Control Number : Item Number : 298. Addendum StartPage: 0

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Control Number : 37276

Item Number: 298


Project No. 37276










Regulatory Contact: Steven Beaty AEP Texas

Regulatory Consultant Phone: (512) 481-4550

Fax: (512) 481-4591


Table of Contents 1. Introduction

II. Critical Loads III. Communication Plan

IV. Curtailment priorities, procedures for shedding load, rotating black-outs, and planned interruptions

V. Priorities for Restoration of Service VI. Pandemic Plan Summary

VII. Wildfire Mitigation Efforts Plan VIII. Potentially Severe Weather Plan

IX. Inventory of Pre-arranged Supplies Plan X. Staffing Plan

XI. Hurricane Plan Summary XII. Conclusion


I. Introduction

In accordance with P.U.C. SUBST. R. 25.53(a), AEP Texas Central Company and AEP Texas North Company (collectively referred to as "AEP Texas"I or when singularly the "Company") file this comprehensive summary of its Emergency Operation Plan (the "Plan") and its Business Continuity Plan ("BCP"). The foundation of AEP Texas' Emergency Operations Plan is an AEP manual entitled Emergency Response Plan ("ERP" or the "Manual"). The purpose of the ERP manual is to establish procedures to assist in the restoration of electrical service to all AEP Texas assets, as well as those owned or jointly owned by Electric Transmission Texas (`ETT")2, in a systematic and efficient manner by utilizing all of the company's human and physical resources; and if necessary, by securing and utilizing outside resources.3

In addition to this comprehensive Manual, AEP Texas has specific detailed plans that are used for emergency service restoration within the various geographical areas it serves (referred to as "Division" plans). These Division-specific plans, in conjunction with the ERP, are reviewed regularly to ensure their appropriateness in managing emergency service restoration conditions. Together these plans constitute the AEP Texas Emergency Operation Plan and for the purposes of this general description will be referred to, not individually but in the aggregate, as the Plan.

The primary objective of the AEP Texas Plan is to establish an emergency operation organization that will efficiently utilize all available resources to resolve the emergency situation. Such a Plan allows AEP Texas to accomplish the rapid and orderly repair of electric facilities for the protection of public health and safety and the restoration of services to all end-use customers in the minimum time possible. The second objective of the Plan is to provide for the timely collection of accurate damage assessment reports for management, employees, and the general public. The reports include such information as the extent of any damage to the distribution and transmission systems and the progress being made in restoring service. The

' For purposes of this filing, AEP Texas encompasses collectively the shared transmission services of AEP TCC and AEP TNC and each of the respective companies' distribution divisions.

2 Please also see the Comprehensive Summary of ETT's Electric Service Operations Plan contemporaneously filed in this PUCT Project No. 34202.

ETT's and the AEP Texas companies' transmission assets are operated and managed by AEP Texas and AEP Transmission personnel within the AEP Service Corp.


information is further used in aid of establishing the necessary liaisons among the AEP Texas Incident Command Structure, state, local and federal agencies, and the media.

When a major emergency or disaster occurs, the first function of AEP Texas personnel will be to clear all known public hazards that pose an immediate danger to the public. The second function will be to conduct a detailed assessment of the damage to the affected AEP Texas systems so that the necessary resources can be procured and management can position crews appropriately for the efficient restoration of service. The third function will be to restore service to the most consumers in the shortest time while keeping in focus restoration of service to vital community services and installations (critical loads). Other institutions whose functions are essential to the health and welfare of the community are added to the list as deemed appropriate. The fourth function will be to restore service to all remaining users as quickly as possible.

On a continuous basis, the AEP Texas Companies prepare to safely protect its work force and meet the public's expectations to provide reliable electric service if a pandemic event were to occur. AEP Texas is taking appropriate and prudent actions to ensure reliability of service and safety of employees and the public. These actions are contained in the AEP Texas BCP, which is continually being assessed particularly in the areas of. the identification of health-related and preventative actions to be taken, areas where cross training may be needed and potential alternative resources, as well as appropriate communications.

It is AEP Texas' intent to ensure that both Companies are able to restore electrical service in a systematic and efficient manner, and maintain critical operations during a potential pandemic event. As new information becomes available, the AEP Texas BCP and Plan will continue to evolve.

II. Critical Loads

AEP Texas maintains a critical load/critical care data base within its Customer Information System (CIS) as qualifying end-use customers are presented to AEP Texas by the customers' retail electric provider (REP). Updates are ongoing whenever a new end-use customer critical care designation form is received by AEP Texas. AEP Texas encourages each end-use customer to work with their respective REP to ensure that AEP Texas has received the necessary information related to accounts they deem to be critical. AEP Texas maintains this information in accordance with P.U.C. SUBST R. 25.53(c)(1)(A), for which electric service is


considered crucial for the protection or maintenance of public safety and welfare. These critical loads include, but are not limited to: hospitals, nursing homes, assisted living facilities, hospice services, water pumping plants and stations, wastewater plants and lift stations, Red Cross shelters, physician's offices, communication centers/towers, Federal Aviation Administration (FAA) navigational facilities, city emergency operations centers, fire departments, and police/sheriff stations. The aforementioned critical loads are prioritized by using a system of categories based on criticality.

Customers with special in-house, life-sustaining equipment are also identified. AEP

Texas maintains a registry, within its CIS, of residential customers who have life-sustaining electrically operated medical equipment as required by P.U.C. SUBST R. 25.497. Each year, as these customer records are reviewed, AEP Texas takes the opportunity to train, or again familiarize its customer service personnel on the processes and procedures necessary to qualify, code, and communicate with critical accounts.

