

used for normal day-to-day operations. This ramp-up was unusually steep due 16

to the high number of crews that were positioned in Florida to respond to 17

expected damage in that state due to Hurricane Isaac’s original projected path. 18

2. A high priority was given to re-establishment of the transmission grid, which 19

is essential to the restoration of the Company’s substations, which, in turn, is 20

essential to allowing end-use service to be restored to customers. 21

3. Even before the storm, the EOCs installed flood-control barriers around 22

substations. Because Hurricane Isaac brought unprecedented flooding to 23


50

some areas, these measures did not eliminate substation flooding, but they 1

were effective in mitigating damage. 2

4. Core teams of restoration workers were positioned in or near the affected 3

areas to allow service to be expeditiously restored in as little as 24 hours to 4

essential service customers (hospitals, Parish Emergency Operation Centers, 5

sewer plants, water plants, and other essential customers) where possible. 6

5. The EOCs acquired specialized equipment of limited availability to be used in 7

the restoration effort, such as airboats, barges, marsh buggies, track machines, 8

cranes, and helicopters. Helicopters allowed for effective and timely damage 9

assessment, canvassing large areas, and identifying concentrations of damage, 10

replacing activities that would normally have taken weeks if performed on 11

foot or in a vehicle. Airboats allowed crews to gain access to key substations 12

in flooded areas to energize breakers and provide power to customers who had 13

not flooded. 14

6. Another massive undertaking was raising, coordinating, and providing 15

logistics and support to a team of over 16,200 workers. 16

17

Q58. WHAT SIGNIFICANT OBSTACLES DID THE COMPANY ENCOUNTER IN 18

REPAIRING DAMAGES FROM THE HURRICANE? 19

A. The significant obstacles that the Company encountered can generally be grouped 20

into the following areas: 21

1. Path and Slow Movement of the Storm 22

2. Forecast Challenges 23


51

3. Flooding/Accessibility 1

4. Shelter in Place 2

5. Technology and Social Media 3

The Path and Slow Movement of Hurricane Isaac: 4

Hurricane Isaac subjected much of Louisiana to powerful winds for an 5

extended period of time, causing extensive damage to the Company’s infrastructure. 6

Due to its large size, the hurricane produced a relatively large storm surge. 7

The National Hurricane Center reported sustained winds of over 39 mph 8

(tropical storm force) for 54 hours in the greater New Orleans area and 60 hours in 9

Louisiana, compared to 21 hours (New Orleans) and 24 hours (Louisiana) for 10

Hurricane Katrina and 27 hours (New Orleans) and 39 hours (Louisiana) for 11

Hurricane Gustav. Around the time of landfall, the forward speed of the hurricane 12

slowed to approximately 5 mph, exposing the Company’s infrastructure to strong 13

winds for nearly twice the duration of prior major hurricanes. 14

Forecast Challenges: 15

Hurricane Isaac proved challenging to weather experts, and forecast 16

challenges affected customer expectations. The storm made two separate landfalls 17

along the Louisiana coast the evening of Tuesday, August 28 and in the early 18

morning hours of Wednesday, August 29, despite a projected landfall along the 19

Florida Panhandle as late as Sunday, August 26. As I described above, Hurricane 20

Isaac’s unexpectedly slow movement inland caused it to linger over the greater New 21

Orleans area for more than two days, through the morning of Thursday, August 30. 22

This impacted the Company’s ability to dispatch assessment and repair crews into the 23


52

field, which delayed the start of aerial bucket restoration work (e.g., work performed 1

from “bucket trucks”) until August 30 (referred to as “Day 1” of restoration) and full 2

ramp up of restoration until August 31. This also gave the impression of a slower-3

than-expected reduction in customer outages. 4

In addition, because Hurricane Isaac had been forecasted to impact the Florida 5

peninsula after it entered the Gulf of Mexico, many of the resources that would 6

normally have been acquired by the EOCs were already acquired and deployed to 7

Florida utilities several days before landfall along the Louisiana coast. When 8

Hurricane Isaac’s path shifted to Louisiana, thousands of resources that normally 9

would have arrived in waves from their home states over multiple days instead 10

arrived much closer together from in and around Florida within 12-16 hours. The 11

large influx of workers caused some congestion in checking-in off-system workers, 12

establishing logistics, and getting resources allocated to networks. But these unique 13

circumstances allowed resources to be deployed to restoration more quickly when 14

compared to prior storms because of their availability and close proximity to the 15

Company’s service territory when the storm made landfall. 16

Flooding/Accessibility 17

Ground saturation caused by excessive rainfall (over 20-inches in parts of the 18

New Orleans area) resulted in flooded rights-of-way which further hindered damage 19

assessment progress and limited restoration access. This extreme rainfall, combined 20

with intense storm surge and long duration of strong winds, resulted in unprecedented 21

flooding in several communities. The storm’s rainfall also led to flooding and 22


53

closures of interstate highways into southeastern Louisiana (I-10 and I-55) and the 1

flooding of a crew check-in site located in Slidell. 2

The Company also had difficulty gaining suitable access to damaged 3

distribution infrastructure because in New Orleans, overhead lines are often located at 4

the rear of customer lots, which impeded access of Company equipment and slowed 5

restoration efforts. 6

Shelter in Place 7

Likely due to Isaac’s Category 1 rating and inconsistent forecasts, many 8

residents of Southeastern Louisiana did not evacuate and instead “sheltered in place,” 9

despite warnings from officials that they could be without power for several days.12 10

Once the storm appeared to be over, customers who were out of service expected to 11

see obvious progress on restoration. As I discuss below, however, a critical step in 12

the restoration process is performing an initial damage assessment that involves a 13

line-by-line visual inspection by qualified scouts to determine damages in order to 14

prioritize where to send appropriate resources (restoration personnel, supplies, 15

materials, and equipment) in order to safely and efficiently restore power. The 16

damage assessment process utilizes small vehicles that may not have necessarily been 17

marked clearly enough for customers to notice that this type of activity was taking 18

place. Additionally, assessing damage to the electrical system was also done by foot 19

and in some cases helicopter, which takes time. Further, customers generally may not 20

have been aware of the point at which winds in their area diminished below the 30 21

12 Mandatory evacuation was limited to lower Plaquemines and St. Charles Parishes, with “shelter in place” for all other areas.


54

mph threshold required for aerial restoration work to begin, which may have led them 1

to conclude conditions were acceptable before they in fact were. Also, little to no 2

public evacuation created traffic congestion, making utility crew movement through 3

the damaged areas more challenging. 4

Technology and Social Media 5

Given the evolving role of technology and social media, other factors that 6

altered restoration expectations by our customers included: (1) wireless 7

communications were largely unaffected, enabling customers to access the internet 8

via smart phones and tablets to obtain real-time information; (2) social media sites 9

like Facebook and Twitter were also used by customers to gain and share real-time 10

information; and (3) web-based tools such as the View Outage mapping software 11

available at www.entergy.com were heavily used by customers to better understand 12

restoration progress in their areas. 13

14

Q59. PLEASE DESCRIBE THE ROLE PERFORMED BY DAMAGE ASSESSMENT 15

SCOUTS AS PART OF THE HURRICANE ISAAC RESTORATION. 16

A. Scouting the Company’s facilities after a hurricane and before directing repair crews 17

to neighborhoods is essential to planning and executing an effective restoration. An 18

additional benefit of scouting is that it allows for unsafe situations and obstacles to be 19

identified in advance of crews arriving on the scene, which is especially important 20

considering the amount of out of state workers that were involved in the restoration 21

process and that were not familiar with their surroundings. The scouting conducted in 22


55

the opening phases of the Hurricane Isaac restoration laid the ground work for a safe 1

and efficient restoration. 2

To that end, in addition to ENO scouting personnel, the EOCs brought in 3

approximately 300 damage assessors from outside of Louisiana to support local 4

assessment. They included a combination of contractors and mutual-assistance 5

workers from other electric utilities. In addition, EOC resources from outside 6

Louisiana were deployed in the damaged area. Once they finished their damage 7

assessment role, these resources, depending on their qualifications, were added into 8

the restoration effort and used by local teams according to their skill sets or 9

discharged. 10

Although it has been widely publicized during and after the storm that aerial 11

bucket restoration activities cannot commence until winds subside below 30 mph 12

(i.e., the manufacturer’s limitation on handling material with aerial lift equipment), 13

we did engage our scout teams to do damage assessment activities at times when the 14

wind speeds exceeded this threshold. Scouts, who can operate in small trucks, cars, 15

and on foot, were able to initiate some modified initial assessments as the weather 16

allowed. Nevertheless, safety is a priority for all restoration workers, and the Region 17

Manager determines when it is safe for scouting activities to commence or continue 18

during a major storm event. Any number of variables, including flooding, falling or 19

flying debris, wind speed/gusts, visibility, rainfall, driving conditions, navigability of 20

city streets, and fatigue of the work force, could stop scouting operations if, in the 21

Region Manager’s judgment, conditions are no longer safe to continue. 22


56

The damage assessment of transmission lines, substations, and distribution 1

backbone is prioritized and directed by the Entergy SCC. Workers generally scout 2

facilities (1) prior to a storm moving into an area for pre-storm activities (t – 96 3

hours); (2) during a storm, as the weather allows, when conditions are deemed safe 4

and for emergency situations (t = 0 hours), and (3) immediately following a storm’s 5

exit from the affected area when conditions are deemed safe for scouts to conduct 6

post-storm preliminary reports (t + 24 hours).13 During a major restoration effort, 7

scouts are responsible for determining the extent and severity of damage and 8

reporting damage assessments in an accurate and timely manner. 9

During the storm, limited utility crews that stayed on location visually 10

patrolled feeder trunks from their vehicles as long as it was safe to do so. Once the 11

hurricane passed through the Company’s service areas and additional scouts began 12

arriving, a full scale damage assessment to the affected infrastructure was able to 13

commence. For personnel locally domiciled inside of the impacted area, the damage 14

assessment and scouting process began when conditions (winds, rain, and debris) 15

subsided enough such that it became safe to be in the field. For personnel travelling 16

to Louisiana from outside the impacted area (including off-system personnel), the 17

process began when they safely arrived at the local network office. 18

While nearly continuous monitoring of the System takes place before and 19

while a storm is moving through the area, the scouting and damage assessment 20

process requires additional time to assess the system after winds have subsided. 21

13 The prolonged exposure to high winds associated with Hurricane Isaac did not permit assessment to begin at t + 24.


57

Workers are assigned to document damages sustained by substations, feeder trunk 1

circuits, lateral and sublateral circuits, and transformers per the restoration priorities 2

in the Company’s restoration plan. Even lines that have been completely and 3

accurately assessed prior to winds falling below the 30 mph threshold for bucket 4

truck restoration activity must be re-scouted for additional damage before restoration 5

work can start because scouts cannot determine the full extent and severity of damage 6

to a circuit until damaging conditions have abated. 7

Once the storm exits the affected service area, the Damage Assessment 8

function has 3 primary phases: Initial Assessment Report, Backbone Feeder 9

Assessment, and the Full Scale Assessment. Louisiana’s State Damage Assessment 10

Supervisor has the responsibility to direct the assessment activities for distribution 11

facilities within his area and report findings using standardized reporting templates. 12

The process for Transmission Damage Assessment is similar but also extensively 13

uses aerial patrols to cover large amounts of territory as rapidly as possible. The 14

findings of these patrols are transmitted to the SCC Planning Team for prioritization. 15

Assessment details are captured in a high-level summary of damage for poles, 16

cross-arms, transformers, spans of wire, and vegetation needs. These details are used 17

to plan material acquisition and resource allocations. A circuit map is also marked 18

with detailed repair needs at each location. This circuit map is the primary planning 19

tool used by the field management team on a daily basis. 20

While the post-storm damage assessment facilitates the creation of an efficient 21

restoration plan, it also enables reconciliation between the predictive damage models 22

and the actual damage early enough in the process for resource requests to be adjusted 23


58

up or down as needed without either delaying arrival of restoration workers or 1

committing resources to areas where they are under-utilized. 2

3

Q60. WHEN DID THE DAMAGE ASSESSMENT SCOUTS BEGIN SCOUTING THE 4

AREAS AFFECTED BY HURRICANE ISAAC? 5

A. Some immediate scouting took place on a limited basis during the storm when 6

conditions were considered safe enough to do so by local management or when 7

responding to emergency situations. Damage assessment efforts ramped up early on 8

Thursday, August 30 and, in some heavily affected areas, took two days to complete. 9

10

Q61. PLEASE DESCRIBE THE SAFETY PERFORMANCE OF THE RESTORATION 11

WORKFORCE. 12

A. The safety of our transmission and distribution employees and restoration workforce 13

was the highest priority of ENO, and the restoration safety performance was generally 14

outstanding. There were zero fatalities among all of the workers employed by the 15

EOCs for the restoration of Hurricane Isaac. The total number of OSHA recordable 16

injuries was 13, with only 1 of those resulting in lost time. In addition, we 17

experienced only 21 American National Standards Institute (“ANSI”) recordable 18

vehicle accidents. 19

20

Q62. WHAT STEPS DID YOU TAKE TO ENSURE SAFETY AMONG YOUR 21

EMPLOYEES AND THE THOUSANDS OF CONTRACTOR PERSONNEL IN 22

LINE CREWS, VEGETATION CREWS, AND OTHER CAPACITIES? 23


59

A. All employees helping with restoration were given a safety orientation prior to 1

starting work. A copy of the orientation was also given to all of the supervisors of the 2

visiting crews. The orientation included all safety rules, locations for medical 3

attention, identification of local hazards, and contact numbers for all safety 4

professionals in case questions arose. An Entergy System safety coordinator was 5

assigned to each area with instructions to make contact with all crews each day. 6

The Company’s Crew Leads were provided updated safety information every 7

day in order to inform the visiting crews where hazards had been identified. In 8

addition, a “Safety Stand Down” topic was developed by our Safety department to be 9

used in the Company’s lead safety meetings. Visiting contractors were encouraged to 10

attend at least one safety meeting with their crews each day. 11

Workers were required to report all accidents to the Entergy System’s Safety 12

organization. Additionally, First Aid Stations located in staging areas reported each 13

instance of first aid and medical attention. Also, Safety Bulletin Boards were located 14

at each staging site, and contained safety reports, contact information, local medical 15

facilities, etc. The restoration workforce took steps to ensure the safety of the public 16

as well, and crews were required to perform a job safety assessment for each 17

restoration project. 18

19

Q63. WHY DID THE COMPANY DEEM IT IMPERATIVE TO RESTORE SERVICE 20

TO ITS CUSTOMERS AS QUICKLY AS POSSIBLE? 21

A. The availability of electric service following storms is critical to the initial recovery 22

process for the affected areas, including the regional economic recovery, particularly 23


60

in the case of Hurricane Isaac, where there was little to no public evacuation in the 1

affected areas. New Orleans has essential infrastructure that are electric-dependent, 2

such as water, sewage, communications, radio, television, hospitals, the Central 3

Business District, and large industrial customers such as the Air Products facility in 4

New Orleans East and the Port of New Orleans. Any delays in getting these units 5

back in service could have had potentially serious consequences not only to New 6

Orleans but for the regional economy. For these reasons, the importance of restoring 7

service as quickly as possible was reinforced at daily meetings with the Council and 8

its Advisors, the Mayor of New Orleans, and the Governor’s Office of Homeland 9

Security and Emergency Preparedness (“GOHSEP”) personnel. 10

11

Q64. WOULD YOU TRY TO RESTORE SERVICE JUST AS QUICKLY IF YOU HAD 12

TO DO IT OVER AGAIN? 13

A. Yes. Restoring service following storms that cause severe damage like Hurricane 14

Isaac, especially during the months of August and September when high temperatures 15

are still peaking, is not just a factor of economics or weighing the storm recovery 16

costs against the economic benefits of having electricity. A paramount concern is the 17

health and safety of the community, which requires restoring service to hospitals, 18

water facilities, and other critical facilities. Our overriding concern was to get the 19

lights back on as quickly and safely as possible, which was a message that ENO 20

received clearly from governmental officials. That is not to say that we proceeded 21

indiscriminately regarding costs, safety, efficiency, and prudence. To the contrary, 22

we paid considerable attention to those concerns. We restored power as quickly and 23


61

efficiently as we could, giving due consideration to those concerns, and we would do 1

so again if faced with a major hurricane today. 2

Q65. HAS THE COMPANY’S STORM PREPAREDNESS AND RESPONSE 3

FOLLOWING HURRICANE ISAAC BEEN REVIEWED BY A THIRD PARTY? 4

A. Yes. As mentioned earlier, Quanta Technology recently issued a report, which is 5

attached as Exhibit DPD-10 to my testimony, addressing among other things, ENO’s 6

storm readiness and storm response following Hurricane Isaac. The report concludes 7

that ENO has a thorough and comprehensive approach to emergency management 8

that comports with industry standards. The report further concluded that: 9

a. The EOCs made efficient and effective use of resources, and results after the 10

storm reflected advance planning and execution of a storm response plan; and 11

b. The restoration was by most industry benchmarks very efficient. Restoration 12

of 95% of customers within five days exceeds what is normally considered 13

effective restoration times in major storms. 14

15

VI. INTERACTION WITH CUSTOMERS AND STAKEHOLDERS 16

Q66. PLEASE DESCRIBE THE COMPANY’S COMMUNICATION WITH ITS 17

CUSTOMERS IN ADVANCE OF HURRICANE ISAAC. 18

A. The Company communicated to customers through the news media several days prior 19

to the storm’s landfall, placing hurricane preparedness advertisements on local radio 20

and in print publications well in advance of the storm in an effort to inform customers 21

and the general public on safety and preparedness issues. Our Customer Service 22


62

Managers participated in live interviews on television and radio stations throughout 1

each area threatened by Hurricane Isaac to discuss our storm preparations. 2

Customer interaction begins well before a particular storm has entered the 3

Gulf of Mexico. Specifically, ENO has someone stationed in the City’s Emergency 4

Operations Center, with other first responder representatives, during emergencies and 5

major events to coordinate activities. 6

7

Q67. PLEASE DESCRIBE THE COMPANY’S INTERACTION WITH ITS 8

CUSTOMERS DURING AND FOLLOWING THE STORM. 9

A. Officials on behalf of the Company communicated and interacted with customers on a 10

daily basis. Customers could call the 1-800-ENTERGY and 1-800-9OUTAGE 11

telephone numbers 24 hours per day to talk to agents in the system network. Senior 12

management appeared frequently on local television newscasts and radio talk shows, 13

and the Company provided regular press releases and information updates to the 14

newspapers. Given our customers’ desire for timely information, ENO, along with 15

the other EOCs, took various additional steps such as quickly opening 21 Customer 16

Information Centers (“CICs”) in more heavily affected areas, 16 of which were 17

located in Louisiana. Through the CICs, customers were given restoration 18

information and estimates for return of service to their particular location. CIC 19

locations and times of operation were advertised in local newspapers and on 20

television and radio interviews. 21

Unique to Hurricane Isaac compared to prior hurricanes such as Gustav and 22

Ike were multi-media options used extensively to communicate with customers. The 23


63

EOCs also answered the more than 875,000 inbound calls, with over 443,000 1

answered by a customer service representative at a 76% service level (meaning a call 2

was answered by a person within 30 seconds). The EOCs initiated over 2 million 3

outbound calls and almost 1.4 million text messages to customers with updated 4

information, interacted with over 32,000 unique customers through social media, 5

investigated and responded to over 500 customer inquiries received through social 6

media and electronic mail, and, finally, embedded Customer Service and other 7

personnel in the various state, parish, and local Emergency Operations Centers to 8

provide face-to-face contact. The EOCs also provided information to their customers 9

through the www.entergy.com website, which contained web-based outage and other 10

key information. 11

As I mentioned above, one of the lessons learned from Hurricane Isaac is the 12

need to address customer desires for more detailed outage information. The 13

Company has taken, and will continue to take, a number of additional steps intended 14

to enhance communication to customers during a major event, including: 15

Changes to the View Outage on-line mapping tool have been implemented to 16

provide customers with an updated Area View that highlights the general 17

geographic boundaries of an outage and gives the total customers affected in that 18

highlighted area. Additional Customer Service resources are being identified to 19

ensure that this view is updated twice per day. These additional resources will 20

directly address some customer frustration that was expressed during the 21

Hurricane Isaac restoration. The Company receives thousands of outage reports 22

in the aftermath of a hurricane, and, consistent with the magnitude of the 23


64

outages, it supplements its normal operations center workforce to help with 1

inputting data in the outage management system that provides information to 2

View Outage. Supplementing that assistance further can improve the timeliness 3

and accuracy of information appearing on View Outage after a major storm. 4

Gathering feedback through customer surveys, focus groups, and neighborhood 5

meetings to determine the most appropriate and effective means of 6

communicating information. 7

Holding community and business association meetings throughout the year to 8

educate local officials as well as the public about pre-event storm planning, the 9

restoration process, etc. 10

Sharing pre-event storm planning information more widely with regulators, local 11

and state officials, state and parish-level Emergency Operations Centers, and the 12

media. 13

Provide clear, practical messages to the public and external stakeholders in 14

advance of a storm event so that customers know more of what to expect. This 15

will be especially important when there is no mandatory evacuation ordered 16

during a given event. 17

During and after a storm event, focus efforts on providing relevant, timely, and 18

accurate information and messaging that our customers expect via the 19

communication channels they utilize most frequently. 20

Develop and deliver localized information using multiple channels (traditional 21

media as well as online, text and voice messaging, social media, etc.) so that our 22

customers can make appropriate plans and take action. 23


65

1

Q68. WHAT EFFECT DID THE HURRICANE HAVE ON THE COMPANY’S CALL 2

CENTER ORGANIZATION? 3

A. From August 29, 2012, when Hurricane Isaac made its second landfall, through 4

September 6, 2012, Entergy’s Customer Service Centers (“CSCs”) handled 875,722 5

total calls (both storm and “normal” business-related calls) with assistance from 6

Entergy employee volunteers and additional temporary contract workers. Of this 7

total, there were 443,791 calls handled by customer service representatives, 250,830 8

of which were outage-related calls. The remainder were handled by the automatic 9

interactive voice response (“IVR”) system, which allows customers to perform 10

several transactions (including reporting an outage) without speaking to a 11

representative. In addition to receiving calls, the CSCs performed the following 12

important activities: (1) making outbound calls to advise customers of changing 13

service commitment dates due to the redeployment of distribution operations’ 14

workforce to storm restoration; (2) recording of Network Overview Cases (“NOCs”) 15

information so that customers could hear the latest restoration status; (3) coordination 16

of the customer callback process; and (4) management of suspension and restoration 17

of account-collection activity within the jurisdictions during and after the storm. 18

The CSCs completed all pre-storm checklists and activated the special CSC 19

Storm Room in Jackson, Mississippi, as Hurricane Isaac developed in the Gulf of 20

Mexico. All CSCs and credit managers and staff worked throughout the event to 21

ensure that reasonable customer service was delivered from the CSCs and the credit 22

organization. 23


66

Pre-storm staffing projections were completed based on weather forecasts, 1

projected landfalls, and wind speed. Data from previous storms, specifically, 2

previously-experienced scenarios of storm restoration length, were used to determine 3

required staffing by employees, contractors, volunteers, and the Twenty First Century 4

Communications (“TFC”) outage management system.14 The CSCs were staffed with 5

customer service representatives (“CSRs”) on 12-hour shifts 24 hours a day, 7 days a 6

week throughout the storm event, with smaller staffing from midnight through 6:00 7

a.m. when call volume is historically lower. CSC manpower was supplemented by 8

the CSCs’ outsourced credit desk in Atlanta, Georgia; CSC support employees; 9

temporary employees; and volunteers from across the Entergy System. During peak 10

call periods, the CSCs employed up to 500 CSRs and 163 support staff and volunteers 11

answering calls. 12

For Hurricane Isaac, the peak call day was August 30, 2012, when CSCs 13

handled 156,594 calls. Of those calls, 69,576 were handled by a CSR. For 14

perspective, on a comparable weekday in August 2011, CSRs handled 30,650 calls, of 15

which 2,564 were outage calls. 16

17

Q69. PLEASE DESCRIBE THE COMPANY’S EFFORTS TO COMMUNICATE WITH 18

THE CITY OF NEW ORLEANS, STATE GOVERNMENTAL OFFICIALS, AND 19

THE STATE EMERGENCY OPERATIONS CENTER IN BATON ROUGE IN 20

ADVANCE OF, DURING, AND AFTER THE STORM. 21

14 TFC is a vendor that provides additional IVR capability when call volume exceeds the capacity of the Entergy IVRs.


67

A. The Company’s Regulatory Affairs and Governmental Affairs organizations are 1

primarily responsible for communication with the City Council, the Mayor of New 2

Orleans, and other State Governmental Officials. Prior to Hurricane Isaac, 3

Regulatory Affairs personnel were in direct communication with the Council and its 4

Advisors, and plans were made for alternative means of communication in case of 5

inaccessibility. During and after Isaac, two ENO employees manned the City EOC at 6

all times on 12-hour shifts providing estimated restoration times and other 7

information as Entergy’s EOP provides. Company personnel stationed around the 8

clock at the City EOC in City Hall provided situation reports at 6:00 a.m. and 5:00 9

p.m. to Lieutenant Colonel (“LTC”) Jerry Sneed, the Deputy Mayor of Public Safety 10

and Homeland Security. ENO’s team worked with Mayor Landrieu, LTC Sneed and 11

other civic leaders to adapt the restoration efforts to the take into account the City 12

leadership’s initiatives and priorities. 13

Moreover, Regulatory Affairs and Governmental Affairs personnel were 14

stationed alongside multiple state and national representatives, including the LPSC, at 15

the State Emergency Operations Center in GOHSEP for approximately 18 hours a 16

day until the state of emergency ceased. Additionally, the Company maintained 17

communication with the Louisiana State Police, the Louisiana National Guard, and 18

other representatives as needed as well as coordinated resources and assistance from 19

the National Guard during the restoration effort. 20

21


68


LOCAL GOVERNMENTAL OFFICIALS AND “FIRST RESPONDERS” IN 2

ADVANCE OF, DURING, AND AFTER THE STORM. 3

A. The Company’s Customer Service organization was primarily responsible for 4

communicating with local government officials and “first responders” before, during, 5

and after the storm. ENO, along with the otherEOCs, conducts a hurricane 6

preparedness presentation for first responders and elected officials each year in 7

advance of hurricane season. This meeting enables the EOCs to review their 8

restoration plan and proactively address questions and concerns from public officials. 9

In advance of the storm’s landfall, the Company’s Customer Service Managers met at 10

least daily with city, parish, and emergency management personnel to communicate 11

the steps the EOCs were taking to prepare for the storm. After the storm, the 12

Company’s Customer Service Managers were available in the City’s Emergency 13

Operating Center to provide restoration updates. Most importantly, the Company’s 14

Customer Service Managers were able to provide feedback to the State and Local 15

Command Centers concerning priorities received from city and parish officials and 16

emergency management personnel. The Company also has a Government 17

Communications Coordinator responsible for supplying information and assisting in 18

the coordination of ad hoc requests. This staff person is generally from the 19

Company’s Customer Service Manager group. 20

21


69


FEDERAL GOVERNMENTAL OFFICIALS IN ADVANCE OF, DURING, AND 2

AFTER THE STORM. 3

A. The System Command Center was in daily contact with the Federal Government 4

agencies and departments. The Command Center attempted to maintain single points 5

of contact with the Department of Energy which served as the funnel through for all 6

federal government requests. 7

After Isaac’s landfall, System Command Center and Regulatory Affairs and 8

Governmental Affairs personnel maintained regular communication with 9

representatives of various federal agencies that were assembled at a joint operations 10

facility in Baton Rouge, including the Department of Homeland Security, FEMA, the 11

Department of Energy, the Department of Defense and the Army Corps of Engineers. 12

Also after Isaac’s landfall, Regulatory Affairs and Governmental Affairs personnel 13

participated on daily conference calls with representatives of various federal agencies, 14

including FEMA and the Department of Energy. System and State Command Center 15

personnel also participated in and provided restoration information during daily 16

FEMA conference calls that included members of Louisiana’s Congressional 17

delegation. Furthermore, personnel at the System Command Center provided 18

information and updates to Southeastern Reliability Corporation (“SERC”) staff, 19

which then participated on daily North American Electric Reliability Corporation 20

(“NERC”) conference calls that included the FERC, the Department of Energy, the 21

Department of Defense, the Southwest Power Pool (“SPP”), the Midwest ISO 22

(“MISO”), the PJM Interconnection (“PJM”), the Nuclear Regulatory Commission 23


70

(“NRC”), the Department of Homeland Security, and the National Gas Association. 1

Representatives of the EOCs also had ongoing communications with the staffs of the 2

FERC and NRC to apprise them of restoration developments. 3

4

VII. RESTORATION RESOURCES AND COSTS 5

Q72. HOW DID THE NEED TO QUICKLY RESTORE SERVICE AFFECT COSTS? 6

A. Restoring power in a prompt manner after a major storm requires the Company to 7

incur significant costs over and above the costs of its normal operations. The 8

following items were significant cost drivers after Hurricane Isaac: 9

Additional Crews — To complete a prompt restoration, the Company had to 10

engage mutual-assistance utility partners and third-party line/vegetation 11

contractors that the Company had used in the restoration of past storms. In all, 12

mutual assistance from 21 other utilities and 138 contractors were utilized. Given 13

the extensive damage to vegetation and to transmission and distribution facilities, 14

the Company had to significantly supplement its existing workforce (by a factor 15

of nine) to clear debris, assess damage to facilities, and repair those facilities so 16

that service could be restored. 17

Overtime — Instead of working typical 40-hour weekly work shifts, employees 18

and contractors were required to work up to 112-hour weekly work shifts (16 x 7) 19

in order to restore service as quickly as possible. Under pre-arranged contracts, 20

the Company were therefore required to pay normal overtime labor rates 21

(typically one and one-half times the normal rate for a 40-hour work week) to 22


71

these workers, but no additional premiums were paid. A 112-hour weekly work 1

shift is nearly three weeks of work compressed into a single week. 2

Lodging — When personnel and crews are brought from outside the Company’s 3

service areas, the cost of these temporary labor forces not only includes labor, but 4

also includes lodging, food, and other related expenses. The challenge faced by 5

the Company to lodge restoration workers after Hurricane Isaac was due to 6

uncertainty of the storm’s projected path and the quick availability of off-system 7

resources that had mobilized to Florida. In addition, the large geographical area 8

of impact for Hurricane Isaac required the EOCs to set up 61 staging sites (45 in 9

Louisiana), including check-in, staging, parking, catering, and turn-key sites or 10

sleeper sites. 11

Food — In addition to lodging, the workers had to be fed. The EOCs provided 12

approximately 288,726 meals to workers during the restoration effort. 13

Materials Prices — The Company utilized existing vendors for materials as 14

much as possible. 15

Fuel – The EOCs acquired approximately 989,000 gallons of fuel to support 16


18

Q73. WOULD SERVICE RESTORATION HAVE TAKEN SIGNIFICANTLY LONGER 19

HAD THE COMPANY NOT INCURRED THESE INCREMENTAL COSTS? 20

A. Yes, service restoration would have taken exponentially longer. Given the number of 21

man-hours required for restoration, it could have taken more than six months using 22


72

only the Company’s employees and base-load contractors seven days a week, 16 1

hours per day. 2

3

Q74. IN THE LIGHT OF THE CIRCUMSTANCES (I.E., THE NEED TO RESTORE 4

SERVICE AS QUICKLY AS POSSIBLE), DID THE COMPANY ACT 5

PRUDENTLY IN ACQUIRING RESOURCES TO RESTORE SERVICE TO ITS 6

CUSTOMERS? 7

A. Yes. The Company recognized the importance of restoring service as quickly as 8

possible not only for the health, safety, and convenience of its customers, but also for 9

the sake of the regional and national economies. Nonetheless, the Company was 10

cost-conscious throughout the process, utilizing less expensive resources first, when 11

possible, and continually re-assessing the level of human resources employed so that 12

the Company did not have more resources at its disposal than it actually needed and 13

could productively utilize. 14

15

Q75. HOW DID THE COMPANY ENSURE THAT IT DID NOT ACQUIRE MORE 16

PERSONNEL OR MATERIALS THAN IT NEEDED OR OVERPAY FOR SUCH 17

RESOURCES? 18

A. The Company pre-staged crews at strategic locations in anticipation of the storm’s 19

impact, ramped up resources to a peak, and then re-allocated and released crews as 20

progress was made. As crews completed work at one location, they were shifted to 21

another location based on need and skill set. As the restoration progressed and 22

workers were shifted between Sub-Networks, the State Command Center, with input 23


73

from local management, made determinations regarding the number of crews that 1

could effectively and safely work in an area. When it was determined that the 2

effective number had been reached, we began re-allocating or releasing those 3

resources and decommissioning the staging sites supporting those resources. As a 4

staging site was decommissioned, we re-assessed the number of contractors that the 5

remaining staging sites could support, and we reassigned the remaining crews to other 6

staging sites. We closely monitored crew needs to ensure that crews were utilized in 7

an efficient manner, that we did not have more crews than we needed at any given 8

time, and that we consolidated staging sites and logistical resources when it became 9

possible to do so. 10

The Company also implemented a structured process to review the invoices 11

received from contractors to ensure that they are accurate. Invoices are sent to the 12

Contractor Invoice Processing Team (“CIPT”), where they are reconciled against 13

documentation provided by the Operations personnel that received the services. 14

Invoices are reviewed using this documentation, such as approved time records and 15

deployment documentation, to make sure that the work was performed and payment 16

is proper. The CIPT also reviews invoices against contract terms and ensures that the 17

appropriate accounting information is applied to each invoice. All invoices verified 18

to be correct are then approved for payment. Any disputed invoices are disallowed or 19

sent back to the contractors for additional information. Company witness Orlando 20

Todd provides additional information about the CIPT process for capturing, verifying, 21

and monitoring costs. 22

23


74

Q76. WHAT ARE THE TOTAL TRANSMISSION-RELATED COSTS OF THE 1

COMPANY’S RESTORATION EFFORT? 2

A. ENO’s total-Company transmission-related costs for Hurricane Isaac restoration were 3

$623 thousand. Please see Exhibit DPD-8, which is a report summarizing costs by 4

major cost category for ENO. These costs include the transmission-related storm 5

recovery costs incurred through December 31, 2013. Please see Exhibit OT-3 6

attached to the testimony of Mr. Todd for the electronic indices containing the 7

transactions underlying the costs for ENO, in the Transmission Class that I sponsor. 8

9

Q77. WHAT ARE THE TOTAL DISTRIBUTION-LEVEL COSTS OF THE 10


A. The total ENO Distribution costs were $45.6 million. Please see Exhibit DPD-8, 12

which is a report summarizing costs by major cost category for ENO. These costs 13

include the distribution-related storm recovery costs incurred through December 31, 14

2013. Also see the testimony of Company witness Orlando Todd as well as Exhibit 15

OT-3 attached to his testimony, which include the transactions underlying the total 16

Distribution-level costs. 17

18

Q78. WHAT ARE THE TOTAL PRODUCTION-RELATED COSTS OF THE 19


A. As set forth in Exhibit DPD-8, ENO incurred total production-related restoration and 21

reconstruction costs of $297 thousand. 22

23


75

Q79. WHAT ARE THE TOTAL “OTHER” STORM RECOVERY COSTS RELATED 1

TO HURRICANE ISAAC? 2

A. As set forth in Exhibit DPD-8, through December 31, 2013, ENO incurred total costs 3

associated with the Other class of $782 thousand. Company witness Orlando Todd 4

provides additional detail about the Other class of costs in his testimony. 5

6

VIII. CONCLUSION 7

Q80. WERE THE TRANSMISSION AND DISTRIBUTION CLASS COSTS INCURRED 8

BY THE COMPANY TO ADDRESS HURRICANE ISAAC REASONABLE AND 9

NECESSARY? 10

A. Yes. The costs were necessary to restore service to customers and to reconstruct our 11

transmission and distribution systems promptly and safely in the wake of the damage 12

caused by Hurricane Isaac in the areas served by the Company. While the amounts 13

expended on materials, labor, and the other cost categories were substantial, it was 14

essential that the Company restore service as quickly as reasonably possible. Had the 15

Company not acquired these resources in the manner that it did, the restoration of the 16

transmission and distribution systems to provide power to essential facilities like 17

water plants, sewage-treatment plants, hospitals, nursing homes, and law enforcement 18

facilities, as well as industries critical to the regional, state, and national economies, 19

would have taken substantially longer, as would the time period for restoring power 20

to other customers throughout the System. Thus, under the circumstances, the costs 21

were necessary to restore power safely, timely, and efficiently. 22


76

The Company ensured the costs were reasonable by putting in place 1

appropriate measures to procure and monitor the material and personnel resources 2

used for the restoration of its transmission and distribution systems. A large majority 3

of the storm recovery costs were incurred according to pre-existing contracts with 4

service providers and vendors and cost-based agreements with mutual-assistance 5

utilities, which ensured that the Company did not have to pay a premium for those 6

resources. With respect to the costs incurred from other service providers and 7

vendors, the Company utilized appropriate measures to procure and monitor those 8

resources so that the prices were reasonable, the vendors were not overpaid, and the 9

vendors’ services were terminated as soon as they were no longer needed for the 10


Given the urgent demand for timely service restoration, the Company was not 12

in a position to bargain-shop for services and materials. The priorities of service 13

restoration, protecting public health and welfare, preserving strategic energy supplies, 14

and supporting emergency responders took precedence over the pursuit of cost 15

reductions that ultimately would have added months to the restoration process. 16

Nevertheless, the Company has years of experience in emergency restoration 17

procurement, and as a highly-skilled purchaser of these services and materials for its 18

facilities, the Company is very familiar with the costs of the products and services of 19

the vendors with which it was working. Accordingly, the Company was able to 20

ensure that the prices and terms under which it purchased services and materials were 21

fair and reasonable under the extreme circumstances. There may be instances in 22

which the Company might have had to pay higher prices than it would have in a non-23


77

emergency situation; however, the Company’s processes and experience ensured that 1

the prices and costs it did pay were reasonable under the circumstances. 2

3

Q81. WERE THE PRODUCTION AND OTHER CLASS COSTS INCURRED BY THE 4

COMPANY TO ADDRESS HURRICANE ISAAC REASONABLE AND 5

NECESSARY? 6

A. Yes. The production costs were necessary to ensure that production was and will be 7

available when needed by the Company’s customers and to address the damage 8

caused by Hurricane Isaac to the Company’s production facilities. When electrical 9

power systems experience a major system outage, as was the case when the areas 10

served by the Company were struck by Hurricane Isaac, production, transmission, and 11

distribution must be restored to service in a careful, coordinated fashion. 12

The costs included in the Other class, including repairing damage to service-13

center sites, are essential to any restoration effort, and, thus, the Other costs incurred 14

by ENO were entirely reasonable and necessary. 15

16

Q82. IN THE LIGHT OF THE FACTS KNOWN TO THE COMPANY AT THE TIME, 17

WAS IT NECESSARY AND REASONABLE FOR THE COMPANY TO 18

ACQUIRE AND UTILIZE THE RESOURCES THAT IT DID TO COMPLETE 19

RESTORATION OF SERVICE AND RECONSTRUCTION OF ITS FACILITIES? 20

A. Yes. 21

22


78


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Page 1 of 1

EMERGENCY OPERATIONS

PLAN

Transmission & Distribution

May 28, 2012 Confidential and Proprietary


Page 1 of 110

ENTERGY CORPORATION - EMERGENCY OPERATIONS PLAN

Revision Date: 05/28/12 Page 2 of 110 Reviewed Date: 05/28/12

Entergy Incident Management System

EIMS Web Page Home

EIMS Web Category Entergy Incident Management System (EIMS)

APPROVALS

Document Title: Emergency Operation Plan - Transmission & Distribution

Document Owner: Greg J. Grillo

Owner Title: System Incident Commander

Revision Date: 05/28/2012

Document Reviewer: Sandra R. Alstadt

Reviewer Title: System Public Information Officer

Reviewed Date: 05/28/2012


Page 2 of 110



TABLE OF CONTENTS 1 INTRODUCTION .................................................................................................................................. 5

1.1 PURPOSE/SCOPE ........................................................................................................................... 5 1.1.1 EOP Maintenance ................................................................................................................... 5 1.1.2 System Command Center ....................................................................................................... 6

1.2 STRATEGY AND PRINCIPLES GOVERNING RESTORATION PROCEDURES ............................................ 6

2 IMPLEMENTATION ............................................................................................................................. 7

2.1 EVENT ACTIVATION ........................................................................................................................ 7 2.2 WEATHER MONITORING .................................................................................................................. 8 2.3 LEVELS OF ACTIVATION .................................................................................................................. 8 2.4 OUTAGE LEVELS .......................................................................................................................... 11 2.5 OFF-OASIS COMMUNICATION RECORD KEEPING DURING EMERGENCY CIRCUMSTANCES ............... 13 2.6 EVENT LEADERSHIP/DECISION MAKING ......................................................................................... 14 2.7 PLAN GOVERNANCE ..................................................................................................................... 15

3 ORGANIZATIONAL STRUCTURE .................................................................................................... 16 3.1 INCIDENT COMMAND CENTER ....................................................................................................... 16

3.1.1 Purpose ................................................................................................................................. 16 3.1.2 Organization .......................................................................................................................... 18 3.1.3 Roles & Responsibilities ........................................................................................................ 21 3.1.4 Processes/Interfaces ............................................................................................................. 25

3.2 PLANNING .................................................................................................................................. 266 3.2.1 Purpose ............................................................................................................................... 266 3.2.2 Organization ........................................................................................................................ 288 3.2.3 Roles & Responsibilities ........................................................................................................ 30 3.2.4 Processes/Interfaces ........................................................................................................... 455

3.3 RESOURCE ................................................................................................................................ 477 3.3.1 Purpose ............................................................................................................................... 477 3.3.2 Organization ........................................................................................................................ 499 3.3.3 Roles & Responsibilities ........................................................................................................ 51 3.3.4 Processes/Interfaces ........................................................................................................... 579

3.4 LOGISTICS ................................................................................................................................... 59 3.4.1 Purpose ................................................................................................................................. 59 3.4.2 Organization ........................................................................................................................ 600 3.4.3 Roles & Responsibility ......................................................................................................... 611 3.4.4 Processes/Interfaces ............................................................................................................. 67

3.5 OPERATIONS ............................................................................................................................... 68 3.5.1 Purpose ................................................................................................................................. 68 3.5.2 Organization ...................................................................................................................... 6969 3.5.3 Roles & Responsibilities ........................................................................................................ 71 3.5.4 Processes/Interfaces ........................................................................................................... 855

3.6 ADMINISTRATION ........................................................................................................................ 866 3.6.1 Purpose ............................................................................................................................... 866 3.6.2 Organization .......................................................................................................................... 87 3.6.3 Roles & Responsibilities ........................................................................................................ 89 3.6.4 Processes/Interfaces ............................................................................................................. 94

3.7 SUPPLY CHAIN ............................................................................................................................. 97 3.7.1 Purpose ................................................................................................................................. 97 3.7.2 Organization .......................................................................................................................... 99 3.7.3 Roles & Responsibilities ...................................................................................................... 100 3.7.4 Processes/Interfaces ........................................................................................................... 104

4 COMMON PROCESSES ................................................................................................................. 106 4.1 POST STORM ANALYSIS ............................................................................................................. 106 4.2 ISSUE RESOLUTION .................................................................................................................... 106 4.3 TRAINING ................................................................................................................................... 106


Page 3 of 110



4.4 TRANSFER OF COMMAND............................................................................................................ 107 4.5 WORK HOURS ............................................................................................................................ 107 4.6 OTHER EMERGENCY PLANS ........................................................................................................ 107 4.7 DEFINITIONS .............................................................................................................................. 108


Page 4 of 110



Emergency Operations Plan 1 Introduction

1.1 Purpose/Scope The purpose of this Transmission and Distribution (T&D) Emergency Operations Plan (EOP) is to establish processes for the coordination, management and support of system emergency operations and restoration of service in a systematic and efficient manner due to a weather disaster, other natural disaster and/or security related event which affects normal operations. This T&D EOP provides basic structure, processes, guidelines, responsibilities, and reference data necessary for appropriate stages of emergency preparedness and response to be followed for orderly transition from routine business operations to emergency operations and restoration in the event of either the threat or impact of severe weather, other natural disasters and/or security related events to the Entergy service area. The focus of the T&D EOP will be the restoration of Transmission and Distribution infrastructure and service and coordination with Gas, Fossil, Nuclear, Business Continuity and Corporate Support functions. 1.1.1 EOP Maintenance

• Maintenance of the T&D EOP is coordinated by the System Outage Response (SOR) organization.

• Maintenance of each Emergency Function (Section) is the responsibility of the respective Section Chief.

• Maintenance of Support Function plans is the responsibility of each function with oversight by the Administration Section as shown in the organization charts.

• Maintenance of Business Function plans is the responsibility of each function.

• Maintenance of Operating Company or State Plans is the responsibility of each Operating Company or State.

• All Support, Business Function and Operating Company/State Plans including organization, roles and responsibilities, processes and interfaces shall align with the principles and strategies within the T&D EOP . Any changes in the T&D EOP deemed necessary, including organization or process adjustments, shall be recommended to the Manager, System Outage Response with explanation for coordination, approval and update. Refer to Section 2.7 Plan Governance for process.

• The plan shall be continuously updated; however, at minimum, an annual review and update should take place prior to hurricane season.

• Plan maintenance related to updating assignments, contact information, etc. shall be performed on an ongoing basis.


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• Business Function plans and Emergency Support Function plans will be reviewed on an ongoing basis and maintained accordingly.

1.1.2 System Command Center • Included in the T&D EOP is the System Command Center

(SCC), which provides system coordination, management and support of emergency functions for business unit emergency operations and restoration.

• The primary location of the SCC will be the Power House and/or the Transmission Headquarters building located in Jackson, Miss.

• Alternate locations will be local business function command centers not impacted, or least impacted, from the event and will be determined specifically to each event. Normally, Baton Rouge, La. would be the first option to explore for alternate SCC activation.

• Each state area includes a command center for Transmission and Distribution Operations.

• Other Business Functions and Support groups include a centralized command center in a location applicable for the event or may be inclusive with other centers.

1.2 Strategy and Principles Governing Restoration Procedures Basic principles governing restoration shall include:

• The safety of the general public and restoration workers will be the highest priority.

• Restoration will be performed as quickly and as safely as possible. • Entergy system resources will be leveraged and, if necessary, include

acquisition and deployment of off-system resources. • The status of restoration and important customer information will be

communicated in a timely manner.

Differences in specific regulatory guidance may result in limited exceptions to system strategies by the different legal entities, operating companies and business functions; however, in general, system restoration strategy includes the following as applicable for the event:

• Safety of the general public and restoration workers will be the highest priority of restoration and operations activities.

• Flexibility to transition response from: o Routine business to emergency activities. o Small geographic area to large geographic area. o Single business function to multiple business functions.

• Leverage resources from multiple business units, geographic areas, legal entities and corporate services to assist the impacted areas.

• Provide system coordination, oversight and support while allowing local operations to manage emergency restoration and operations, utilizing common procedures and philosophies; however, recognizing


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unique requirements in different operating areas and business units. • Utilize concepts of the Incident Command System, to coordinate and

leverage efficiency in system restoration including restoration priorities, resources, and support.

• Provide restoration “mutual assistance” to other utilities in order to influence obligation of other utilities to provide assistance to Entergy when requested.

• Monitor and forecast threatening emergency conditions. Alert management, employees, contractors, and suppliers of potential conditions and damages before impact. Proactively take actions to prepare for response including activating command centers, evacuating coastal areas, pre-positioning resources or acquiring and deploying resources to be in position for timely restoration activities as deemed appropriate.

• Restore generation, stabilize the grid and restore service critical to public safety and service. Then restore the largest numbers of customers down to single customers.

• Key activities: o Continuously monitor weather for risks to system. o Alert employees, vendors, contractors, and governmental agencies

for readiness. o Coordinate preparedness, evacuation as applicable, and critical

restoration with governmental agencies. o Activate command centers for system, business functions and

geographic locations. o Plan response appropriate to risks. o Acquire and deploy resources, including pre-positioning resources

out of harm’s way, but near storm impact areas for quick response. o Support resources (Logistics, Fleet, and Supply Chain). o Repair and rebuild infrastructure, restore service, operate the

system. o Communicate restoration status and capture event information. o Account for, process and pay restoration expenses accurately and

timely. o Review response and restoration performance and critique for

lessons learned. o Develop, enhance, implement and train drill improvement

opportunities.

2 Implementation

2.1 Event Activation When a condition exists, or is expected to occur, that exceeds the capabilities of the normal operational organization to provide adequate response and recovery, the situation is considered to be a major event, or a “Black” Outage Level event:


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The process for activation of the T&D EOP takes in to account several factors:

• Type of weather. • Probability and confidence in forecasts. • Timing of impact. • Duration of impact. • Target area. • Size and intensity of the weather system. • Potential impact of storm, predicted damages and estimated resources

required for recovery.

2.2 Weather Monitoring The System Outage Response (SOR) organization is responsible for determining if there is a potential threat to the Entergy System and is responsible for initiating the activation process for major storm events by:

• Monitoring weather and risk assessment. • Alerting the System Incident Commander of potential threats, of an

existing or forecasted event that requires system response. • Recommending to the System Incident Commander

o declaration of an emergency o implementation of the Emergency Operations Plan o activation of the System Command Center (SCC) including the

level of activation and timing relative to threat. • Alerting the System Storm Incident Management Organization

(functional leadership) of potential threats. • Initiating communications and instructions for activation of the SCC. The System Incident Commander shall approve and implement:

• Declaration that a state of emergency exists or is forecasted to occur • Activation of the T&D EOP • Activation of the SCC • Activation of Business Function and Support Function emergency

plans and command centers

2.3 Levels of Activation The level of activation of the T&D EOP will depend on the level of the storm. Activation Decision:

• Level I – Decision to activate is made by the “local” Incident Commander.

• Level II-IV - Decision to activate command centers in impacted areas is made by the System Incident Commander. Other Operations and Support Function command center activation will be determined by that function incident commander based on the level of involvement required.


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• Levels III-IV - Activation of personnel to “Full” staffing may be phased in over multiple days at the discretion of the Section Chief or Incident Commander at each site; however, necessary staffing shall be activated to ensure all required tasks are completed for timely response preparedness and implementation.

Activation Responsibilities:

• SOR shall notify the System Incident Commander Steering Committee of any severe weather threats (SOR Weather Alert). With forecasts that require Level II activation, a System Incident Commander Conference Call will be scheduled to brief all functions of the pending threat or of an incident that has occurred, to discuss any preparations or response activities required including activation of command centers. The System Incident Commander will determine the specific date and time for opening or closing the SCC and coordinate the opening and closing of State Command Centers for a multi-state event. When only one state is threatened or impacted, the State Incident Commander shall determine State Command Center opening/closing date and times.

• Each individual Section Chief shall insure that his/her section is informed of the EOP Activation and is properly staffed to perform at the requested level.

• As part of the SCC Activation Plan, the SCC Logistics Section will inform the Power House Conference Center management that the SCC is being activated. The Power House Manager or his/her representative, in coordination with the SCC Logistics Staff, will direct all IT, Facilities, and Telecom activities to insure that the SCC will be functional at the specified time. The Transmission Headquarters Building will be utilized as the System Command Center for an EOP activation Level II.

• The System Incident Commander shall lead the implementation of the EOP.

Event Levels and Criteria for Command Activation: Based on the principles of the Incident Command System, any incident response will include a command structure even if only one site is involved with the initial response. As more sites or areas are affected by an incident, plans call for engagement of local work area management, to regional management to Business Function or State Incident Commander to System Incident Commander. The table below shows the storm levels and criteria for emergency plan and command center activation:


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Event Level and Criteria for Command Activation Table:

Activation Level

Weather Forecast Criteria Guide

System Command Center

State Command Center

Activation Timeline

Estimated Tool Workers ( plus additional 30% in support)

Level I • Tropical Depression or less • Severe weather (strong thunderstorms, high

winds) • Tornados • Ice – up to ½” ice and/or >4”wet snow in

isolated area (33% or less of service area in one state of service territory)

• Three or more Networks “Red” level in a single state

Virtual Mode Minimal staffing as required (10-20)

Virtual Mode “Minimal” staffing as required

48 hours prior to impact (with advance forecast)

Up to 2,500

Level II • Tropical Storm - weak Category 1 Hurricane • Ice: ½” to 1” in large area (33% or greater of

service area in one state or less than 33% in each of multiple states)

• Three or more Networks “Red” or Black level in multiple states

THQ Core staffing as required (30-40)

EOC Mode Partial staffing

72 hours prior to impact

2,500 - 5,000

Level III • Strong Category 1 – Category 2 Hurricane • Ice: 1” to 1½” in large area (33% or greater

of service area in one state or less than 33% in multiple states)

SCC Partial staffing as required (40-70); Phased in

EOC Mode Full staffing


5,000-10,000

Level IV • Hurricane – Cat 3 or Greater • Ice: greater >2” in large area (33% or

greater of service area in one state or less than 33% in multiple states)

SCC Full staffing (70-120); Phased in

EOC Mode Full staffing


>10,000

Virtual Mode: Personnel required to be engaged in event response perform activities from normal or remote locations. EOC Mode: Personnel required to be engaged in event response perform activities from the “Emergency Operations

Center” or Command Centers as designated by various Business Units and Support Functions.


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2.4 Outage Levels In order to estimate an adequate resource level to handle all aspects of outage restoration, weather forecasts are translated into response categories or estimated “Outage Levels.” These are defined by the estimated average restoration time (duration). As weather conditions intensify, the resources needed to effectively restore the outages and communicate with key constituents also increases. The Outage Levels or operating conditions are referenced by a color designation and is defined as follows:

• Green - Normal daily activity, network commitments are not at risk and outage restoration time is normally less than two hours.

• Yellow - Service restoration will exceed the two-hour target and other service commitments will be at risk at the network level. Initial restoration estimates will be between 2 and 8 hours.

• Red - Service restoration will exceed the two-hour target and other service commitments will be missed at the state level. Resources will be moving inside the state or from other states, and initial outage restoration estimates may be as long as 2 days.

• Black - Service restoration will exceed the two-hour target and other service commitments will be missed in state(s). Outage workload requires external system resources. Initial outage restoration estimates will be greater than 48 hours. Entergy’s goal is to restore all power as quickly and as safely as possible to those who are able to take service.

A set of procedures referred to as “protocols” have been developed that outline the processes for various key operational functions or positions within Entergy’s normal organization. These processes were developed to cover the range of operating conditions from normal circumstances to severe conditions affecting several states. The table below shows the Outage Levels and criteria for response engagement:


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Outage Levels and Criteria for Response Engagement Table: Level Green Yellow Red Black

Restoration < 2 hours > 2 < 8 hours > 8 < 48 hours > 48 hours Process Engagement

Operations Dispatch Repair Rebuild Restore Switching Operate Restoration Information

Operations Dispatch Repair Rebuild Restore Switching Operate Restoration Information Support Communications CSC CSM Environmental Fleet Safety Supply Chain

Planning Damage Assessment Resource Line, Veg, Scout, Equipment, Support, Mutual Assistance Logistics Meals, Lodging, Staging, Fleet Operations Dispatch Repair Rebuild Restore Switching Operate Restoration Information Administration Invoice Support Storm Credit Card Support Communications CSC CSM Environmental Fleet Safety Supply Chain

Planning Risk Monitoring Damage Predict Damage Assessment Situational Analysis Recovery Prioritization TOC Support IAP Resource Line, Veg, Scout, Equipment, Support, Mutual Assistance Logistics Meals, Lodging, Staging, , Fleet Operations Dispatch Repair Rebuild Restore Switching Operate Restoration Information Administration Invoice Support Storm Credit Card Reporting Cost Estimates Cost Allocation Supply Chain Material acquisition & delivery Support Communications Customer Service Centers Customer Service Environmental Fleet Safety Supply Chain

Responsible Management

Operations • Distr Line Supv • Transm Line Supv • Substation Area

Supv • DOC OC • TOC OC

Operations • Region Manager • Transm Line

Manager • Subst Opns

Manager • DOC Mgr/Supv • TOC Mgr • Support Supv

BF/State Command Support Supv

• System Command • BF/State Command • Business Continuity

Command

Criteria of Engagement

15 cases or less (25 BR)

2 Area Lines – Yellow 1 Area Line – Red

>2 AL – Yellow >1 Region >1 AL – Red>1 Region >1 AL – Red>1 State *In-Sys Resources Req’d *Off-Sys Resources Req’d

Requests Management Decision Any AL Black In-Sys Resources Req’d Off-Sys Resources Req’d


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2.5 Off-OASIS Communication Record Keeping During Emergency Circumstances • Federal Energy Regulatory Commission (FERC) Order No. 717,

issued in late 2008, amended the Standards of Conduct (“Standards”) for electric transmission providers.

• During an emergency circumstance, under the revised FERC Standards: o A utility can no longer simply post on OASIS that it intends to

deviate from the FERC Standards of Conduct restrictions on sharing transmission information with Marketing Function Employees (MFEs).

o Sharing of Non-Public Transmission Function Information (NPTFI) with MFEs can still occur if the information pertains to compliance with FERC-approved Reliability Standards or is necessary to maintain or restore operation of the transmission system or generating units.

o However, the utility must retain a record of the information sharing or interaction.

o If a contemporaneous record cannot be made of such sharing or interaction, a record must be made as soon as practicable after the fact, ideally within 24-hours of the sharing or interaction.

o Voice recordation is the preferred method, when an interaction has a reasonable potential to lead to a transfer of NPTFI to an MFE.

o Otherwise, a written record may be prepared and sent to the Off-OASIS Protocol (Off-OASIS Protocol) Outlook email address.

• In the event of a call with any MFE that does not include a participant using a recorded phone line, a recorded phone line at the SOC may be used that automatically answer calls from remote locations and terminates each call automatically when the participants hang up. The phone number of the recorded line is (870) 541-3998 (external) or 8-760-3998 (internal). This phone is in the SOC Telecom Room and set for AutoDial.

• Detailed information is provided in the Off-OASIS Communications Record Keeping Process during Emergency Circumstances procedure that can be found on the SOR Homepage – Planning Section – Procedures or at the following link:

Off-OASIS Communications Record Keeping Process During Emergency Circumstances

• If a disclosure may have occurred of NPTFI that is not permissible to share with an MFE, notice must be provided immediately to Transmission Compliance, FERC Compliance or Federal Regulatory Legal. Such notice shall include the NPTFI disclosed to the MFE, the responsible party name, reason for the disclosure, and date, time and place of the disclosure.

• Creating a record of each interaction between a TFE and an MFE that describes whether and what NPTFI was exchanged will prevent serious problems that could result if such a record is not created.


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FERC may impose civil penalties of up to $1 million per day, per violation, for as long as the violation continues. Other consequences can include disgorgement of profits, compulsory compliance plans, and restrictions on the way business is conducted – such as the loss of market based rate authority. FERC can also pursue criminal penalties against an individual or corporate entity that fails to abide by FERC’s orders, rules, or regulations.

2.6 Event Leadership/Decision Making A successful restoration plan depends on good leadership and decision making. All involved levels of leadership, including, but not limited to Vice Presidents, Directors, Managers, and Supervisors, will be given full authority and responsibility for implementing their portion of the Plan. Empowerment and flexibility within the restoration plans shall characterize the decision-making environment. The key leadership actions will be to: • Emphasize that safety is “first” in all we do. Safety ALWAYS Trumps

Speed. • Build mutually productive and collaborative relationships with internal

and external stakeholders. • Develop teamwork and team support within the restoration process. • Build and maintain a positive, results-oriented work climate. • Deal with negative situations in a constructive manner. • Remove barriers to understanding and cooperation. • Stay balanced and objective when dealing with people and

problems. • Maintain the self-confidence and self-esteem of others. • Work to create a climate of trust and effective communication. • Focus on the situation, issue, or behavior, not on the person. • Take initiative to make things better. • Lead by example - Walk the Talk.

Based on the principles of the Incident Command System, any incident response will include a command structure even if only one individual is the initial response. As more sites or areas are affected by an incident, plans call for engagement of local work area management, to regional management to Business Function or State Incident Commander to System Incident Commander. Section processes should be standardized and executed consistently across all States since leveraging use of Entergy resources, including manpower, equipment, tracking systems, outage manage systems, etc. which provides the greatest efficiency for all States in response. Section Chiefs shall be responsible for development, documentation, training and implementation of these processes, guidelines, and use of tools etc.


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Incident Commanders shall be responsible to insure integration of these section functions during an event at the appropriate level required (i.e. local work area, regional, Business Function or State and System). Each level of escalated oversight management shall have responsibility and authority over the lower levels for execution of the T&D EOP. The System Incident Commander shall be the highest level of emergency management responsibility and authority.

2.7 Plan Governance

Governance, administration and modification of the T&D EOP shall be accomplished as follows: The System Incident Commander Steering Committee (ICSC) shall approve all modifications and revisions of the T&D EOP. The committee is made up of the following representatives: • System Incident Commander • System Incident Commander Support • System Safety Officer • System Public Information Officer • System Governmental Liaison Officer • System Customer Experience Officer • System Planning Chief and Deputy Chief • System Resource Section Chief and Deputy Chief • System Logistics Section Chief and Deputy Chief • System Operations Section Chief and Deputy Chief • System Administration Section Chief and Deputy Chief • System Supply Chain Section Chief and Deputy Chief • Arkansas T&D Incident Commander and Deputy Commander • Louisiana T&D Incident Commander and Deputy Commander • Mississippi T&D Incident Commander and Deputy Commander • Texas T&D Incident Commander and Deputy Commander • Gas Incident Commander and Deputy Commander If a change to the plan is proposed, the Commander, Officer, Chief, Deputy Chief or Director of the area with the proposed change shall: • Document the proposed change on a standard form. • Document the justification for the change. • Provide the proposed change to the System Incident Commander

Steering Committee in advance of an ICSC meeting or call. • Lead discussion on proposal. • Obtain agreement, cross functional approval by all members of the

committee. • Revise proposal as-needed or cancel. • Forward approved change to System Outage Response to track and

update the T&D EOP.


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Similarly, proposed changes within a Section shall require similar process structure and approval for change. If a State or other function recommends changes, the recommending State/Section shall document the proposed change, including justification, and bring it to the local State Section Chief for initial approval. Local State Section Chief shall then bring it to all State Section Chiefs and System Section Chief for approval.

3 Organizational Structure

3.1 Incident Command Center 3.1.1 Purpose

The purpose of a structured emergency organization is to ensure the orderly transition from routine business operations to emergency operations and restoration in the event of either the threat or impact of severe weather, other natural disaster and/or security related events to the Entergy service area. Entergy has adopted the basic Incident Command System (ICS) structure, terminology and philosophy. However, the plan includes customized variances and cultural terminology in lower levels of the emergency organization to facilitate efficient implementation and operations. Incident Command System (ICS): The National Incident Management System includes a key feature known as the Incident Command System (ICS), which: • Standardizes management for meeting demands of

emergency or non-emergency situations. • Represents “best practices” that have become the standard

for emergency management. • May be used for planned events, natural disasters and acts of

terrorism.

The Entergy Incident Management Organization includes the following: • Office of the Chief Executive (OCE) - Top level of

management providing strategic leadership and guidance. • System Incident Commander – Incident Commander

providing leadership, oversight management of system emergency operations including management of the System Command Center.

• State, Business Function, Support Function Incident Commander - Incident Commander providing leadership, oversight management of the State, Business Function, Support Function emergency operations including management of their respective Command Center.

• System Command Center - Command staff and General staff coordinating overall system response and managing Section


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functions. • State Command Center - Command staff and General staff

coordinating overall state response and managing Section functions.

• Business Function (Unit) Command - Providing leadership, oversight management of Business Unit emergency operations including management of the Business Unit Command Center.

• Emergency Support Function Command - Providing leadership, oversight management of Emergency Support Function emergency operations including management of the Emergency Support Function Command Center.

• Business Continuity Command - Providing leadership, oversight management of emergency business continuity operations including management of the Business Continuity Command Center. The Business Continuity Command reports directly to the CEO but coordinates support required by the System Incident Commander.

Each state shall adopt the system T&D EOP or as other plans are required, align those with the system T&D EOP and include any unique requirements for their operations. Other Business Function (Unit)rt and Support Functions shall have individual emergency plans that align with the EOP. Modifications and revision to this plan shall be administered through the “governance procedure.” Under the Incident Command System (ICS), Unified Command shall be utilized so that Business Functions (Units) and Emergency Support Functions share responsibility for incident management from a single coordinate. For emergencies that have not been declared a major emergency, some parts of the emergency operations organization will maintain their normal day-to-day responsibilities. However, there could be certain elements of the System Incident Management Organization that may be activated to perform their emergency duties. Entergy's Transmission and Distribution Incident Management Organization is divided into four states and includes six Legal Entities, three in Louisiana and one in each of the other three states. Each State is led by a State Operating Company President. Each State (T&D Business Function) has an Operations VP/Director and an Operations Manager that perform the State Storm Incident Commander responsibilities for the incident management organization. Gas Operations has its own EOP, and is led by the State/Legal Entity President, with the Vice President Gas Operations having the role of Incident Commander.


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Nuclear and Fossil, also have their own respective EOP, and are led by their respective organization management.

3.1.2 Organization To effectively manage a major restoration effort, clear lines of organizational responsibilities must be established across all levels of Entergy. The Entergy Storm Management Process (see chart below) displays organization roles and responsibilities and shows the lines of emergency organization relationships. The Incident Management Organization is divided into three areas: • Strategic – provides strategy, guidance and decisions on

major response and recovery activities that affect the company

• Oversight and Support - provides for the overarching management of response and recovery activities and support of Tactical operations.

• Tactical - provides for the management of the field personnel directly associated with repair or replacement of infrastructure required for restoration and operations.

However, it is in no way intended to inhibit the critical operational communications that must take place across organizational lines. Some position titles for the emergency organization may be different from normal titles to allow management at each level to have the freedom to make assignments that would be most beneficial to their operation. It is important for all members of the various emergency operations organizations to be familiar with the responsibilities of the other organizations. This knowledge will allow for clear lines of communication. When problems are encountered that cannot be resolved at that level of responsibility, the problem should be directed to the individual at the next higher level until resolution is found. Issues involving system-wide organizations or concerns should be directed to the System Command Center for resolution. The following chart is a summary of the Entergy Incident Management Process:


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Entergy Incident Management Process

System Resource Call • System Resource Chief leads meeting with

Safety Officer, System Planning rep, State Resource Chiefs, System Logistics rep, System Operations rep and System Support (Safety, Supply Chain, Fleet, Envir, Comm) to: o gather resource information regarding

requirements & availability by states o determine in system allocations,

assignments, deployments and off system acquisition requirements

o determine strategy to achieve objectives o determine method to make adjustments

in strategy or resource

System Planning Call to prepare for ICSC Call • Planning Chief leads • Review Safety status/issues • Review restoration effectiveness

& efficiency • Gather info to make adjustment

decisions

System Incident Commander Steering Committee Conf Call (Check Progress/Adjust Objectives) • Planning Chief leads meeting with System

Incident Commander Steering Committee • Determine progress & adjust Incident

Objectives as required • Document objectives for Operations Briefing

o Prioritization o Resource adjustments

State T&D Conference Calls • Resource Chief leads resource & key

support functions on working call to: o gather resource information regarding

requirements & availability o plan allocations, assignments,

deployments • Logistics Chief leads logistics on working

call for same as Resource. • Operation Chief leads field Mgrs/Supv on

working to identify special requirements and develop implementation planning

• Planning Chief leads planning to insure updated prediction or assessment information included

Prepare IAP & Approval • Develop IAP • Prepare Operations Briefing

System Incident Commander Call • Communicate incident information • Communicate initial response, objectives

strategy • Insures all Business Functions and State

Command are on alert and preparing or responding as appropriate

Operations Briefing • Operations Chief delivers Incident Action

Plan to Leadership of tactical resources

System Incident Commander Steering Committee Conf Call (Develop Strategy & Objectives) • Incident Commander leads call • Determine incident objectives & strategy

based on initial assessment • Assign incident objectives for each

operational period • Gather information or provide immediate

direction that cannot wait until planning cycle complete

Begin New Operational Period (usually Next Day)

Execute Plan (Recovery) • Manage Safety • Dispatch resources • Manage resources • Repair and restore • Report progress and recovery projections • Manage communications • Assess progress

SOR Conf Call • Planning leads review of threat (weather)

specifics and initial assessment • Incident Commander determines activation

level and immediate response coordination that cannot wait until System Command Call

• Insure Transfer of Command if required

“Manage By Objectives” • The “P” shape is used to represent “planning” as a means and guide to

incident response. • The leg of the “P” represents the initial response at the beginning or

prior to an incident occurring. This includes recognition of the incident and notification of the organization for initial response as appropriate.

• The top of the “P” represents continuous cycles of operational planning conducted to insure development of incident response

Initial Assessment Planning performs initial assessment for outages, damages, resource requirement, ETA prediction for threat Notifications (SOR Weather) Alert organization of threat or incident Monitor Weather (SOR) Monitor several daily forecast sources for threats

Recovery Strategy & Objectives

Implement Plan

Check progress; Adjust Objectives

Initi

al R

espo

nse


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Office of the Chief Executives & Operating Company Chief Executive Officers

System Incident Commander

Business Continuity Leader

Entergy Incident Management System

System Resource

Oversight Support

Strategy & Objectives(OCE)

StrategicPlan & Direct

Strategy & Objectives(Command Centers)

TacticalExecute

Strategy & Objectives(Field Operations)

State Customer

Service

Field Logistics

DistributionLine Areas

Field Operations

TransmissionLine Areas

Substation Operation

Areas

System Safety

Federal Govt’l

Liaison

GasNetworks

FossilPlants

NuclearPlants

Lodging Sites

Staging Sites

Customer Service

StateEOC

Liaisons

C&I Accounts

Field Safety

Field Assessment

State Operations

System Planning

State Logistics

StatePlanning

State Administration

System Operations

StateSafety

StateGovt’l

Liaison

Field Customer.

Service

Major/Nat’l Accounts

Field EOC

Liaisons

FieldCorp

Comm

State PSC/PUCLiaisons

System Administration

System Logistics

State Resource

SystemInformation

StateInformation

Parish/CountyEOC

Liaisons

Reporting & RecordsCorporate Suppor Corp Admin/Facilities- /Security Real Estate/AviationUtility Support Environmental Human Resources Claims LegalFinance AccountingCIPT Work Orders Cost Allocation

Off System Log CTCAcquisition, Allocation & DeploymentLodgingStagingMealsTransportationFleet

Off System Line & Veg CTC, Mutual Assistance, Special EquipmentIn-System Support (ARP)Acquisition, Allocation & DeploymentCheck-In Off System CrewsCrew Tracking to StateCoordination with Logistics

Planning SupportRestoration PrioritizationRisk Analysis Weather Monitoring/Alerts, Damage, Resource & Outage PredictSituational Analysis Damage AssessmentSOC

Risk MonitoringDamage PredictionDamage AssessmentRestoration Prioritization

Assignment (Reassignment & Release) & Tracking of ETR Crews, Base Load CTC, Off System crews assigned to State, to Work Area & StagingWork Area Check-InCoordination with Logistics

Manage SafetyManage CrewsRestoration InfoOutage InfoSwitchingDispatchConfiguration Mgmt

Invoice SupportCredit Card SupportEvent Reports/RecordsSupport Functions as required

LodgingStagingMealsTransportation

CICsCheck-In Sites AccountingFinance-CIPT

CASClaims

EnvironmentalReal Estate/

AviationHR

LegalSecurity

Supply ChainWarehouses

Fleet-ShopsRepair/Fuel

Coordination with Federal Agencies (DOE, DHS, FEMA…)

Safety & Health Prevention, Reporting

Internal & External (National, International) Communications,Media

Coordination with State Agencies (PSC/PUC, DHS, FEMA…)

Safety & Health Prevention, Reporting

Internal & External (Local), CommunicationsMedia

System OversightSystem Oversight

TOC Ops & SpptNetwork -Telecomm Compliance Configuration MgmtState Ops Support

AR T&D Incident

Commander

LA T&D Incident

Commander

MS T&D Incident

Commander

TX T&D Incident

Commander

Gas Incident

Commander

FossilIncident

Commander

NuclearIncident

Commander

System Supply Chain

MaterialStaging

Material ProcurementMaterial DeliveryMaterial StagingMaterials management

Remote

Reports to other Section/Branch

IT & Telecomm

System Oversight

System Customer

Experience

CSC/EBCCust Info Cont


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3.1.3 Roles & Responsibilities Oversight and Support

OCE - Top level of management providing leadership and support for strategic guidance in system emergency operations. Operating Company Presidents - Top level of management providing leadership and support for strategic guidance in system emergency operations and oversight management of State emergency operations. Business Continuity Officer – Top level of management providing oversight management of emergency business continuity operations including management of the Business Continuity Command Center.

A. System Command Center A.1. System Storm Incident Commander

The Incident Commander and his direct reports in the management organization are responsible for planning incident objectives and strategies to achieve the objectives; including providing oversight and support of the activities. The Incident Commander is responsible for the overall incident management, including, but not limited to, the following: • Ensuring incident safety. • Establishing Incident Command. • Establishing the level of organization needed for

effectiveness. • Coordinating activities of Command Staff and

General Staff. • Determining incident objectives and strategies to

be followed. • Approving requests for additional resources or

release of resources. • Approving Incident Action Plans. • Approving use of auxiliary personnel. • Ordering demobilization of incident when

appropriate. • Ensuring incident records are maintained and

complete. • Authorizing information release to media.

As noted in the Storm Levels and Activation Criteria, the Business Function/State Incident Commanders also perform the roles and responsibilities of the Incident Commander in their respective organizations when a single Business Function or State is the only


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area involved in an incident and there is no system command activation.

A.2. Command Staff The Command Staff is assigned to carry out staff functions needed to support the Incident Commander. The Command Staff positions are established to assign responsibility for key activities not specifically identified in the General Staff function elements. These positions include the Governmental Liaison Officer, Public Information Officer, Safety Officer, , and the Customer Experience Officer in addition to various others, as required or assigned by the Incident Commander.

1. Governmental Liaison Officer The Governmental Liaison Officer is responsible for coordinating emergency issues with governmental agencies. At a System Command level, the interface is with federal agencies such as FEMA, DHS and DOE. At a State Command level, the interface is with the state agencies such as the State Emergency Management Agency, Utility Commissions, State Police or other governmental agencies or departments. Includes but not limited are the following responsibilities: • Act as a point of contact for agency

representatives. • Maintain a listing of assisting and

cooperating agencies and representatives. • Develop relationships with contacts to

facilitate effective and efficient communications and cooperation.

• Assist in setting up and coordinating interagency contacts.

• Monitor incident operations to identify current or potential inter-organizational opportunities.

• Participate in planning meetings, providing resource requests or status of agency assistance if applicable, including limitations and capabilities of agency representatives.

• Coordinate special reports and information as required by agencies related to critical customers, restoration progress, etc., and


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coordinate external information review and or delivery with Public Information Officer.

• Provide agency-specific demobilization information and requirements.

• 2. Public Information Officer

The Public Information Officer is responsible for coordination, development and communication of response and restoration information with employees and media. This includes coordination with state Public Information Officers. Included but not limited are the following responsibilities: • Obtain Incident Commander approval of

information release. • Ensure “One-Voice” process is utilized;

managing all information released, including media releases, talk points, etc.

• Conduct periodic briefings with management, media, and employees.

• Maintain company external and internal websites.

• Arrange for video and photography of incident activities including storm damage.

3. Safety Officer The Safety Officer is responsible for overall safety and health activities associated with emergency operations and restoration. Included but not limited are the following responsibilities: • Identify and mitigate hazardous situations. • Ensure safety messages and briefings are

made. • Ensure Safety orientations are delivered to

Off-System restoration resources. • Review Incident Action Plans for safety

implications. • Ensure Safety personnel are adequately

trained and able to perform. • Participate in Planning meetings. • Initiate and ensure accidents & incidents

are investigated with plans to mitigate future occurrences.

• Ensure accident reporting protocols are understood and executed when required.


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• Insure safety records are maintained and complete.

• Facilitate placement of medical services when required.

• Assign and coordinate field safety oversight and support.

4. Customer Experience Officer The Customer Experience Officer coordinates direct customer communication during major outage events and assures direct customer messages are appropriate and effective throughout an event. Delivery channels include Customer Service Centers, Interactive Voice Response System, View Outages, text messages and customer service managers. Included but not limited to are the following responsibilities: • Works closely with the Public Information

Officer to ensure the One Voice Process is followed.

• Oversees View Outages, VOICES and text messages working with field organization.

• Responsible for assuring that proper monitoring occurs of customer-direct messages that are delivered through View Outages, Interactive Voice Response System and text messaging.

• Works with field distribution operations to ensure that the appropriate restoration statuses are being reflected in trouble cases.

• Resolves issues regarding customer messaging.

• Working with the CSC Branch director, who oversees all storm related activities of the Customer Service Center & Credit organization during an event.

A.3. General Staff

The General Staff represents and is responsible for the functional aspects of the incident command structure. The General Staff consists of the Planning, Resource, Logistics, Operations, Administration, and Supply Chain Chiefs.


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General guidelines related to the General Staff positions include: • Only one person will be designated to lead each

General Staff position. • The Section Chief is responsible for the overall Section

processes, staffing, training and execution for an incident.

• Positions may be filled with qualified persons from any jurisdiction, work group, or Business Function.

• Positions report directly to the Incident Commander.

The following sections of the plan include specifics related to the objectives, organization, roles and responsibilities, processes and interface of the General Staff Functions.

3.1.4 Processes/Interfaces 3.1.4.1 Planning

o Risk analysis. o Planning support. o Restoration prioritization. o Situational assessment. o Technical analysis. o System operations. o Report status and measure performance.

3.1.4.2 Resource o Activate resource. o Identify requirements, manpower and equipment,

locations and date needed. o Integrate resource and logistics including fleet. o Acquire resources. o Manage resource contracts. o Prioritize, allocate and deploy acquired resources. o Track resources. o Report status and measure performance.

3.1.4.3 Logistics o Activate logistics. o Identify requirements, logistics contractors, lodging,

staging, meals, transportation, fuel. o Integrate resource and logistics including fleet. o Acquire logistics resources. o Manage logistics contracts. o Manage lodging. o Manage staging. o Report status and measure performance.


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o

3.1.4.4 Operations o Repair and rebuild Transmission and Distribution

infrastructure. o Operate Transmission and Distribution systems. o Manage system configuration. o Manage critical infrastructure protection. o Manage information systems and telecommunications. o Manage materials supply, delivery and staging. o Report status and measure performance.

3.1.4.5 Administration

o Manage finances. o Manage costs allocations. o Manage Invoice processing. o Manage event reporting. o Manage Corporate Administrative Services, including

Security, Aviation, Facilities, Real Estate and Corporate Administrative Services.

o Manage Utility Administrative Services, including Human Resources, Environmental, Legal, Claims.

o Manage Customer Service Centers and Entergy Business Center.

o Report status and measure performance.

3.1.4.6 Supply Chain o Acquire needed materials. o Deliver needed materials. o Establish and staff staging sites. o Facilitate the prioritization of needed materials with

Operations Sections. o Report status and measure performance.

3.2 Planning 3.2.1 Purpose

The System Command Center (SCC) Planning Section’s function will be responsible for providing overall direction and coordination of weather risk analysis and weather information updates, system-level damage prediction and assessment, grid stabilization, and system-level restoration prioritization. The overall direction and coordination includes:

• Contact with key weather vendors, development of weather-related reports, and development of damage prediction estimates.


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• Coordination of damage prediction estimates with Operations Branch including system-level summarization of damage assessment information.

• Assessment and analysis of grid conditions including coordination of grid stabilization efforts and communication with internal and external stakeholders.

• Development of a system-level restoration prioritization of work activities; including, risk assessment of fiber optic communication associated with structure/wire damage.

• Development of system-level restoration prioritization including impact to national economy and national security as coordinated with the Department of Energy and Department of Homeland Security.

• Perform special studies to support restoration; such as fault study analysis, relay coordination, motor start calculations, and stability analysis.

• Preparation and retention of required documentation for these activities.

The State Transmission & Distribution Planning Section will be responsible for providing overall coordination of all state-based planning, damage prediction, and assessment for the recovery effort, including the deployment of damage assessment resources to the affected state locations (Regions, Networks, Line Areas…) as necessary. * Nuclear, Fossil and Gas Operations perform similar Planning Section functions within their own organizations unless otherwise requesting assistance.


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3.2.2 Organization


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3.2.3 Roles & Responsibilities A. System Command Center

A.1. SCC Planning Section Chief The SCC Planning Section Chief is responsible for directing Planning Team personnel and coordinating all Planning Section restoration and assessment activities. In addition, the Planning Section Chief is responsible for providing updates to the SCC Incident Commander on the magnitude of damage to the Entergy distribution and transmission systems and the restoration progress for the Entergy distribution and transmission systems. Upon activation of the SCC, the Planning Section Lead will inform all team members and provide detailed instructions on the staffing timeline for the System Command Center.

A.2. Planning Administrative Leader The Planning Administrative Leader is responsible for providing direct support to the Incident Commander and SCC Planning Section members on an as-needed basis. Specific duties will vary with each emergency response, but will generally include telephone and fax support and assistance in maintaining storm databases. Additional responsibilities include the documentation of SCC Planning Team activities and the archival of all generated documentation and/or reports.

A.3. Risk Analysis Director Weather Risk Analysis System Outage Response (SOR) has the primary responsibility for coordinating the monitoring of weather events that could impact the Entergy service area. SOR works with weather forecast services to insure that there is 24/7 coverage for the service area. SOR will collect the weather data from several sources and provide a summary of key factors to operational and support groups. This data will be used as part of the decision making process for the activation of the System Command Center and the acquisition of restoration resources. Also, SOR will coordinate the weather-related portion of the System Resource and Incident Commander Calls. Once the SCC is activated this duty shifts to the Risk Analysis Director. Transmission and Distribution Damage Prediction is done in concert with the State Damage Assessment Supervisors and other members of the SCC staff to achieve a single prediction of the impact on the system. The Damage Prediction process is used to assist the other SCC sections


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including Resource, Logistics and Operations functions to determine the location and magnitude of damage and the resulting restoration resource requirements. This is done through the use of current weather forecast tracking and internally-developed damage prediction modeling.

A.4. Damage Prediction Supervisor The Damage Prediction Supervisor is responsible for overseeing the development of transmission and distribution infrastructures’ damage prediction based on a specific threat scenario. This prediction information includes physical infrastructure damage and the estimations for restoration worker-days, and estimated number of workers needed to restore the affected area within a specific number of days. Also, this person will oversee and coordinate the distribution damage prediction products and record retention of those products.

A.5. Damage Prediction Leader The Damage Prediction Leader is responsible for acquisition, communication and coordination of the necessary information needed in the preparation of the damage prediction model runs. Also, this person will assist in the distribution of the damage prediction model products and the record retention of those products.

A.6. Weather Prediction Leader The Weather Prediction Leader is responsible for assisting in the planning, acquisition, tracking, communication and coordination of the necessary information required in developing the weather prediction products. Also, this person will assist in the distribution of the weather prediction information and the record retention of those products.

A.7. Situational Branch Director The Situational Branch Director assesses the impact of outages to the stability of the transmission system and coordinating special studies to support the return of transmission facilities and load restoration. Working with the Prioritization Director, the Situational Branch Director is also responsible for creating a prioritized restoration list for transmission system outages. The Situational Branch Director will direct the Transmission System Assessment Support Team to perform analysis to support system restoration, load return, generation ramp-up, stability analysis, etc. on an as-needed basis. Other duties include:

• Provide the Incident Commander and SCC Planning


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Team Lead with current information relative to the status of the Transmission System and magnitude and location of damage.

• Assess system strength and integrity and advise the Incident Commander and SCC Planning Team Lead of line and substation restoration priorities.

• Distribution Damage Assessment is begun after the event has cleared the specific portion of the service area. The Damage Assessment function has 3 primary phases; Initial Assessment Report, Backbone Feeder Assessment, and the Full Scale Assessment. Each State Damage Assessment Supervisor will have the responsibility to direct the assessment activities within their area and to report their findings to the SCC’s using standardized reporting templates. The distribution assessment and restoration leads will coordinate the restoration of large blocks of load with the situational assessment function.

• The process for Transmission Damage Assessment follows a similar track but also extensively uses aerial patrols to cover large amounts of territory as rapidly as possible. The findings of these patrols are transmitted to the SCC Planning Team for prioritization of restoration.

• The Situational Branch is also responsible for developing power flow models to accurately represent system conditions and for performing power flow analysis, and requesting stability studies, and motor start studies to support the restoration prioritization of transmission facilities and load restoration.

• In addition, this team will generate reports, as required, to report transmission system outage and restoration activities, major industrial customer outages and restoration times, and load restoration in affected regions. This team will also assist in the preparation of a prioritized transmission facility restoration list, as appropriate.

A.8. System Operations Support Supervisor The System Operations Support Supervisor is responsible for monitoring overall transmission system conditions as conditions change during the managed event, insuring that models are developed to properly evaluate the current conditions, providing input to the Situation Branch Director and Incident Commander on transmission system risks, the desired restoration needs from a system perspective and coordinating restoration capabilities and priorities with the Prioritization Branch. This representative will insure


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coordination occurs with multiple groups to gather and assess information on the status of the system.

A.9. Load Flow Model Development & Analysis Leader The Load Flow Model Development and Analysis Leader are responsible for creating load flow models relevant to the situation. Any analysis results generated from this group will be passed to the Situational Branch Director as required. Analysis performed by this group will follow all regulatory requirements (e.g. NERC Standards, FERC Orders, etc…)

A.10. Load Restoration Analysis Leader The Load Restoration Analysis Leader will coordinate all load flow studies to determine the proper amount of load, including priority, to be restored while maintaining the normal operating limits of the transmission grid. Close coordination with Situational Branch Director, SPO, Nuclear, Fossil, SOC and ICTE will be required.

A.11. Nuclear / Transmission Liaison Leader The Nuclear/Transmission Liaison Leader are responsible for providing the Transmission interface to the Nuclear organization. The duties of this position include the following: Prior to Onset of the Storm:

• Communicate the status of transmission grid, transmission facilities within the vicinity of nuclear units.

• Review results of damage prediction modeling to assess potential impact on Off-Site Power of nuclear units.

• Communicate the potential impact on Off-Site sources to System Operations Support Supervisor, Situation Branch Director & Restoration Prioritization Director. Additionally communications are provided to Nuclear Command Center in coordination with Nuclear Liaison.

• Review external communications to NRC, NERC and SERC to insure they are complete and factual.

During the Storm:

• Maintain situational awareness of the transmission grid within the vicinity of nuclear units and capability of Off-Site sources.

After the Storm:

• Assess the actual damage to transmission grid and capability of the Off-Site sources to the nuclear units.


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• In coordination with Power Flow Analysis Leader perform assessment of nuclear Off-Site sources.

• Communicate results of the Off-Site power assessments to System Operations Support Supervisor, Situation Branch Director and Restoration Prioritization Branch Director.

• Develop primary and alternate plans to restore capabilities of Off-Site source to the nuclear units.

• Based on system restoration plans perform assessment of start power requirements of the nuclear units.

• Working in coordination with Nuclear Liaison, System Operations Support Supervisor, Power Flow Analysis Supervisor develop start-up plan, ramp rate and hold points for nuclear unit power ascension.

A.12. Nuclear Liaison Leader The Nuclear Liaison is responsible for communicating the status of all nuclear units on the Entergy system to the SCC Planning Team. This communication will include emergency shut-down timelines, detailed information on internal plant procedures and/or plant condition, and any special considerations for the transmission organization. In addition, this individual is responsible for disseminating transmission and distribution restoration information to appropriate individuals within the nuclear organization.

A.13. Fossil Liaison Leader The Fossil Liaison is responsible for communicating the status of all fossil units on the Entergy system to the SCC Planning Team. This communication will include shut-down timelines, detailed information on internal plant procedures and/or plant condition, and any special considerations for the transmission organization. The Fossil Liaison will also work with the System Assessment Lead and other members of the SCC Planning Team to coordinate the shut-down of fossil facilities in anticipation of the emergency event and the start-up of fossil facilities in the aftermath of an emergency event. In addition, this individual is responsible for disseminating transmission and distribution restoration information to appropriate individuals within the fossil organization.

A.14. System Planning & Operations Liaison Leader The SPO coordinator will communicate with SPO to insure that there is sufficient generation available and scheduled to insure there are sufficient generation reserves to meet the expected load restoration and that the transmission system is operated within normal operating limits.


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A.15. System Operations Center Interface Leader The SOC Interface is responsible for monitoring overall transmission system conditions and providing input on restoration activities and restoration priorities from a system perspective. The SOC Interface is the primary point of contact at the System Command Center for the SOC Operations Staff. This individual is responsible for coordinating restoration activities, as required, with SOC personnel, SPO (as dictated by Standards of Conduct) and impacted TOCs. Along with other SOC personnel, the SOC Interface will coordinate with neighboring utilities and the ICT.

A.16. Data Collection and Reports Supervisor The responsibility of this position is to oversee the team that is responsible for data collection and generating reports, as required, to report transmission system outage and restoration activities, major industrial customer outages and restoration times, and load restoration in affected regions. This position will also assist in the preparation of a prioritized transmission facility restoration list, as appropriate.

A.17. Transmission Data Collection Leader The responsibility of this position is to gather all of the information necessary to generate reports, as required, to report transmission system outage and restoration activities, major industrial customer outages and restoration times, and load restoration in affected regions.

A.18. Reports, Dashboard, Situational Maps Leader The responsibility of this individual includes the design and operation of the SCC Planning Team Dashboard to display updated customer outage information and restoration progress. Prior to the activation of the system command center, this leader will be dispatched to the SCC to insure setup of the communications systems is complete upon the arrival of other personnel. In addition, this leader will work with IT support to monitor the communications system at the System Command Center for operability and take action when required, working with corporate IT to fix problems and keep systems available.

A.19. Transmission Facilities Status Leader This position will be responsible for determining the status of the Transmission System. This individual will monitor EMS/SCADA, and Consolidated Outage System (COS) application to determine the transmission facilities out of service. This individual also works closely with the TOCs to


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determine facilities outages when RTUs are out of service and the line status cannot be determined through EMS/SCADA. This individual provides information to the Data Collection Leader to be included in the reports that are sent from the Transmission Situational Assessment group.

A.20. Technical Analysis Supervisor The Technical Support Supervisor will support the responsibilities of the Situation Assessment Director by establishing hardware and software connectivity to collect necessary real-time data and historical data. The Support Branch group is also responsible for developing power flow models to accurately represent system conditions and for performing power flow analyses, stability studies, and motor start studies to support the restoration prioritization of transmission facilities and load restoration. In addition, this team will generate reports, as required.

A.21. Short Circuit Analysis Leader The Short Circuit Analysis Leader will update the short circuit models to accurately represent system conditions. When requested, this representative will provide the fault current levels at transmission substations and determine the fault impedance for modeling unbalanced faults in transient stability studies.

A.22. Motor Start Analysis Leader The Motor Start Analysis Leader will perform motor start studies and report the results to Major Accounts and Restoration Prioritization section as-needed. Major Accounts representatives will convey motor start requirements from the large industrial customers and coordinate information exchange with the Motor Start Analysis representative.

A.23. Stability Analysis Leader The Stability Analysis Leader will evaluate the potential for instability issues within the Entergy System as transmission and generating facilities are restored.

A.24. Relaying Support Leader The Relay Support Leader will provide relay Settings and RTU reconfiguration support. This representative is responsible for directing the reevaluation of relay settings of affected transmission facilities. When necessary, this representative will lead/oversee the issuance of revised relay settings for temporary transmission system configurations due to restoration activities.


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The Transmission System Protection Support representative is responsible for directing modifications to system protection schemes of affected transmission facilities and communicating any modifications to the SCC Planning Team. This representative will also participate in communications to neighboring entities as appropriate regarding coordination of protective device settings.

A.25. Distribution Situational Assessment Supervisor The Distribution System Assessment Supervisor will work with the AM/FM Outage Management team member for reporting distribution system customer outage information to the SCC. This representative will collect information on Distribution restoration priorities and coordinate information and priorities with the SCC Assessment Branch and Prioritization Branch related to Distribution priority plans.

A.26. Distribution System Status Leader This individual will work with the AM/FM Support Team on an as-needed basis before an emergency event to implement enhancements to the storm reporting capability of the AM/FM System and during an emergency event to generate distribution customer outage information.

A.27. Distribution Situational Assessment Map Leader Deliverables from this representative include color-coded distribution outage maps by region and actual customer outage and restoration data. Additional responsibilities include support for any executive reports, support of the command center dashboard and DOE and other ad hoc reports as-needed.

A.28. Restoration Prioritization Branch Director The Restoration Prioritization Branch Director is responsible for reviewing information from multiple sources to develop a realistic restoration plan based on system needs, critical load requirements, recommendations from the situation assessment function, and condition in the field. The plan must be updated frequently and communicated to key stakeholders. Adjustments to the restoration plan are made as system conditions are updated, input is received from key stakeholders, and as recommended by the situational assessment function or System Incident Commander. In addition, this representative is responsible for coordinating transmission restoration priorities and estimated restore times to assist in the restoration prioritization of distribution assets working with personnel at the system and state organizations. Key personnel


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include the Transmission Damage Assessment Supervisor who will work with the state Transmission System Assessment Supervisor to receive reports on the magnitude of damage to affected transmission facilities. The State Transmission System Assessment Supervisor is responsible for communicating the restoration plan for affected Transmission facilities.

A.29. Transmission Damage Assessment Leader The Transmission Damage Assessment Leader is responsible for receiving damage assessments from Asset Management grid personnel and ensuring that field work plans coincide with the restoration prioritization plan developed by this representative and Transmission Restoration Prioritization Director. This leader will work with the Substation Equipment Support representative to determine transmission substation equipment needs in the aftermath of an emergency event. Other responsibilities of this representative include the compilation of impacted substation equipment, an inventory of spare equipment available on the system for immediate replacement, and an evaluation of acceptable spare equipment. This individual will be expected to coordinate with the System Damage Assessment Supervisor and field personnel, as appropriate. This position will also be responsible for working with the State Situational Analysis Branch group to consolidate the damage reports into one report. Information will then be given to the Transmission Data Collection Leader to be included in the reports that are sent from the Transmission Situational Assessment group.

A.30. Transmission Operations Center Support Supervisor Transmission Operation Center Support Supervisor is responsible for ensuring additional technical support (Technical Support Leaders), within the affected TOCs, is available and on site during major storm events. The TOC Support Supervisor acts as the liaison between the Restoration Prioritization Branch at the SCC, and the State Area and Prioritization Support Branch Directors, to insure that the system prioritization plans are clearly identified and communicated. Likewise, the TOC Support Supervisor will insure that prioritization needs/concerns identified by the State Area Prioritization Branch are communicated to the SSC for consideration in the overall prioritization process.


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A.31. TOC Support Leader The TOC Support Leader is responsible for providing additional technical manpower and support within the affected transmission grids. The support to be provided includes, but is not limited to, performing load flow analysis, working with TOC operators in the development of effective and efficient switching plans, coordinating other technical analysis that may be needed with the Technical Analysis Branch leader at the SCC. The TOC in the affected area is responsible for entering transmission line outages in Consolidated Outage System (COS) and communicating with the TOC coordinator, at the SCC, on the status of information in COS as it relates to information available from SCADA or from field reports. This information becomes one of the key data sources for the situation assessment. The TOC Support Leaders will support the TOC operators need to provide timely and accurate reporting of transmission line outages in COS by reviewing and checking the data entered by the operators as required.

A.32. Power Flow Analysis Supervisor The Power Flow Analysis Supervisor is responsible for developing forward looking transmission models based on models developed by the Load Flow Model Development & Analysis Leader and performing analysis to aid in restoration prioritization. Activities will include:

• Analysis of potential energization schedules to ensure restoration priorities are technically feasible and contribute to improving transmission system reliability.

• Analysis of potential system conditions beyond the operating horizon to ensure system restoration proceeds in an orderly fashion and balances immediate system needs with longer-term plans.

• Identification of opportunities to upgrade facilities where they are prudent based on near-term planned upgrades incorporated into Entergy’s transmission construction plan.

• Coordination with Situational Branch functions to increase model accuracy.

• Input into restoration prioritization decisions based on analysis performed.


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A.33. Power Flow Analysis Leader The Power Flow Analysis Leaders will conduct transmission studies based on transmission models to aid in restoration prioritization. Analysis will include studies of current operating conditions, short-term feasibility and effectiveness of restoration plans, and longer-term analysis of energization scenarios being developed by the Restoration Prioritization branch.

A.34. Planning Support Branch Director The Planning Support Branch Director is responsible for managing wholesale customer support, communications with regulatory and industry reliability organizations, documentation for the Planning Section, and data updates as-needed by the Corporate Communications group. The Planning Support Branch Director shall coordinate these activities with the leads described below.

A.35. Wholesale Customer Support Leader The Wholesale Customer Response Leader and his/her support team serves as the Entergy contact for all transmission customers (other utilities, co-ops, municipalities, merchant generators, etc.). Prior to activation of the System Command Center, wholesale customer response team members shall prepare a list of any potentially impacted customer’s emergency contact information. Wholesale Customer Support team members should be kept informed of restoration progress and activities, as necessary, and communicate restoration efforts to transmission customers as appropriate on daily status calls. The support team is also responsible for informing the Planning Chief, Incident Commander and Public Information Officer, as appropriate, of customer issues concerning damage or restoration. The support team shall insure that FERC Standards of Conduct are followed and coordinate any issues/concerns with Entergy’s Chief Compliance Officer.

A.36. Documentation Specialist Leader The Documentation Specialist is responsible for collecting and retaining records documenting storm restoration activities including the storm timeline. These records should be based on the Incident Commander call, executive reports, System Command Center situation assessment summaries, and other related reports. Maintained daily logs should include, at a minimum, the following: weather conditions, storm damage impact, restoration progress, key decisions/actions by function or Operating Company, etc. These records shall be


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maintained and archived in anticipation of regulatory requirements (i.e., formal data requests, storm cost recovery testimonies, outage reporting).

A.37. Planning Branch Communication Leader The Planning Branch Communication Leader is responsible for interfacing with the Unified Incident Command Center’s Public Information Officer and providing reports as requested; including details relating to outages, transmission and distribution line damage, substation damage, and other relevant information. In addition, this support team shall communicate storm damage information to the SERC office, as-needed.

B. State Command Center B.1. State Planning Section Chief

The State Planning Section Chief (SPSC) is responsible for directing Planning Team personnel and coordinating all Planning Section’s restoration and assessment activities. In addition, the Planning Section Chief is responsible for providing updates to the State Incident Commander on the magnitude of damage to the State distribution and transmission systems and the restoration progress for that distribution and transmission systems. Upon activation of the State Command Center, the Planning Section Chief will inform all section members and provide detailed instructions on the staffing timeline for the State Command Center. The SPSC is responsible for working with the System Command Center to prioritize the transmission restoration effort with input from the States to insure transmission grid stability. The SPSC will insure the coordination of both transmission and distribution restoration efforts that meet both the System Command Center and the State’s prioritization plans. The SPSC will ensure communications is occurring between T&D personnel involved in the restoration efforts and that both T&D prioritization efforts are in synch. The SPSC will receive damage assessment reports from affected regions and provide input to the Resource Section Chief concerning resource requirements, and the Logistics Section Chief for logistical support. Will provide the following daily: 1. T&D Damage Assessment reports. 2. T&D restoration coordination updates. 3. Report outlining accomplishments of the day and

expectations for tomorrow.


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B.2. State Planning Administrative Leader The Administrative Leader is responsible for providing direct support to the state Planning Section members on an as-needed basis. Specific duties will vary with each emergency response, but will generally include telephone and fax support and assistance in maintaining storm databases. Additional responsibilities include the documentation of State Planning Team activities and assisting with archival of all generated documentation and/or reports.

B.3. State Risk Analysis Branch Director The State Risk Analysis Director is responsible for – transmission and distribution damage prediction working in concert with the System Damage Prediction Leader and other members of the SCC staff to achieve a clear understanding of the impact on the State. The Damage Prediction process is used to assist the other State sections including Resource, Logistics and Operations functions to determine the location and magnitude of damage and the resulting restoration resource requirements. This is done through the use of current weather forecast tracking and internally-developed damage prediction modeling.

B.4. State Weather Analysis Leader Monitor state weather conditions using local vendors, seeking to reconcile this information with that received from SCC resources. The stated goal is the best possible weather analysis as input to the decision-making processes regarding resource allocation and logistics.

B.5. State Transmission Damage Prediction Leader Based on current weather predictions and in coordination with the SCC, determine a prediction of damage to the Transmission Grid based on experience from previous storms and internally developed damage prediction models provided by the SCC. The Damage Prediction Process will assist Resource, Logistics and Operations functions to determine the location and magnitude of damage and the resulting restoration resource requirements.

B.6. State Distribution Damage Prediction Leader Distribution damage prediction is done in concert with the System Damage Prediction Leader and other members of the SCC staff to achieve a clear understanding of the potential impact on the State. The Damage Prediction process is used to assist the other state sections including Resource, Logistics and Operations functions to determine


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the location and magnitude of damage and the resulting restoration resource requirements. This is done through the use of current weather forecast tracking and internally-developed damage prediction modeling.

B.7. State Situational Analysis Director The State Situational Branch Director assesses the impact of outages to the Transmission and Distribution systems and coordinating with system and state command centers. The State Situational Branch Director will direct the T&D System Damage Assessment.

B.8. State Distribution Damage Assessment Leader The state distribution damage assessment is begun after the event has cleared the specific portion of the service area. The damage assessment function has three primary phases; Initial Assessment Report, Backbone Feeder Assessment, and the Full Scale Assessment. Each State Damage Assessment Leader will have the responsibility to direct the assessment activities within their area and to report their findings to the State’s Situation Branch Director.

B.9. State Transmission Damage Assessment Leader The process for transmission damage assessment follows a similar track but also extensively uses aerial patrols to cover large amounts of territory as rapidly as possible. The findings of these patrols are transmitted to the State Situational Branch Director for prioritization of restoration.

B.10. State Technical Analysis Leader This representative is responsible for ensuring that field work plans coincide with the restoration prioritization plan developed by the Transmission Damage Assessment Leader and Transmission Restoration Prioritization Director. Works with field supervisors to insure technical resources and equipment are available to support Transmission and Distribution restoration efforts.

B.11. State Transmission and Substation Scouting Supervisors and Leaders

Coordinate all T&D aerial patrol activities for Transmission lines and Substations. Coordinate foot patrol of T-lines when necessary and damage assessments on substations.

B.12. State Distribution Scouting Supervisors and Leaders The Scout Crew Leader is responsible for managing scouting resources to ensure safe work practices and scouting of the outage affected portions of the system. As well as to identify, document, and communicate to the


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Distribution Damage Assessment Supervisor, Network Leaders and/or Supervisors, the repairs and materials necessary to restore the system.

B.13. State Restoration Prioritization Branch Director This position is responsible for ensuring T&D prioritization restoration efforts are coordinated on a state level. Insures that distribution and transmission priorities are developed and communicated to applicable parties and take into consideration such issues as load readiness, generation availability, national security, emergency response customer needs, and key accounts.

B.14. State Distribution Restoration Prioritization Supervisor The Distribution Restoration Prioritization Supervisor is responsible for reporting distribution restoration activities to SCC Planning Section’s prioritization team. In addition, this Director is responsible for utilizing transmission restoration priorities and estimated restore times to assist in the restoration prioritization of distribution assets.

B.15. State Transmission Restoration Prioritization Supervisor The Transmission Restoration Prioritization Branch Supervisor will receive reports on the magnitude of damage to affected transmission facilities. Working with the SCC Planning Section’s prioritization team, this individual is responsible for prioritizing and directing the restoration activities of all affected Transmission facilities.

B.16. State Commercial & Industrial Account Leader The Commercial and Industrial Account Leader is responsible for identifying and communicating special customer needs and priorities to the State Restoration Prioritization Director so this information can be used in the development of the prioritized restoration plan.

B.17. State National Account Leader In a similar manner the National Account Leader is responsible for identifying and communicating special customer needs and priorities to the State Restoration Prioritization Director so this information can be used in the development of the prioritized restoration plan.

B.18. State Area Support Branch Director The Area Support Branch Director will insure switching activities required for returning load to Distribution facilities during restoration efforts is synchronized for efficiency between the T&D field operations and the Transmission / Distribution Operation Centers. The area support branch


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director will coordinate restoration of load to customers with State Restoration Prioritization Branch Director.

B.19. State Transmission Operations Center Support Leader This representative is responsible for support of TOC regarding switching, modeling, and other technical expertise.

B.20. State Distribution Operations Center Support Leader This representative shall coordinate distribution switching activities and restoration of load with Transmission Operations personnel responsible for Transmission switching (re-energizing T- Facilities). This position is responsible for support of Distribution Operations Center regarding switching, modeling, and other technical expertise.

B.21. State Planning Support Director The State Planning Support Director will insure state area planning resources are available to support distribution restoration efforts.

B.22. State Technical Customer Support Leader This representative will provide technical support to distribution field restoration efforts restoring service to distribution customers. Coordinate switching of loads to other transformers to return as many customers to service as soon as practical. Provide technical direction for restoring service to critical customer’s loads such as hospitals, large industrial customers, co-gen facilities, etc.

B.23. State Documentation Support & Record Retention Leader Maintain all field documentation including scouting maps and damage assessment recording. This includes all reports associated with damage reporting, restoration progress and T&D coordination. Maintain and file all records, drawings, documentation and reports required for retention and or necessary for regulatory audits. Documentation is turned in each day and collected by recorders. Once storm is over, all documents are gathered and sent to System Storm Command.

3.2.4 Processes/Interfaces 3.2.4.1 Weather Monitoring & Notifications

This process is designed to identify those weather-related events that could pose a risk to the power system. Working in


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close coordination with weather forecaster vendors, the weather risk information will be provided to the key operational personnel throughout the company.

3.2.4.2 Damage Prediction Key weather information provided by weather vendors will be accessed to determine the most realistic scenario that could impact the System. This data is input into the appropriate damage prediction model and the output is then reviewed and forwarded to the key operational personnel within the System and State Command Centers. This process will be repeated each time new weather data becomes available.

3.2.4.3 Event Restoration Planning Criteria This process is designed to identify a specific planning criterion that will be recommended by the Planning Section Chief to the System Incident Commander. This will be done by evaluating the weather risk information and the event timeline and the damage prediction model output. The recommended Planning Criteria will be established utilizing these tools and consulting with other members of the System Command Center. The Incident Commander will act upon this recommendation and the approved Planning Criteria will be given to all operational and support groups. This planning criterion will be the basis for the restoration activities.

3.2.4.4 SCC Activation Decision/Timing (Pre-activation SOR – Duplicated in Implementation) Once the most realistic scenario is determined and all related information is reviewed, an event timeline will be established setting the estimated time at which the event will begin to impact the System. Based on this timeline, a recommendation will be made by the SOR Manager to the System Incident Commander that the System Command Center be opened at the appropriate activation level. The System Incident Commander will authorize the opening of the System Command Center. Each System Section and State Command Center will open and staffing will begin in keeping with the Incident Commander’s activation order.

3.2.4.5 Damage Assessment Once it is safe to work, the damage assessment process will begin with the Damage assessment teams that are pre-deployed to the affected area. These teams will provide the results of their efforts after a preset period of time. This information will be summarized at the local sites and forwarded to the State Command Center’s Damage Assessment Leader who will then combine these reports and


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provide the results to the State Incident Commander and the System Planning Group’s Situational Assessment group.

3.2.4.6 Evacuation After the most realistic scenario has been determined and the event timeline has been established, The Planning Section Chief, in consultation with other members of the System Command Center, will make an evacuation recommendation for certain coastal areas of Louisiana and Texas. The System Incident Commander will:

• Work with the potentially impacted state incident commanders to develop a recommendation for the OCE and affected state president.

• Act upon the approved recommendation to ensure that there is consistency between business functions.

• Monitor and adjust the ongoing evacuation based on changing weather factors that could change the scope of the effort.

3.2.4.7 Restoration Prioritization The State Restoration Prioritization representative is responsible for reporting distribution restoration activities to the SCC Planning Team members. In addition, this representative is responsible for utilizing transmission restoration priorities and estimated restore times to assist in the restoration prioritization of the state distribution assets. The State Restoration Prioritization representative will receive reports on the magnitude of damage to affected transmission and distribution facilities.

3.3 Resource 3.3.1 Purpose

The purpose of the Resource Section function is to proactively identify resources requirements, manage contracts, acquire, allocate, deploy, track, and report Transmission and Distribution manpower and equipment resources* in a timely manner to safely support an effective and efficient response of storm event restoration. Included are proactive communications and coordination with Planning, Logistics, Operations and Administration Sections, Check-In Teams, Mutual Assistance and Off-System contractors and vendors. The System Command Center Resource Section will be responsible for providing overall direction and coordination of resources, both manpower and equipment, for the recovery effort, including the augmentation of Transmission and Distribution manpower and special


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equipment, allocation and tracking of resources between states as necessary. This includes Entergy personnel, base load and off-system contract crews as well as mutual assistance crews. The State Command Center Transmission and Distribution (T&D) Resource Section will be responsible for providing overall coordination of resources, both manpower and equipment, for the recovery effort, within each respective state, including the allocation and tracking of resources between state locations (Regions, Networks, Line Areas…) as necessary. * Nuclear, Fossil and Gas Operations perform similar Resource Section functions within their own organizations unless otherwise requesting assistance.


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3.3.2 Organization


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3.3.3 Roles & Responsibilities

A. System Command Center A.1. Resource Section Chief

The Resource Section Chief is responsible for development, implementation and execution of overall Resource processes with oversight and support of State T&D Resource Sections, and other Business Function resource support necessary to insure process compliance and system coordination of resources. He/She will coordinate resource requirements, requests, availability, acquisitions, allocations deployments, tracking and reporting of resource related information to appropriate Sections as well as the Incident Commander as-needed.

A.2. Off-System Branch Director The Off-System Branch Director is responsible for the overall coordination of acquisition and deployment of Off-System Manpower and Equipment based on priorities coordinated with the System Resource Section Chief. He/She will also ensure communications of status through timely and complete update of appropriate tracking systems as required for efficient and effective deployment of personnel. In addition, the Off-System Branch Director will coordinate Mutual Assistance and Contract Administration as required.

A.3. Manpower Leader (Distribution Line, Transmission Line, Transmission Substation, Vegetation, Scout, Mutual Assistance, Supply Chain)

These Manpower Leaders are responsible for acquisition, allocation and deployment of off-system resources for storm response to meet resource targets; including adjustments for in-system acquisition, recalls, swap-outs, other loaned crews, or other loss of crews. They are also responsible to maintain current listings and contacts for those companies with which storm contracts are required and ensure contracts are current.

A.4. Special Equipment Leader The Special Equipment Leader is responsible for planning, acquisition, allocation, deployment, tracking and communication of status for off-system special equipment, above what is available in the states.

A.5. Contract Administration Leader The Contract Administration Leader is responsible for establishing and maintaining contracts with available


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utilities and contractors that have the capability to respond to an emergency within Entergy’s service area. He will coordinate with “functional manpower and equipment leaders” to determine contracts necessary to support the restoration effort based on resources requested. He will also create/modify contracts to meet requirements of both Entergy and Contractor as need arises during restoration efforts.

A.6. In-System Support Branch Director The In-System Support Branch Director is responsible for the overall coordination, acquisition and deployment of In-System Manpower Support including the Auxiliary Resource Pool (ARP) based on priorities coordinated with the System Resource Section Chief. He/She will also ensure communications of status through timely and complete update of appropriate tracking systems and reporting as required for efficient and effective deployment of personnel.

A.7. In-System Support Leader The In-System Support Leader will assist the In-System Manpower Support Branch Director with tracking In-System (ARP) personnel available in PMT, and during emergencies track employees provided by Business Unit Liaisons (BULs) for deployment including coordination of rosters which are sent to the SCC Crew Tracking Branch of entry into RoD. He/She will ensure communications with donor work groups and receiving work groups as required for efficient and effective deployment of personnel as well as set expectations for ARP personnel.

A.8. In-System Support Business Unit Liaison The In-System Support Business Unit Liaison (BUL) is responsible for continuous maintenance of lists of respective Business Unit employees by skills and locations that can be utilized during major emergencies to supplement first responders. During emergencies, the BUL is responsible for acquiring personnel from their list, additional Business Unit employees as-needed, and provide rosters of responders to the In-System Support Branch Director who will coordinate deployment of ARP personnel based on priorities coordinated with the System Resource Chief.

A.9. System Check-In Branch Director The Check-In Branch Director is responsible for overall coordination of Check-In of Off-System Contractors and Mutual Assistance crews during events. Included is


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development of a Check-In Plan for the specific event, coordination with the System Resource Section Chief to determine which Check-In sites to use, whether stand-alone check-in or in conjunction with staging activities, when to open and close check-in activities, assignment of state team or auditors and roster clerks to staff each site; coordination with T&D Logistics to ensure no conflict with use of potential Staging Sites for Check-In sites and communication of the plan. Also, he/she will monitor Check-In operations to determine if crew arrival or Check-In operational adjustments are necessary during an event and identify potential adjustments to eliminate backlog at Check-In sites. He/She will assist Check-In Team Supervisors with decisions and operations of Check-In sites as-needed (hours of operation, staffing, open/closure, problem solving) to ensure Check-In resource process execution (Check-In site assignment, team assignment, crew audits, open/closure, etc.) and documentation are accurate and timely.

A.10. Check-In Tracking Leader The Check-In Tracking Leader is responsible for monitoring and tracking projected resource arrival volume at various time intervals for each Check-In site and informing Check-In Branch Director of volume status or issues on a periodic basis. This will be accomplished through the use of RoD tracking and reporting.

A.11. Check-In Team Supervisor The Check-In Team Supervisor is responsible for overseeing Check-In team and site operations including staffing, hours of operations, audit, crew tracking, logistics, coordination with System Resource and resolving any issues as-needed. Also, he/she will oversee & coordinate Check-In site setup and shutdown as-needed and in coordination with System Resource instructions.

A.12. Crew Tracking Branch Director The Crew Tracking Branch Director is responsible for coordinating tracking of off-system and in-system support resources and other internal resources not managed by States. He/She will coordinate implementation of crew assignment or travel adjustments determined with System Resource Section Chief and Check-In Branch Director, as-needed, to eliminate crew delays at Check-In sites (communicate implementation and tracking of bypass, reassignments, arrival delay/holdup etc of crews to Check-In sites). Also, he/she is responsible to oversee, monitor, coordinate and ensure timely and accurate maintenance of


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System RoD requirements to ensure appropriate, accurate, complete and timely update of all off-system crew tracking, as well as ensuring timely and accurate data for reporting resource status to the SCC Resource Section Chief and others as directed.

A.13. Crew Tracking Leader The Crew Tracking Leader is responsible for creating crew sets or import rosters and ensuring all off-system crew rosters as well as any internal crew rosters not managed by States are input into RoD completely, accurately, timely and assigned appropriately. Also, he/she is to ensure crew rosters are as accurate as possible including company names, hierarchy, employee names, contact positions, equipment and appropriate comments up to the point of hand-off. The Crew Tracking Leader will perform periodic “Road Checks” on each crew to monitor progress to maintain accurate ETA’s to the Check-In sites.

A.14. Resource Support Branch Director The Resource Support Branch Director is responsible for overall coordination of reporting of resources and the distribution or making report data available as directed by the System Resource Section Chief.

A.15. Reporting / Records Leader The Reporting / Records Leader is responsible for completely, accurately and timely providing reports of resource status and for distributing or making report data available to others as directed by the System Resource Section Chief.

A.16. Resource Support Leader The Resource Support Leader is responsible for providing general clerical and administrative assistance as required or instructed.

B. State Command Center B.1. State T&D Resource Section Chief

The Resource Section Chief is responsible for providing general oversight and ensuring compliance of executing system standard Resource processes and procedures for T&D in the State. He/She will oversee and manage resource allocation, deployment, tracking and reporting of in-state manpower and equipment and out of state, off-system resources assigned to State. He/She will also coordinate any issues with the System Resource Chief that cannot be resolved within State to meet system process compliance. He/She will ensure integrated resource-


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logistics requirement projections for all functions have been developed, documented, and compiled into state projection and completed in the Integrated Resource-Logistics Planning Model (RoD Resource-Logistics Request). He/She will coordinate with the System Resource Section Chief to ensure all state resources are appropriately assigned pre-event for Planning, Operations, Logistics, Administration, Command Center staffing and maintained in the appropriate “storm assignment” tracking tool, Personnel Maintenance Tool (PMT) or other current application on an ongoing basis including when personnel change jobs or a change in storm assignment required.

B.2. State Manpower Supervisor The Manpower Supervisor is responsible to ensure the Resource Manpower Leaders, for each type resource, plan the amount, type, location and timing of need for state resource requirements, make timely and effective decisions on allocations, deployment and work area assignments and effectively coordinate the supply of appropriate information to Crew Tracking and Logistics for efficient management and support of resources. He/She is responsible to coordinate the requirement with the Manpower Supervisor and assist with entry of requirements in to RoD. Also, he/she is to ensure timely and accurate use of RoD to manage resource requirements, request, team acquisitions, allocations and deployments. He/She will coordinate with State T&D Resource Section Chief on resources needs.

B.3. State Manpower Leader (Distribution Line, Transmission Line, Transmission Substation, Vegetation, Scout)

These Manpower Leaders are responsible for planning, allocation, deployment, tracking, communication and coordination of resources and related support within State; including planning requirements and assignments for in-state and out of state resources assigned. He/She is responsible to coordinate the requirements with the Manpower Supervisor. He/She will also ensure crews are timely assigned to work areas and staging sites in RoD, after Check-In notification received if crews handed from system to state, by self or assignment to state crew tracker.

B.4. State Support Manpower Leader The Support Manpower Leader is responsible for planning, acquisition allocation, deployment, tracking, communication and coordination of Support Manpower Resources within state including requirements and


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assignments for In-System Support and out of state assigned. Support requested and provided by other states shall be coordinated through System Command Center. However, in state support including Security Guards, Pilots, Truck Drivers, Fuel Handlers, Environmental contractor, Managers, Command Center Teams etc. shall be planned, acquired, deployed and tracked by the Support Manpower Leader and include coordination with respective state emergency support personnel. Example, the State Manpower Support shall coordinate with the State Security Leader to acquire, obtain rosters and deploy local security guards. He/she will also insure crews are timely assigned to work areas and staging sites in RoD.

B.5. State T&D Special Equipment Leader The Special Equipment Leader is responsible for planning, acquisition, allocation, deployment, tracking, communication and coordination for Special Equipment within state including planning requirements and assignments for in-state and out of state resources assigned. Also, he/she will coordinate with System Special Equipment Leader to insure system prioritization and off-system requirements.

B.6. State Resource Support Leader The Resource Support Leader is responsible for providing general clerical and administrative assistance as required or instructed.

B.7. State Crew Tracking Supervisor The Crew Tracking Supervisor is responsible for coordinating tracking of state manpower resources including state company personnel, base load contractors and out of state assigned resources such as loaned in-system travel teams and in-system support manpower, mutual assistance and off-system contractors. He/she is responsible to oversee, monitor, coordinate and insure timely and accurate maintenance of State RoD requirements to insure appropriate, accurate, complete and timely update of all state resource tracking, as well as ensuring timely and accurate reporting of tracking, road check and assignment communication with crews, crew arrival status, reassignment and release as directed by the Manpower Supervisor or staff.

B.8. State Crew Tracking Leader The Crew Tracking Leader is responsible for creating crew sets for in-state company personnel and for in-state base load contractors and ensuring all crew sets are adjusted


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and deployed into RoD accurately, timely and assigned appropriately. Also, as directed by Resource Manpower Leaders, maintain RoD requirements to ensure appropriate, accurate, complete and timely update of all crew roster maintenance and crew tracking including communication to crews, assignments in RoD. The Crew Tracking Leader will track all Off-System and Mutual Assistance crews from the point of “Hand-Off” and ensure crew ETAs and rosters are provided to the work areas where crews are assigned.

3.3.4 Processes/Interfaces 3.3.4.1 Activate Resource Section

This process is to communicate activation of the System Emergency Operations Plan. This includes placing staff on alerts and activating emergency response for System Command and for State Command as required by the event or declaration by the System Incident Commander. A SOR-Weather notice will be forwarded to the SCC Resource Section Branch Directors and the State Resource Chiefs as an alert to monitor weather and be prepared for activation. The State Chiefs may be activated by the State Incident Commander if only that respective State is at risk or impacted. When multiple States are at risk or impacted, the System Resource Section Chief will page and email the System Resource Branch Directors and State Chiefs to activate. Each Director/Chief shall then alert their respective branches/groups to activate at the level required or as designated.

3.3.4.2 Identify Resource Requirements This process is to determine and validate the type, number, location, and timing of resources needed or released for specific forecast based on input from System Planning Section and State T&D Operations Section. This information will be timely provided to Logistics for integrated planning and reported to the System and State Incident Command organizations.

3.3.4.3 Integrate Resource Requirements with Logistics Capabilities The process of Resource and Logistics integration includes proactive communication of Resource plans to Logistics for development of a Logistics plan to support the resources including Fleet and Supply Chain capabilities. Every effort should be made by Logistics to support the Resource plan. However, when it is not feasible, or adequate support cannot be implemented, planning adjustments to the Resource plan


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need to be made. This planning process is to be performed in advance of a storm to coordinate and match resource and logistics support.

3.3.4.4 Acquire Resources Manpower and Special Equipment needs will be secured based on input from outside Contractors, Mutual Assistance Companies and Entergy Operational and Functional areas. Resources will be acquired based on availability and approval by State Incident Commanders/System Incident Commander.

3.3.4.5 Manage Contracts Contracts will be secured with Vendors and Contractors who perform storm restoration tasks. Based on input from the field, contract addendums and invoice payments will be determined by the Supply Chain Contract Administration group and Contract Invoice Processing Team (CIPT).

3.3.4.6 Allocate and Deploy Resources Based on input from States, Resources will be allocated based on availability, need, and customers at risk. If multiple events occur at the same time, resources will be reallocated among States based on restoration times and criticality of service. This information will be provided back to the States.

3.3.4.7 Check-In Resources Resources will be checked-in based on Check-In Site activation/closure, timing and Check-In Team assignments. Validation of personnel and equipment at Check-In Sites or Staging sites will be provided to States. Resources not checkedin by Check-In teams shall be checked in by Operations personnel/Entergy Leads at work sites or staging sites.

3.3.4.8 Track Resources Crew and support personnel rosters and associated information including “Hand-Off” notification of crews from acquisition, road check status en route, assignment to Check-In Sites, Work Areas, and Staging Sites, deployment, re-assignments and releases will be tracked in a common system and available to all Sections (Planning, Resource, Logistics, Operations, Administration) and System Incident Commander.

3.3.4.9 Report Resources Based on crew information received from System and State Resource Sections, Resource reports will be issued to the System Incident Commander, System Section Chiefs and State Incident Commanders and maintained for records of event resources.


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3.4 Logistics 3.4.1 Purpose

Logistics is defined as the procurement and delivery of needed resources in a timely manner to support the restoration effort which could include lodging, staging areas with ancillary support such as meals, showers, laundry, restrooms, transportation, supplies and business continuity logistical needs. The purpose of the logistics process is to be a productivity enhancement to the restoration effort. All logistics processes will be governed by this concept. It is expected that these logistic efforts may be carried out at times of emergency and under stressful conditions. Proficiency and flexibility in the utilization of this plan are needed to guarantee that the goals of the logistics efforts are met. Each defined position should be staffed for 24 hours of activity or to the level necessary to provide adequate logistics support. Proper documentation of logistical activities is vital in proper, timely payment of invoices and cost recovery from the affected regulatory jurisdiction. Contracts, when required, should be executed and maintained by Supply Chain. All logistical staff should be trained in the documentation requirements for the activities they perform. The system-level logistics effort would occur in the event of System Command Center Activation and/or remotely if the affected State logistics group(s) is not able to provide the necessary services without additional resources.


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3.4.2 Organization

Staging Branch Director

State Logistics Section Chief

Logistics Interface Leader

Lodging BranchDirector

Evacuation/Business Continuity Leader

Fleet Services Leader

Lodging Support

Logistics Audit /Invoice Process

Leader

Staging Support

Business Continuity Leader

Logistics Contract Administration Branch

Director

Region Logistics Supervisor

Lodging Leader Staging Leader

RoD Operators

FieldLodging

AlternateLodging

CommercialLodging

LodgingSupport

StagingSupport

Off Site Alt Lodging

Off Site Alt Lodging

Staging Site Managers

LEGEND*Position will be utilized to limit span of control as needed depending on specific restoration requirements

Staging Site Recorder

SystemLogistics Section Chief

Logistics Support Branch Director

Fleet Services Branch Director

Lodging Branch Director

Staging Branch Director

Logistics Contract Documentation Supervisor

Logistics Organization

Logistics Contract Documentation Leader

Metrics and Reporting Leader

Process/Control Leader

Logistics Contract Administration Leader

SCC Support Leader

Supply Chain Leader

Supply Chain Leader

*


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3.4.3 Roles & Responsibility A. System Command Center

A.1. System Logistics Section Chief The System Logistic Chief is responsible for coordinating system activities associated with restoration and business continuity logistical needs including transportation activities, and assisting the States in meeting specific logistical requests. The System Logistics Section Chief will be located in the System Command Center and will coordinate specific logistical needs required by the State(s). The primary role of this position is to provide a system-wide level of coordination between the State Logistics Section Chiefs, logistics contractors and other System Command Center sections during the company’s evacuation and/or restoration efforts while ensuring compliance with all logistic processes and required documentation of logistic services. System Logistics Section Chief will review the market resource availability with the System Planning Section Chief, System Resource Section Chief, and System Storm Incident Commander to determine the proposed system level of resource requirements for event planning. If requested by the affected States, logistics vendor authorization and engagement processes will be initiated and coordinated at this level if System Command Center is engaged.

A.2. Logistics Support Branch Director The System Logistic Support Branch Director is responsible for coordinating system activities associated with restoration and business continuity logistical needs including transportation and assisting the States in meeting specific logistical requests.

A.3. Metrics and Reporting Leader The System Metrics and Reporting Leader will provide assistance and support in acquisition, management, and distribution of data/information. Assist with obtaining, documenting and storing records.

A.4. Process/Control Leader The Process/Control Leader will have oversight for the processes and procedures within the Logistics SCC. This will include development and management of those control processes and procedures. This position will document decisions within the logistical section and will also maintain flow charts that describe our controls and processes. This position will serve as backup to each logistical Director


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position. In addition this position will support the System Metrics and Reporting Leader.

A.5. Business Continuity Leader The System Business Continuity Leader is responsible for the coordination of all non-restoration business functions needed for successful corporate operations. The specific duties will vary with each particular event.

A.6. SCC Support Leader The System Command Center Support Leader is responsible for coordinating all logistical needs of the System Command Center with Power House management. These activities include telecom, IT, lodging, and meals for all activation levels at the Transmission Headquarters and the Power House.

A.7. System Staging Branch Director The System Staging Branch Director coordinates with the State Logistics Section Chiefs and/or State Staging Branch Director to determine what logistics services and support will be needed for supporting the restoration workers. Should the State Logistics Section Chief and the State Incident Commander determine that certain logistics needs will be supplied by a logistics contractor; the Staging Branch Director will make sure that the contractor has been notified and that the “Notice to Proceed” form has been properly completed and sent to the appropriate logistics vendor. The System Staging Branch Director will ensure all required processes, procedures, and documentation is being followed and provide periodic status reports to System Logistics Section Chief.

A.8. System Lodging Branch Director The System Lodging Branch Director will work closely with the System Command Center Resource function and the State Logistics Section Chiefs to determine where and what type of lodging will be needed. This will include the use of alternate lodging resources. Also, the Lodging Branch Director is responsible for coordinating with Mutual Assistance companies on the level of self-contained crews they can provide and in determining the level in which they will respond. The position will ensure all required processes, procedures, and documentation is being followed and provides periodic status reports to System Logistics Section Chief.

A.9. System Fleet Services Branch Director The System Fleet Services Branch Director, in coordination with the System Logistics Section Chief, is


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responsible for coordinating system activities associated with the servicing of transportation equipment, securing additional transportation as required, and assisting the States in meeting remote site fuel requirements.

A.10. Logistics Contract Administration Branch Director The System Logistics Contract Administration Branch Director is responsible for coordinating and assisting the System Logistics Section and the State Logistics Section with the execution of logistical contracts.

A.11. Logistics Contract Administration Leader The Logistics Contract Administration Leader is responsible for coordinating and assisting the Contract Administration Branch Director, System Logistics Section and the State Logistics Section with the execution of logistical contracts.

A.12. Logistics Contract Documentation Supervisor The System Logistics Contract Documentation Supervisor is responsible for coordinating with the System Logistics Section and the State Logistics Section (Audit/Invoice Process Coordinator) to ensure the proper documentation is completed, compiled and provided to the appropriate location for invoice processing and payment.

A.13. Logistics Contract Documentation Leader The System Logistics Contract Documentation Leader is responsible for coordinating with the System Contract Documentation Supervisor to ensure the proper documentation is completed, compiled and provided to the appropriate location for invoice processing and payment.

B. State Command Center B.1. State Logistics Section Chief

The State Logistics Section Chief is responsible for coordinating state activities associated with restoration and business continuity logistical needs, including transportation activities, in meeting specific logistical requests. The State Logistics Section Chief will be located in the State Command Center and will coordinate specific logistical needs required by the State. The primary role of this position is to provide a state wide level of coordination between the State Logistics Branch Directors, Leaders, and Logistics Contractors during the company’s evacuation and/or restoration efforts. The State Logistics Section Chief will coordinate with the State Planning/Resource Section Chiefs and State Operations Manager/Grid Manager to estimate resource requirements for the forecasted event.


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This position is responsible for requesting and developing the required documentation to memorialize the logistic events according to the logistic processes. This position is responsible for enforcement of logistic processes for their applicable State. Logistics vendor engagement process will be initiated at this level if the System Command Center is not engaged. Authorization to commit vendor engagement is required before notice to proceed is sent to vendor.

B.2. State Evacuation /Business Continuity Leader The Evacuation/Business Continuity Leader is responsible for the coordination of information regarding an evacuation order to all business functions with identified work groups and for the coordination of all non-restoration business function needed for successful corporate operations. The specific duties will vary with each particular event.

B.3. State Logistics Interface Leader The Logistics Interface Leader will obtain information/data from the State Resource Section Chief and other State Function Rooms (Resource, Planning, Vegetation, Gas, Grid, etc.) that Logistics requires, and needs, to make informative decisions.

B.4. State Lodging Branch Director The Lodging Branch Director will work closely with the State Logistics Section Chief to determine where and what type of lodging will be needed and to manage the end-to-end lodging process. The goal is to acquire and utilize decent, cost-effective lodging in geographically sensible locations. This will include the use of alternate lodging resources as necessary. (Alternate lodging includes traditional hard-shell facilities and non-traditional housing; namely, tents, bunk trailers, travel trailers, etc.)

B.5. State Lodging Support Lodging support will provide all necessary reports, tracking and updates to the Lodging Branch Director as to status of all lodging needs and or facilities utilized.

B.6. State Staging Branch Director The Staging Branch Director coordinates with the Region Logistics Supervisors, Staging Leaders, and Staging Site Managers to determine what logistics processes will be needed for supporting the restoration workers. Should the State Logistics Section Chief and the State Incident Commander determine that certain logistics needs will be supplied by a logistics contractor; the System Staging Branch Director/State Staging Branch Director/Region Logistics Supervisor will make sure that the contractor has


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been notified and that the “Notice to Proceed” form has been submitted (See Vendor Initiation Process). It is imperative that approval is received from upper management before spending any dollars. The State Staging Branch Director will notify State Resource Section Chief/Region Resource Supervisor on any crews showing up at the wrong staging site or sitting idle at a staging site when crews should have departed to work locations. The State Logistics Section Chief will provide periodic status reports to System Logistics Section Chief.

B.7. State Staging Support Staging support will provide all necessary reports, tracking and updates to the Staging Branch Director as to status of all staging needs and facilities.

B.8. State Fleet Services Leader The Fleet Services Leader, in coordination with the State Logistics Section Chief, is responsible for coordinating activities associated with the servicing of transportation equipment, securing additional transportation as required, bussing schedules and assisting in meeting remote site fuel requirements.

B.9. State Logistics Audit/Invoice Process Leader The Logistics Audit/Invoice Process Leader will work with the State Logistics Section Chief and the system logistics Contract Documentation Supervisor to ensure proper documentation/audits of all logistical invoices.

B.10. State Region Logistics Supervisor The Region Logistics Supervisor will be utilized to limit span of control, as-needed, depending on specific restoration requirements.

B.11. State Lodging Leader The Lodging Leader will work closely with the Region Logistics Supervisor to determine where and what type of lodging will be needed and to manage the head-to-bed lodging process. Goal is to acquire and utilize decent, cost-effective lodging in geographically sensible locations. This will include the use of alternate lodging resources as necessary. (Alternate lodging includes traditional hard-shell facilities and non-traditional housing; namely, tents, bunk trailers, travel trailers, etc.) The Lodging Leader will work closely with the PDD Operators, Lodging Support and all field lodging to consider alternate and commercial lodging facilities to ensure adequate lodging needs are met.

B.12. State Alternate Lodging Leader


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Alternate Lodging is responsible for the set-up and decommission of the lodging facilities on-site. Individual executes alternate lodging agreements and manages daily operations of the lodging process. Ensures sufficient supplies/resources for the lodging facility, coordinates crew assignment to beds. Manages all on-site lodging support personnel, sets performance standards and maintains positive moral. Responsible individual coordinates with the lodging site vendor to maintain proper documentation of bed assignments. Also, ensures that the site is safe and that all safety and environmental standards are maintained. Individual ensures that invoices and site inventory tracking forms are completed and submitted. Handle all alternate lodging site problems as they arise.

B.13. State Off-Site Alternate Lodging Leader Off-Site Alternate Lodging will work with Alternate Lodging on the set-up and decommission of the assigned lodging facility, daily operations, reports and status.

B.14. State RoD Operators The RoD operators will maintain and update all lodging information on a timely basis regarding acquisitions and assignments, locations and personnel regarding lodging in RoD.

B.15. State Field Lodging Leader Field Lodging will coordinate and acquire commercial and alternate lodging facilities, execute appropriate lodging agreements with facilities.

B.16. State Commercial Lodging Leader Commercial Lodging will execute Storm Lodging Agreements with Non-CLC facilities, acquire commercial lodging beds, assign resources to beds and provide info to RoD operators timely, completely and accurately. Individual will communicate with appropriate Crew Tracker as to crews’ assignments and will work with Field Lodging for additional rooms.

B.17. State Lodging Support Leader Lodging Support will assist the Lodging Leader in the coordination of all lodging facilities.

B.18. State Staging Leader The Staging Leader will work closely with the Region Logistics Supervisor to determine what logistics processes will be needed for supporting the restoration workers at sites. The Staging Leader coordinates with Staging


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Support and the Staging Site Managers for all site facility needs, reports and documentation requirements.

B.19. State Staging Site Manager The Staging Site Manager is responsible for the set-up and decommissioning of the site along with management of daily operations of site while ensuring sufficient supplies/resources for the site following the ‘notice to proceed’ process for all additional requests to vendor. Individual manages all on-site support personnel, setting performance standards and maintaining positive morale. He/she completes the daily safety briefing form with all on-site personnel. Coordinating with site vendor, all supply vendors, network logistics lead, line supervisors, Customer Service Managers and crew leaders. Individual ensures that all safety and environmental standards are maintained, conducts a safety orientation with on site vendors and works to ensure that invoices and site inventory tracking forms are completed and submitted. He/She also resolves all site problems as they arise.

B.20. State Staging Site Recorder The Staging Site Recorder maintains record/inventory of all resources on site, conducts pre/post site inspection which may include coordination with environmental. Receives all billable goods invoicing, submits daily staging site tracking form to region/state command center. Inventory tracking and maintaining daily records of assets on-site and communicates to Site Manager. Receives all invoices and shipment purchase orders and submits them to the Site Manager.

B.21. State Staging Support Staging Support will manage and coordinate installation and maintenance of all site facilities to include IT, Telecom, lights, portable restrooms, generators, cold storage, trash bins, and portable buildings. He/She coordinates with the Staging Manager all aspects of the site to ensure proper function and efficient. Conducts before/after inspections of site (include photos) and completes repairs as-needed. Communicates all unresolved issues to Staging Site Manager.

3.4.4 Processes/Interfaces 3.4.4.1 Logistical Planning

This process is to determine and validate the type, number, location, and timing of resources needed or released for specific forecast based on input from System Planning Section and State T&D Resource Section. This information


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will be utilized for determining the overall logistical plan for the event including staging sites, lodging requirements, and all other aspects of logistical support needed. Once this plan is developed, it will be provided to the System Incident Commander and the System and State Command Center Section Chiefs including Command Staff.

3.4.4.2 Logistics Vendor Contracting Process based on obtaining the required approval authority to initiate and engage vendors while outlining the planning, coordinating, assigning, managing and releasing logistics vendors once engaged. This process will also ensure the proper contracting of logistical services including documentation needed for invoice processing and post storm cost recovery.

3.4.4.3 Staging Site Operations and Documentation Identifies the process for a staging site manager to adequately and safely prepare and operate a site daily for all personnel, vendors and contractors. This process also insures proper contract documentation to facilitate invoice processing, payment, and cost recovery.

3.4.4.4 Lodging Determination, Acquisition and Assignment Identifies steps in determining the types and locations of lodging facilities, the acquisition of lodging facilities, the communication between resources and logistics to facilitate advance preliminary lodging assignments of those resources to the lodging facilities. This process also ensures proper contract documentation to facilitate invoice processing, payment, and cost recovery.

3.5 Operations 3.5.1 Purpose

The purpose of the Operations Section function is to proactively manage resources to ensure safe work practices, repair and rebuild of infrastructure, operation of the system, and reporting progress of restoration efforts. Included is closing down and making routine project or work sites safe in advance of storms, checking in resources that do not get checked in through Check-In sites, managing crew rest times, managing crew assignments to restoration prioritization requirements, monitoring and managing safe work practices, efficiently managing dispatching, and proactively reporting restoration progress. * Nuclear, Fossil & Gas Operations perform similar Operations Section functions within their own organizations.


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System Transmission & Distribution

Operations Chief

State Operations Support Branch Director

Compliance Branch DirectorTOC Operations Support Branch

Director

System Command Center Operations Section

System Incident Commander

Transmission Line Support Leader

Distribution Line Support Leader

Substation Operations Support

Leader

Configuration Management Supervisor

TX TOC Supervisor

S-LA TOC Supervisor

MS TOC Supervisor

AR TOC Supervisor

WM-LA TOC Supervisor

Operations Support Leader

Arkansas T&DOperations Chief

Louisiana T&DOperations Chief

Mississippi T&DOperations Chief

Texas T&DOperations Chief

The State T&D Operations Chief will be responsible to execute operation responsibilities, developed by system and states, and report directly to the State Incident Commander when a State Command Center is activated

Transmission Compliance Leader

CIP Leader

Vegetation Support Leader

DOC Support Leader

Configuration Management Transmission Leader

Configuration Management Distribution Leader

TOC Support Supervisor

April 1, 2011

Transmission IT Support Leader

Process Control System Operations Leader

System Telecomm Support Supervisor

Network/Telecom Support Branch Director

IT Data Center Operations Leader

Command Center IT Support Leader

Control Center Support Supervisor

Southeast LASOC

Gretna TOC/DOCB. R. LA TOC/DOC

Little Rock TOC/DOC

Texas

Baton Rouge

West Monroe

Jackson

Little Rock

Jackson TOC/DOC

Beaumont TOC/DOC

W Monroe TOC/DOC

3.5.2 Organization


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A.1. System Transmission & Distribution Operations Chief The System Operations Chief is responsible for directing the Distribution and Transmission restoration activities and coordinating the State’s T&D emergency operations and restoration efforts. The Operations Chief has the responsibility for operating the system, assuring the coordination of resources to manage restoration prioritization, repair of infrastructure, restoring service, and reporting progress which includes the following duties:

• Ensure the safety of all employees and the public. • Determine the amount of resources, i.e. personnel and

equipment that will be required to support the state for any event and to coordinate a request for such resources through the System Command Center/Resource section. These will include resources not assigned within the state, i.e. off-system contractors, company employees from non-impacted areas, including support from Corporate, etc.

• Ensure coordination of Grid restoration and Distribution restoration for sharing of resources.

• Implements and directs the state’s restoration efforts and plan(s) to ensure a safe and efficient restoration.

• Activates and mobilizes the state’s Network/Sub Network Command Structure.

• Communicates restoration resource needs with the Systems Resource Chief and Logistic Chief.

A.2. Compliance Branch Director The Compliance Branch Director is responsible for the overall coordination and direction of activities associated with Transmission Compliance, Critical Infrastructure Protection, and Configuration Management. This responsibility includes the coordination of efforts among the states to insure that Compliance, Critical Infrastructure Protection and Configuration Management requirements are being met, including:

• Oversight of the activities pursuant to conformance with regulations regarding transmission policy.

• Oversight of the activities pursuant to conformance with regulations regarding Critical Infrastructure Protection.

• Oversight of Configuration Management activities to control and capture configuration of, and asset changes in, the Transmission and Distribution System.


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• Communicating with the Compliance Lead, CIP Lead and Configuration Management Supervisor on issues impacting the execution of Configuration Management procedures.

A.3. Configuration Management Supervisor The Configuration Management Supervisor is responsible for directing the Distribution and Transmission Configuration Management activities. The Configuration Management Supervisor has the responsibility for assuring that asset and configuration changes of the Transmission and Distribution systems, which occur during repairs of infrastructure and restoring of service, are captured and documented, which includes the following duties:

• Overseeing the reporting and performance of Configuration Management processes.

• Overseeing the processes for gathering data on reported outages and damages (Transmission and Distribution).

• Communicating with the Compliance Director on issues impacting the execution of Configuration Management procedures.

A.4. Configuration Management Transmission Leader The Configuration Management Transmission Leader has the responsibility for assuring the documentation of asset and configuration changes of the Transmission system which occur during repairs of infrastructure and restoring of service; including the following duties:

• Receiving damage assessment reports from the Situational Assessment unit and work with the state Command Centers to ensure continuity of the configuration management process throughout the restoration effort.

• Reviewing damage assessment reports for damaged line sections and substations against the current asset databases for the individual components comprising a facility, identify opportunities to upgrade damaged limiting components, and make recommendations to the Operations Section Chief and Planning Section Chief.

• Reviewing emergency replacement work scope and communicate facility rating information to designated organizations as part of the energization notice process.

• Assembling a report of facilities that required asset replacements under the emergency replacement


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process and track submittal of the asset data information to engineering and configuration management for appropriate document and database updates.

• Ensuring engineering was engaged in any work scope that affected the design basis.

• Performing updates to the facility ratings workbooks as repairs are completed and the as-built information is submitted.

• Performing updates to Substation Work Management System and Line Work Management System databases with new asset information

• Interacting with the State Substation Operations Supervisors and Transmission Line Supervisors to identify work scope replacing assets and the work orders under which the work is being performed.

A.5. Configuration Management Distribution Leader The Configuration Management Distribution Leader is responsible for administering and performing the Distribution Configuration Management Major Storm Procedure, which includes the following duties:

• Receiving damage assessment reports of the distribution system and interface with the Distribution Operations Section to ensure continuity of the configuration management process throughout the restoration effort.

• Working with the state Operations Section to assemble a report of the distribution facilities that required asset replacements under the major emergency and establish tracking of submittal of the circuit map mark-ups and DCO forms to the Data Maintenance Coordinator.

• Working with the state Operations Section to identify complex circuits under restoration that may require as-built walk-down audits upon completion of circuit restoration.

A.6. Transmission Compliance Leader The Transmission Compliance Leader is responsible for ensuring the continuity of the compliance with regulatory requirements (NERC, FERC. etc) throughout the restoration effort, and ensuring the continuity of the Paperless Condition Reporting System process throughout the restoration effort, which includes the following duties:

• Coordinating on-call support for Entergy Transmission Tariffs and Scheduling / Open Access Transmission Inc. / Independent Coordinator of Transmission.


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• Supporting documentation and evaluation of identified issues.

• Reviewing OASIS for required postings (Order 890) Order 717 and other applicable Orders.

• Identifying and coordinating new informational postings on OASIS.

• Ensuring Procedure Availability and Compliance with the T&D Management Manual.

• Providing procedural interpretations.

A.7. Critical Infrastructure Protection (CIP) Leader The Critical Infrastructure Protection Leader is responsible for ensuring the integrity of the Electronic Security Perimeter (ESP) during times of emergencies and disasters by monitoring and documenting the devices that are introduced into the ESP pursuant of the Electronic Access Security Perimeter procedure, which includes the following duties:

• Ensuring the disposal or redeployment of critical cyber assets as a result of a disaster or emergency pursuant to the Managing Disposal and Re-deployment of Cyber Assets procedure.

• Document and communicate CIP incidents as a result of a disaster or emergencies to ES-ISAC (when necessary), in accordance with the Incident Reporting Procedure.

• Ensuring that accounts created, modified, or removed during disasters or emergencies are pursuant to the Account Management for Cyber Assets within an ESP.

• Overseeing the Security Policy exceptions granted during the state of emergency, which may be approved verbally per the Exception procedure by the NERC CIP Senior Manager.

• Ensuring that exceptions to the Security Policy made during times of emergencies and disasters are captured in PCRS pursuant with the Exception procedure steps.

A.8. State Operations Support Branch Director The State Operations Support Branch Director is responsible for providing area support to the Distribution and Transmission Operations within the state T&D Operations Section. Support activities include:

• Ensure the safety of all employees and the public. • Provide additional technical support and manpower to

the Transmission and Distribution field groups for needed additional: o Aerial Patrol.


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o Transmission Sub Networking. o Distribution Sub Networking.

• Coordinate the inventory and staging of portable generators into the affected areas for Substation DC Battery recovery.

• Maintenance of the Substation/Relay Storm Damage Field Report Form.

• Interface with SCADA support and Transmission field groups on RTUs out of service (RTU Hardening).

• Responsible for providing T&D Equipment Support: o Compilation of impacted substation equipment. o Inventory of spare equipment available. o Evaluation and optimization of spare equipment

needed during restoration. • Ensuring that field work plans coincide with the

restoration prioritization developed by the System Command Center Planning Section.

A.9. Transmission Line Support Leader The Transmission Line Support Leader is responsible for providing oversight for the effectiveness and progress of the execution of storm response and restoration of Transmission lines and equipment ensuring that any gaps with coordination, integration, and resources are effectively closed. This includes pre-storm activities, initial post storm damage assessments, transmission line and equipment restorations, and post restoration activities. Also included is oversight of transmission restoration activities to ensure that field work plans coincide with the restoration prioritization, providing technical guidance and expertise, coordinating any spare/special equipment needs, and communicating any deficiencies to the state Operations Support Branch Director.

A.10. Distribution Operations Support Leader The Distribution Operations Support Leader is responsible for providing oversight for the effectiveness and progress of the execution of storm response and restoration of distribution lines and equipment ensuring that any gaps with coordination, integration, and resources are effectively closed. This includes pre-storm activities, initial post storm damage assessments, temporary power requirements, and distribution line and equipment restorations. Also included is oversight of distribution restoration activities to ensure that field work plans coincide with restoration prioritization, providing technical guidance and expertise, coordinating any spare/special equipment needs, and communicating


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any deficiencies to the state Operations Support Branch Director.

A.11. Substation Operations Support Leader The Substations Operations Support Leader is responsible for providing oversight for the effectiveness and progress of the execution of storm response and restoration for substations and ensuring that any gaps with coordination, integration, and resources are closed. This includes pre-storm activities, initial post storm damage assessments, temporary power requirements, and substation equipment restorations. Also included is oversight of the grid’s restoration activities to ensure that field work plans coincide with the restoration prioritization, providing technical guidance and expertise, coordinating any spare equipment needs, and communicating any deficiencies to the state Operations Support Branch Director.

A.12. Vegetation Support Leader The Vegetation Operations Support Leader is responsible for providing oversight for the entire vegetation operations storm response and restoration effort. This includes ensuring the effectiveness and progress of the execution of storm preparations, response, and restoration for the vegetation organization and making sure any gaps with coordination, integration, or resources are closed. Included is support and coordination of the Distribution and Transmission Vegetation Operations within the state Operations Section and the T&D Vegetation Off-System Manpower branch of the System Resource Section, by providing oversight of the effectiveness and progress of the execution of the storm response. This includes pre-storm activities such as determining availability of resources, pre-coordination of crew tracking and logistics, pre-notification of safety requirements and pre-staging of resources; initial damage assessment and resource requirements, monitoring allocation of off-system resources and coordination between states. Providing leadership and guidance to ensure that restoration activities coincide with the restoration prioritization provided by the planning section and communicating deficiencies to the state Operations Support Branch Director.

A.13. DOC Support Leader The DOC Support Leader is responsible for coordinating with Entergy’s six Distribution Operations Centers to ensure each are able to provide the necessary support for restoration of the Distribution system after a major event.


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A.14. TOC Operations Support Branch Director

The TOC Support Branch Director is responsible for coordinating with Entergy’s five Transmission Operations Centers to ensure each are able provide the necessary support for restoration of the Transmission system after a major event.

A.15. Network/Telecomm Support Branch Director The Network/Telecomm Support Branch Director is responsible for coordinating the operations including restoration of any voice, data, and IT systems needed during the event for both business and process control systems. The leader coordinates/delivers this service through the coordination of activities of six functional groups. Those groups include:

• System Telecomm Support. • Process Control System Operations. • IT Data Center Operations. • Control Center Support. • Transmission IT Support. • Command Center IT Support.

A.16. System Telecomm Support Supervisor The System Telecomm Support Supervisor reports to the Director of the Network/Telecomm Support Branch and is responsible for operation and restoration of all microwave, fiber optic, telephone and two-way radio operations and restoration.

A.17. Process Control System Operations Leader The Process Control Systems Operations Leader reports to the Director of the Network/Telecomm Support Branch and is responsible for coordinating the operations of process control systems. The leader works closely with leaders of the IT Data Center Operations and Control Center Support to ensure the availability of process control systems during the event.

A.18. IT Data Center Operations Leader The IT Data Center Operations Leader reports to the Director of the Network/Telecomm Support Branch and is responsible for the IT Data Center Operations. The leader coordinates the support of all systems, except the Process Control Systems, including business applications and the operation of Entergy’s voice, data, and IT business systems. Key activities of this leader include:

• Support the operations of the Corporate IT systems.


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• Communicate to the Process Control System Operations of changes to systems that may impact process control systems operations.

• Coordinate the response of Field Services.

A.19. Control Center Support Supervisor The Control Center Support Supervisor reports to the Director of the Network/Telecomm Support Branch and is responsible for the on-site support of Control Center Operations at Entergy’s SOC, TOCs, and DOCs. The Control Center Support Supervisor supports the control center operations by coordinating the activities of on-site employees and contractors at each Control Center and insures there are adequate resources on-site to support the operations of the control centers. Key responsibilities of this functional group are:

• Prepare periodic RTU outage reports. • Work with Telecommunications to restore RTU

communications. • Provide Tier 1, 2 and 3 Support for the operation of the

Process Control systems, both hardware and software. • Work with Facilities to ensure critical control center

infrastructure such as UPS and emergency generator are available and operational.

A.20. Transmission IT Support Leader The Transmission IT Support Leader reports to the Director of the Network/Telecomm Support Branch and is responsible for the support of Transmission Business applications and the preparation of performance reports. Key activities include:

• Provide Tier 1, 2, and 3 support for Transmission Business applications.

• Support visualization of the transmission grid during major events.

• Assemble the RTU Outage reports into one comprehensive report.

• Assemble reports, as-needed, regarding the performance of IT/Telecomm infrastructure.

• Working with other branches, identify and communicate transmission lines down with fiber optic cable on the transmission line structures.


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B. State Command Center

B.1. State Command Center IT Support Leader The Command Center IT Support Leader reports to the Director of the Network/Telecomm Support Branch and is responsible for the setup and operational support of voice, data, and IT business systems used at the System Command Center. The leader works closely with the leaders of System Telecomm Support Branch and the IT Data Center Operations to ensure all systems needed at the System Commend Center are available during the event.

B.2. State Transmission & Distribution Operations Section Chief

The state Transmission & Distribution Operations Section Chief is responsible for preparing Distribution, Transmission & Substation restoration activities, managing the State’s emergency operations and restoration efforts; and has the responsibility for operating the system, coordinating resources to manage restoration prioritization, repair of the infrastructure, restoring service, and reporting progress.

B.3. State Distribution Director The Distribution Director is responsible for preparing the Distribution line and 69kV line, substation restoration activities, managing the state’s Distribution emergency operations and restoration efforts, and has the responsibility for operating the system, coordinating resources to manage restoration prioritization, repair of the infrastructure, restoring service, and reporting progress.

B.4. State Distribution Operations Center Supervisor The Distribution Operations Center Supervisor is responsible for coordinating dispatching responsibilities and outage information flow within the state, which includes the following specific duties:

• Coordinates with the state Incident Commander, Transmission and Distribution Directors and the 69kv Supervisor in providing dispatching services to each of the affected Networks or Sub-Networks.

• Oversees the dissemination of information to the Customer Information Centers.

• Provides the state Incident Commander with a timely and accurate customer outage count.

• Controls the re-energizing of all distribution circuits and all distribution substations following repairs.


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• Operates and switch 69Kv system in event of “overload” in TOC (only for those who have 69kv system).

• Coordinates with TOC for grid restoration and system stabilization.

• Writes and executes DOC controlled switching orders for the distribution system.

• Updates the Network Overview Cases (NOC) with data provided from the Regions.

• Oversees and assists in providing damage assessment and restoration status on Feeder and Network cases.

B.5. State DOC Leaders The DOC Leaders (Dispatchers) are responsible for providing dispatching services and ensuring that AM/FM information is up to date and reflects, as close as possible, the status of the outage cases that have been entered; including the following specific duties: • Ensure the safety of all primary switching within the

area of responsibility. • Provide assistance to the Distribution Region

Supervisors and Distribution Network Leaders in understanding & establishing restoration priorities.

• Closely monitors the restoration activities of the Storm Teams and updates AM/FM outage cases to reflect actual field conditions.

• Works with the Distribution Region Supervisors and Distribution Network Leaders to develop an accurate and timely customer outage count, and the number of trouble cases assigned/unassigned by location and type of predicted device.

• Assists the Distribution Region Supervisors and Distribution Network Leaders in maintaining accurate and current records of the restoration effort.

• Provide assistance to the Distribution Region Supervisors and Distribution Network Leaders in the assignment of Storm Teams.

• Provide assistance to the Distribution Region Supervisors and Distribution Network Leaders in providing customer outage information to the DOA Command Center.

B.6. State Distribution Region Supervisors The state Distribution Region Supervisor is responsible for preparing Distribution restoration activities and managing the state’s Distribution emergency operations and restoration efforts, has the responsibility for operating the


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system, coordinating resources to manage restoration prioritization, repair of the infrastructure, restoring service, and reporting progress.

B.7. State 69kV Line/Substation Supervisor (only for those who have 69KV system)

This position operates under the control of the Distribution Operations Director. During a major emergency, this position is responsible for managing and coordinating the 69kV grid restoration effort and providing crews based off the damage assessment, critical facilities and as directed from state Command Center.

B.8. State 69kV Switching/Clearance Leaders The 69kV Switching/Clearance Leaders is responsible for providing dispatching services for 69kV Lines and Substations, ensuring that AM/FM and COS information is up to date and reflects, as close as possible, the status of the outage cases that have been entered.

B.9. State Distribution Network Leaders The Distribution Network Leaders are responsible for managing and coordinating the Network restoration efforts and for providing crews based on the damage assessment, critical facilities and as directed from the State Command Center. The Distribution Network Leader is also responsible for providing daily information regarding restoration efforts in the recent past and immediate plans for work in the Network. This information may include, but is not limited to, circuit specific information, substation\feeder restoration information, general area information, and customer specific information.

B.10. State Line Crew Leaders The Line Crew Leaders are responsible for assisting the 69kV, Transmission Line, Distribution Network Leaders and Region Supervisors in managing and coordinating the Network restoration efforts, providing crews based on the damage assessment, critical facilities, and as directed from the state Command Center.

B.11. State Dispatch Leaders (AM/FM) This position is responsible for providing dispatch services and ensuring that AM/FM information is up to date and reflects, as close as possible, the status of the outage cases that have been entered.

B.12. State Damage Assessment Supervisor The Damage Assessment Supervisor is responsible for managing scouting resources to ensure safe work


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practices and scouting of the outage affected portions of the system, as well as to identify, document, and communicate to the Network Leaders, and/or Supervisors, the repairs and materials necessary to restore the system.

B.13. State Scout Crew Leader The Scout Crew Leader is responsible for managing scouting resources to ensure safe work practices and scouting of the outage affected portions of the distribution/transmission system to identify, document, and communicate the repairs and materials necessary to restore the distribution/transmission system.

B.14. Vegetation Crew Supervisor The Vegetation Crew Supervisor is responsible for managing resources to ensure safe work practices and clearing trees from the transmission and distribution system as necessary to repair and rebuild the distribution system for their assigned areas.

B.15. State Transmission Director The Transmission Director is responsible for preparing restoration activities and managing the state’s Transmission Line and Substation emergency operations and restoration efforts, has the responsibility for operating the system, coordinating resources to manage restoration prioritization, repair of infrastructure, restoring service, and reporting progress.

B.16. State Transmission & Distribution Information Director The Information Team will collect outage data and restoration estimates. This information will be gathered from the TOC, DOC, Transmission, Region Commands, Local Networks and Sub-Networks leaders. Information will also be collected from the TOC on estimated restoration and outages effecting distribution restoration. The team will then feed this data to state Incident Commanders, Public Information Officer and Governmental Liaison Officer.

B.17. State Information Coordinator The Information Coordinator will collect outage data and restoration estimates from both Distribution and Transmission and coordinate the interface between the DOC and TOC. The T&D Information Coordinator will assist in restoration coordination between Transmission and Distribution, both in cases where distribution is working transmission structures to restore an under built distribution circuit, or cases were distribution needs transmission work completed to restore under built distribution.


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B.18. State Transmission Operations Center Supervisor The TOC Supervisor is the controlling authority for the operation of, and the issuing of, clearances for switching, tagging and grounding of transmission facilities and the coordination of restoration of customers as facilities are available.

B.19. State Substation Operations Supervisor The Substation Operations Supervisor will coordinate all substation crew activities and will have the following specific responsibilities: • Manage substation damage repair and failure projects

due to storm related causes. • Assist Transmission Director in accessing manpower

needs prior to event. • Work as a team with Transmission Director,

Transmission Line Supervisor, and Substation Leaders to develop restoration plan.

• Manage the assignment, and dispatching, of substation and relay crews.

• Ensures all resources are properly checked in including those not using the check in process.

• Ensures all time sheets and invoices are correct and signed by Entergy Leaders.

• Work with switching coordinators to schedule switchman.

B.20. State Transmission Line Supervisor The Transmission Line Supervisor will coordinate all line crew activities with specific responsibilities that include:

• Assist Transmission Director in accessing manpower needs prior to event.

• Work as a team with Transmission Director, state Substation Operations Supervisor, Vegetation and Line Operations Leaders to develop restoration plan.

• Assign and dispatch line crews. • Ensures all resources are properly checked in,

including those not using the check in process. • Ensures all time sheets and invoices are correct and

signed by Entergy Leaders. • Work with switching coordinators to schedule

switchman. • Hold a clearance on all de-energized 138kV and above

line facilities, and to be the last one to release.


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B.21. State Transmission Switching Leaders

Coordinate all switching activities.

• Work with the Transmission Line Supervisor, TOC, DOC and Substation Leaders and 69kV Line\Substation Supervisor to schedule switchmen.

• This position may be located within the TOC in order to manage resources available for dispatchers to utilize during switching operations.

B.22. State Substation and Relay Leaders The Substation and Relay Leaders will assign specific assignments to internal and external crews to achieve results as defined by the Substation Operations Supervisor and report progress and location of crews. Specific responsibilities include:

• Assigns available crews to specific tasks as directed by the Substation Operations Supervisor.

• Records crew names, location, job assignment and progress.

• Reports to Substation Operations Supervisor the progress on the job assigned.

• Reports to Logistics the location of crews for food, lodging, and other incidental needs.

• Reports to crews any needs concerning lodging or transportation, if needed.

• Reports to Staging Area/Transportation Logistics any needs and location for additional materials and/or fuel.

• Reports status of “Alert” and solicits volunteers when it becomes necessary.

• Review Job Safety Analysis and Tail Boards. • Review timesheets and complete all required

paperwork. • Work with Material Coordinator for material delivery. • Work with the Transmission Switching and the 69kV

Switching/Clearance Leaders to schedule switchman. B.23. State Substation / Relay Crew Leaders

The Substation and Relay Crew Leaders will coordinate all substation and relay crew activities, which includes assisting in accessing manpower needs prior to the event and working closely with the state Substation Operations Supervisor to develop a restoration plan.

B.24. State Aerial Patrol Leaders The Aerial Patrol Leaders will coordinate all T&D aerial patrol activities and assist Transmission Line Supervisor in


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assessing damage on transmission lines. Duties also include ensuring compliance with all federal and state aviation requirements and that competent persons are deployed for aerial damage and restoration assessment.

B.25. Transmission Line & Substation Materials Supervisor The Transmission Line and Substation Materials Supervisor is responsible for acquiring, tracking, arranging disposal, and maintaining documentation justifying materials for all restoration activities within the Grid, including those provided by support functions. He/She will also work with the Accounting Leader to verify proper Capital Work Orders are created and that code block assignments are made to financial transactions for acquisitions and removals. He/She will coordinate with System Resource and Investment Recovery for salvage and cleanup of refuse material.

3.5.4 Processes/Interfaces 3.5.4.1 Activate Operations Section

This process is to communicate activation of the System Emergency Operations Plan. This includes placing staff on alerts and activating emergency response for System Command and for state Command as required by the event or declaration by the System Incident Commander. A SOR-Weather notice will be forwarded to the SCC Operations Section Branch Directors and the State Operations Chiefs as an alert to monitor weather and be prepared for activation. The state Chiefs may be activated by the State Incident Commander if only that respective state is at risk or impacted. When multiple states are at risk or impacted, the System Operations Section Chief will page and email the System Operations Branch Directors and state Chiefs to activate. Each Director/Chief shall then alert their respective branches/groups to activate at the level required or as designated.

3.5.4.2 Coordinate Resources for Restoration This process is to coordinate the resources that System Resource has allocated to the states based on interaction with Planning Group and restoration prioritization to safely and efficiently manage the restoration with those resources, personnel and equipment.

3.5.4.3 Manage Compliance This process is to ensure the overall coordination and direction of activities with the restoration process meets all compliance requirements of Transmission, Critical Infrastructure Protection and Configuration Management.


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3.5.4.4 State Operations Support

This process is to provide States impacted with support to the Distribution and Transmission Operations, compilation of equipment/resource needs, ensuring prioritization of restoration as directed by Planning Section. Coordinating with the state Operations Chiefs, documenting key measures and maintaining reports.

3.6 Administration 3.6.1 Purpose

The purpose of Administration Section function is to proactively manage the financial accounting and expense processing, reporting and recording of an event. Included is the collection of information and development of cost estimates, executive reports, filing of mandated reports when applicable, and recording of key activities and information to document the event. Also, responsibilities include proactive determination and communication of Storm Work Orders, expense allocation for support of multiple legal entities and audit and processing of contractor invoices. Additionally, to minimize the number of interfaces with support functions, Administration will interface and coordinate Environmental, Human Resource, Security, Claims, Aviation, Real Estate, CAS, Facilities and Legal function activities through liaisons as each function has their own emergency organization, plans, and activities.


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3.6.2 Organization


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A.1. Administration Section Chief The Administration Section Chief is responsible for development, implementation and execution of overall Administration processes including oversight and support of State T&D Administration Sections, and other Business Function administration support necessary to ensure process compliance and system coordination of administration. Included are coordination of information inputs from Finance, System Command Center Sections, state T&D Administration Sections, Business Unit and Support Functions as required to manage financial accounting and expense processing, reporting and documentation aspects of an incident, and coordination of key support activities as required.

A.2. Reporting Branch Director The Report Branch Director is responsible for coordination, review, edit, appropriate approval, distribution or filing with external agencies as required, retention of cost estimates, outage counts and mapping, executive and DOE reports for a specific major event. Also included are coordination, recording and retention of the history of an event including system wide key activities and records, Section and/or Support reports, etc.

A.3. Executive Report Leader The Executive Report Leader is responsible for coordination of input from other Sections and Functions, development of the System Executive Report per schedule required, approval and distribution of the report to a pre-defined list of system management.

A.4. Customer Count Report Leader The Customer Count Report Leader is responsible for coordination with State T&D Administration to validate accurate outage counts, development of the System Customer Count Report per schedule required, approval and distribution of the report to a pre-defined list of system management.

A.5. DOE Report Leader The DOE Report Leader is responsible for coordination of information from other Sections and Functions, development, approval and filing, distribution of the OE-


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417 report to a pre-identified distribution list when criteria for reporting is met for storm events.

A.6. Cost Estimate Report Leader The Cost Estimate Report Leader is responsible for gathering section and support function report information, generating the Cost Estimate per schedule required, and distributing to pre-determine personnel. Continuously revise Cost Estimate at periodic intervals throughout the event as cost factors evolve and become more defined and complete.

A.7. Customer Outage Count Report Leader The Customer Outage Count Leader is responsible for coordinating with state T&D Administration groups to validate accurate outage counts, generate, save for record, and distribute copies of the Customer Outage Projection report to the pre-determined distribution list. Customize and generate related reports as required.

A.8. Finance Branch Director The Finance Branch Director is responsible for overall coordination, approval, and distribution of appropriate Storm Work Orders, expense allocations, and auditing and processing of contractor invoices. Also included is coordination with Communications to record, post and distribute appropriate instructions for use of Storm Work Orders and coordination with Resource Section for communications with contractors of where to send storm related invoices. This position also fields all Finance questions and coordinates with the cost estimate report specialist as-needed to facilitate reviews and approvals of estimates.

A.9. Payroll Leader The Payroll Leader is responsible to develop charge allocation to various Storm Work Orders for appropriate accounting of time (labor), or other expenses, associated with a multi-legal entity, or multi-business unit, event and proactively communicate the allocation and method for recording each. Included is the coordination of Payroll system change requirements for System Command Center personnel and/or provide Workbook Tool to spread time to various codes and coordination with Communications to ensure appropriate communication instructions for charging to Storm Work Orders. The Payroll Leader works with the Human Resource leader on all questions


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regarding the recording of time in alignment with the storm event and company policies.

A.10. Project Code Leader The Project Code Leader is responsible for coordination with the System Planning Section to determine which business units and legal entities are estimated to be, or are, impacted by a specific incident and coordination with Budget Coordinators to ensure appropriate Storm Work Orders to account for preparation and recovery charges are proactively generated and distributed to them. Included is coordination with Communications to record, post and distribute appropriate instructions for use of Storm Work Orders. This position also answers storm accounting policy questions and lead the application of the policy to the specific event, in consultation with the Chief Accounting Officer, as-needed.

A.11. Contractor Invoice Processing Team Supervisor The Contractor Invoice Processing Team Supervisor is responsible for alert and activation of the CIPT at the appropriate location and timing in order to receive, track, audit, process and file contractor invoices for a specific event. Included is coordination with State Administration Invoice Support to acquire required support documentation for invoice, reconciliation of issues, appropriate accounting, and timely approval of invoice payment. NOTE: This position is NOT located at the System Command Center. The CIPT, when activated, will follow its emergency preparedness plan regarding location, and the team leader will be at that location.

A.12. Corporate/Utility Support Branch Director(s) The Corporate/Utility Support Branch Director(s) is responsible for proactive and timely coordination and resolution of Human Resource, Environmental, Legal, Security, Claims, Aviation, CAS, Real Estate, and Facilities issues that arise between those functions and others. Also included is support to perform special projects as-needed and backup, or assist, the Report Director and/or Report Leaders.

A.13. Human Resource Leader The Human Resource Leader is responsible to perform as a liaison between the Human Resources organization and System Command Center to coordinate and report the status of Human Resources issue resolution such as


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accounting for employees after major storm impact, labor issues, etc.

A.14. Legal Support Leader The Legal Support Leader is responsible to perform as a liaison between the Legal organization and System Command Center to coordinate and report the status of Legal issue resolution such as contract, finance, labor or other areas requiring Legal counsel.

A.15. Environmental Leader The Environmental Leader is responsible to perform as a liaison between the Environmental organization and System Command Center to coordinate and report the status of Environmental issue resolution such as contacting and leveraging environmental regulatory contacts for needs, i.e. shut down of consumer activities that endanger utility workers, waver or postponement of permitting for marsh restoration work, monitoring Industrial Hygiene, etc.

A.16. Security Leader The Security Leader is responsible to perform as a liaison between the Security organization and System Command Center to coordinate and report requests for additional security resources and/or the investigation of security breeches.

A.17. Claims Leader The Claims Leader is responsible to perform as a liaison between the Claims organization and System Command Center to coordinate and report the status of Claims issue resolution dealing with Public Inflicted Damage (PID) to Entergy facilities, Customer claims of property loss (liability claims), and Workman Comp claims as a result of a significant storm event.

A.18. Aviation Leader The Aviation Leader is responsible to perform as a liaison between the Aviation organization and System Command Center to coordinate and report movement/availability of corporate aviation assets.

A.19. Real Estate Leader The Real Estate Leader is responsible to perform as a liaison between the Real Estate organization and System


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Command Center to coordinate and report the acquisition of temporary facilities.

A.20. Corporate Administration Services Leader The Corporate Administration Services Leader is responsible to perform as a liaison between Corporate Administrative Services and the System Command Center to coordinate continuity activities for Senior Management team members.

A.21. Facilities Leader The Facilities Leader is responsible to perform as a liaison between the Facilities organization and System Command Center to coordinate and report the condition of existing Entergy building/facilities, repairs of said facilities, and/or ensuring safe return into existing facilities.

A.22. Administration Support Leader The Administration Support Leader is responsible to provide general administrative and clerical support for the System Command Center Administration Section including maintenance of the System Command Center Mailbox to file storm records and assist with setup or take down of the entire command center upon activation or ramp down.

B. State Command Center B.1. State Administration Section Chief

The State T&D Administration Section Chief is responsible to provide general oversight and ensure execution of state T&D Administration responsibilities and activities.

B.2. State Recorder/Document Control Leader The Recorder/Document Control Leader is responsible for gathering, organizing and retaining state T&D reports of event recovery activities, key activities for history of event and other post event reporting that may be required. Included is coordination of State Customer Count for reporting by accessing Resource on Demand (RoD), verifying customer counts numbers extracted from AMFM, obtaining approval for reporting from State Incident Commander including overwrite of counts as instructed, and acknowledge to System Customer Count Reporter per pre-determined schedules.

B.3. State Finance/Accounting Leader The Finance/Accounting Leader is responsible for ensuring appropriate Storm Work Orders are generated and


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distributed timely for accounting of event expenses and coordinating with System Project Code Coordinator as-needed to ensure appropriate instruction provided for charging incident expenses.

B.4. State Storm Credit Card Leader The Storm Credit Card Leader is responsible for ensuring appropriate distribution and tracking of Storm Credit Cards for state T&D, proactively contacting credit card lender to inform of anticipated trend change in card usage with forecasted or actual event, periodically gathering field credit card receipts and transaction logs, organizing, filing and preparing for audit of storm credit card invoices and timely and accurately auditing, reconciling issues and processing storm credit card invoices.

B.5. State Administrative Support Leader The Administration Support Leader is responsible to provide general administrative and clerical support for the State T&D Command Center Administration Section, including assisting Recorder Specialist with responsibilities and Command Center set-up and take-down.

B.6. State Invoice/Audit Support Branch Director The Invoice/Audit Support Branch Director is responsible for coordination of receiving, tracking, organizing and resolving incomplete information or documents to be provided to the Contractor Invoice Processing Team, when activated, and auditing and processing contractor invoices when CIPT not activated. When the CIP Team is activated, the following functions must be performed by each state command center (although the organizational structure will vary from state to state).

3.6.4 Processes/Interfaces 3.6.4.1 Manage incident reports, including development,

distribution and record retention Executive Report – The Executive Report Leader collects information daily from appropriate Section/Function representatives on the status of safety, weather forecasts, damages, preparation, recovery and system stability, resources, logistics, customer outage and restoration, environmental, regulatory, media or other significant issues and summarizes it in to a report that is distributed to company management after approval by the System Incident Commander.


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Customer Count Report – The Customer Count Report Leader reports customer outage count information that is collected and reported through AMFM Outage Reporting. The Customer Count Report Specialists monitors AMFM Outage Reporting and reports outage counts at intervals during impact until peak outage count is reached. Then customer counts out of service and/or percentages restored and projected restoration are summarized and reported at periodic intervals to coincide with the Public Information Officer requirements for “One Voice” communications. However, outage specifics are viewable “real time” on the Outage Viewer Mapping. The periodic reporting includes validation of the outage count accuracy with the state Administration contacts before summary at system level and distribution to company management and personnel who interface with customers and media. Cost Estimate Report – The Cost Estimate Leader collects information from Communications/Advertising, Customer Service Centers, Environmental, Gas, Logistics Section, Resource Section, Security (tent cities only), and Transmission (other) and develops an event cost estimate. Depending on the scope of the event, several revisions or updates may be made at periodic intervals. After approval by Administration Section Chief, the Cost Estimate Report is provided to limited and specific management (Senior Vice President, Chief Accounting Officer, Source System Accounting Manager, Corporate Reporting Manager, System Incident Commander and executives) until such figures are finalized and public. OE-417 Report – The OE-417 Report Leader monitors AMFM Outage Reporter, completes and files or distributes the OE-417 Report, which is required to be completed and provided to the U.S. Department of Energy, Office of Electricity Delivery and Energy Reliability and other regulatory agencies when one or more of several criteria are met. The criteria for storm reporting is generally when more than 50,000 customers are out of service for more than one hour. The report is distributed to a specific list including Department of Energy, North American Electric Reliability Corporation, SERC Reliability Corporation, Southwest Power Pool, System Incident Commander System Operations Center, System Outage Response and Administration representatives.

3.6.4.2 Manage incident documentation Administration Support at both System Command Center and State Command Centers will collect reports and other


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pertinent information related to a specific event, maintain and store those records for history and post storm review.

3.6.4.3 Manage incident finances, including accounting, distribution and record retention Payroll/Cost Allocation – The Payroll Leader will coordinate with the System Planning Section, Cost Estimate Report Leader, Project Code Leader and other appropriate Business Unit representatives to determine the Legal Entity and Business Units affected, and will determine the allocation of expenses to specific Storm Work Orders for a specific payroll period. The allocation will be communicated timely to personnel who may need to charge time (labor) or other expenses to multiple codes such as the System Command Center. Included, when appropriate, may be coordination with Payroll to download Storm Work Order Codes and allocations into the Time & Labor System for specific personnel and coordination of instruction to be distributed by Corporate Communications in Inside Entergy and posted on the FOC website. Project Codes – The Project Code Leader will proactively coordinate with the System Planning Section, System Logistics Director, Cost Estimate Report Leader, Payroll Leader and other appropriate Business Unit representatives to determine the appropriate Legal Entity and Business Units affected and will determine the appropriate specific Storm Work Orders to be issued for the event. Close coordination and communication with Budget Analyst to create and/or issued codes is required. Included is coordination of instruction and codes to be distributed by Corporate Communications in Inside Entergy and posted on the Financial Operations Center website. Contractor Invoice Process Team – The Contractor Invoice Process Team will coordinate with the Finance Director to determine activation, timing and location based on target and scale of storm. The team will also coordinate receipt of invoice support documents from State Administration Invoice/Audit Support teams who capture support documents from field Operations, organize and perform preliminary audit information. The CIPT will receive, track, audit, resolve disputes and process contractor invoices for payment. When the CIPT is not activated, State Administration provides the support documentation to appropriate State personnel, usually Resource Coordinators, for invoice audit and payment processing.


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3.6.4.4 Manage Storm Credit Cards The Storm Credit Card Leader will coordinate distribution of cards at the State organization, manage credit limits, coordinate collection of receipts from card users during an event, track and manage transaction logs, etc., audit the support documentation by card, and process card invoices payment including reconciliation of any issues.

3.6.4.5 Coordinate/Utility Support Functions The Corporate/ Utility Support Directors will maintain contact with Support Function liaisons of Human Resource, Environmental, Legal, Security, Claims, Aviation, Real Estate, Facilities, and CAS and coordinate resolution and status reporting of issues that arise between other Sections and Supports Functions. Also perform special projects during incident as required.

3.7 Supply Chain 3.7.1 Purpose

The Supply Chain Section will be responsible for acquiring and delivering needed materials, establishing and staffing staging sites and facilitating the prioritization of needed materials with the Operations Sections. The Supply Chain section will also be responsible for negotiating contracts for materials and services, including logistics, supporting the CIPT efforts, and investment recovery activities. The overall direction and coordination includes:

• Coordination with state and local operational managers to ensure that needed materials are available.

• Contact with key suppliers to ensure that ordered materials are delivered timely.

• Coordination with Manpower Leaders and Contract Administration Leaders regarding needed contracts for manpower, equipment or logistics.

• Coordination with CIPT to ensure timely resolution of invoice / contract discrepancies.

• Coordination of investment recovery activities, which could include clean-up of work sites, gathering of materials to central work sites, security of high theft items, and eventual disposition of materials.

Included are proactive communications with the Resource, Logistics, Operations and Administration Sections as well as with service contractors and materials suppliers.


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As a centralized essential service, the Supply Chain Section organizational functions and assignments will remain the same for most roles at the system and state levels, unless they are otherwise designated as state assignments.


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3.7.2 Organization


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3.7.3 Roles and Responsibilities A. System Command Center

A.1. Supply Chain Section Chief The Supply Chain Section Chief is responsible for the Supply Chain processes, staffing, training and execution in case of an incident.

A.2. Supply Chain Section Deputy Chief The Supply Chain Section Deputy Chief is responsible for supporting the Supply Chain Section Chief and serving in this role in the absence of the Supply Chain Section Chief.

A.3. Supply Chain Business Continuity Branch Director The Supply Chain Business Continuity Branch Director is responsible for providing the basic structure, procedures, guidelines, responsibilities, and reference data needed for successful corporate operations. The particular duties will vary with each event. This individual is also responsible for providing Supply Chain related services and support to the Corporate, IT and Facilities groups as well as for Supply Chain systems.

A.4. Supply Chain Operations Branch Director The Supply Chain Operations Branch Director oversees both the Supply Chain Transmission and Distribution Operations areas and is responsible for ensuring that all necessary tasks are accomplished and that identified issues are raised to the appropriate levels. This individual is also responsible for ensuring the safe operation of all Supply Chain work areas and sites.

A.5. Supply Chain T&D Sourcing Branch Director The Supply Chain T&D Sourcing Branch Director is responsible for overseeing the procurement and purchasing of all Transmission and Distribution materials and services.

A.6. Storm Contracts & CIPT (Contract Invoice Process Team) Support Branch Director The Storm Contracts & CIPT Support Branch Director is responsible for coordinating activities surrounding new storm contracts, providing copies of executed storm contracts to the CIPT and serving as the liaison between Supply Chain and Operations in the System Command Center War Room.

A.7. Generation Branch Director


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The Generation Branch Director is responsible for coordinating activities in support of non-nuclear generation incident response.

A.8. Communications Reporting Branch Director The Communications Reporting Branch Director is responsible for coordinating the outflow of pertinent data / information to others such as the Administrative Section Chief and Supply Chain management as well as supporting data requests related to amounts of materials (inventory count and costs), personnel engaged, etc.

A.9. Investment Recovery Leader The Investment Recovery (IR) Leader is responsible for providing day to day coordination and management of all investment recovery contractors. They coordinate with the state and local operational managers and leadership to establish priorities, goals and work plans. They also coordinate with local environmental and safety personnel to ensure that IR operations comply with all Entergy policies, laws, regulations and best practices. In addition, the IR Leader coordinates with “gateway” personnel regarding processing of investment recovery suppliers.

A.10. Logistics Contract Administration Branch Director The Logistics Contract Administration Branch Director is responsible for coordinating with and assisting the System Logistics Section and the State Logistics Sections with the execution of logistical contracts. Additional responsibilities include: negotiating logistic agreements, capturing potential suppliers, maintaining the logistics supplier contact list, identifying contract improvement opportunities, coordinating with legal, tax and other departments associated with contract issues.

A.11. Supply Chain Logistics Branch Director The Supply Chain Logistics Branch Director is responsible for coordinating the efforts of the Supply Chain State Logistics Leaders. These efforts include lodging, meals and laundry for all on and off-system resources assigned to the EDCs.

A.12. Supply Chain Distribution Operations Manager The Supply Chain Distribution Operations Manager is

responsible for overseeing operations at the Distribution Entergy Distribution Centers (EDCs), managing field staging sites and managing the investment recovery process. In addition, this individual is responsible for working closely with State Distribution Operations, through the assigned Regional Materials Manager (RMR), to


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determine material needed for restoration. They then coordinate with Procurement to ensure timely order and delivery of these materials.

A.13. Supply Chain Transmission Operations Manager The Supply Chain Transmission Operations Manager is

responsible for overseeing operations at the Transmission EDCs and managing the field staging site manager process. In addition, this individual is responsible for working closely with Transmission Grids, through the assigned RMR, to determine material needed for restoration. They then coordinate with Procurement to ensure the timely order and delivery of these materials.

A.14. Supply Chain Safety Leader The Supply Chain Safety Leader is responsible for any activity required to ensure an incident-free work experience and environment for all human resources engaged in the service of Supply Chain during a major event. These activities include:

• Facilitate Safety Orientations for all incoming personnel (Entergy, other utilities, and contractor) at Supply Chain Gateways.

• Ensure tailgates are being conducted at prescribed schedules and as needed.

• Assume role of escalating acute safety issues including calls for immediate safety stand-downs.

• Hold short safety meetings with crews to discuss safety issues.

• Report safety issues to Supply Chain Section Chief and Assistant Section Chief.

• Ensure all Supply Chain sites, including material laydown yards, are visited by assigned safety personnel.

• Assist all crews (Entergy, other utilities and contractors) in resolution of any safety issues.

A.15. Supply Chain Materials Manager The Supply Chain Materials Manager is responsible for interfacing with all necessary Supply Chain, supplier and operational staff to ensure that needed materials are available for restoration efforts. This individual is also responsible for providing the current status of any materials requested. Coordination with Standards may be necessary to obtain approval for possible substitute materials and alternate suppliers.


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A.16. Supply Chain Services Manager The Supply Chain Services Manager is responsible for

interfacing with all necessary Supply Chain, supplier and operational staff to ensure needed craftsmen are available for restoration efforts. This individual is also responsible for required / requested contract reporting to the Supply Chain T&D Sourcing Branch Director.

A.17. Standards Manager The Standards Manager is responsible for providing approval for substitute materials not currently on the materials list. This will ensure that materials used in restoration efforts are in compliance with the requirements set forth by the Standards group. The Supply Chain Materials Manager will work with Standards as necessary to obtain this approval.

A.18. Supply Chain System RoD (Resources on Demand) Maintenance Leader The Supply Chain System RoD Maintenance Leader is responsible for coordinating with the System Resource Section regarding the entry of Supply Chain employee and contractor information into RoD. They will also coordinate with the Logistics Section to update lodging assignments for Supply Chain employees and contractors working as part of the restoration effort. This individual will develop and distribute reports as requested by the Supply Chain Section Chief or Supply Chain function management.

A.19. Supply Chain Manpower Leader The Supply Chain Manpower Leader is responsible for coordinating additional resources needed to support Supply Chain Operations’ restoration efforts. These resources may include: runners, storekeepers, security services and any on demand non-supply chain resources as requested by Supply Chain’s Distribution Operations Manager, Transmission Operations Manager, and Materials Manager.

A.20. System Command Center Contract Services System Command Center Contract Services individuals are responsible for coordinating contract activities with the System Resource Section Chief to maintain up-to-date storm contracts and identify and sign on new vendors to support storm restoration activities.

B. State Command Center Support B.1. State War Room Contract Services


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The State War Room Contract Services Specialists are responsible coordinating contract activities with State T&D Operations Section Chiefs to maintain up-to-date storm contracts and identify and sign on new vendors to support storm restoration activities.

B.2. State RMRs (Transmission) The State Transmission RMRs are responsible for overseeing material activity at the staging sites beginning with the site set up and continuing through clean up and material returns. These individuals are also responsible for conducting the training and orientation for contract storekeepers and maintaining communication with Operations Section Leads, Scouts, and the Supply Chain Transmission Operations Manager.

B.3. State RMRs (Distribution) The State Distribution RMRs are responsible for overseeing material activity at the staging sites beginning with the site set up and continuing through clean up and material returns. These individuals are also responsible for conducting the training and orientation for contract storekeepers and maintaining communication with Operations Section Leads, Scouts, and the Supply Chain Distribution Operations Manager.

B.4. Supply Chain State RoD Maintenance The Supply Chain State RoD Maintenance individuals are responsible for coordinating with the State Resource Section regarding the entry of Supply Chain employee and contractor information into RoD. They will also coordinate with the Logistics Section to update lodging assignments for Supply Chain employees and contractors working as part of the restoration effort. These individuals will develop and distribute reports as requested by the Supply Chain Section Chief or Supply Chain functional management.

B.5. Supply Chain State Logistics Leaders The Supply Chain State Logistics Leaders are responsible for coordinating with the State Logistics Section Chief for all rooms, meals, laundry, and daily activity reports for both Entergy and off-system resources assigned to the EDCs.

3.7.4 Processes/Interfaces 3.7.4.1 Negotiate and Manage Contracts

The Supply Chain Services Manager will coordinate with the Storm Contracts and CIPT Support Branch Director to ensure that contracts are secured with suppliers and


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contractors who perform storm restoration tasks. Coordination with Operations Section will be necessary to ensure that contracts are up to date and new contracts are executed as needed.

3.7.4.2 Materials Management Identifies steps in ensuring timely acquisition of materials needed for restoration. The Supply Chain Materials Manager will track material inventory levels and provide reports, as necessary, to the Supply Chain Section Chief, Supply Chain Section Deputy Chief, Supply Chain T&D Sourcing Branch Director, Supply Chain Distribution Operations Manager and Supply Chain Transmission Operations Manager.

3.7.4.3 Materials Staging Site Operations The Supply Chain Distribution Operations and Transmission Operations Managers will ensure that material staging sites are set up in support of restoration efforts. This process includes all steps starting with determination of staging site locations through to clean up and material returns.

3.7.4.4 Logistics Support The Logistics Contract Administration Branch Director will ensure the proper contracting of logistical services. Key process steps include negotiating logistic agreements, capturing potential suppliers, maintaining the logistics supplier contact list, identifying contract improvement opportunities, coordinating with legal, tax and other departments associated with contract issues. The State Logistics Leaders will coordinate with the State Logistics Section Chief for all rooms, meals, laundry, and daily activity reports for both Entergy and off-system resources assigned to the EDCs.

3.7.4.5 CIPT Support The Storm Contracts and CIPT Support Branch Director will support the Finance Director and CIPT reconciliation of restoration invoices to contracts.

3.7.4.6 Investment Recovery The Investment Recovery Leader will coordinate with investment recovery suppliers to address clean up of work sites, gathering of materials to central work sites, security of high theft items, and eventual disposition of materials.

3.7.4.7 Communications and Reporting The Communication and Reporting Branch Director will respond to Supply Chain related requests from other section Chiefs and will also produce status and exception reports.


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As necessary, this process also includes supporting scheduled and unscheduled Supply Chain meetings during incident response. The type of activities required will depend on the size of the event.

4 Common Processes 4.1 Post Storm Analysis

Following the completion of a major emergency restoration effort, a post restoration lessons learned review will be conducted to identify any specific situations that were not anticipated or improvement to existing processes. A review analysis will be submitted to the Manager, System Outage Response, and will include recommendations for process adjustments necessary to address the situation in the future, amendments to the T&D EOP, and methods for testing the new processes.

4.2 Issue Resolution It is important for all members of the various emergency restoration organizations be familiar with the responsibilities of the other organizations. This knowledge will allow for clear chain of command and unity of command. When problems are encountered that cannot be resolved at that level of responsibility, the problem should be directed to the individual at the next higher level until a solution is found. Issues involving system-wide organizations or concerns should be directed to the System Command Center for resolution.

4.3 Training The success of this plan will be determined to a great extent by the degree of familiarity employees have with their plan assignments and responsibilities. Many individuals will be needed to perform duties that are different from their normal assignments making the training of these employees of prime importance. Senior management for each business function is responsible for incorporating the processes outlined in this plan into their specific EOP to ensure business function continuity and that all employees understand the duties and responsibilities of their assigned task. All levels of management must recognize that training is a vital key for the plans to be successful. EOPs should be reviewed annually with all personnel expected to have a storm Incident Management assignment. Their normal work duties must not be allowed to overshadow the importance of attending scheduled training sessions. System Drill: A System Drill will be held on an annual basis prior to hurricane season to exercise, test, and evaluate the capabilities of this plan, specific components or processes as deemed necessary. Functional Responsibilities:


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Each functional area shall conduct specific training to ensure employees are prepared to perform their storm assignments.

4.4 Transfer of Command The process of moving the responsibility for incident command from one Incident Commander to another is called “transfer of command.” It should be recognized that transition of command on an existing incident is to be expected. It does not reflect on the competency of the current Incident Commander. Transfer of Command may be required for various reasons such as:

• The current Incident Commander is required for another assignment, even temporarily.

• The current Incident Commander is required to be “out of pocket.” • Illness.

When a “transfer of command” is necessary, the following steps should be completed: • The incoming Incident Commander should, if at all possible,

personally perform an assessment of the incident situation with the existing Incident Commander.

• The incoming Incident Commander must be adequately briefed. • After the briefing, the incoming Incident Commander should

determine an appropriate time for transfer of command. • At the time of transfer, notice of the change in incident command

should be made to: o General Staff. o Command Staff. o Other Command Center Commanders. o All Incident Personnel.

• The incoming Incident Commander may give the previous Incident Commander another assignment of the incident.

4.5 Work Hours Initially, personnel work hours are dependent upon when the emergency actually occurs. However, as soon as possible, manpower should be scheduled to work primarily during daylight hours allowing at least eight hours of rest time during the nighttime hours. Emergencies, priority loads, and management functions that require twenty-four hour manning should be handled with a minimal number of restoration personnel.

4.6 Other Emergency Operations Plans Other Business Functions have their own respective EOPss, managed by their Incident Commanders that coordinate with the System Incident Command:

• Gas Operations. • Fossil. • Nuclear.


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Other Support Functions have their own respective emergency plans, managed by their Incident Commanders that coordinate with the System Incident Commander:

• Public Information/Corporate Communications. • Claims. • Customer Relations. • Customer Service Center (CSC). • Environmental. • Finance. • Fleet Management. • Human Resources. • Information Technology (IT/Telecomm). • Managed Accounts. • Safety. • Security (Corporate). • Vegetation.

Other Emergency Plans

• Black Start. • Business Continuity. • Earthquake. • Flood. • Load Risk. • Pandemic.

4.7 Definitions

Major Emergency

A event that is anticipated or actually exits that exceeds the ability of Entergy, an Operating Company or Business Unit to restore service within 48 hours (Black Event), requires assistance beyond normal capacity (resources) for recovery within reasonable timeline, or declared by governmental, regulatory authorities that impacts Entergy, an Operating Company or Business Unit ability to operate as normal status.

Distribution Operating Area [DOA] (Division)

Geographic division by state of the distribution system.

Region (Branch) Geographic division of the distribution system during normal operations.

Line Area (Branch) Geographic division of the Region distribution system during normal operations.


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Grid (Division) Geographic division of the Transmission system. System.

RoD –Resources on Demand - application used to track manpower and logistics resources during major events.

Group Functional areas of operation.

Section Group of similar functional activities identified as key component of ICS.

Branch (Area Line) Division of Group or Division for manageable span of control.

Division (DOA/Grid) Geographic division of an Incident Area.

Incident Command

Management system designed to enable effective and efficient domestic incident management by integrating a combination of facilities, equipment, personnel, procedures and communications operating within a common organizational structure.

Establishment and Transfer of Command

The command function must be clearly established at the beginning of an incident. When command is transferred, the process must include a briefing that captures all essential information for continuing safe and effective operations.

Chain of Command Chain of Command refers to the orderly line of authority within the ranks of the incident management organization.

Unity of Command Unity of Command means that every individual has a designated supervisor to whom he or she reports for the incident.

Unified Command

In incidents that involve multiple jurisdictions, a single jurisdiction with multi-agency involvement, or multiple jurisdictions with multi-agency involvement, Unified Command allows agencies with different legal, geographic, and functional authorities and responsibilities to work together effectively without affecting individual agency authority, responsibility or accountability.

Management by Objectives

Management by Objectives includes establishing overarching objectives, developing strategies based on incident objectives, developing and issuing assignments, plans, processes, and protocols; establishing specific measurable objectives for various incident management functional activities and directing efforts to attain them, in support of defined, strategies; and documenting results to measure performance and facilitate corrective action.


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Modular Organization

The Incident Command organizational structure develops a modular fashion that is based on the size and complexity of the incident, as well as the specifics of the hazard environment created by the incident.

Incident Action Planning Incident Action Planning (IAPs) provides a coherent means of communicating the overall objectives in the context of both operational and support activities.

Span of Control

Span of Control is key to effective and efficient management. With ICS, the span of control of any individual with incident management supervisory responsibility should typically range from three to seven subordinates.

Incident Locations and Facilities

Various types of support facilities are established in the vicinity of an incident to accomplish a variety of purposes. Typical designated facilities include Incident Command Posts, Bases, Camps, Staging Areas, Mass Casualty Triage Areas, and others as required.

Resource Management

Maintaining an accurate and up to date picture of resource utilization is a critical component of incident management. Resources are defined by personnel, teams, equipment, supplies, and facilities available or potentially available for assignment or allocation in support of incident management and emergency response activities.

Integrated Communications Incident communications are facilitated through the development and use of a common communications plan and interoperable communications processes and architectures.

Information and Intelligence Management

The incident management organization must establish a process for gathering, analyzing, sharing and managing incident related information and intelligence.

Accountability

Effective accountability at all jurisdictional levels and within individual functional areas during incident operations is essential. To that end, the following principles must be adhered to: Check-In. Incident Action Plan, Unity of Command, Personal Responsibility, Span of Control and Resource Tracking.

Dispatch/Deployment Personnel and equipment should respond only when requested or when dispatched by an appropriate authority.


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Page 3 of 37

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Page 4 of 37

COSOutageNumber Jurisdiction Priority Voltage Line

163789 ELL 115 GOLDENMEADOW-FOURCHON115(148.0,239.0)

163789 ELL 115 GOLDENMEADOW-FOURCHON115(148.0,239.0)

163797 ELL/ENOI 115 AVENUE C - PATERSON 90, 86 115 kV (86.1,86.2,86.3,90.0)




163798 ELL 115 LULING-NINEMILESWITCHYARD115(228.1,228.2)


163799 ELL 115 BARATARIA-NINEMILESWITCHYARD115(177.2)

163801 ELL 115 LUTCHER-SORRENTO115(115.8)



163805 ELL 115 GOLDENMEADOW-VALENTINE115(145.0,236.0)



163807 ELL 115 HOUMA-CITYOFHOUMA115

163808 ELL 115 BARATARIA-GOLDENMEADOW115(172.0)

163810 ELL 115 ALLIANCE-BARATARIA115(192)163811 ELL 115 ALLIANCE-HAPPYJACK115

163812 ELL 115 CHALMETTE-POYDRAS115(158.1)

163813 ELL 115 CHAUVIN-VALENTINE115(211)

163815 ELL 230 BEHRMAN-KAISER(LPL)230(164.4,164.5,199.1)

163816 ENOI 115 CLAIBORNE-MICHOUDSWITCHYARD115(98.1)

163817 ELL 230 WATERFORD230SW/YD-WTRFORD1&2(GEN2)

163819 ELL 230 WATERFORD230SW/YD-WTRFORD1&2(GEN1)

163822 ELL 230 BOGALUSA-SLIDELLNORTH(CLECO)

163822 ELL 230 BOGALUSA-SLIDELLNORTH(CLECO)

163824 ELL 115 AMERICANCYANAMID-NINEMILESWITCHYARD137.1115(137.1)

163827 ELL 115 AMERICANCYANAMID-NINEMILESWITCHYARD137.1115(137.1)

163828 ELL 115 HOUMA-CITYOFHOUMA115163829 ELL 115 HOUMA-CITYOFHOUMA115163830 ELL 115 HOUMA-CITYOFHOUMA115163831 ELL 115 BEHRMAN-PORTNICKEL115(156.2)

LineIdentification


Page 5 of 37


163833 ELL 115 PAINCOURTVILLE(NPR)-RACELAND115(128.0,130.1)




163835 ENOI 115 DELTA-PATERSONCLAIBORNE#1115(91.2,91.3,91.4)

163836 ENOI 230 MICHOUDSWITCHYARD-FRONTSTREET230(84.0)

163840 ELL 115 PORTNICKEL-POYDRAS115(158.3)

163841 ELL 115 CARLISLE(LPL)-PORTNICKEL115(168.1)

163842 EGSL 69 EAST-TIGER69(372.0,399.0)

163842 EGSL 69 EAST-TIGER69(372.0,399.0)

163842 EGSL 69 EAST-TIGER69(372.0,399.0)

163842 EGSL 69 EAST-TIGER69(372.0,399.0)



163845 ELL 230 BELLEPOINT-LITTLEGYPSY230(183.1)

163846 ELL 115 PARADIS-RACELAND115(126.2)

163847 ELL 230 HARAHAN-NINEMILESWITCHYARD230(134.1,134.2)




163850 EGSL 69 BLOUNT - BROWN 69 kV (367.0) 163850 EGSL 69 BLOUNT - BROWN 69 kV (367.0) 163850 EGSL 69 BLOUNT - BROWN 69 kV (367.0)

163851 ELL 115 BAYOURAMOS(CLECO)-HUMPHREY115(157.3,157.4)

163851 ELL 115 BAYOURAMOS(CLECO)-HUMPHREY115(157.3,157.4)

163852 ELL 230 LITTLEGYPSY-PONTCHARTRAIN230(146)

163853 ENOI 230 MICHOUDSWITCHYARD-FRONTSTREET230(84.0)

163855 ELL 230 VACHERIE-WATERFORD230SW\YD230(191.0)

163856 ELL 230 NINEMILESWITCHYARD-WATERFORD230SW/YD(231.0)

163857 ELL 230 NINEMILESWITCHYARD-WATERFORD230SW/YD(231.0)

163858 ELL 230 LITTLEGYPSY-WATERFORD230SW\YD#3230

163860 ELL 115 NORCO230X115-SNAKEFARM115(187.4,187.5,187.6)163860 ELL 115 NORCO230X115-SNAKEFARM115(187.4,187.5,187.6)163861 ELL 230 HAMMOND-SORRENTO230(115.3,115.4)

163861 ELL 230 HAMMOND-SORRENTO230(115.3,115.4)


163862 ELL 230 LITTLEGYPSY-PONTCHARTRAIN230(146)


163865 ELL/EMI 230 BOGALUSA-TYLERTOWN115(142.0,151.1,151.2)




163867 ELL 230 IRONMAN230SS-LITTLEGYPSY230


Page 6 of 37


163870 ELL 230 MICHOUDSWITCHYARD-FRONTSTREET230(84.0)

163871 ELL 230 VACHERIE-WATERFORD230SW\YD230(191.0)

163873 ELL 230 MICHOUDSWITCHYARD-FRONTSTREET230(84.0)

163874 ELL/ENOI 230 JOLIET-SOUTHPORT95.1230

163875 ENOI 230 ALMONASTER-JOLIET230

163876 EGSL 69 ANGOLA-FRANCIS69(386.0)163876 EGSL 69 ANGOLA-FRANCIS69(386.0)

163878 EMI 115 FRANKLIN EHV - NATCHEZ SES SWITCHYARD 115 kV (129.1,129.2,129.3,129.4)





163879 EGSL 69 FRANKLIN EHV - NATCHEZ SES SWITCHYARD 115 kV (129.1,129.2,129.3,129.4)



163879 EGSL 69 BLOUNT-PORTHUDSON69(332.0,700.0)

163880 ELL 230 CONVENT-FRISCO 230 kV (183.4)

163881 EGSL 138 KROTZSPRINGSREA-WILBERT138(236,312,642)




163882 EGSL 69 ANGOLA-FRANCIS69(386.0)163882 EGSL 69 ANGOLA-FRANCIS69(386.0)163883 EGSL 69 ANGOLA-FRANCIS69(386.0)163883 EGSL 69 ANGOLA-FRANCIS69(386.0)

163884 EGSL 69 MORIL-INTERNATIONAL69(224.0,635.0)

163885 EGSL 138 ADDIS-WILLOWGLEN138138(702)163886 EGSL 138 ADDIS-WILBERT138(392)163887 EGSL 230 ADDIS-TIGER230(782)

163888 EGSL 138 LOUISIANASTATION-PORTHUDSON(L314,714)

163889 EGSL 138 LOUISIANASTATIONSWITCHYARD-WILBERT138(303)

163890 ELL/EMI 115 AMITE-LIBERTY(116.0,162.1,162.2)



163891 EGSL 69 ANGOLA-FRANCIS69(386.0)163891 EGSL 69 ANGOLA-FRANCIS69(386.0)163893 EGSL 69 BELFAIR-FLORIDA69(710.0)163893 EGSL 69 BELFAIR-FLORIDA69(710.0)163894 EGSL 69 DRUSILLA-EAST69(373,779)163894 EGSL 69 DRUSILLA-EAST69(373,779)

163895 EGSL 138 LOUISIANASTATION-PORTHUDSON(L314,714)

163896 ELL 115 HUMPHREY-TERREBONNE115(157.1,157.2)

163896 ELL 115 HUMPHREY-TERREBONNE115(157.1,157.2)

163898 EGSL/ELL 230 COLY-SORRENTO230(711.0)



163900 EGSL 69 KAISER#2(GSU)-MOHICAN69

163901 EGSL 138 GONZALES-WILLOWGLEN138138(300.0,331.1)




Page 7 of 37

163902 EGSL 69 ANGOLA-FRANCIS69(386.0)163902 EGSL 69 ANGOLA-FRANCIS69(386.0)163903 EGSL 230 ADDIS-TIGER230(782)

163904 EGSL 69 JAGUAR-MICKENS69(370.0)


163905 EGSL 138 BAYOUWAREHOUSE-DUBOIN(223)138

163906 EGSL 69 ANGOLA-FRANCIS69(386.0)163906 EGSL 69 ANGOLA-FRANCIS69(386.0)



163908 EGSL 69 JULIA-HIGHLAND(GSU)69(330.0)

163908 EGSL 69 JULIA-HIGHLAND(GSU)69(330.0)

163909 EGSL 69 ANGOLA-FRANCIS69(386.0)163909 EGSL 69 ANGOLA-FRANCIS69(386.0)163910 EGSL 69 ANGOLA-FRANCIS69(386.0)163910 EGSL 69 ANGOLA-FRANCIS69(386.0)163911 EGSL 69 ANGOLA-FRANCIS69(386.0)163911 EGSL 69 ANGOLA-FRANCIS69(386.0)

163912 EGSL 230 DAWSONCREEK-DOWNTOWN230(753)

163912 EGSL 230 DAWSONCREEK-DOWNTOWN230(753)

163913 ELL 230 AMITE-HAMMOND230(101.1,101.2)













163920 EGSL 138 BAYOUCOVE138-RICHARD(L258)138

163921 EGSL 69 LAKEARTHUR-LAWTAG69(38.0,39.0)










163923 ETI 69 ECHO-FAWIL69(81.0,409.0,439.0,460.0)

163923 ETI 69 ECHO-FAWIL69(81.0,409.0,439.0,460.0)

163925 ETI 138 FAWIL-NEWTONBULK(420)138




163927 ELL/EMI 115 AMITE - MCCOMB 115 kV (113.1,113.2,150.0,150.1,150.2,150.5)



Page 8 of 37










163929 EGSL 69 COLY-JONESCREEK69(749.0)

163929 EGSL 69 COLY-JONESCREEK69(749.0)

163930 EGSL 69 COLY-GLORIA69(759.0)










163933 EGSL 69 BLOUNT-PORTHUDSON69(332.0,700.0)

163934 EMI 115 PORTGIBSON-NATCHEZSESSWITCHYARD115(195.1,195.2,195.3,195.4)




Page 9 of 37



163935 EGSL 138 BAYOUWAREHOUSE-IVANHOECO138(699)

163936 EMI 115 BROOKHAVEN-FRANKLINEHV2115(181.1,181.2)

163936 EMI 115 BROOKHAVEN-FRANKLINEHV2115(181.1,181.2)

163937 EGSL 230 BIGCAJUN#1-FANCYPOINT230(715,715.1)

163937 EGSL 230 BIGCAJUN#1-FANCYPOINT230(715,715.1)

163939 EMI 115 LIBERTY - NATCHEZ 115 kV (124.1,124.2,124.4,124.5,124.6,124.7,124.8,124.9)









163941 EMI 115 BROOKHAVEN - BYRAM 115 kV (139.1,139.2,139.3,139.4,139.5,139.6,139.9)









Page 10 of 37





163943 EGSL/ELL 230 COLY-HAMMOND230






163946 ELL/EMI 115 NATCHEZSESSWITCHYARD-REDGUM115(110.2,122.0)

163947 EGSL 69 ANGOLA-FRANCIS69(386.0)

163947 EGSL 69 ANGOLA-FRANCIS69(386.0)

163949 EMI 115 FRANKLIN EHV - LIBERTY 115 kV (158.1,158.2)




163950 ELL 115 AMITE - BOGALUSA 115 kV (114.1,114.2,114.3,114.4)










163953 EMI 115 SILVER CREEK - TYLERTOWN 115 kV (166.0)






Page 11 of 37













163957 EMI 115 RAY BRASWELL EHV - VICKSBURG 115 kV (136.1,136.2,136.3,136.4,136.5,136.6,136.7,136.8,136.9)









163960 EMI 115 BROOKHAVEN - MCCOMB 115 kV (128.1,128.2,128.3)





Page 12 of 37


163961 EAI 115 EL DORADO EHV - CAMDEN MAGUIRE 115 kV (913.2,949.3,949.4,950.0)




163962 ELL 115 BELLE POINT-LUTCHER 115 kV (115.7)

163963 EAI 69 THAYER SOUTH - ALTON (SHO-ME) 69 kV (609.0)

163965 EAI 115 WOODWARD - CARPENTER DAM 115 kV (895.0,969.0)










163969 EGSL 138 BAYOU WAREHOUSE-IVANHOE CO 138 kV (699)






163974 EGSL 230 COLY - PORT HUDSON 230 kV (712.1,712.2,747.0)

163975 EGSL 69 CARENCRO - SUNSET 69 kV (216.0,622.0)




163978 EMI 115 MAGEE - SILVER CREEK 115 kV (165.1,165.2)

163978 EMI 115 MAGEE - SILVER CREEK 115 kV (165.1,165.2)

163979 ELL 115 BEAVER CREEK - STANDARD 115 kV (117.1,117.2,165.0)



163981 ELL 230 DERBIGNY-MICHOUD SWITCHYARD 230 kV (97.5,97.6,133.0,150.2)


Page 13 of 37

















163991 EAI 115 WOODWARD - STUTTGART RICUSKEY 115 kV (882.0,883.0,967.1)







163992 EAI 161 INDEPENDENCE-ISES - SEARCY PRICE 161 kV (822.1,839.0,880.0)






Page 14 of 37

From To SegmentLength Length From To SectionsAffected Date/TimeOut

21.05 GOLDENMEADOW FOURCHON GOLDENMEADOW-LEEVILLE 8/28/12 02:44:00

21.05 GOLDENMEADOW FOURCHON LEEVILLE-FOURCHON 8/28/12 02:44:00

2.35 AVENUEC PATERSON AVENUEC-MIDTOWN 8/28/12 17:19:00

2.35 AVENUEC PATERSON MIDTOWN-PAUGER 8/28/12 17:19:00

2.35 AVENUEC PATERSON PONTCHARTRAINPARK-PATERSON 8/28/12 17:19:00

0 AVENUEC PATERSON PAUGER-PONTCHARTRAINPARK 8/28/12 17:19:00

15.99 LULING NINEMILESWITCHYARD LULING-WAGGAMAN 8/28/12 17:36:00

15.99 LULING NINEMILESWITCHYARD WAGGAMAN-NINEMILESWITCHYARD 8/28/12 17:36:00

15.25 BARATARIA NINEMILESWITCHYARD BARATARIA-NINEMILESWITCHYARD 8/28/12 17:42:00

13.47 LUTCHER SORRENTO115 LUTCHER-SORRENTO 8/28/12 19:06:00



24.63 GOLDENMEADOW SHELLLOOP CLOVELLY-SHELLLOOPTAP 8/28/12 19:31:00

24.63 GOLDENMEADOW SHELLLOOP GOLDENMEADOW-CLOVELLY 8/28/12 19:31:00

24.63 GOLDENMEADOW SHELLLOOP CLOVELLY-VALENTINE 8/28/12 19:31:00

0 HOUMA CITYOFHOUMA HOUMA-CITYOFHOUMA 8/28/12 20:03:00

BARATARIA GOLDENMEADOW 30.65 30.65 BARATARIA GOLDENMEADOW BARATARIA-GOLDENMEADOW 8/28/12 19:52:00

13.97 ALLIANCE BARATARIA ALLIANCE-BARATARIA 8/28/12 19:31:0019.6 ALLIANCE HAPPYJACK ALLIANCE-HAPPYJACK 8/28/12 19:31:00

9.31 CHALMETTE POYDRAS CHALMETTE-POYDRAS 8/28/12 21:11:00

CHAUVIN VALENTINE 19.44 19.44 CHAUVIN VALENTINE CHAUVIN-VALENTINE 8/28/12 21:13:00

5.16 BEHRMAN KAISER(LPL) BEHRMAN-LOWERCOAST 8/28/12 20:54:00

12.65 CLAIBORNE MICHOUDSWITCHYARD CLAIBORNE-MICHOUDSWITCHYARD 8/28/12 21:38:00

1.27 WATERFORD230SW\YD WATERFORD1&2 WATERFORD230SW/YD-WATERFORD1&2 8/28/2012 21:49

0 WATERFORD230SW\YD WATERFORD1&2 WATERFORD230SW/YD-WATERFORD1&2 8/28/2012 21:50

0 BOGALUSA NORTHSLIDELL(CLECO) TALISHEEK-SLIDELLNORTH(CLECO) 8/28/2012 21:58

0 BOGALUSA NORTHSLIDELL(CLECO) BOGALUSA-TALISHEEK 8/28/2012 21:58

11.29 AMERICANCYANAMID NINEMILESWITCHYARD AMERICANCYANAMID-NINEMILESWITCHYARD 8/28/2012 23:05

11.29 AMERICANCYANAMID NINEMILESWITCHYARD AMERICANCYANAMID-NINEMILESWITCHYARD 8/28/2012 23:24

0 HOUMA CITYOFHOUMA HOUMA-CITYOFHOUMA 8/28/2012 23:400 HOUMA CITYOFHOUMA HOUMA-CITYOFHOUMA 8/29/2012 0:000 HOUMA CITYOFHOUMA HOUMA-CITYOFHOUMA 8/29/2012 0:09

BEHRMAN PORTNICKEL 4.03 4.03 BEHRMAN PORTNICKEL BEHRMAN-PORTNICKEL 8/29/2012 0:45

RemainingOutofService LineIdentification


Page 15 of 37

8.39 LULING NINEMILESWITCHYARD WAGGAMAN-NINEMILESWITCHYARD 8/29/2012 1:03

0 PAINCOURTVILLE RACELAND PAINCOURTVILLE-NAPOLEONVILLE 8/29/2012 1:20

0 PAINCOURTVILLE RACELAND NAPOLEONVILLE-RACELAND 8/29/2012 1:20

0 PAINCOURTVILLE RACELAND PAINCOURTVILLE-NAPOLEONVILLE 8/29/2012 1:30

0 PAINCOURTVILLE RACELAND NAPOLEONVILLE-RACELAND 8/29/2012 1:30

7.17 DELTA PATERSON DELTA-PATERSON 8/29/2012 1:30

0 MICHOUDSWITCHYARD FRONTSTREET(CLECO) MICHOUDSWITCHYARD-FRONTSTREET 8/29/2012 1:52

PORTNICKEL POYDRAS 8.04 8.04 PORTNICKEL POYDRAS PORTNICKEL-POYDRAS 8/29/2012 0:45

CARLISLE(LPL) PORTNICKEL 14.09 14.09 CARLISLE(LPL) PORTNICKEL CARLISLE-PORTNICKEL 8/29/2012 0:45

13.92 EAST EAST-WESTDALE 8/29/2012 2:59

13.92 EAST WESTDALE-L-399/372TAP 8/29/2012 2:59

13.92 EAST L-399/372TAP-TIGER 8/29/2012 2:59

13.92 EAST L-399/372TAP-NESSER(L-372)TAPTAP 8/29/2012 2:59

32.73 PAINCOURTVILLE RACELAND NAPOLEONVILLE-RACELAND 8/29/2012 3:08

32.73 PAINCOURTVILLE RACELAND PAINCOURTVILLE-NAPOLEONVILLE 8/29/2012 3:08

0 BELLEPOINT LITTLEGYPSY BELLEPOINT-LITTLEGYPSY 8/29/2012 3:36

PARADIS RACELAND 13.98 13.98 PARADIS RACELAND PARADIS-RACELAND 8/29/2012 3:47

4.4 HARAHAN NINEMILESWITCHYARD HARAHAN-AVONDALE 8/29/2012 3:26

4.4 HARAHAN NINEMILESWITCHYARD AVONDALE-NINEMILESWITCHYARD 8/29/2012 3:26

4.4 HARAHAN NINEMILESWITCHYARD HARAHAN-AVONDALE 8/29/2012 4:10

4.4 HARAHAN NINEMILESWITCHYARD AVONDALE-NINEMILESWITCHYARD 8/29/2012 4:10

3.93 BLOUNT BROWN MAIN LINE-PLANTATION PIPELINE (GSU) 8/29/2012 4:253.93 BLOUNT BROWN PLANTATION PIPELINE (GSU)-BROWN 8/29/2012 4:253.93 BLOUNT BROWN BLOUNT-MAIN LINE 8/29/2012 4:25

14.99 BAYOURAMOS(CLECO) HUMPHREY BAYOURAMOS(CLECO)-GIBSON 8/29/2012 4:14

14.99 BAYOURAMOS(CLECO) HUMPHREY GIBSON-HUMPHREY 8/29/2012 4:14

0 LITTLEGYPSY PONTCHARTRAIN LITTLEGYPSY-PONTCHARTRAIN 8/29/2012 4:31

0 MICHOUDSWITCHYARD FRONTSTREET(CLECO) MICHOUDSWITCHYARD-FRONTSTREET 8/29/2012 4:34

16.2 VACHERIE WATERFORD230SW\YD VACHERIE-WATERFORD230SW/YD 8/29/2012 4:33

0 NINEMILESWITCHYARD WATERFORD230SW\YD NINEMILESWITCHYARD-WATERFORD230SW/YD 8/29/2012 4:59

0 NINEMILESWITCHYARD WATERFORD230SW\YD NINEMILESWITCHYARD-WATERFORD230SW/YD 8/29/2012 4:59

2.24 LITTLEGYPSY WATERFORD230SW\YD LITTLEGYPSY-WATERFORD230SW\YD 8/29/2012 5:00

0 NORCO230X115 SNAKEFARM KENNER-SNAKEFARM 8/29/2012 5:090 NORCO230X115 SNAKEFARM NORCO230X115-KENNER 8/29/2012 5:090 HAMMOND SORRENTO230 HAMMOND-SPRINGFIELD 8/29/2012 2:44

0 HAMMOND SORRENTO230 FRENCHSETTLEMENT(LAGEN)-SORRENTO230 8/29/2012 2:44

0 HAMMOND SORRENTO230 SPRINGFIELD-FRENCHSETTLEMENT(LAGEN) 8/29/2012 2:44

18.89 LITTLEGYPSY PONTCHARTRAIN LITTLEGYPSY-PONTCHARTRAIN 8/29/2012 5:18

9.46 BELLEPOINT LITTLEGYPSY BELLEPOINT-LITTLEGYPSY 8/29/2012 5:39

3.19 BOGALUSA DEXTERMEPA DEXTERSSSMEPA-DEXTERMEPATAP 8/29/2012 5:59

7.19 BOGALUSA DEXTERMEPA DEXTERSSSMEPA-TYLERTOWN 8/29/2012 5:59

19.97 BOGALUSA DEXTERMEPA BOGALUSA-DEXTERSSSMEPA 8/29/2012 5:59


2.19 IRONMAN230KVSS LITTLEGYPSY IRONMAN230SS-LITTLEGYPSY 8/29/2012 6:06


Page 16 of 37


23.34 MICHOUDSWITCHYARD FRONTSTREET(CLECO) MICHOUDSWITCHYARD-FRONTSTREET 8/29/2012 6:48

16.2 VACHERIE WATERFORD230SW\YD VACHERIE-WATERFORD230SW/YD 8/29/2012 6:42

23.34 MICHOUDSWITCHYARD FRONTSTREET(CLECO) MICHOUDSWITCHYARD-FRONTSTREET 8/29/2012 7:39

2.32 JOLIET SOUTHPORT JOLIET-SOUTHPORT 8/29/2012 7:35

7.43 ALMONASTER JOLIET ALMONASTER-JOLIET 8/29/2012 7:34

4.08 ANGOLA FRANCIS PLATTENBURG-FRANCIS 8/29/2012 8:1612.56 ANGOLA FRANCIS ANGOLA-PLATTENBURG 8/29/2012 8:16

4.11 FRANKLINEHV NATCHEZSESSWITCHYARD

WASHINGTONSSSMEPA/SWEPA-NATCHEZSESSWITCHYARD 8/29/2012 8:46


CRANFIELDSSSMEPA-WASHINGTONSSSMEPA/SWEPA 8/29/2012 8:46

9.8 FRANKLINEHV NATCHEZSESSWITCHYARD ROXIE-CRANFIELDSSSMEPA 8/29/2012 8:46

12.72 FRANKLINEHV NATCHEZSESSWITCHYARD MEADVILLE-ROXIE 8/29/2012 8:46

20.16 FRANKLINEHV NATCHEZSESSWITCHYARD FRANKLINEHV-MEADVILLE 8/29/2012 8:46

0.06 BLOUNT PORTHUDSON BAKER-DIXIEBAKER 8/29/2012 8:46

3.9 BLOUNT PORTHUDSON BLOUNT-BAKER 8/29/2012 8:46

5.45 BLOUNT PORTHUDSON DIXIEBAKER-ZACHARY 8/29/2012 8:46

6.4 BLOUNT PORTHUDSON ZACHARY-PORTHUDSON 8/29/2012 8:46

14.41 CONVENT FRISCO CONVENT-FRISCO 8/29/2012 9:15

19.24 KROTZSPRINGSREA WILBERT LIVONIA-WILBERT 8/29/2012 9:20

0.18 KROTZSPRINGSREA WILBERT KROTZSPRINGSREA-COLONIALSPRINGSTAP(L-642) 8/29/2012 9:20

0.43 KROTZSPRINGSREA WILBERT COLONIALSPRINGSTAP(L-642)-COLONIALSPRINGS 8/29/2012 9:20

12.89 KROTZSPRINGSREA WILBERT COLONIALSPRINGSTAP(L-642)-LIVONIA 8/29/2012 9:20

4.08 ANGOLA FRANCIS PLATTENBURG-FRANCIS 8/29/2012 9:2912.56 ANGOLA FRANCIS ANGOLA-PLATTENBURG 8/29/2012 9:294.08 ANGOLA FRANCIS PLATTENBURG-FRANCIS 8/29/2012 10:12

12.56 ANGOLA FRANCIS ANGOLA-PLATTENBURG 8/29/2012 10:12

8.53 MORIL INTERNATIONAL MORIL-INTERNATIONAL 8/29/2012 10:43

14.21 ADDIS WILLOWGLEN138 ADDIS-WILLOWGLEN138 8/29/2012 11:427.1 ADDIS WILBERT ADDIS-WILBERT 8/29/2012 11:425.69 ADDIS TIGER ADDIS-TIGER 8/29/2012 11:42

6.91 LOUISIANASTATIONSWITCHYARD PORTHUDSON THOMAS-PORTHUDSON 8/29/2012 11:45

8.82 LOUISIANASTATIONSWITCHYARD WILBERT LOUISIANASTATIONSWITCHYARD-WILBERT 8/29/2012 11:49

0 AMITE LIBERTY GILLSBURGSSSMEPA-GILLSBURG(MEPA) 8/29/2012 9:20

14.91 AMITE LIBERTY GILLSBURGSSSMEPA-LIBERTY 8/29/2012 9:20

24.9 AMITE LIBERTY AMITE-GILLSBURGSSSMEPA 8/29/2012 9:20

4.08 ANGOLA FRANCIS PLATTENBURG-FRANCIS 8/29/2012 12:3112.56 ANGOLA FRANCIS ANGOLA-PLATTENBURG 8/29/2012 12:311.87 BELFAIR FLORIDA SEARS-FLORIDA 8/29/2012 12:352.34 BELFAIR FLORIDA BELFAIR-SEARS 8/29/2012 12:351.54 DRUSILLA EAST DRUSILLA-JEFFERSON 8/29/2012 12:474.04 DRUSILLA EAST JEFFERSON-EAST 8/29/2012 12:47

7.59 LOUISIANASTATIONSWITCHYARD PORTHUDSON LOUISIANASTATIONSWITCHYARD-THOMAS 8/29/2012 12:52

0.55 HUMPHREY TERREBONNE HUMPHREY-GREENWOOD(SLECA) 8/29/2012 12:44

10.13 HUMPHREY TERREBONNE GREENWOOD(SLECA)-TERREBONNE 8/29/2012 12:44

5.6 COLY SORRENTO230 VIGNES(CAJUN)-DEMCOAIRLINE 8/29/2012 12:56

10.44 COLY SORRENTO230 COLY-VIGNES(CAJUN) 8/29/2012 12:56

10.59 COLY SORRENTO230 DEMCOAIRLINE-SORRENTO230 8/29/2012 12:56

1.37 KAISER#2(GSU) MOHICAN KAISER#2(GSU)-MOHICAN 8/29/2012 12:52

3.64 GONZALES WILLOWGLEN138 GONZALES-DUPLESSIS 8/29/2012 12:57

3.88 GONZALES WILLOWGLEN138 DUPLESSIS-OAKGROVE 8/29/2012 12:57

13.49 GONZALES WILLOWGLEN138 OAKGROVE-WILLOWGLEN138 8/29/2012 12:57


Page 17 of 37

4.08 ANGOLA FRANCIS PLATTENBURG-FRANCIS 8/29/2012 13:0612.56 ANGOLA FRANCIS ANGOLA-PLATTENBURG 8/29/2012 13:065.69 ADDIS TIGER ADDIS-TIGER 8/29/2012 13:07

1.58 JAGUAR MICKENS JAGUAR-SEVENTYSECOND 8/29/2012 13:12

2.44 JAGUAR MICKENS SEVENTYSECOND-MICKENS 8/29/2012 13:12

12.47 BAYOUWAREHOUSE DUBOIN BAYOUWAREHOUSE-DUBOIN 8/29/2012 13:26

4.08 ANGOLA FRANCIS PLATTENBURG-FRANCIS 8/29/2012 13:3312.56 ANGOLA FRANCIS ANGOLA-PLATTENBURG 8/29/2012 13:33

1.58 JAGUAR MICKENS JAGUAR-SEVENTYSECOND 8/29/2012 13:35

2.44 JAGUAR MICKENS SEVENTYSECOND-MICKENS 8/29/2012 13:35

1.33 JULIA HIGHLAND(GSU) JULIA-BROUSSARD 8/29/2012 13:35

3.54 JULIA HIGHLAND(GSU) BROUSSARD-HIGHLAND(GSU) 8/29/2012 13:35

4.08 PLATTENBURG FRANCIS PLATTENBURG-FRANCIS 8/29/2012 14:0012.56 ANGOLA PLATTENBURG ANGOLA-PLATTENBURG 8/29/2012 14:004.08 PLATTENBURG FRANCIS PLATTENBURG-FRANCIS 8/29/2012 14:09

12.56 ANGOLA PLATTENBURG ANGOLA-PLATTENBURG 8/29/2012 14:094.08 PLATTENBURG FRANCIS PLATTENBURG-FRANCIS 8/29/2012 14:21

12.56 ANGOLA PLATTENBURG ANGOLA-PLATTENBURG 8/29/2012 14:21

3.12 DAWSONCREEK CONCORD DAWSONCREEK-CONCORD 8/29/2012 14:43

3.74 CONCORD DOWNTOWN CONCORD-DOWNTOWN 8/29/2012 14:43

8.43 AMITE INDEPENDENCE230 AMITE-INDEPENDENCE230 8/29/2012 14:22

9.76 INDEPENDENCE230 HAMMOND INDEPENDENCE230-HAMMOND 8/29/2012 14:22







1.58 JAGUAR SEVENTYSECOND JAGUAR-SEVENTYSECOND 8/29/2012 15:34

2.44 SEVENTYSECOND MICKENS SEVENTYSECOND-MICKENS 8/29/2012 15:34

5.33 HAMMOND SPRINGFIELD HAMMOND-SPRINGFIELD 8/29/2012 14:25

8.21 FRENCHSETTLEMENT(LAGEN) SORRENTO230 FRENCHSETTLEMENT(LAGEN)-SORRENTO230 8/29/2012 14:25

17.1 SPRINGFIELD FRENCHSETTLEMENT(LAGEN) SPRINGFIELD-FRENCHSETTLEMENT(LAGEN) 8/29/2012 14:25

22.6 BAYOUCOVE138 RICHARD BAYOUCOVE138-RICHARD 8/29/2012 15:54

0 POTTER(SLEMCO) THORNWELL POTTER(SLEMCO)-THORNWELLTAP 8/29/2012 16:12

0 WINN POTTER(SLEMCO) WINN-POTTER(SLEMCO)TAP 8/29/2012 16:12

0.41 WINN TEXLAKE(L-38)TAP-WINN 8/29/2012 16:12

1.41 TEXLAKE TEXLAKE(L-38)TAP-TEXLAKETAP 8/29/2012 16:12

3.46 LAKEARTHUR LAKEARTHUR-TEXLAKE(L-38)TAP 8/29/2012 16:12

3.68 WINN ROBBIE(SWEPCO) WINN-ROBBIE(SWEPCO) 8/29/2012 16:12

5.77 ROBBIE(SWEPCO) LAWTAG ROBBIE(SWEPCO)-LAWTAG 8/29/2012 16:12

5.33 HAMMOND SPRINGFIELD HAMMOND-SPRINGFIELD 8/29/2012 16:12

8.21 FRENCHSETTLEMENT(LAGEN) SORRENTO230 FRENCHSETTLEMENT(LAGEN)-SORRENTO230 8/29/2012 16:12

17.1 SPRINGFIELD FRENCHSETTLEMENT(LAGEN) SPRINGFIELD-FRENCHSETTLEMENT(LAGEN) 8/29/2012 16:12

4.4 ECHO ECHO-SABRA(L-460)TAP 8/29/2012 16:49

0 ECHO FAWIL SABRA(L-460)TAP-DEWYVILLEJNECO 8/29/2012 16:49

0 FAWIL NEWTONBULK FAWIL-TEXASEASTERNNEWTONCO 8/29/2012 16:58

0 FAWIL NEWTONBULK JASPERNEWTONREA-NEWTON 8/29/2012 16:58

0 FAWIL NEWTONBULK NEWTON-NEWTONBULK 8/29/2012 16:58

0 FAWIL NEWTONBULK TEXASEASTERNNEWTONCO-JASPERNEWTONREA 8/29/2012 16:58

0 AMITE MCCOMB CHATAWASSSMEPA-PROGRESSSSMEPA 8/29/2012 17:07

0 AMITE MCCOMB FERNWOOD-OAKDALESSSMEPA 8/29/2012 17:07


Page 18 of 37

0 AMITE MCCOMB FERNWOOD-PROGRESSSSMEPA 8/29/2012 17:07

0 AMITE MCCOMB OAKDALESSSMEPA-MCCOMB 8/29/2012 17:07

0 AMITE MCCOMB OAKDALESSSMEPA-MCCOMB/EASTMEPA 8/29/2012 17:07

0 AMITE MCCOMB PROGRESSSSMEPA-PLANTATIONPIPELINE 8/29/2012 17:07

0 AMITE MCCOMB PROGRESSSSMEPA-PROGRESSMEPA 8/29/2012 17:07

0 AMITE MCCOMB CHATAWASSSMEPA-COLONIALPIPELINE 8/29/2012 17:07

0 AMITE MCCOMB COLONIALPIPELINE-FERNWOOD 8/29/2012 17:07

0 AMITE MCCOMB KENTWOOD-CHATAWASSSMEPA 8/29/2012 17:07

0 AMITE MCCOMB AMITE-KENTWOOD 8/29/2012 17:07

12.13 COLY JONESCREEK COLY-LOCKHART 8/29/2012 17:21

12.13 COLY JONESCREEK LOCKHART-JONESCREEK 8/29/2012 17:21

9.15 COLY POLYFORM DENHAMSPRINGS-GLORIA 8/29/2012 17:29

9.15 COLY POLYFORM COLY-DENHAMSPRINGS 8/29/2012 17:29

9.15 COLY POLYFORM COLY-POLYFORMTAP 8/29/2012 17:29

0 LAKEARTHUR THORNWELL POTTER(SLEMCO)-THORNWELLTAP 8/29/2012 17:19

0 LAKEARTHUR THORNWELL WINN-POTTER(SLEMCO)TAP 8/29/2012 17:19

0 LAKEARTHUR THORNWELL TEXLAKE(L-38)TAP-WINN 8/29/2012 17:19

0 LAKEARTHUR THORNWELL TEXLAKE(L-38)TAP-TEXLAKETAP 8/29/2012 17:19

0 LAKEARTHUR THORNWELL LAKEARTHUR-TEXLAKE(L-38)TAP 8/29/2012 17:19

0 LAKEARTHUR THORNWELL WINN-ROBBIE(SWEPCO) 8/29/2012 17:19

0 LAKEARTHUR THORNWELL ROBBIE(SWEPCO)-LAWTAG 8/29/2012 17:19

11.91 BLOUNT PORTHUDSON ZACHARY-PORTHUDSON 8/29/2012 17:48

0 PORTGIBSON NATCHEZSESSWITCHYARD LORMANSS-ALCORNSWMEPA 8/29/2012 19:23

0 PORTGIBSON NATCHEZSESSWITCHYARD LORMANSS-LORMANSWMEPA 8/29/2012 19:23

0 PORTGIBSON NATCHEZSESSWITCHYARD PORTGIBSON-LORMANSS 8/29/2012 19:23


Page 19 of 37

0 PORTGIBSON NATCHEZSESSWITCHYARD LORMANSS-FAYETTE 8/29/2012 19:23

0 PORTGIBSON NATCHEZSESSWITCHYARD FAYETTE-NATCHEZSESSWITCHYARD 8/29/2012 19:23

0 BAYOUWAREHOUSE IVANHOECO BAYOUWAREHOUSE-IVANHOE(CLECO) 8/29/2012 19:35

16.99 BROOKHAVEN FRANKLINEHV BROOKHAVEN-BROOKHAVEN/SOUTH 8/29/2012 19:43

16.99 BROOKHAVEN FRANKLINEHV BROOKHAVEN/SOUTH-FRANKLINEHV 8/29/2012 19:43

0 BIGCAJUN#1 FANCYPOINT BIGCAJUN#1-WATERLOO 8/29/2012 19:55

0 BIGCAJUN#1 FANCYPOINT WATERLOO-FANCYPOINT 8/29/2012 19:55

75.55 LIBERTY KINGSTONSWMEPA NATCHEZ/SOUTHEASTSS-KINGSTONSWMEPATAP 8/29/2012 20:12

75.55 LIBERTY KINGSTONSWMEPA NATCHEZ/SOUTHEASTSS-NATCHEZ 8/29/2012 20:12

75.55 LIBERTY KINGSTONSWMEPA GLOSTER-CROSBYSSSMEPA/SWMEPA 8/29/2012 20:12

75.55 LIBERTY KINGSTONSWMEPA GLOSTER-CENTREVILLETAP 8/29/2012 20:12

75.55 LIBERTY KINGSTONSWMEPA CENTREVILLE-WOODVILLESWMEPATAP 8/29/2012 20:12

75.55 LIBERTY KINGSTONSWMEPA CROSBYSSSMEPA/SWMEPA-NATCHEZ/SOUTHEASTSS 8/29/2012 20:12

75.55 LIBERTY KINGSTONSWMEPA LIBERTY-GLOSTER 8/29/2012 20:12

39.8 AMITE LIBERTY GILLSBURGSSSMEPA-GILLSBURG(MEPA) 8/29/2012 21:05

39.8 AMITE LIBERTY GILLSBURGSSSMEPA-LIBERTY 8/29/2012 21:05

0 BROOKHAVEN BYRAM COPIAHSSSMEPA-SHADYGROVE(SPECA) 8/29/2012 21:45

0 BROOKHAVEN BYRAM HAZLEHURST-COPIAHSSSMEPA 8/29/2012 21:45

0 BROOKHAVEN BYRAM JAMESROADSSSMEPA-HAZLEHURST 8/29/2012 21:45

0 BROOKHAVEN BYRAM COPIAHSSSMEPA-GALLMAN 8/29/2012 21:45

0 BROOKHAVEN BYRAM GALLMAN-CRYSTALSPRINGS 8/29/2012 21:45

0 BROOKHAVEN BYRAM TERRY-BYRAM 8/29/2012 21:45

0 BROOKHAVEN BYRAM BROOKHAVEN-WESSON 8/29/2012 21:45

0 BROOKHAVEN BYRAM CRYSTALSPRINGS-TERRY 8/29/2012 21:45


Page 20 of 37

0 BROOKHAVEN BYRAM WESSON-JAMESROADSSSMEPA 8/29/2012 21:45

20.7 LIBERTY KINGSTONSWMEPA GLOSTER-CENTREVILLETAP 8/29/2012 22:26

20.7 LIBERTY KINGSTONSWMEPA CENTREVILLE-WOODVILLESWMEPATAP 8/29/2012 22:26

20.7 LIBERTY KINGSTONSWMEPA LIBERTY-GLOSTER 8/29/2012 22:26

26.34 COLY HAMMOND COLY-HAMMOND 8/29/2012 22:31


WASHINGTONSSSMEPA/SWEPA-NATCHEZSESSWITCHYARD 8/29/2012 23:35


CRANFIELDSSSMEPA-WASHINGTONSSSMEPA/SWEPA 8/29/2012 23:35

20.16 FRANKLINEHV NATCHEZSESSWITCHYARD ROXIE-CRANFIELDSSSMEPA 8/29/2012 23:35

20.16 FRANKLINEHV NATCHEZSESSWITCHYARD MEADVILLE-ROXIE 8/29/2012 23:35

20.16 FRANKLINEHV NATCHEZSESSWITCHYARD FRANKLINEHV-MEADVILLE 8/29/2012 23:35

11.39 NATCHEZSESSWITCHYARD REDGUM N.S.E.S.-REDGUM 8/29/2012 23:46

16.64 ANGOLA FRANCIS PLATTENBURG-FRANCIS 8/30/2012 0:09

16.64 ANGOLA FRANCIS ANGOLA-PLATTENBURG 8/30/2012 0:09

26.86 FRANKLIN EHV LIBERTY ARLINGTON SS SMEPA-ARLINGTON (MEPA) 8/30/2012 0:43

26.86 FRANKLIN EHV LIBERTY ARLINGTON SS SMEPA-SMITHDALE SS SMEPA/MEPA 8/30/2012 0:43

26.86 FRANKLIN EHV LIBERTY FRANKLIN EHV-ARLINGTON SS SMEPA 8/30/2012 0:43

26.86 FRANKLIN EHV LIBERTY SMITHDALE SS SMEPA/MEPA-LIBERTY 8/30/2012 0:43

37.06 AMITE BOGALUSA FRANKLINTON-LAGEN PINECLIFF 8/30/2012 1:12

37.06 AMITE BOGALUSA CHICKENFARM TAP-LAGEN HOLTON 8/30/2012 1:12

37.06 AMITE BOGALUSA CHICKENFARM TAP-CHICKENFARM 8/30/2012 1:12

37.06 AMITE BOGALUSA AMITE-CHICKENFARM TAP 8/30/2012 1:12

37.06 AMITE BOGALUSA FRANKLINTON-BOGALUSA 8/30/2012 1:12

37.06 AMITE BOGALUSA LAGEN HOLTON-FRANKLINTON 8/30/2012 1:12

32.89 AMITE MCCOMB OAKDALE SS SMEPA-MCCOMB 8/30/2012 1:12

65.32 LIBERTY KINGSTON SWMEPA GLOSTER-CENTREVILLE TAP 8/30/2012 0:43

65.32 LIBERTY KINGSTON SWMEPA CENTREVILLE-WOODVILLE SWMEPA TAP 8/30/2012 0:43

65.32 LIBERTY KINGSTON SWMEPA LIBERTY-GLOSTER 8/30/2012 0:43

36.05 SILVER CREEK TYLERTOWN SALEM SS SMEPA-SALEM 8/30/2012 1:53

36.05 SILVER CREEK TYLERTOWN SALEM SS SMEPA-TYLERTOWN 8/30/2012 1:53

36.05 SILVER CREEK TYLERTOWN SILVER CREEK-SALEM SS SMEPA 8/30/2012 1:53

32.89 AMITE MCCOMB CHATAWA SS SMEPA-PROGRESS SS MEPA 8/30/2012 2:26

32.89 AMITE MCCOMB FERNWOOD-OAKDALE SS SMEPA 8/30/2012 2:26


Page 21 of 37

32.89 AMITE MCCOMB OAKDALE SS SMEPA-MCCOMB 8/30/2012 2:26

32.89 AMITE MCCOMB OAKDALE SS SMEPA-MCCOMB/ EAST MEPA 8/30/2012 2:26

32.89 AMITE MCCOMB PROGRESS SS MEPA-PLANTATION PIPELINE 8/30/2012 2:26

32.89 AMITE MCCOMB PROGRESS SS MEPA-PROGRESS MEPA 8/30/2012 2:26

32.89 AMITE MCCOMB CHATAWA SS SMEPA-COLONIAL PIPELINE 8/30/2012 2:26

32.89 AMITE MCCOMB COLONIAL PIPELINE-FERNWOOD 8/30/2012 2:26

32.89 AMITE MCCOMB KENTWOOD-CHATAWA SS SMEPA 8/30/2012 2:26

32.89 AMITE MCCOMB AMITE-KENTWOOD 8/30/2012 2:26

51.8 FRANKLIN EHV NATCHEZ SES SWITCHYARD

WASHINGTON SS SMEPA/ SWEPA-NATCHEZ SES SWITCHYARD 8/30/2012 2:45


CRANFIELD SS SMEPA-WASHINGTON SS SMEPA/ SWEPA 8/30/2012 2:45

51.8 FRANKLIN EHV NATCHEZ SES SWITCHYARD ROXIE-CRANFIELD SS SMEPA 8/30/2012 2:45

51.8 FRANKLIN EHV NATCHEZ SES SWITCHYARD MEADVILLE-ROXIE 8/30/2012 2:45

11.45 RAY BRASWELL EHV VICKSBURG RAYMOND-CAPLINE-RAYMOND 8/30/2012 3:55

11.45 RAY BRASWELL EHV VICKSBURG WATERWAYS CORP OF ENGR-VICKSBURG 8/30/2012 3:55

11.45 RAY BRASWELL EHV VICKSBURG VICKSBURG/ EAST 115 SS-WATERWAYS CORP OF ENGR 8/30/2012 3:55

11.45 RAY BRASWELL EHV VICKSBURG VICKSBURG/ EAST 115 SS-VICKSBURG/ EAST 8/30/2012 3:55

11.45 RAY BRASWELL EHV VICKSBURG BOLTON-RAYMOND-CAPLINE 8/30/2012 3:55

11.45 RAY BRASWELL EHV VICKSBURG RAY BRASWELL EHV-BOLTON 8/30/2012 3:55

11.45 RAY BRASWELL EHV VICKSBURG BOLTON-EDWARDS 8/30/2012 3:55

11.45 RAY BRASWELL EHV VICKSBURG EDWARDS-VICKSBURG/ EAST 115 SS 8/30/2012 3:55

11.45 RAY BRASWELL EHV VICKSBURG BOLTON-UTICA 8/30/2012 3:55

NORFIELD SS SMEPA MCCOMB 9.38 23.07 BROOKHAVEN MCCOMB NORFIELD SS SMEPA-MCCOMB 8/30/2012 6:46

23.07 BROOKHAVEN MCCOMB MALLALIEU SS SMEPA-MALLALIEU MEPA 8/30/2012 6:46

23.07 BROOKHAVEN MCCOMB NORFIELD SS SMEPA-LITTLE CREEK MEPA 8/30/2012 6:46

23.07 BROOKHAVEN MCCOMB BROOKHAVEN-MALLALIEU SS SMEPA 8/30/2012 6:46


Page 22 of 37

23.07 BROOKHAVEN MCCOMB MALLALIEU SS SMEPA-NORFIELD SS SMEPA 8/30/2012 6:46

0 SMACKOVER SS SMACKOVER SMACKOVER SS-SMACKOVER 8/30/2012 10:22

0 SMACKOVER SS HAYS CITY SMACKOVER SS-HAYS CITY TAP 8/30/2012 10:22

0 EL DORADO EHV SMACKOVER SS EL DORADO EHV-SMACKOVER SS 8/30/2012 10:22

0 SMACKOVER CAMDEN MAGUIRE SMACKOVER-CAMDEN MAGUIRE 8/30/2012 10:22

8.65 BELLE POINT LUTCHER BELLE POINT-LUTCHER 8/28/2012 19:06

1.35 THAYER SOUTH THAYER NORTH THAYER SOUTH-THAYER NORTH 8/30/2012 10:58

2.02 TEXAS EASTERN P.S. #4 SS MALVERN SOUTH TEXAS EASTERN P.S. #4 SS-MALVERN SOUTH 8/30/2012 11:24

11.61 TEXAS EASTERN P.S. #4 SS TEXAS EASTERN P.S. #4 TEXAS EASTERN P.S. #4 SS-TEXAS EASTERN

P.S. #4 TAP 8/30/2012 11:24

13.39 MALVERN SOUTH CARPENTER DAM MALVERN SOUTH-CARPENTER DAM 8/30/2012 11:24

20.55 WOODWARD AECC SHERIDAN SOUTH WOODWARD-AECC SHERIDAN SOUTH 8/30/2012 11:24

22.16 AECC SHERIDAN SOUTH TEXAS EASTERN P.S. #4 SS

AECC SHERIDAN SOUTH-TEXAS EASTERN P.S. #4 SS 8/30/2012 11:24

2.02 TEXAS EASTERN P.S. #4 SS MALVERN SOUTH TEXAS EASTERN P.S. #4 SS-MALVERN SOUTH 8/30/2012 11:50

11.61 TEXAS EASTERN P.S. #4 SS TEXAS EASTERN P.S. #4 TEXAS EASTERN P.S. #4 SS-TEXAS EASTERN

P.S. #4 TAP 8/30/2012 11:50

13.39 MALVERN SOUTH CARPENTER DAM MALVERN SOUTH-CARPENTER DAM 8/30/2012 11:50

20.55 WOODWARD AECC SHERIDAN SOUTH WOODWARD-AECC SHERIDAN SOUTH 8/30/2012 11:50

22.16 AECC SHERIDAN SOUTH TEXAS EASTERN P.S. #4 SS

AECC SHERIDAN SOUTH-TEXAS EASTERN P.S. #4 SS 8/30/2012 11:50

2.25 BAYOU WAREHOUSE IVANHOE CO BAYOU WAREHOUSE-IVANHOE(CLECO) 8/30/2012 12:07

0 WOODWARD TEXAS EASTERN P.S. #4 TEXAS EASTERN P.S. #4 SS-MALVERN SOUTH 8/30/2012 15:09

0 WOODWARD TEXAS EASTERN P.S. #4 TEXAS EASTERN P.S. #4 SS-TEXAS EASTERN P.S. #4 TAP 8/30/2012 15:09

0 WOODWARD TEXAS EASTERN P.S. #4 MALVERN SOUTH-CARPENTER DAM 8/30/2012 15:09

0 WOODWARD TEXAS EASTERN P.S. #4 WOODWARD-AECC SHERIDAN SOUTH 8/30/2012 15:09

0 WOODWARD TEXAS EASTERN P.S. #4 AECC SHERIDAN SOUTH-TEXAS EASTERN P.S. #4 SS 8/30/2012 15:09

17.72 COLY PORT HUDSON ZOAR-PORT HUDSON 8/30/2012 14:39

0.81 SUNSET INTERSTATE PIPELINE TAP-SUNSET 8/30/2012 17:23

1.16 INTERSTATE PIPELINE (GSU)

INTERSTATE PIPELINE TAP-INTERSTATE PIPELINE (GSU) 8/30/2012 17:23

7.38 CARENCRO CARENCRO-INTERSTATE PIPELINE TAP 8/30/2012 17:23

0 FRANKLIN EHV - LIBERTY 115 kV (158.1,158.2) FRANKLIN EHV FRANKLIN EHV-ARLINGTON SS SMEPA 8/30/2012 19:00

0 MAGEE SILVER CREEK NEW HEBRON-SILVER CREEK 8/30/2012 23:23

0 MAGEE SILVER CREEK MAGEE-NEW HEBRON 8/30/2012 23:23

0 BEAVER CREEK MIDWAY JENA-MIDWAY TAP 8/31/2012 3:48

0 BEAVER CREEK MIDWAY JENA-STANDARD 8/31/2012 3:48

0 BEAVER CREEK MIDWAY BEAVER CREEK-JENA 8/31/2012 3:48

6.75 DERBIGNY MICHOUD SWITCHYARD DERBIGNY-TRICOU 8/31/2012 7:14


Page 23 of 37

32.88 FRANKLIN EHV NATCHEZ SES SWITCHYARD MEADVILLE-ROXIE 8/31/2012 9:16


CRANFIELD SS SMEPA-WASHINGTON SS SMEPA/ SWEPA 8/31/2012 9:16

32.88 FRANKLIN EHV NATCHEZ SES SWITCHYARD ROXIE-CRANFIELD SS SMEPA 8/31/2012 9:16

32.88 WASHINGTON SS SMEPA/ SWEPA

NATCHEZ SES SWITCHYARD

WASHINGTON SS SMEPA/ SWEPA-NATCHEZ SES SWITCHYARD 8/31/2012 9:16

0 AVENUE C PATERSON PAUGER-PONTCHARTRAIN PARK 8/31/2012 14:20

0 AMITE MCCOMB CHATAWA SS SMEPA-PROGRESS SS MEPA 8/31/2012 15:44

0 AMITE MCCOMB FERNWOOD-OAKDALE SS SMEPA 8/31/2012 15:44

0 AMITE MCCOMB OAKDALE SS SMEPA-MCCOMB 8/31/2012 15:44

0 AMITE MCCOMB OAKDALE SS SMEPA-MCCOMB/ EAST MEPA 8/31/2012 15:44

0 AMITE MCCOMB PROGRESS SS MEPA-PLANTATION PIPELINE 8/31/2012 15:44

0 AMITE MCCOMB PROGRESS SS MEPA-PROGRESS MEPA 8/31/2012 15:44

0 AMITE MCCOMB CHATAWA SS SMEPA-COLONIAL PIPELINE 8/31/2012 15:44

0 AMITE MCCOMB COLONIAL PIPELINE-FERNWOOD 8/31/2012 15:44

0 AMITE MCCOMB KENTWOOD-CHATAWA SS SMEPA 8/31/2012 15:44

0 AMITE MCCOMB AMITE-KENTWOOD 8/31/2012 15:44

10.94 BROOKHAVEN BYRAM WESSON-JAMES ROAD SS SMEPA 8/31/2012 15:45

6.6 WOODWARD STUTTGART RICUSKEY STUTTGART NORTH SS-STUTTGART RICUSKEY 8/31/2012 20:10

6.6 WOODWARD STUTTGART RICUSKEY ALTHEIMER SS-ALTHEIMER TAP 8/31/2012 20:10

6.6 WOODWARD STUTTGART RICUSKEY STUTTGART NORTH SS-STUTTGART NORTH TAP 8/31/2012 20:10

6.6 WOODWARD STUTTGART RICUSKEY ALTHEIMER SS-WABBASEKA 8/31/2012 20:10

6.6 WOODWARD STUTTGART RICUSKEY WABBASEKA-AECC HUMPHREY 8/31/2012 20:10

6.6 WOODWARD STUTTGART RICUSKEY AECC HUMPHREY-STUTTGART NORTH SS 8/31/2012 20:10

6.6 WOODWARD STUTTGART RICUSKEY WOODWARD-ALTHEIMER SS 8/31/2012 20:10

0 INDEPENDENCE-ISES SEARCY PRICE BALD KNOB-TEXAS EASTERN T.C. P.S. #6 SS-BALD KNOB- 8/31/2012 21:59

0 INDEPENDENCE-ISES SEARCY PRICE BALD KNOB-TEXAS EASTERN T.C. P.S. #6 SS-BALD KNOB 8/31/2012 21:59

0 INDEPENDENCE-ISES SEARCY PRICE BALD KNOB-SEARCY PRICE 8/31/2012 21:59

0 INDEPENDENCE-ISES SEARCY PRICE AECC COFFEEVILLE-BALD KNOB-TEXAS EASTERN T.C. P.S. 8/31/2012 21:59

0 INDEPENDENCE-ISES SEARCY PRICE INDEPENDENCE-ISES-AECC COFFEEVILLE 8/31/2012 21:59


Page 24 of 37

Comments Vegetation StructuresDestroyed Structures/SpansDamaged Repairs EstimatedRTS SectionRTS LineRTS EntireLineRestored

3-Pole Structure Down (Extreme Lean) Broke Static Bar Shieldwire Down on Phase

Structure Down ( 3-Pole Structure) Structure Down ( H-Frame) Structure Down ( Steel

Pole)

9/6/2012 9/5/12 14:19:00 Y

9/6/2012 9/5/12 14:19:00 Y

8/31/12 16:50:00 Y

8/31/12 16:50:00 Y

Shieldwire down 8/31/12 16:50:00 Y

8/31/12 16:50:00 Y

9/1/12 20:36:00 Y

9/1/12 20:36:00 Y

8/28/12 17:43:00 Y

Conductor unpinned - Conductor damage Need repair rods for conductor 9/1/12 20:48:00 Y

8/28/12 19:11:00 Y

Broke Cross-arm Structure Down (H-Frame) 9/2/2012 9/3/12 13:38:00 Y

Broken Suspension Insulator - Conductor Down 9/1/12 17:30:00 Y

Bent Static Bar Broke Static Bar - Shieldwire on conductor Cross-Arm Twisted 9/1/12 17:30:00 Y

Twisted H-Frame Structure 9/1/12 17:30:00 Y

8/28/12 20:08:00 YBroken Cross-Arm - Contacting Conductor

Guy Pole Broke - Guy Wire across Conductor Shield Jumper Broke Static Bar Bent Structure

Down - H-Frame Structure Leaning (H-Frame) & Broken Cross-Arm Structure

Leaning - H-Frame

9/7/2012 N

9/3/2012 9/3/12 18:55:00 Y9/3/2012 9/3/12 20:00:00 Y

Broken suspension insulator - conductor down 9/1/12 19:56:00 Y

Structure Down - Steel Pole In Marsh 9/9/2012 N

Center Phase down on River Crossing Tower Requires new conductor 9/5/2012 9/5/12 17:05:00 Y

Shieldwire Down 8/31/12 15:03:00 Y



8/28/12 22:00:00 Y

8/28/12 22:00:00 Y

8/28/12 23:07:00 Y

Broken Cross-Arm Broken Cross-Arm Debris(Aluminum) around Insulator-contacting

phase

DANGER TREE - uprooted held up by another tree Tree on

line

9/2/12 22:03:00 Y

8/28/12 23:47:00 Y8/29/12 00:05:00 Y8/29/12 07:21:00 Y

Broken Insulator - Suspension 9/4/2012 N

RestorationActivitiesDamages


Page 25 of 37

Broken Suspension Insulator - conductor down 9/1/12 17:12:00 Y

8/29/2012 1:21 Y

8/29/2012 1:21 Y

8/29/2012 1:31 Y

8/29/2012 1:31 Y

8/31/2012 11:59 Y

8/29/2012 1:53 Y

3-pole str w/washout around base - appears stable Broken suspension insulator -

conductor down Shield arm broken (laying on X-arm) - H-Frame Structure Down - Single

pole

9/6/2012 N

Broken X-Arm (H-Frame) & Suspension insulator Structure Down - H-Frame Structure

Leaning - Single Pole - Almost in Water9/9/2012 N

Tree on line - Giraffe/Flex Track

Go thru Doctor's property 9/1/2012 20:05 Y







Structure Leaning -Tree fell through line -

not on line ( no damage)

9/6/2012 9/3/2012 11:49 Y

Tree fell through line - not on line ( no

damage)8/29/2012 3:09 9/3/2012 11:49 Y

8/29/2012 3:38 Y

Structure Down - H-Frame Structure Leaning - H-Frame X-Brace unbolted

Bad Access in marsh - 2 canals can be

energized9/4/2012 N

8/29/2012 3:27 Y

8/29/2012 3:27 Y

8/30/2012 19:24 Y

Shieldwire down 8/30/2012 19:24 Y

8/29/2012 4:26 Y8/29/2012 4:26 Y8/29/2012 4:26 Y

8/29/2012 7:57 Y

8/29/2012 7:57 Y

8/29/2012 4:33 Y

8/29/2012 4:36 Y

8/29/2012 4:35 Y

8/29/2012 5:01 Y

8/29/2012 5:00 Y

Shieldwire Down - East side River crossing Tower Back to Gypsy 9/2/2012 13:55 Y

8/29/2012 5:09 Y8/29/2012 5:09 Y8/29/2012 2:45 Y

8/29/2012 2:45 Y

8/29/2012 2:45 Y

Shieldwire down 8/31/2012 21:35 Y

8/29/2012 5:41 Y

8/29/2012 6:01 Y

8/29/2012 6:01 Y

8/29/2012 6:01 Y

8/29/2012 6:03 Y

8/31/2012 14:51 Y


Page 26 of 37

8/31/2012 18:49 Y

8/29/2012 6:48 Y

Broke Arm on Lattice Tower Tree on line 9/3/2012 0/3/2012 16:24 Y

8/31/2012 12:57 Y

8/30/2012 10:21 Y

Jumper damage (bird cage) on Flying T Jumper fell (open) on Flying T Shieldwire

down (on phase)

N. White & Conti St. Ann & N. Rocheblave

St. Louis & N. Dorgenois

8/30/2012 20:17 Y

8/29/2012 8:16 Y8/29/2012 8:16 Y

8/29/2012 8:47 Y

8/29/2012 8:47 Y

8/29/2012 8:47 Y

8/29/2012 8:47 Y

8/29/2012 8:47 Y

Tree on Line 8/30/2012 12:26 Y

Tree on Line 8/30/2012 12:26 Y

Broken Post Insulator - Polymer Tree on Line 8/30/2012 12:26 Y

Tree on Line 8/30/2012 12:26 Y

8/31/2012 12:39 Y

Tree on line Needing grounding 9/2/2012 13:51 Y




8/29/2012 9:30 Y8/29/2012 9:30 Y

8/29/2012 10:13 Y8/29/2012 10:13 Y

Conductor unpinned from Polymer Post Ins. Phase Down Phase Down & Jumper Burned

openTree on line 8/30/2012 20:54 Y

8/29/2012 11:44 Y8/29/2012 11:44 Y8/29/2012 11:44 Y

8/30/2012 9:42 Y

Broken Cross-Arm (H-Frame) Structure Down (H-Frame) 9/9/2012 9/4/2012 16:03 Y

Tree on line 8/29/2012 12:10 Y

Tree on line 8/29/2012 12:10 Y

D-Line close to north phase Tree on line 8/31/2012 19:29 Y

8/29/2012 12:31 Y8/29/2012 12:31 Y8/29/2012 12:35 Y8/29/2012 12:35 Y8/29/2012 12:48 Y8/29/2012 12:48 Y

D-Line Conductor - D/C w/ Kaiser - Mohican 8/30/2012 19:29 Y

8/29/2012 12:51 Y

8/29/2012 12:51 Y

8/29/2012 13:04 Y

8/29/2012 13:04 Y

8/29/2012 13:04 Y

D-Line Conductor - D/C w/ LA Station - Thomas 8/30/2012 19:39 Y

Tree on line 8/31/2012 20:38 Y

Tree on line 8/31/2012 20:38 Y

8/31/2012 20:38 Y


Page 27 of 37

8/29/2012 13:07 Y8/29/2012 13:07 Y8/29/2012 13:08 Y

8/29/2012 13:14 Y

8/29/2012 13:14 Y

8/29/2012 13:27 Y

8/29/2012 13:34 Y8/29/2012 13:34 Y

8/29/2012 13:36 Y

8/29/2012 13:36 Y

8/29/2012 13:45 Y

8/29/2012 13:45 Y

8/29/2012 14:01 Y8/29/2012 14:01 Y8/29/2012 14:09 Y8/29/2012 14:09 Y8/30/2012 0:00 Y8/30/2012 0:00 Y

8/29/2012 14:44 Y

8/29/2012 14:44 Y

8/29/2012 14:34 Y

8/29/2012 14:34 Y

8/29/2012 14:34 Y

8/29/2012 14:34 Y

8/29/2012 14:34 Y

8/29/2012 14:34 Y

8/31/2012 23:35 Y

8/31/2012 23:35 Y

8/29/2012 15:35 Y

8/29/2012 15:35 Y

8/29/2012 14:30 Y

8/29/2012 14:30 Y

8/29/2012 14:30 Y

8/29/2012 15:55 Y

8/29/2012 16:12 Y

8/29/2012 16:12 Y

8/29/2012 16:12 Y

8/29/2012 16:12 Y

8/29/2012 16:12 Y

8/29/2012 16:12 Y

8/29/2012 16:12 Y

8/29/2012 16:14 Y

8/29/2012 16:14 Y

8/29/2012 16:14 Y

8/29/2012 16:52 Y

8/29/2012 16:52 Y

8/29/2012 21:49 Y

8/29/2012 21:49 Y

8/29/2012 21:49 Y

8/29/2012 21:49 Y

TREE ON LINE BTW STR 35&36; TREE

LEANING ON STR 369/1/2012 19:21 Y


LEANING ON STR 369/1/2012 19:21 Y


Page 28 of 37

TREE LEANING TOWARD LINE BTW STR 5 & 6


LEANING ON STR 369/1/2012 19:21 Y


LEANING ON STR 369/1/2012 19:21 Y


LEANING ON STR 369/1/2012 19:21 Y


LEANING ON STR 369/1/2012 19:21 Y


LEANING ON STR 369/1/2012 19:21 Y


LEANING ON STR 369/1/2012 19:21 Y


LEANING ON STR 369/1/2012 19:21 Y


LEANING ON STR 369/1/2012 19:21 Y


LEANING ON STR 369/1/2012 19:21 Y

Tree on line - need track equip 8/31/2012 16:02 Y

Broken strut brace (Not on Line) Tree on line - need track equip 8/31/2012 16:02 Y

Broken Insulator (Post Polymer) - Shield unpinned Tree on line Off of Frenchtown Rd 9/2/2012 9/3/12 11:49 Y

Tree on line Off of Frenchtown Rd 8/29/2012 17:32 9/3/12 11:49 Y

Tree on line Off of Frenchtown Rd 8/29/2012 17:32 9/3/12 11:49 Y

8/29/2012 17:20 Y

8/29/2012 17:20 Y

8/29/2012 17:20 Y

8/29/2012 17:20 Y

8/29/2012 17:20 Y

8/29/2012 17:20 Y

8/29/2012 17:20 Y

Pole top broke Tree on line Pole to be repaired-not replaced 8/30/2012 17:55 Y

8/29/2012 19:25 Y

8/29/2012 19:25 Y

8/29/2012 19:25 Y


Page 29 of 37

8/29/2012 19:25 Y

8/29/2012 19:25 Y

8/29/2012 19:36 Y

TREE ON LINE AT ST 37&38 8/31/2012 19:41 Y

Cross arm damage str 38 TREE ON LINE AT ST 37&38 8/31/2012 19:41 Y

8/29/2012 20:12 Y

8/29/2012 20:12 Y

Tree on line BTW 108 and 109 8/31/2012 21:30 Y





PUT SLEEVE ON CONDUCTOR Tree on line BTW 108 and 109 8/31/2012 21:30 Y


TREE ON LINE BTW STR 27&28 8/30/2012 21:15 Y

TREE ON LINE BTW STR 27&28 8/30/2012 21:15 Y

8/29/2012 21:47 Y

8/29/2012 21:47 Y

8/29/2012 21:47 Y

8/29/2012 21:47 Y

8/29/2012 21:47 Y

8/29/2012 21:47 Y

8/29/2012 21:47 Y

8/29/2012 21:47 Y


Page 30 of 37

TREE FELL THRU LINE AND IS CLEAR; 362 INSULATOR BR 8/29/2012 21:47 Y

8/29/2012 22:26 Y

8/29/2012 22:26 Y

8/29/2012 22:26 Y

Broken Post Insulator (strut looks ok)Leaning tree --- line

can be energized prior Tree on line

8/31/2012 19:20 Y

TREE ON LINE AT STR 74&75 8/31/2012 15:58 Y

SHIELD WIRE DAMAGE TREE ON LINE AT STR 74&75 8/31/2012 15:58 Y




1 BROKEN X-ARM; 1 SHIELD WIRE BROKEN 1 BROKEN X-ARM; 1 SHIELD

WIRE BROKEN

STR 4&5 TREE ONLINE 9/1/2012 18:17 Y

Limb on Line 8/30/2012 20:13 Y

Limb on Line 8/30/2012 20:13 Y

8/30/2012 19:02 Y

8/30/2012 19:02 Y

8/30/2012 19:02 Y

8/30/2012 19:02 Y

8/31/2012 14:49 Y

8/31/2012 14:49 Y

8/31/2012 14:49 Y

8/31/2012 14:49 Y

8/31/2012 14:49 Y

8/31/2012 14:49 Y

8/30/2012 1:13 Y

8/30/2012 19:35 Y

8/30/2012 19:35 Y

8/30/2012 19:35 Y

8/30/2012 22:30 Y

8/30/2012 22:30 Y

8/30/2012 22:30 Y

8/30/2012 19:53 Y

8/30/2012 19:53 Y


Page 31 of 37

8/30/2012 19:53 Y

8/30/2012 19:53 Y

8/30/2012 19:53 Y

8/30/2012 19:53 Y

8/30/2012 19:53 Y

8/30/2012 19:53 Y

8/30/2012 19:53 Y

8/30/2012 19:53 Y

8/30/2012 20:34 Y

8/30/2012 20:34 Y

8/30/2012 20:34 Y

8/30/2012 20:34 Y

8/30/2012 3:59 Y

8/30/2012 3:59 Y

8/30/2012 3:59 Y

8/30/2012 3:59 Y

8/30/2012 3:59 Y

8/30/2012 3:59 Y

8/30/2012 3:59 Y

8/30/2012 3:59 Y

8/30/2012 3:59 Y

9/5/2012 9/6/2012 17:21 Y

8/30/2012 7:49 9/6/2012 17:21 Y

8/30/2012 7:49 9/6/2012 17:21 Y

8/30/2012 7:49 9/6/2012 17:21 Y


Page 32 of 37

8/30/2012 7:49 9/6/2012 17:21 Y

8/30/2012 10:22 Y

8/30/2012 10:22 Y

8/30/2012 10:22 Y

8/30/2012 10:22 Y

9/1/2012 20:50 Y

8/30/2012 10:58 Y

8/30/2012 11:25 Y

8/30/2012 11:25 Y

8/30/2012 11:25 Y

8/30/2012 11:25 Y

8/30/2012 11:25 Y

8/30/2012 16:34 Y

8/30/2012 16:34 Y

8/30/2012 16:34 Y

8/30/2012 16:34 Y

8/30/2012 16:34 Y

8/30/2012 12:12 Y

8/30/2012 15:13 Y

8/30/2012 15:13 Y

8/30/2012 15:13 Y

8/30/2012 15:13 Y

8/30/2012 15:13 Y

8/30/2012 16:22 Y

8/30/2012 17:33 Y

8/30/2012 17:33 Y

8/30/2012 17:33 Y

8/30/2012 19:02 Y

8/30/2012 23:24 Y

8/30/2012 23:24 Y

8/31/2012 3:48 Y

8/31/2012 3:48 Y

8/31/2012 3:48 Y

8/31/2012 13:06 Y


Page 33 of 37

8/31/2012 22:11 Y

8/31/2012 22:11 Y

8/31/2012 22:11 Y

8/31/2012 22:11 Y

8/31/2012 14:34 Y

8/31/2012 15:47 Y

8/31/2012 15:47 Y

8/31/2012 15:47 Y

8/31/2012 15:47 Y

8/31/2012 15:47 Y

8/31/2012 15:47 Y

8/31/2012 15:47 Y

8/31/2012 15:47 Y

8/31/2012 15:47 Y

8/31/2012 15:47 Y

8/31/2012 20:01 Y

9/1/2012 18:37 Y

9/1/2012 18:37 Y

9/1/2012 18:37 Y

9/1/2012 18:37 Y

9/1/2012 18:37 Y

9/1/2012 18:37 Y

9/1/2012 18:37 Y

8/31/2012 21:59 Y

8/31/2012 21:59 Y

8/31/2012 21:59 Y

8/31/2012 21:59 Y

8/31/2012 21:59 Y


Page 34 of 37

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Page 36 of 37

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Page 37 of 37

Carrying Costs for 2013 2,549,475.56 Carrying Costs for 2014 2,786,638.06 Carrying Costs for 2015 (as of June 2015) 1,482,394.29

Total Carrying Costs 6,818,507.91

Entergy New Orleans, Inc.Hurricanes Ike Storm Capital Costs

For Period: January 2013 - June 2015Summary of Carrying Costs


Page 1 of 4

WACC annual rate 8.320% *

Capital Storm Costs at 12/31/2012 28,896,036.69 Current Month Charges 278,222.47 Carrying Costs (based on prior month balance) 200,345.85



Capital Storm Costs at 3/31/2013 30,042,379.03 Current Month Charges (19,316.23) Carrying Costs (based on prior month balance) 208,293.83






Capital Storm Costs at 9/30/2013 31,571,709.01 Current Month Charges 508.48 Carrying Costs (based on prior month balance) 218,897.18



Capital Storm Costs at 12/31/2013 32,235,154.80


* - Estimated WACC based on 2013.


Calculation of Carrying CostsFor Year 2013


Page 2 of 4

WACC annual rate 8.320%

Capital Storm Costs at 12/31/2013 32,235,154.80 Current Month ChargesCarrying Costs (based on prior month balance) 223,497.07


















Page 3 of 4








Capital Storm Costs at 6/30/2015 36,504,187.15 Current Month ChargesCarrying Costs (based on prior month balance)










Calculation of Carrying CostsFor Period: January 2015 - June 2015


Page 4 of 4

Previous Testimony of Dennis DawseyTYPE OF TESTIMONY JURISDICTION CLIENT DOCKET Filing Date

Direct Testimony LPSC EGSL and ELL U-30981 5/11/2009Direct Testimony LPSC EGSL, ELL, and ITC U-32538 9/5/2012Direct Testimony CNO ENO and ELL UD-12-01 9/12/2012Direct Testimony LPSC EGSL and ELL U-32764 4/9/2013Rebuttal Testimony LPSC EGSL, ELL, and ITC U-32538 5/21/2013Deposition LPSC EGSL, ELL, and ITC U-32538 7/1/2013Hearing Transcript LPSC EGSL, ELL, and ITC U-32538 7/18/2013Rebuttal Testimony LPSC EGSL and ELL U-32764 10/14/2013


Page 1 of 1

BEFORE THE


APPLICATION OF ENTERGY NEW ORLEANS, INC. FOR CERTIFICATIONS OF COSTS RELATED TO HURRICANE ISAAC, AND FOR RELATED RELIEF

) ) ) ) )


DIRECT TESTIMONY

OF

ORLANDO TODD

ON BEHALF OF


February 2014

Entergy New Orleans, Inc. Direct Testimony of Orlando Todd CNO Docket No. UD-14-_____

i

TABLE OF CONTENTS Page

I. INTRODUCTION AND QUALIFICATIONS ...................................................................... 1

II. STORM RECOVERY COSTS.............................................................................................. 3

A. Amount of Storm Recovery Costs ........................................................................ 3

B. Accounting for Hurricane Isaac Storm Recovery Costs ........................................ 9

1. Project Codes and Scope Statements ..............................................................9

2. Accounting Approvals ................................................................................. 13

III. CONCLUSION ................................................................................................................... 20

EXHIBIT LIST Exhibit OT-1 Summary of ENO’s Total Company Hurricane Isaac Costs by Class and

Major Resource Category Exhibit OT-2 Hurricane Isaac Project Codes used by ENO Exhibit OT-3 Electronic Index of Hurricane Isaac Transactions (CD only) – ENO Exhibit OT-4 Summary of Prior Testimony Exhibit OT-5 Summary of Carrying Costs


1


Q1. PLEASE STATE YOUR NAME, OCCUPATION, AND BUSINESS ADDRESS. 2

A. My name is Orlando Todd. I am employed by Entergy Services, Inc. (“ESI”)1 and I 3

currently serve as the Jurisdictional Finance Director for Entergy New Orleans, Inc. 4

(“ENO” or the “Company”). My office is located at 1600 Perdido Street, New 5

Orleans, Louisiana 70112. 6

7

Q2. WHAT ARE YOUR PRINCIPAL RESPONSIBILITIES FOR THE COMPANY AS 8

JURISDICTIONAL FINANCE DIRECTOR? 9

A. As Jurisdictional Finance Director, I am responsible for financial management, 10

planning, monitoring, reporting, as well as providing regulatory support to the 11

Company. 12

13

Q3. ON WHOSE BEHALF ARE YOU TESTIFYING IN THIS PROCEEDING? 14

A. I am testifying on behalf of ENO. 15

16

1 ESI is an affiliate of the six Entergy Operating Companies (“EOCs”) and provides administrative and support services to the EOCs. The six EOCs are Entergy Arkansas, Inc. (“EAI”), Entergy Louisiana, LLC (“ELL”), Entergy Gulf States Louisiana, L.L.C. (“EGSL”), Entergy Mississippi, Inc. (“EMI”), Entergy Texas, Inc. (“ETI”), and ENO. The electric generating resources and bulk transmission facilities of ENO, ELL, EGSL, ETI and EMI are currently operated pursuant to the System Agreement on a single, integrated basis and are referred to collectively as the “Entergy System” or the “System.” In December 2013, EAI terminated its participation in the Entergy System Agreement and currently operates independently of the remaining System Agreement EOCs.


2

Q4. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND, PROFESSIONAL 1

QUALIFICATIONS, AND EXPERIENCE. 2

A. I have a B.B.A. in Accounting from Southern Arkansas University and an M.B.A. 3

from the University of Arkansas – Little Rock. I am a Certified Public Accountant. I 4

began my career with the Entergy System in 1983. I started in Property Accounting 5

and have worked in other departments, including General Accounting, the Finance 6

Operations Center, and Corporate Reporting. Prior to my career with the Entergy 7

System, I worked for Price Waterhouse (now PricewaterhouseCoopers) for two and 8

one-half years. 9

10

Q5. HAVE YOU EVER TESTIFIED BEFORE THE CITY COUNCIL OF NEW 11

ORLEANS? 12

A. Yes. See Exhibit OT-4 for a list of my prior testimony before Council of the City of 13

New Orleans (“CNO” or the “Council”). 14

15

Q6. PLEASE SUMMARIZE THE RELIEF THAT THE COMPANY IS SEEKING IN 16

ITS APPLICATION. 17

A. Through this proceeding, ENO requests entry of a Council order: (1) determining that 18

the entire amount of ENO’s total storm recovery costs (“Total Storm Recovery 19

Costs”), $47.3 million, was reasonable and necessary to rebuild ENO’s electric 20

infrastructure and to restore power to its customers; (2) certifying ENO’s Total Storm 21

Recovery Costs as eligible for recovery; and (3) authorizing the Company to recover 22

carrying costs on approved storm recovery costs. 23


3

1

Q7. WHAT IS THE PURPOSE OF YOUR TESTIMONY? 2

A. My testimony supports the Company’s request for approval and recovery of costs 3

related to restoration efforts following Hurricane Isaac. My testimony addresses: 4

The costs incurred by the Company in connection with Hurricane Isaac; 5

The Company’s accounting and auditing procedures for costs related to Hurricane 6

Isaac. 7

8

II. STORM RECOVERY COSTS 9

A. Amount of Storm Recovery Costs 10

Q8. WHAT ARE THE AMOUNTS OF STORM RECOVERY COSTS RELATED TO 11

HURRICANE ISAAC THAT THE COMPANY IS ASKING THE COUNCIL TO 12

APPROVE IN THIS DOCKET? 13

A. As shown in Exhibit OT-1, ENO’s Hurricane Isaac Total Storm Recovery Costs were 14

$47.3 million through December 31, 2013. Thus, the Company requests that the 15

Council certify that the full amount of ENO’s Total Storm Recovery Costs, or $47.3 16

million before carrying costs, was prudently incurred and recoverable. 17

Moreover, at this time, ENO is evaluating several cost-recovery mechanisms 18

and will continue to work with the Council Advisors to determine the best method for 19

recovering its storm recovery costs. At an appropriate time, ENO will request that the 20

Council issue a Resolution authorizing a specific cost-recovery mechanism. 21

22


4

Q9. IS THE COMPANY REQUESTING THAT THE COUNCIL APPROVE 1

CARRYING COSTS ASSOCIATED WITH ITS HURRICANE ISAAC 2

RESTORATION? 3

A. Yes. The Company is seeking recovery of carrying costs on net storm recovery costs 4

at the weighted average cost of capital from January 2013 through the date of 5

recovery. My calculation of projected carrying charges from January 2013 through 6

June 2015 is set forth for ENO in Exhibit OT-5. For purposes of this filing, I have 7

calculated projected carrying costs through June 2015, but the Company proposes that 8

this amount be adjusted either upward or downward through the date the costs are 9

recovered. As reflected in Exhibit OT-7, ENO seeks the recovery of carrying costs in 10

the amount of $6.8 million, subject to any necessary adjustments since the time of 11

filing. 12

13

Q10. WHAT FUNCTIONAL CLASSES OF COSTS ARE INCLUDED IN THE TOTAL 14

COST AMOUNTS? 15

A. The Company’s storm recovery costs are broken down into the following four major 16

cost classes: (1) Production, (2) Transmission, (3) Distribution, and (4) Other. 17

18


5

Q11. WHAT CATEGORIES OF COSTS ARE INCLUDED WITHIN THE FOUR 1

MAJOR CLASSES OF COSTS? 2

A. Within each of the four functional classes of costs, costs are further assigned to one of 3

seven major cost categories, as shown in Exhibit OT-1:2 4

The Materials cost category includes the cost of parts and materials used in 5

the restoration effort. 6

The Contract Work cost category includes the cost of third-party contractors 7

and workers supplied by other utility companies to assist in the restoration 8

effort. 9

The Internal Labor cost category includes the total labor costs (including 10

employee payroll, benefits, and taxes) incurred on behalf of and charged to the 11

Company by personnel from ENO, ESI, and/or other EOCs. 12

The Employee Expense cost category includes the cost of providing lodging, 13

meals, and other logistical items necessary to the restoration work force. This 14

category also includes travel expenses, such as mileage, and other 15

reimbursable expenses incurred by the Company’s employees. 16

The Transportation cost category includes the cost of operating and 17

maintaining fleet vehicles and equipment, including the cost of fuel. 18

Finally, the All Other cost category includes additional costs not specifically 19

categorized elsewhere, such as an Allowance for Funds Used During 20

2 The following descriptions are intended to be illustrative only and the listed examples within each category are not all-inclusive.


6

Construction (“AFUDC”), capital suspense, ESI billings, equipment rentals, 1

and telecommunications. 2

3

Q12. DOES THE COMPANY ANTICIPATE THAT ITS TOTAL STORM RECOVERY 4

COSTS WILL BE APPROPRIATELY ADJUSTED FOR INCREASES OR 5

DECREASES IN THOSE COSTS THAT ARISE OR BECOME KNOWN AFTER 6

THIS FILING? 7

A. Yes. It is anticipated that approved storm recovery costs will be adjusted (or trued-8

up) to reflect increases or decreases in storm costs arising after this Application, such 9

as receipt of storm cost invoices after the filing that were not included in the 10

December 31, 2013 totals, and any storm-related invoice discounts or rebates 11

received after the filing. At this time, ENO expects such adjustments, if any, to be 12

extremely minor. 13

14

Q13. HAS THE COMPANY REDUCED ITS REQUESTED RECOVERY TO 15

ACCOUNT FOR ESTIMATED INSURANCE PROCEEDS OR FEDERAL OR 16

STATE RELIEF GRANTS? 17

A. The Company has not received any insurance proceeds to date, and it is not expected 18

at this time that any insurance proceeds will be received. As discussed in prior storm 19

cost proceedings, insurance has not been reasonably available for damages to 20

transmission and distribution lines, which as reflected on Exhibit OT-1 represent the 21

vast majority of damages from Hurricane Isaac. With respect to insurance coverage 22

for other property for which coverage was reasonably available, the damages to 23


7

production facilities and Company buildings did not exceed the applicable self-1

insured retention. Additionally, the Company has not received any relief grants or 2

funds from any federal or state governmental bodies nor does it expect to receive any. 3

However, the Company would propose a true-up mechanism to handle any future 4

amounts received, were there to be any. 5

6

Q14. HAS ENO ACCOUNTED FOR DISBURSEMENTS FROM THE STORM 7

RESERVE IN CONNECTION WITH HURRICANE ISAAC? 8

A. Yes. In November 2012, ENO withdrew $10 million from the storm reserve escrow 9

account (“Storm Reserve”) for storm-related deferred operations and maintenance 10

(“Deferred O&M”). In addition, in June 2013, the Company withdrew an additional 11

$7.4 million from the Storm Reserve. Thus, ENO has already withdrawn a total of 12

$17.4 million from the Storm Reserve to offset Deferred O&M costs. 13

Accordingly, although ENO seeks a determination that the entire $47.3 14

million in storm recovery costs were reasonable, necessary, and eligible for recovery, 15

only $29.9 million remains unrecovered from customers. This amount represents the 16

total $47.3 million of storm recovery costs less the $17.4 million already withdrawn 17

from the Storm Reserve. 18

19

Q15. IS THE TOTAL STORM RECOVERY COSTS AMOUNT SHOWN ABOVE FOR 20

ENO RECORDED IN ENO’S ACCOUNTING BOOKS AND RECORDS? 21

A. Yes. 22

23


8

Q16. WHAT AMOUNT OF ENO’S STORM RECOVERY COSTS RELATING TO 1

HURRICANE ISAAC HAS BEEN OR WILL BE CAPITALIZED, AND WHAT 2

AMOUNT HAS BEEN OR WILL BE CHARGED TO THE STORM RESERVE? 3

A. Exhibit OT-1 shows that of ENO’s Total Storm Recovery Costs of $47.3 million, 4

approximately $29.7 million are or will be capital costs and approximately $17.6 5

million are Deferred O&M costs that have been or will be charged to the Storm 6

Reserve. 7

8

Q17. PLEASE ELABORATE ON THE COSTS INCLUDED IN THE AMOUNTS THAT 9

ARE CAPITALIZED. 10

A. Capitalized costs include both direct costs (e.g., materials, internal labor, and contract 11

labor) and certain allocated costs called capital suspense. Additionally, capitalized 12

costs also include an allowance for funds used during construction (“AFUDC”) on 13

Construction Work in Progress (“CWIP”). 14

The capital portion of Hurricane Isaac storm recovery costs is recorded 15

initially in Account 107, CWIP. In accordance with the Federal Energy Regulatory 16

Council’s (“FERC”) Uniform System of Accounts, as the construction work is 17

completed on the various system restoration projects, the assets are transferred from 18

the CWIP account to a plant-in-service account. During the construction period (i.e. 19

while the costs are in the CWIP account), the costs accrue AFUDC. As the various 20

assets are placed in service and thus transferred out of the CWIP account, the 21

AFUDC accruals cease on the assets. 22


9

Capital suspense represents labor costs for support personnel who are not 1

included in the direct labor costs associated with capital project work, but who 2

provide support for multiple capital projects. Capital suspense is distributed across 3

multiple capital projects using a rate that distributes these costs proportionally. 4

5

Q18. HOW MUCH OF THE OTHER COSTS RELFECTED IN EXHIBIT OT-1 IS 6

ATTRIBUTABLE TO AFUDC? 7

A. The Total Storm Recovery Costs included in Exhibit OT-1 include $0.3 million of 8

AFUDC. 9

10

B. Accounting for Hurricane Isaac Storm Recovery Costs 11

1. Project Codes and Scope Statements 12

Q19. HOW DID THE COMPANY COMPILE AND RECORD THE HURRICANE 13

ISAAC STORM RECOVERY COSTS ADDRESSED IN THIS APPLICATION? 14

A. Consistent with the Company’s accounting practices, Hurricane Isaac storm recovery 15

costs were compiled and recorded on the Company’s books and records through the 16

use of specific project codes that have been grouped into the four function-related 17

classes of costs that I discussed previously: Production, Transmission, Distribution, 18

and Other. The storm recovery costs clearly identified with work on Production, 19

Transmission, or Distribution, were recorded to those classes, as appropriate, using 20

function-specific project codes. Costs that were not specifically identified with those 21

four classes, such as overall organization, common facilities, and information 22

technology costs, were recorded to the fourth class: Other. 23


10

1

Q20. WHAT ARE PROJECT CODES? 2

A. A project code is an alphanumeric code used to capture related costs for a particular 3

task or service. Project codes are used by each EOC, including ENO, to accumulate 4

costs. In addition, project codes are used by ESI to accumulate costs to be billed 5

directly or allocated to affiliated companies. 6

7

Q21. HOW IS A PROJECT CODE ESTABLISHED? 8

A. Project codes are established in the Company’s accounting systems when 9

management determines there is a need to be able to identify and aggregate costs for a 10

specific project, which may include an aggregation of expenses for a particular 11

purpose or for the creation of a new capital asset. Setting up a project code requires a 12

substantial amount of information. Additionally, the completion of the project code 13

setup process requires multiple approvals, including those from Accounting, to ensure 14

that the project code attributes are appropriate. 15

16

Q22. WHAT INFORMATION IS REQUIRED IN ORDER FOR A NEW PROJECT 17

CODE TO BE ESTABLISHED? 18

A. The answer depends on the circumstances under which the project code is 19

established. When a project code that will be used by ESI employees is established, a 20

“scope statement” is developed for that project code. The scope statement sets out, in 21

narrative form, a description of the project and the type of work that will be 22

performed under that project code. The project code scope statement typically 23


11

describes the project purpose and activities, the primary deliverables that will result 1

from the services provided, and the rationale for the billing method that is assigned to 2

the project code. 3

When project codes that will be used by non-ESI employees are established, a 4

project description is required. The project description may not be as detailed as a 5

scope statement because, in a project that will be used by non-ESI employees, the 6

work typically is performed for a single EOC and, as such, all of the work will be 7

recorded on the books solely of that Operating Company, rather than being allocated 8

among multiple Operating Companies. 9

In a non-emergency situation, the scope statements and project descriptions 10

may be fairly detailed, but if the new project code is created in the context of an 11

emergency situation, such as storm restoration work, the scope statement or project 12

description might not be detailed. For this reason, scope statements and project 13

descriptions that were developed for the Hurricane Isaac storm restoration efforts 14

might not contain the level of detail that would be found in more typical, non-15

emergency scope statements and project descriptions. 16

Other key information required to establish a project code includes the 17

physical location of the project and the department responsible for the project for 18

which the costs will be incurred. For a capital project, information regarding the 19

following is required: removal, salvage, additions, project manager, and estimated in-20

service date. 21

22


12

Q23. WHAT ARE THE PROJECT CODES THAT CAPTURE THE COMPANY’S 1

STORM RECOVERY COSTS FOR HURRICANE ISAAC? 2

A. The list of project codes applicable to ENO’s Hurricane Isaac storm restoration and 3

their brief descriptions can be found in Exhibit OT-3. 4

5

Q24. HOW DID PERSONNEL KNOW TO WHICH PROJECT CODE THEY SHOULD 6

BILL THEIR TIME AND EXPENSES RELATED TO HURRICANE ISAAC 7

RESTORATION? 8

A. Immediately following Hurricane Isaac, communications were distributed to inform 9

employees of the project codes to be used for system restoration efforts. Those 10

communications included both hard copy and electronic distribution of guidelines and 11

project codes. The guidelines directed employees to consider whether they were 12

performing non-storm-related tasks, were performing tasks and incurring expenses 13

related to system restoration, or were unable to work due to the storm. The 14

communications program also included a list of project codes for each function and 15

business unit. Employee time and expense reports are required to be approved by 16

supervisors or managers. This approval process serves as a key control to ensure that 17

time and expenses are charged to appropriate project codes. 18

19

Q25. WERE ANY OF THE HURRICANE ISAAC-RELATED PROJECT CODES USED 20

TO RECORD COSTS RELATED TO ANY NON-HURRICANE ISAAC COSTS? 21

A. No. As a result of the Company’s internal control processes, there should be no non-22

Hurricane Isaac costs included. However, to verify this, the Company engaged 23


13

PricewaterhouseCoopers, LLC (“PwC”) to perform an attestation examination of the 1

costs included in the Hurricane Isaac project codes as of January 31, 2013,3 as 2

discussed later in my testimony. 3

4

2. Accounting Approvals 5

Q26. PLEASE DESCRIBE THE INTERNAL CONTROLS PROCESS USED BY THE 6

COMPANY TO ENSURE PROPER ACCOUNTING FOR HURRICANE ISAAC 7

COSTS. 8

A. ENO and ESI maintain a strong system of internal controls, including the approvals 9

for costs incurred before payments are made to suppliers or when employees record 10

their time and expenses. Because of the emergency nature and magnitude of the 11

system restoration efforts and the number of employees and outside parties involved, 12

additional review processes were implemented to supplement existing procedures to 13

ensure the proper accounting of storm recovery costs. Teams were established, and 14

they followed specific procedures to review and approve storm-related invoices from 15

contractors and mutual assistance companies. 16

17

Q27. REGARDING INTERNAL CONTROLS, WAS IT POSSIBLE OR NECESSARY 18

TO APPROVE EVERY EXPENSE AND HOUR WORKED AHEAD OF TIME? 19

A. No. Because of the need to restore infrastructure and resume power service as 20

quickly as possible, there are instances in which time spent or funds incurred were not 21

3 Approximately 98% of ENO’s Total Storm Recovery Costs were incurred by January 31, 2013.


14

approved ahead of time. Given the health and safety issues involved with power 1

system restoration, both for our own employees and contractors and for the public, it 2

is important that we act quickly and with flexibility, while also working as safely as 3

possible. This means that, in some instances, specific work and expenses may have 4

proceeded on the spot based on decisions by field supervisory personnel without prior 5

management authorization. As discussed below, no invoice was paid until it was 6

audited in light of the applicable contract and supporting documentation, especially 7

time sheets that were approved by operations personnel. 8

9

Q28. DESCRIBE THE PROCEDURES USED BY THE COMPANY TO ENSURE THAT 10

COSTS BILLED BY CONTRACTORS WERE ACCURATE AND WERE 11

RECORDED PROPERLY IN THE COMPANY’S FINANCIAL RECORDS. 12

A. Each invoice that the Company received from a third-party contractor was audited 13

under the supervision of the internal audit department or finance department prior to 14

payment. Invoice processing teams were established to process the following types 15

of storm-related invoices: (1) transmission and distribution line and vegetation, (2) 16

facilities, (3) fossil, (4) nuclear, and (5) logistics.4 17

4 The Company refers to storm preparation and restoration support costs as “logistics” costs. Logistics costs include those costs necessary to support restoration crews as they prepare for and then work on system restoration following a weather event. Logistics activities include among other things: (1) setting up and manning staging sites, (2) feeding, housing, and providing hygiene facilities for restoration crews, and, (3) providing incremental transportation-related support needed due to storm restoration conditions, such as access to fuel, tire repair, etc. To account for their use by class, logistics costs were functionalized to the Distribution and Transmission classes based on the number of personnel utilized to restore power at the peaks of the restoration effort for the two functions.


15

Each of these teams accomplished the following tasks with respect to the 1

invoices they processed: (1) obtaining confirmation from operations personnel of 2

receipt of the services being billed on the invoice, (2) tracing the rates being billed on 3

the invoice to the appropriate contract, if applicable, or confirming the reasonableness 4

of rates with operations for non-contract-based services, (3) recalculating the amount 5

of the invoice, and (4) addressing disputes prior to payment. The appropriate 6

accounting codes were assigned to each invoice, based on the information supplied by 7

operations as to the location and scope of the work performed. In particular, costs 8

were either assigned to a Hurricane Isaac expense project code or a capital project 9

code for the appropriate EOC. The Contractor Invoice Processing Team was 10

responsible for processing all invoices for transmission and distribution line and 11

vegetation contract crew services. These services represented a substantial majority 12

of the contractor invoices processed for Hurricane Isaac in terms of the number and 13

dollar value of invoices processed. 14

15

Q29. PLEASE EXPLAIN THE INTERNAL AUDIT CONTROLS FOR THIRD-PARTY 16

CONTRACT LINE AND VEGETATION SERVICES IN MORE DETAIL. 17

A. The Company’s procedures for processing Hurricane Isaac invoices were based upon 18

the control procedures that were developed to process invoices for the storm recovery 19

costs following Hurricanes Katrina, Rita, Gustav, and Ike. These procedures were 20

refined to facilitate improved efficiencies and timeliness of audit information, while 21

maintaining a high degree of accuracy, to enable ESI to audit each invoice prior to its 22

payment. Because this process was designed to identify billing discrepancies for a 23


16

given invoice prior to the release of any funds for payment of that invoice, ESI, on 1

behalf of the Company, maintained maximum negotiating leverage to settle accounts 2

with vendors when we determined that charges were not in accord with the 3

documentation of work performed and/or the applicable contract. 4

This approach to auditing utilized a two-phase process that included an initial 5

audit review and a second audit review, both of which were performed by 6

professional auditors. In the first review, the auditors performed the following steps: 7

(1) recalculated all of the basic arithmetic on the face of the invoice; (2) tested a 8

minimum of 20% of the line items of each invoice by tracing the calculations back to 9

the applicable contract and supporting documentation, especially the time sheets that 10

were approved by operations personnel; and, (3) assessed the overall reasonableness 11

of the invoice in light of all of the available information. The second review included 12

the following steps: (l) a sample of yet more invoice line items that were traced back 13

to the contract and supporting documentation, (2) an assessment of the accuracy of 14

the first auditor’s work, and, (3) a second assessment of the overall reasonableness of 15

the invoice. If a significant billing discrepancy was discovered in either the first or 16

second audit review, all line items of the invoice were recalculated, traced back to 17

supporting documentation, and compared to the applicable contract terms. All 18

discrepancies were then itemized and quantified and, if material, brought to the 19

vendor’s attention for resolution. 20

In order to strike the proper balance between accuracy and efficiency, the 21

Company established a materiality threshold for the audit. The Company believes 22

that this materiality threshold was a prudent and effective means to distinguish 23


17

between significant billing discrepancies that should be vigorously disputed and 1

minor discrepancies for which disputes, if pursued, would use more resources than 2

could be saved even if those disputes were resolved in the Company’s favor. 3

Pursuant to this materiality threshold, all billing discrepancies that exceeded the lesser 4

of $500 or 1% of the original amount of the invoice were pursued. When such 5

material discrepancies were found, a member of the audit team contacted the vendor 6

and asked the vendor to provide an explanation and/or documentation to resolve the 7

issue or to accept an adjustment to the invoice. 8

Because no funds were released prior to resolution for any disputed invoice, 9

the Company was generally able to settle most disputes in a reasonable and timely 10

manner. Difficult cases were sent to a special dispute resolution team. When the 11

audit revealed a material discrepancy in the vendor’s favor, the auditors informed the 12

vendor and adjusted the invoice accordingly. The Company believes that this 13

approach is the right thing to do and also lowers costs in the long run by developing 14

goodwill with the vendors, which generally enables the Company to settle amicably 15

other disputes that are in its favor without incurring legal fees. Additionally, the 16

Company believes that it is important, whenever possible, to maintain good relations 17

with vendors because sooner or later the Company will need to call upon most of 18

them again to assist with emergency storm restoration or normal base-load work. The 19

Company believes that the third-party contractor invoice payment process is a 20

prudent and effective way of processing the Company’s storm invoices to minimize 21

the cost of system restoration for customers for this storm and over the long-run. 22

23


18

Q30. DID THE OTHER INVOICE PROCESSING TEAMS OBTAIN THE SAME 1

LEVEL OF ASSURANCE AS DID THE TEAM PROCESSING THE INVOICES 2

FOR TRANSMISSION AND DISTRIBUTION LINE AND VEGETATION 3

CONTRACT CREW SERVICES? 4

A. Yes. In order to obtain a similar level of assurance, each of the other teams 5

confirmed receipt of the services received, verified the reasonableness of rates 6

charged, recalculated the amount of the invoice, and addressed disputes before the 7

invoices were paid. These teams, which were comprised of personnel from the 8

operations, supply chain, finance, and internal audit departments, obtained assurance 9

regarding storm-related invoices for facilities, fossil generating facilities, nuclear 10

generating facilities, and logistics using audit procedures that were tailored to the 11

situation underlying the invoices to be processed. 12

13

Q31. IF A VENDOR DISAGREED WITH ESI’S CONCLUSION THAT THE VENDOR 14

HAD OVERBILLED THE COMPANY, WHAT PROCEDURES WERE 15

FOLLOWED TO RESOLVE THE DISPUTE? 16

A. When a material discrepancy was found by a member of one of the invoice 17

processing teams, he or she made a good faith effort to resolve the dispute by 18

obtaining from the vendor an explanation of the variance, additional documentation, 19

and/or acceptance of a reduction in the amount of the invoice. If the auditor was 20

unable to settle the matter with the vendor after an initial good faith effort, payment 21

of the invoice was withheld, and the invoice file was typically forwarded to a special 22

dispute resolution team that would continue to negotiate with the vendor until the 23


19

dispute was resolved. In difficult cases, ESI’s dispute resolution personnel consulted 1

with the Supply Chain and Legal departments, and a small number of invoice files 2

were transferred to the Supply Chain department for ultimate resolution. 3

4

Q32. DID THE COMPANY SEEK AN EXTERNAL REVIEW OF ITS HURRICANE 5

ISAAC STORM RECOVERY COSTS? 6

A. Yes. The Company retained PwC to undertake an independent attestation 7

examination of the Company’s summaries of Hurricane Isaac storm recovery costs 8

through January 31, 2013 to determine and ensure their completeness and accuracy. 9

10

Q33. WILL THE COMPANY MAKE DATA AVAILABLE FOR THE PARTIES TO 11

CONDUCT A REVIEW OF HURRICANE ISAAC STORM RECOVERY COSTS? 12

A. Yes. The Company will make available all documentation supporting its storm 13

recovery costs. Because of the huge volume of this information, the Company is not 14

attaching and filing this information as a workpaper. I am attaching Exhibit OT-3, 15

which is a detailed electronic index in Microsoft Excel format to all of ENO’s 16

transactions relating to the Hurricane Isaac storm restoration. With these electronic 17

indices, a party can sort the data and determine which transactions to audit or review. 18

Although PwC has already conducted an independent attestation, the data production 19

process that I am suggesting will allow the parties to undertake their own review. 20

This could work much like a financial audit in which the parties will determine a 21

statistically relevant but discrete level of transactions out of the entire set of 22

transactions that they wish to review and test for accuracy. From these indices, the 23


20

parties can submit their selected transactions list to the Company. The Company asks 1

that the parties submit a single joint list for testing. Based on this list, the Company 2

would then pull all documents underlying those selected transactions and make them 3

available to the parties. 4

5

III. CONCLUSION 6


A. Yes, at this time. 8

AFFIDAVIT

STATE OF LOUISIANA

PARISH OF ORLEANS

NOW BEFORE ME, the undersigned authority, personally came and

appeared, Orlando Todd, who after being duly sworn by me, did depose and say:

That the above and foregoing is his sworn testimony in this proceeding

and that he knows the contents thereof, that the same are true as stated, except as to

matters and things, if any, stated on information and belief, and that as to those matters

and things, he verily believes them to be true.

t!JM\<k=1~ Orlando Todd

SWORN TO AND SUBdRIBED BEFORE ME THIS ~DAY OF h.rlldJlli--=-' 2014.

/JJJL41wfi ,£ 1U iWlxJiV TARYPUBLIC

~~~ La. Bar. No. 32618

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Exhibit OT-1 CNO Docket No. UD-14-__

Page 1 of 1

Project Project DescC7PPSJ4091 HURRICANE ISAAC DIST ENOI 8/28/12C8PPISE003 ISAAC REPAIRS - 3734 TULANEC8PPISN002 ISAAC REPAIRS - 3700 TULANE AVEC8PPISN003 NOE Fence Upgrades -- IsaacC8PPISN005 New Orleans East SC 1C8PPRA8083 Tricou:Hurricane IsaacC8PPRA8088 Delta:Hurricane IsaacE2PPISAACN ENOI Hurr. Isaac Business ContinuitE2PPISCAUN Isaac Storm Cost Audit - ENOIE2PPISCENO ENOI-FACILITIES ISAAC RESTORATIONE2PPISCLEN Isaac Storm Legal Costs - ENOIE2PPSJ4087 HURRICANE ISAAC T-Grid ENOI 8.28.12E2PPSJ4EG4 Storm GAS O&M ENOI H.Isaac 8/27/12E2PPWJ0120 ENOI Storm Costs - 2012


Page 1 of 1

BEFORE THE


APPLICATION OF ENTERGY NEW ORLEANS, INC. FOR CERTIFICATIONS OF COSTS RELATED TO HURRICANE ISAAC, AND FOR RELATED RELIEF

) ) ) ) )


EXHIBIT OT-3

VOLUMINOUS

PROVIDED IN SEPARATE EXCEL FILE

February 2014

Previous Testimony of Orlando ToddTYPE OF TESTIMONY JURISDICTION CLIENT DOCKET Filing Date

Direct Testimony CNO ENO UD-08-03 7/31/2008Direct Testimony CNO ENO UD-08-03 9/15/2008Deposition CNO ENO UD-08-03 10/22/2008Direct Testimony CNO ENO UD-11-03 7/8/2011Direct Testimony CNO ENO UD-08-03 1/31/2013Rebuttal Testimony CNO ENO UD-08-03 6/7/2013


Page 1 of 1

Carrying Costs for 2013 2,549,475.56 Carrying Costs for 2014 2,786,638.06 Carrying Costs for 2015 (as of June 2015) 1,482,394.29



For Period: January 2013 - June 2015Summary of Carrying Costs


Page 1 of 4

WACC annual rate 8.320% *



















Page 2 of 4




















Page 3 of 4


















Calculation of Carrying CostsFor Period: January 2015 - June 2015


Page 4 of 4

BEFORE THE



) ) ) ) )


DIRECT TESTIMONY

OF

MICHAEL A. HERMAN

ON BEHALF OF


February 2014

Entergy New Orleans, Inc. Direct Testimony of Michael A. Herman CNO Docket No. UD-14-_____

i

TABLE OF CONTENTS I. INTRODUCTION ................................................................................................................. 1

II. PURPOSE OF TESTIMONY ............................................................................................... 3

III. EXPLANATION OF AN ATTESTATION EXAMINATION ............................................ 5

IV. SUMMARY OF THE SCOPE OF OUR ATTESTATION PROCEDURES .................... 11

V. TRANSACTION TESTING ............................................................................................... 17

VI. RESULTS OF TESTING .................................................................................................... 25

VII. CONCLUSION .................................................................................................................... 26

EXHIBIT LIST

Exhibit MAH-1 Report of Independent Accountants Concerning Entergy New Orleans, Inc.’s Summary of Hurricane Costs


1

1

I. INTRODUCTION 2

Q1. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS 3

A. My name is Michael A. Herman. My office is located at One North Wacker Drive, 4

Chicago, Illinois 60606. 5

6

Q2. BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY? 7

A. I am a partner in PricewaterhouseCoopers LLP (“PwC”), which is an international 8

firm of independent public accountants. I am currently the Assurance Services 9

Leader of our U.S. Power & Utility practice and am a member of our U.S. Power & 10

Utility Practice Leadership Team. 11

12

Q3. ON WHOSE BEHALF ARE YOU TESTIFYING IN THIS DOCKET? 13

A. I am testifying on behalf of Entergy New Orleans, Inc, which I refer to in this 14

testimony as ENO, or the Company. 15

16

Q4. PLEASE PROVIDE YOUR BACKGROUND AND EXPERIENCE IN THE 17

PUBLIC UTILITY INDUSTRY. 18

A. I have spent 27 years as an auditor with PwC, the last sixteen as a partner. For nearly 19

that entire time, I have participated in or led the financial statement audits of a number 20

of our Firm’s electric utility clients, including clients such as Exelon Corporation, 21

CMS Energy, FirstEnergy, The Tennessee Valley Authority, Puget Sound Energy, 22

Associated Electric Cooperative, Inc., and CLECO Corporation. During the time 23

period from 1994 through 1999, I first served as our senior audit manager and 24


2

subsequently a partner on our financial statement audits of Entergy and its 1

subsidiaries. 2

3

Q5. HAVE YOU TESTIFIED PREVIOULY BEFORE A REGULATORY 4

AUTHORITY? 5

A. Yes. I have previously testified before several regulatory agencies including 6

providing testimony in Louisiana and Texas in relation to attestation procedures 7

performed by PricewaterhouseCoopers LLP on the Summaries of Hurricane Costs for 8

Hurricanes Katrina and Rita, Gustav and Ike. I have also filed testimony in U.S. 9

Federal Bankruptcy Court, and have led PwC engagements to provide required audit 10

services and Expert Reports on Affiliate Costs for previous ENO, Entergy Louisiana, 11

LLC, (“ELL”), Entergy Gulf States Louisiana, LLC (“EGSL”), and Entergy Texas 12

rate case filings. 13

14

Q6. ARE YOU A CERTIFIED PUBLIC ACCOUNTANT? 15

A. Yes. I am a certified public accountant licensed in several states including Louisiana 16

and Illinois 17

18

Q7. WHAT IS YOUR EDUCATIONAL BACKGROUND? 19

A. I hold a Bachelors of Science in Management with emphasis in Economics and 20

Accounting from Tulane University, which I received in 1986. 21

22


3

II. PURPOSE OF TESTIMONY 1

Q8. WHAT SERVICE WAS PwC ENGAGED TO PERFORM? 2

A. Entergy Services, Inc. (“ESI”) engaged PwC to perform Attestation Examinations on 3

the Reports on Incurred Costs related to Hurricane Isaac (“Summary of Hurricane 4

Costs”) for ENO. A Copy of the Summary of Hurricane Costs applicable specifically 5

to ENO is attached as my Exhibit MAH-1. The purpose of PwC’s examination of 6

each Summary of Hurricane Costs was to assess whether, in our opinion, 7

Management’s assertion that the Summary of Hurricane Costs is a complete and 8

accurate presentation of valid storm costs based on the criteria set forth in 9

Management’s assertion is fairly stated in all material respects. The result of our 10

Attestation Examinations is our Report of Independent Accountants, which is 11

included as page 1 of the Summary of Hurricane Costs attached as Exhibit MAH-1. 12

13

Q9. WHAT IS THE PURPOSE OF YOUR TESTIMONY? 14

A. The purpose of this testimony is to: 15

1. explain the purpose of an Attestation Examination; 16

2. describe the Professional Standards that govern CPAs in the performance 17

of Attestation Examinations; 18

3. provide a general description of the scope of the procedures performed to 19

support our Reports; and 20

4. provide a general summary of the results of our procedures. 21

22

Q10. PLEASE DESCRIBE THE SUMMARY OF HURRICANE COSTS. 23

A. Summaries of Hurricane Costs were prepared for several of the Entergy Operating 24

Companies – including ENO. The Report states the costs incurred through January 25


4

31, 2013 by each Operating Company as a result of Hurricane Isaac. Because the 1

hurricane affected multiple Operating Companies, and because ESI provides 2

centralized corporate support services to the Operating Companies, ESI managed and 3

coordinated the preparation of the Summary of Hurricane Costs for the affiliated 4

Operating Companies. 5

Because the filing in this docket applies only to ENO’s costs, the remainder of 6

my testimony will focus primarily on ENO's Summary of Hurricane Costs, which is 7

attached as my Exhibit MAH-1. 8

The Summary of Hurricane Costs is a summary report that includes both data 9

and narrative information to describe the Companies' efforts and expenses incurred to 10

restore its hurricane-damaged facilities to operating condition as soon as possible after 11

Hurricane Isaac. ENO's Management, in conjunction with ESI (hereafter “ENO 12

Management”), asserts on page 2 of their Summary of Hurricane Costs that the 13

Summary of Hurricane Costs is a complete and accurate presentation of valid storm 14

costs based on the criteria set forth in Management’s assertion. 15

16

Q11. WHAT WAS THE SCOPE OF PWC’S ATTESTATION PROCEDURES? 17

A. The overall purpose of PwC’s procedures was to express an opinion on (or attest to) 18

Management’s assertion that the Summary of Hurricane Costs for ENO is a complete 19

and accurate presentation of valid storm costs based on the criteria set forth in 20

Management’s assertion. In general terms, PwC used a three-step approach to form 21

this opinion. First, we considered, and in some instances tested, the accounting 22

processes, systems, and internal controls used in processing the storm costs. This 23

consideration was not designed to form an opinion about the adequacy or quality of 24

the processes and controls, but rather to assess the degree of risk as to whether the 25


5

Companies’ processes and controls would detect an error or misstatement in the 1

information included in the Summary of Hurricane Costs.1 Second, after considering 2

this assessment of risk, we designed and executed a substantive testing plan of 3

individual transactions sufficient to provide adequate evidence supporting our opinion 4

on Management’s assertion that the Summary of Hurricane Costs is a complete and 5

accurate presentation of valid storm costs according to the descriptions included in the 6

notes to the Summary of Hurricane Costs. Finally, we considered the results of our 7

internal control and substantive testing and from that formed our conclusion. 8

9

III. EXPLANATION OF AN ATTESTATION EXAMINATION 10

Q12. WHAT IS AN ATTESTATION EXAMINATION? 11

A. An Attestation Examination is an audit of non-financial statement information by an 12

Independent Accountant. The non-financial statement information in this case is the 13

written assertion by ENO (the client) that their Summary of Hurricane Costs is a 14

complete and accurate presentation of valid storm costs based on the criteria set forth 15

in Management’s assertion. While each Summary of Hurricane Costs includes 16

financial information about the costs attributable to Hurricane Isaac, it is not 17

considered to be a “financial statement” because it is not a complete presentation of 18

ENO’s financial position and results of operations as required by generally accepted 19

accounting principles. 20

The American Institute of Certified Public Accountants (“AICPA”) has 21

promulgated attestation standards that govern the provision of attestation services. 22

These standards provide guidance and establish a broad framework for the provision 23

1 As I discuss later in my testimony, we concluded that ENO's processes and internal controls did mitigate the risk that the Company would fail to detect an error.


6

of attest services. They are designed to provide professional guidelines that enhance 1

both consistency and quality in the performance of such services. The main objective 2

of the attestation standards is to provide a general framework for and set reasonable 3

boundaries around the attest service. The attestation standards deal with the need for 4

technical competence, independence in mental attitude, due professional care, 5

adequate planning and supervision, sufficient evidence, and appropriate reporting. 6

While there are several levels of assurance available under the attestation standards, 7

our engagement was an “attestation examination,” which is roughly analogous in 8

scope to an audit of financial statements. 9

10

Q13. WHAT ARE THE RELEVANT STANDARDS FOR PERFORMANCE FOR THE 11

ATTESTATION EXAMINATION PwC PERFORMED ON THE SUMMARY OF 12

HURRICANE COSTS? 13

A. Professional Standards for the performance of Attestation Services are specified in the 14

AICPA Professional Standards for Attestation Services, commonly referred to in the 15

public accounting industry as the AT standards. Specifically, AT 101 “applies to 16

engagements in which a certified public accountant in the practice of public 17

accounting is engaged to issue or does issue an examination, a review, or an agreed-18

upon procedures report on subject matter, or an assertion about the subject matter, that 19

is the responsibility of another party.” 20

21

Q14. ARE THERE ANY INDEPENDENCE REQUIREMENTS WITH RESPECT TO AN 22

ATTESTATION EXAMINATION? 23

A. Yes. As described in the attestation standards at AT 101 paragraphs .35 to .38: 24


7

The fourth general standard is "In all matters relating to the engagement, an 1

independence in mental attitude shall be maintained by the practitioner. The 2

practitioner should maintain the intellectual honesty and impartiality necessary 3

to reach an unbiased conclusion about the subject matter or the assertion. This 4

is a cornerstone of the attest function. In the final analysis, independence in 5

mental attitude means objective consideration of facts, unbiased judgments, 6

and honest neutrality on the part of the practitioner in forming and expressing 7

conclusions. It implies not the attitude of an advocate or an adversary but an 8

impartiality that recognizes an obligation for fairness. Independence in mental 9

attitude presumes an undeviating concern for an unbiased conclusion about the 10

subject matter or an assertion no matter what the subject matter or the 11

assertion may be. The profession has established, through the AICPA's Code 12

of Professional Conduct, precepts to guard against the presumption of loss of 13

independence. Presumption is stressed because the possession of intrinsic 14

independence is a matter of personal quality rather than of rules that formulate 15

certain objective tests. Insofar as these precepts have been incorporated in the 16

profession's code, they have the force of professional law for the independent 17

practitioner.” [Emphasis in original.] 18

19

Q15. AS IT RELATES TO ENO, HAVE YOU AND PwC COMPLIED WITH THE 20

INDEPENDENCE STANDARDS SPECIFIED IN THE AICPA CODE OF 21

PROFESSIONAL CONDUCT? 22

A. Yes. PwC and I are independent from Entergy Corporation and its subsidiaries, 23

including ENO, as defined by the AICPA. 24

25


8

Q16. WHICH LEVEL OF ATTESTATION SERVICE DID PwC PROVIDE TO ENO: AN 1

EXAMINATION, A REVIEW, OR AGREED-UPON PROCEDURES? 2

A. We performed an Attestation Examination. In AT Standard 101, paragraph 54, an 3

Attestation Examination is referred to as providing a “high level of assurance,” while 4

the level of assurance referenced for a review engagement is considered “moderate.” 5

The scope of an Attestation Examination is intended to provide a conclusion by the 6

Independent Accountant as to whether each Company’s assertion is materially 7

correct. Conversely, the scope of a review engagement is designed to provide a 8

“negative” assurance: that is, that nothing came to the auditors’ attention that caused 9

them to believe that the Companies' assertion was not materially correct. 10

11

Q17. WHAT IS THE ASSERTION ON WHICH YOU PERFORMED YOUR 12

ATTESTATION ENGAGEMENT? 13

A. As described in the Report of Management’s Assertion included in the Summary of 14

Hurricane Costs, we attested to the following Company assertion: 15

Management of Entergy New Orleans, Inc. has prepared the 16

accompanying Summary of Hurricane Costs through January 31, 17

2013. Management asserts that the Summary of Hurricane Costs is 18

a complete and accurate presentation of valid storm costs according 19

to the criteria set forth below. 20

For the purposes of this assertion, management has defined valid 21

storm costs as those costs that are directly related to Hurricane 22

Isaac (the “Storm”), were incurred through January 31, 2013, and 23

are supported by appropriate documentation as required by the 24

Company’s policies and procedures at August 25, 2012. Costs 25


9

directly attributable to the Storm include costs which were incurred 1

to repair or replace the Company’s electric generation, 2

transmission and distribution system and supporting operations, or 3

the incurrence of liabilities that would not otherwise have been 4

incurred, as further described in the Notes to the Summary of 5

Hurricane Costs. 6

7

For the purposes of this assertion, management has defined the 8

complete and accurate presentation of valid storm costs in the 9

Summary of Hurricane Costs as inclusion of all known costs 10

incurred through January 31, 2013 and appropriately charged to a 11

valid storm project code pursuant to the Company’s policies and 12

procedures at August 25, 2012, as further described in the Notes to 13

the Summary of Hurricane Costs. 14

15

Q18. WHAT IS THE SIGNIFICANCE OF ENO’s REFERENCE IN THE ASSERTION 16

THAT “THE SUMMARY OF HURRICANE COSTS IS A COMPLETE AND 17

ACCURATE PRESENTATION OF VALID STORM COSTS ACCORDING TO 18

THE CRITERIA SET FORTH BELOW”? 19

A. While the term “storm costs” (or “storm recovery costs”) may be commonly used in 20

regulatory proceedings and other venues, I am not aware of any specific generally 21

accepted financial accounting definition of what types of costs are or are not “storm 22

costs.” Therefore, ENO has provided detailed descriptions of the types of costs that it 23

considers to be storm costs for the purposes of preparing its Summary of Hurricane 24

Costs. Those descriptions, included in the notes to the Summary of Hurricane Costs, 25


10

are known as criteria in the AT Standards and provide the basis against which we 1

audit. 2

The AT Standards specify that “Suitable criteria must have each of the 3

following attributes: 4

• Objectivity - Criteria should be free from bias. 5

• Measurability - Criteria should permit reasonably consistent 6

measurements, qualitative or quantitative, of subject matter. 7

• Completeness - Criteria should be sufficiently complete so that those 8

relevant factors that would alter a conclusion about subject matter are not 9

omitted. 10

• Relevance - Criteria should be relevant to the subject matter.” 11

The AT Standards presume that criteria that are established or developed by groups 12

composed of experts, who follow due process procedures, including exposure of the 13

proposed criteria for public comment, ordinarily should be considered suitable. 14

However, the standards also specifically provide that criteria may be established or 15

developed by a client without the benefit of publicly debated due process procedures. 16

When that is the case, the auditor must determine whether the criteria are suitable by 17

evaluating them based on the four attributes described above. Additionally, as 18

discussed in AT Standard 101.28, the determination that criteria are suitable does not 19

presume that all persons or groups would be expected to select the same criteria in 20

evaluating the same subject matter; therefore, there may be more than one set of 21

suitable criteria for a given subject matter. 22

As I discuss in more detail below, PwC has concluded that ENO’s criteria for 23

defining storm costs as set forth in management’s assertion, as further described in the 24


11

Notes to the Summary of Hurricane Costs, are suitably objective, measurable, 1

complete, and relevant. 2

3

Q19. WERE THERE ANY DIFFERENCES IN MANAGEMENT'S ASSERTION 4

BETWEEN THE SPECIFIC COMPANIES? 5

A. There were no differences in the substance of Management's assertion for ENO. 6

7

IV. SUMMARY OF THE SCOPE OF OUR ATTESTATION PROCEDURES 8

Q20. PLEASE SUMMARIZE IN GENERAL TERMS THE SCOPE OF YOUR 9

ATTESTATION EXAMINATION. 10

A. PwC’s engagement can generally be described as being divided into three phases: (i) 11

engagement planning, including the assessment of control risk; (ii) substantive testing 12

of detailed storm damage costs; and (iii) consideration of testing results and reporting. 13

14

Q21. PLEASE DESCRIBE THE ENGAGEMENT PLANNING/ASSESSMENT OF 15

CONTROL RISK PHASE OF THE ATTESTATION EXAMINATION. 16

A. The overall objective of PwC’s engagement was to perform procedures sufficient to 17

evaluate whether Management’s assertion that ENO’s Summary of Hurricane Costs is 18

a complete and accurate presentation of valid storm costs based on the criteria set 19

forth in Management’s assertion was fairly stated in all material respects. I was in 20

charge of the PwC team that undertook this engagement. To plan the necessary 21

procedures, my team and I first needed to understand how the Companies had 22

recorded and then accumulated all of the many transactions summarized in their 23

Summary of Hurricane Costs. Accordingly, our first steps in the engagement were to 24

determine the types of costs the Companies were reporting as storm costs, and then 25


12

update our understanding of the systems, processes, and procedures used to record 1

those transactions. As we had previously performed the attestation work in relation to 2

the storm costs associated with Hurricanes Katrina, Rita, Gustav and Ike we had 3

accumulated significant relevant information on the Companies' systems, processes, 4

procedures and methodology for accounting for the storm costs; we were able to use 5

this historical knowledge as a basis to begin our planning process and design testing 6

procedures. 7

Taking payroll charges for the Companies’ employees as an example, in order 8

to determine the type and extent of testing necessary for those transactions, we first 9

needed to confirm our understanding as to how each Company recorded the costs of 10

the transactions in order to assess the risk that the costs may have been recorded or 11

reported incorrectly. To make this assessment, we confirmed our understanding of 12

the process ESI uses to record and monitor payroll costs on behalf of ENO, including 13

an understanding of the computer systems utilized for payroll accounting. The 14

procedures and systems for accounting for these costs were not changed from the 15

Companies’ normal transaction processing methods. We confirmed our 16

understanding for all of the significant processes supporting the Company’s Summary 17

of Hurricane Costs, including ESI’s payroll, accounts payable, storm invoice 18

processing, inventory, Service Company Allocations and general ledger systems. 19

20

Q22. HAD THE INTERNAL CONTROLS OVER THESE SYSTEMS PREVIOUSLY 21

BEEN REVIEWED OR AUDITED BY OTHERS? 22

A. Yes. The controls over these processes had previously been documented and tested 23

by the Company’s management as part of its 2012 Sarbanes-Oxley Section 404 24

(“SarbOx 404”) assessment. SarbOx 404 requires management of all SEC-registered 25


13

companies to assert that their internal controls over financial reporting are effective in 1

providing reasonable assurance over the reliability of their financial statements. 2

SarbOx 404 also requires each Company’s registered public accounting firm to audit 3

this assertion. Entergy, in its 2012 Form 10-K asserted that, at the corporate level as 4

well as for each of its SEC-registered subsidiaries, including ENO, internal controls 5

over financial reporting were effective. Entergy’s (and ENO’s) independent auditor 6

agreed with those assertions. Pursuant to widely accepted protocols describing how 7

Management must support their assertions, as well as Public Company Accounting 8

Oversight Board auditing standards for auditors, this assertion and audit opinion are 9

generally supported by significant documentation and testing, both by Management 10

and the auditor. My team and I reviewed Management work papers, files, and other 11

documents that support the Company’s internal control assessment for all of the 12

processes and systems that were relevant to the Summary of Hurricane Costs. 13

14

Q23. DID YOU INDEPENDENTLY DETERMINE IF THE COMPANY ADHERED TO 15

ITS DOCUMENTED PROCESSES DURING THE ACCOUNTING FOR STORM 16

COSTS? 17

A. Yes. In addition to reviewing the Companies' documentation, we also performed 18

independent “walkthroughs” to verify that the processes functioned as described. A 19

walkthrough is an auditing procedure in which the auditor traces a single transaction 20

through the Company’s entire process from inception (e.g., the initial payroll time 21

entry) to completion (posting of the payroll cost to the general ledger). We performed 22

this process (review of documentation to understand the process and systems, and 23

performance of a walkthrough to confirm the documentation) for ESI’s payroll, 24


14

accounts payable, storm invoice processing, inventory, employee expenses, and 1

general ledger systems. 2

3

Q24. DID YOU PERFORM ANY OTHER TESTS TO DETERMINE IF INTERNAL 4

CONTROLS WERE FUNCTIONING AS DESIGNED? 5

A. Yes. We evaluated the results of the Company’s controls testing, evaluated the 6

adequacy of its control test procedures, and performed our own testing of certain 7

controls that we determined were more critical to the Company’s storm cost 8

accounting processes. Our testing did not reveal instances of internal control failures. 9

To provide some perspective on the scope of internal controls testing, we selected 5 10

controls from the storm costs accounting process and tested multiple instances of each 11

control functioning during the period that storm costs were being incurred and 12

processed. Our testing of controls covered the period September 1, 2012 through 13

December 31, 2012, and covered transaction related to ENO’s jurisdiction 14

specifically. 15

16

Q25. DID YOU CONSIDER THE GENERAL COMPUTER CONTROLS OF THE ENO 17

SYSTEMS USED TO PROCESS AND STORE THE RELEVANT 18

TRANSACTIONS? 19

A. Yes. General Computer controls, sometime known as ITGCs (Information 20

Technology General Controls), are used to manage and control a Company’s 21

information technology activities. The controls are designed to provide integrity to 22

the information processing activities and the automated internal control and 23

accounting procedures of the Company (i.e., calculations and automatic posting of 24

transactions). We confirmed our understanding of the ITGCs over the relevant 25


15

applications and configurable controls for the significant processes that impacted the 1

reporting of storm costs. These processes include payroll, accounts payable, 2

inventory, ESI Billings, and general ledger maintenance. Our procedures primarily 3

consisted of reviewing the Company’s documentation of these controls, as well as the 4

scope and results of its testing from its SarbOx 404 process. The types of ITGCs that 5

we were most concerned with were those restricting the ability to gain access or 6

change program functionality or data. Substantive detail testing was performed at 7

high level to mitigate the low level of controls comfort. 8

9

Q26. IN ADDITION TO THE PREVIOUSLY EXISTING INTERNAL CONTROLS 10

OVER THE PROCESSING OF TRANSACTIONS, DID THE COMPANY 11

IMPLEMENT ANY SUPPLEMENTAL PROCESSES OR CONTROLS OVER 12

STORM COST TRANSACTIONS? 13

A. Yes. As described by Company witness Orlando Todd, Jurisdictional Finance 14

Director for Entergy New Orleans, Inc., due to the significance of the storm costs, the 15

Company formed several teams to review and internally audit the storm-specific 16

invoices. Part of the PwC procedures involved testing this internal storm cost review 17

process. As part of the procedures we performed for our attestation work related to 18

Hurricane Isaac, we documented and tested, on a sample basis, certain key controls 19

within the internal storm-cost review process. As part of our procedures for this 20

attestation engagement, we performed walkthroughs with the designated personnel 21

responsible for processing invoices and conducted independent testing of the controls 22

within the storm cost review process, including controls that were added or modified 23

since our last attestation engagement. As discussed in Orlando Todd’s testimony, 24

Entergy's storm-cost review process requires each invoice received from third-party 25


16

contractors to be audited prior to payment. This process was based on the control 1

procedures developed to process invoices for the recovery costs of Hurricanes Katrina 2

and Rita, and Gustav and Ike; however, it has been refined to improve the efficiency 3

and timeliness of the process. This refined process utilizes a more targeted approach 4

and also utilizes sampling in the audit of the line items within an invoice. Entergy has 5

also established a materiality threshold for the investigation of discrepancies arising 6

from the audit process. This threshold is as follows - billing discrepancies exceeding 7

the lesser of $500 or 1% of the original invoice amount are investigated with the 8

respective vendor. This threshold appears reasonable and has been set at such a level 9

to obtain reasonable assurance that material billing discrepancies should be 10

investigated and resolved prior to payment of the invoice. 11

12

Q27. IS THE RESULT OF YOUR INTERNAL CONTROLS TESTING THE 13

EXPRESSION OF AN OPINION THAT THE COMPANY’S INTERNAL 14

CONTROLS ARE EFFECTIVE? 15

A. No. PwC offers no opinion either way. As described above, the purpose of our 16

internal controls testing for the Attestation Examination was to help us assess the risk 17

that the Company’s internal controls might not detect an error in its accounting. This 18

risk assessment was then considered when we planned the design, timing, and extent 19

of our substantive transaction testing, which I discuss later in my testimony. 20

Therefore, the scope of our control testing was not designed to form an independent 21

conclusion about the Company’s internal controls, and accordingly we are not in a 22

position to form such a conclusion. 23

24


17

V. TRANSACTION TESTING 1

Q28. HOW DID YOU DESIGN YOUR SUBSTANTIVE TRANSACTION TESTING 2

APPROACH? 3

A. As discussed previously, the purpose of our engagement was to determine whether the 4

reported storm costs, as reflected in ENO’s Summary of Hurricane Costs, are fairly 5

stated in all material respects. Our process of auditing ENO Management’s assertion 6

required us to accumulate enough audit evidence to support our conclusion that the 7

Summary of Hurricane Costs was fairly stated in all material respects. While the 8

evidence we obtained about ENO’s internal controls provided a valuable foundation 9

on which to build our audit support, significantly more audit evidence was needed to 10

support a conclusion regarding ENO Management’s assertion. Therefore, we needed 11

to design a substantive testing plan to build upon the control testing with the goal of 12

eventually gathering the level of evidence we needed to develop our conclusion and 13

written opinion. 14

15

Q29. WHAT IS MEANT BY THE TERM “SUBSTANTIVE TESTING”? 16

A. Substantive testing refers to the auditing or testing of individual transactions or 17

account balances to confirm that they are accurate. Examples of substantive tests 18

include the review of internal supporting documentation such as approved time sheets, 19

expense reports, and management analyses, as well as reviewing externally created 20

evidence, such as vendor invoices or third-party confirmation sent directly to the 21

auditor. 22

23


18

Q30. HOW DID YOU DETERMINE YOUR SUBSTANTIVE TESTING PLAN? 1

A. In addition to considering our assessment of the reliability of internal controls, we 2

also had to consider the dollar value and transaction volumes of various types of 3

transactions included in each Summary of Hurricane Costs, as well as gain an 4

understanding of the sources of data supporting the Report. All transactions recorded 5

in the Companies' accounting systems are assigned a code-block that provides details 6

about the transaction being recorded. Some important elements of ENO’s code-block 7

for the purposes of this project are: 8

Business Unit - designates a regulated or unregulated company belonging to 9

the Entergy System. This is also used to identify the company that is 10

responsible for the performance of a transaction. 11

Department – designates who provides the service and who will budget, 12

record, and report costs. 13

Resource – defined as items used or consumed in the conduct of work 14

activities. Essentially, the resource is used to track types and amounts of items 15

consumed. For example, some of the different Resource codes are for: 16

contract work, payroll, payroll taxes, and employee benefits. 17

Project Code – the collection of tasks that usually have a start and stop date. 18

Projects are generally set up for the following purposes: billing inter-company 19

services provided, capturing storm damage costs, capturing costs specific to 20

major regulatory rate proceedings, cost tracking, budgets for planned capital 21

additions and projects, and capturing the authorized capital expenditures. 22

ENO populated the individual line items of their Summary of Hurricane Costs by 23

generating queries from their general ledger (also known as the Peoplesoft Enterprise 24

Data Warehouse), which summarized all transactions that had specific combinations 25


19

of code-block elements for specified periods of time. For example, the Summary of 1

Hurricane Costs line item titled “Storm Costs – Third Party Costs” was populated 2

with all transactions with Resource Code CTC within the applicable Project Codes 3

recorded in the period August 31, 2012 through January 31, 2013. CTC is the 4

summary resource code for contract work; it designates that the specific transaction 5

incurred by ENO is for services performed by third-party contractors. When the CTC 6

charges are found in combination with defined storm project codes, the cost was 7

included in the Summary of Hurricane Costs as a “Third-Party Cost.” Each of these 8

queries provided a detail of every transaction supporting the amount stated in the 9

Summary of Hurricane Costs. Therefore, these queries provided us with both 10

important information about the number and materiality of transactions supporting 11

each line item, as well as a population of the transactions, which we could then test. 12

13

Q31. DID YOU WAIT TO BEGIN YOUR ASSESSMENT AND TESTING UNTIL YOU 14

HAD ALL DATA THROUGH JANUARY 31, 2013? 15

A. No. We initially began working with data for the period August 31, 2012 through 16

November 30, 2012; however, this data was eventually augmented by the combined 17

transactions for the months of December 2012 and January 2013. This detail 18

transaction data, such as number of transactions and dollar amount supporting each 19

line item combined with our assessment of control risk, provided us with the context 20

we needed to design detailed substantive transaction testing plans. Materiality was 21

assessed for cumulatively for the two periods noted above for ENO. 22

23


20

Q32. PLEASE PROVIDE A MORE DETAILED EXAMPLE OF YOUR SUBSTANTIVE 1

TESTING PLANNING PROCESS. 2

A. The methodology used in designing and executing our substantive testing plan is 3

consistent with that employed in the execution of our attestation work for Hurricanes 4

Katrina and Rita, and Gustav and Ike. The design of our testing plan for the line item 5

transaction titled “Storm Costs – Third Party Costs” provides a typical example of our 6

planning process and resulting substantive testing plan. We had previously assessed 7

the internal controls over the Companies' purchase and payables and supplemental 8

storm invoice accounting process. My conclusion was that these controls were 9

effective at reducing the risk of an error in these areas. We determined that, through 10

January 31, 2013, there were 1,126 third-party vendor transactions totalling 11

$35,274,014 of Storm Costs – Third Party Costs, for ENO. We then considered 12

whether we could apply targeted testing to the populations. Targeted testing allows 13

the auditor to exercise judgment over what items should be tested and involves 14

selecting items to test based on some characteristic (typically monetary value or 15

higher risk), rather than selecting them "randomly" using audit sampling. We 16

reviewed the populations of Storm Costs – Third Party Costs to determine whether 17

there were individually significant transactions in these populations. Based on our 18

judgment, we considered individual transactions greater than $504,000, for ENO, to 19

be significant transactions for the purposes of this substantive test of detail. We 20

determined these thresholds based on the dollar coverage this would provide and the 21

number of items that would require testing. A higher threshold would not have 22

provided a level of coverage to make the test efficient, and a lower threshold would 23

have increased the sample size of the test considerably without substantially 24

increasing the coverage, and therefore the assurance level, by a commensurate 25


21

amount. We identified and tested 18 individually significant transactions that totalled 1

$21,318,288, for ENO. As the untested portion of the populations after testing 2

individually significant transactions was still considered material, we utilized non-3

statistical sampling on the remaining populations of Storm Costs – Third Party Costs 4

to achieve our required level of assurance over the populations. 5

6

Q33. WHAT DO YOU MEAN BY THE TERM “NON-STATISTICAL AUDIT 7

SAMPLING”? 8

A. Audit sampling, as defined by AICPA Auditing Standards (AU 350), is the 9

application of auditing procedures to a representative group of less than 100% of the 10

items within a class of transactions for the purpose of evaluating some characteristic 11

of the entire class or population tested. A "population" does not need to be an entire 12

class of transactions. For example, a class of transactions may be divided into two 13

populations, with high-dollar testing applied to one population, and audit sampling 14

applied to the other. 15

AU 350 recognizes both non-statistical and statistical audit sampling. The 16

primary advantages of statistical audit sampling are a statistically derived sample size 17

and a statistically determined evaluation of sampling risk. However, the advantages 18

of statistical sampling do not outweigh the primary disadvantages, which include the 19

complexity of its application and the use of formal techniques to determine sample 20

size, to select the sample, and to evaluate the results. Therefore, PwC’s audit 21

approach has concluded that a properly executed application of non-statistical audit 22

sampling will generally be the preferable approach. 23

The underlying principles, procedures, and matters relevant to the planning 24

and performance of audit sampling are similar for both non-statistical and statistical 25


22

methods. Thus, while the procedures and methods used in non-statistical sampling 1

are less formal, they are nonetheless rigorous. Ordinarily, the application of non-2

statistical sampling will result in a sample size comparable to the sample size 3

resulting from an efficient and effectively designed statistical sample considering the 4

same sampling parameters (AU 350.23). Additionally, audit sampling guidance used 5

in this engagement, while directed to non-statistical sampling applications, is 6

grounded in statistical theory and is designed to provide the necessary information to 7

determine appropriate sample sizes and selection techniques, and to properly project 8

and evaluate results from non-statistical audit sampling. 9

10

Q34. HOW DID YOU DETERMINE THE SAMPLE SIZES USED IN YOUR NON-11

STATISTICAL AUDIT SAMPLING, AND HOW DID YOU SELECT THE 12

INDIVIDUAL ITEMS IN YOUR SAMPLE? 13

A. To determine the appropriate sample sizes, we utilized a PwC-developed audit tool 14

designed to assist in determining required sample sizes. The primary variables and 15

judgments necessary to arrive at the sample sizes are discussed below: 16

Tolerable misstatement – the largest amount of misstatement we can 17

tolerate in an account or population and still conclude that we have 18

obtained sufficient assurance that the account or population does not 19

contain a material misstatement. 20

Estimated misstatement - Estimated misstatement is our estimate of the 21

population misstatement (made before performing audit sampling 22

procedures). 23

Required level of assurance - In the context of audit sampling, the level 24

of assurance required and the resulting sample size is inversely related to 25


23

the amount of sampling risk we can accept. The greater the required 1

assurance, the larger the sample size, and the lower the sampling risk. 2

For this application of sampling, we assessed the required level of 3

assurance as high (as opposed to moderate or low) as a result of 4

assurance obtained through our assessment of risk, the results of our 5

internal controls testing, and, in some cases, the targeted testing of a 6

portion of the class of transactions being tested. 7

Considering all of these variables and assumptions, we concluded that, for the 8

population of Storm Costs – Third-Party Costs incurred through January 31, 2013 of 9

1,126 third-party vendor transactions (excluding those individually significant 10

transactions that were tested separately) totalling $3,940,732 samples of 122 11

transactions were appropriate, for ENO. We utilized a random sample selection 12

methodology to select our individual transactions, which provided assurance that any 13

transaction in the population was as likely to have been selected in our sample as any 14

other and eliminated the potential for bias in selecting the sample. 15

16

Q35. HOW DID YOU TEST THE TRANSACTIONS SELECTED AS INIDIVIDUALLY 17

SIGNIFICANT ITEMS AND THOSE SELECTED THROUGH THE 18

APPLICATION OF NON-STATISTICAL SAMPLING? 19

A. Using the Storm Costs – Third Party Costs as an example, we obtained source 20

documents supporting the 122 transactions (the total tested for the period through 21

January 31, 2013), for ENO, from ESI accounting personnel. We then tested to 22

determine that each selected transaction met the definition of storm cost as defined in 23

the criteria included in the notes to the Summary of Hurricane Costs. For example, 24

when testing the Storm Costs – Third Party Costs, we tested to determine whether: 25


24

the respective invoice package had proper code-block approvals, supporting 1

documents (e.g., invoices, purchase orders), was set up in accordance with 2

contract specifications, and was properly authorized. During this review of 3

paid voucher files, we reviewed for invoices that were not regularly printed 4

vendor invoices on vendor letterhead or that were handwritten invoices. If 5

these types of invoices were discovered, we verified that the vendors were 6

legitimate business concerns and that an employee-vendor relationship did not 7

exist. We also verified that the invoice was not a duplicate; 8

the invoice amount (rate multiplied by hours) was properly calculated in 9

accordance with contractual terms and supported by authorized time sheets; 10

the costs were properly charged to the correct project code (e.g., reporting 11

jurisdiction, storm recovery cost vs. business continuity cost, and functional 12

split). This was achieved by reviewing the code-block, confirming where the 13

service was provided, and validating the nature of the work performed as 14

described in the invoice; and 15

the timing of the period of performance was reasonable given the nature of the 16

charges. 17

18

We performed similar sample selection and auditing procedures for each type of 19

storm cost deemed significant and that were included in the Summary of Hurricane 20

Costs. To provide a context to the scope of our substantive testing, for ENO, out of a 21

total of more than 25,238 transactions processed through January 31, 2013, we tested 22

a total of 22 individual transactions that were considered individually significant 23

(totaling $22,292,375), and 217 transactions on a non-statistical audit sampling basis, 24

including the Storm Costs – Third-Party Costs. 25


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1

VI. RESULTS OF TESTING 2

Q36. WHAT WHERE THE RESULTS OF YOUR TESTING? 3

A. In general, we found only a small number of minor exceptions as a result of our 4

testing. 5

6

Q37. HOW DO YOU EXTRAPOLATE THE RESULTS OF YOUR TESTING TO THE 7

GENERAL POPULATION OF TRANSACTIONS? 8

A. Exceptions noted through the execution of targeted testing procedures are not 9

extrapolated to the untested population of testing, as the transactions have been 10

selected on the basis of a certain characteristic and are not considered representative 11

of the general population. 12

As the purpose of non-statistical audit sampling is to draw inferences from the 13

sample to the population, we project the exception results of the sample to the 14

population from which the non-statistical sample was selected. This extrapolation 15

creates a statistically meaningful estimate of the errors in the population. For 16

instance, for ENO in our testing of Employee Expenses, we target tested a total of 3 17

transactions incurred in the period from for the period August 31, 2012 through 18

January 31, 2013 and noted zero exceptions. In testing the items selected through non-19

statistical sampling, for the same period, we noted four exceptions totalling $23,056. 20

We extrapolated the effect of this item to the sampling population to create a 21

meaningful estimate of the errors in the entire population, which totalled $29,954. 22

The extrapolated error identified through testing was deemed by ENO and PwC to be 23

immaterial to the total storm costs reported by ENO. Consequently, it did not alter 24


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our ultimate conclusion that ENO’s Summary of Hurricane Costs presents, in all 1

material respects, the storm costs of ENO. 2

While the Employee Expense Storm Cost category had the highest error rate 3

and dollar value of estimated errors of all categories of transactions, the extrapolation 4

of the errors was so low as to be immaterial. Accordingly, I would expect that the 5

error rates would be consistent between cost categories and that unless these error 6

rates were significantly higher, any extrapolated errors in other categories would, in 7

my opinion, also be immaterial. 8

9

VII. CONCLUSION 10

Q38. WHAT ARE YOUR CONCLUSIONS RELATIVE TO THESE TESTING 11

PROCEDURES FOR ENO’s STORM COSTS? 12

A. Based on the results of our testing procedures, our Report of Independent Accountants 13

for each of the Companies concludes that “in our opinion, Management’s assertion 14

referred to above is fairly stated, in all material respects, based on the criteria set forth 15

in Management’s assertion.” 16


A. Yes, at this time 18

Exhibit MAH-1 CNO Docket No. UD-14-__

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