III. Communication Plan

AEP Texas designates, as part of the Incident Command System (ICS), the Public Information Officer organization (the PIO) to coordinate the release of information and publicity. The PIO has the primary responsibility for coordinating with the ICS team to receive timely status reports and information needed for the news media and customers. The PIO's other duties in emergency situations include: distributing emergency advertising and public information to all ICS structure participants and contacting media to establish communication lines. AEP Texas utilizes radio as its primary communication tool to provide continual updates and emergency announcements to customers and also keeps newspapers and television stations informed. The extent of these communication efforts and their coverage throughout the AEP Texas service territories will depend upon the severity, and potential effect on the AEP Texas' system and its effect on the community, created by the emergency situation.

The AEP Customer Operations Centers have 92 phone lines which are available for customers to call daily. Moreover, AEP can handle 100,000 calls per hour utilizing overflow automated outage reporting systems. Additionally, as part of the day-to-day operations, the AEP Customer Operations Centers have the ability to roll over its calls back and forth between five additional AEP integrated Customer Operations Centers which provides a larger pool of live


resources to answer calls. AEP Texas has the ability to redirect callers from one Customer Operations Center to another in the event a center experiences technical difficulties or otherwise becomes unavailable.

Outages to critical load customers affect the lives of many individuals. Therefore, AEP Texas includes in its plan a process for communicating with commercial centers, governmental agencies, and emergency facilities intended to facilitate the status of restoration with such customers.

The AEP Texas "Storm and Outage Center" available on is another source of information for end-use customers. It provides end-use customers with outage related information and is updated throughout the day. End-use customers also obtain outage information by zip code or county on the AEP Texas website. In addition, the end-use customers in the AEP Texas service area, they can sign up to receive outage alerts by email or a text message when their power goes out.

AEP Texas also notifies the Public Utility Commission of Texas (PUC) as required by P.U.C. SUBST. R. 25.52(e)(1). After a significant interruption event lasting more than 24 hours, AEP Texas submits a Summary Report to the PUCT as required by P.U.C. SUBST. R. 25.52(e)(2). AEP Texas will also notify the Electric Reliability Council of Texas (ERCOT), the US Department of Energy (DOE), and other regulatory agencies, as necessary and/or prescribed by ERCOT Protocol or Operating Guide.

IV. Curtailment Priorities

In the event that the AEP Texas transmission system is faced with a load congestion or emergency situation such as loss of generation resources on the ERCOT System, AEP Texas system dispatchers will operate the AEP Texas transmission system pursuant to the ERCOT Protocols and the direction of ERCOT. AEP Texas uses its Manual Emergency Load Shed Plan to rotate outages until adequate generation reserves are returned to the ERCOT System. AEP Texas will notify the DOE, ERCOT, PUC and other governmental agencies of the emergency conditions as required.


V. Priorities for Restoration of Service

As indicated previously, the AEP Texas priorities after a major emergency are to utilize all available resources to effectively and efficiently resolve the emergency situation and accomplish the rapid and orderly repair of electric service facilities for the protection of public health and safety and the restoration of service to all customers in the minimum time possible. After a major emergency or disaster, AEP Texas immediately assesses the damage to its electric system. Detailed responsibilities for AEP Texas personnel are described in the ERP for each area regarding their specific duties in assessing the extent of the damage, apprising management of hazardous situations, and restoring electric service to Critical Loads and eventually all end-use customers. In order to restore electric service to as many end-use customers as possible, transmission circuits, substations and distribution feeders are the first focus for restoration.

VI. Pandemic Plan Summary

Pandemic preparedness by AEP Texas has been coordinated on an AEP operating company and AEP System basis. The broader AEP organization supports its operating companies system wide by providing assistance during emergencies and by securing increased efficiencies through coordination of planning, design, construction, maintenance, and operation in all business aspects, including pandemic preparedness.

AEP Texas, in coordination with other AEP affiliates across the AEP system, plans on a continuous basis to protect its work force and strive to meet the public's expectations to provide reliable electrical service if a pandemic were to occur. To accomplish this, AEP commissioned the formation of an Avian Task Force to develop a corporate plan and recommendations from a business continuity perspective. A group of employees from across the AEP system were tasked with the development of a series of recommendations to mitigate the impacts of a pandemic to the system and to maintain a base of information for its employees and customers. The focus areas of the Avian Task Force included, but were not limited to, leadership and decision-making authorities, investment project reviews, health and travel restrictions, equipment and medicinal necessities, strategic communications, contracts, security, and regulatory and technological requirements. The pandemic preparations are intended to build upon the AEP Texas existing resources, processes and procedures (i.e. storm restoration, emergency response procedures) whenever possible but also address the unique nature of a pandemic threat.


The BCP, of which the AEP Texas Pandemic Plan is encompassed, defines the procedures employed to ensure the timely and orderly resumption of a company's business operations in the event a pandemic were to occur. This plan outlines procedures and tests how well its organization is prepared to survive a business disruption with minimum interruption to its daily routine. The plan reflects the specifics of the organization, focusing on understanding the organization's needs, critical business operations, and their respective dependencies.

The AEP Texas BCP is designed to address the following three disaster scenarios: loss of building, loss of applications and loss of workforce and includes the following objectives:

• Establish policies to be implemented during a pandemic;

Maintain a healthy work environment for AEP Texas employees with effective

policies and practices to contain and minimize the spread of infection in the workplace;

• Educate AEP Texas employees on how to maintain a healthy environment at home and minimize the spread of infection within their families;

Allocate resources to protect AEP Texas employees and customers;

• Ensure the coordination and alignment of an AEP Texas response with other critical organizations, key suppliers, and the community;

• Maintain critical operations during a pandemic; and,

• Maintain contact with local health organizations to ensure coordination and availability of current information regarding a potential pandemic

VII. Wildfire Mitigation Efforts Plan

Vegetation identified during circuit patrols as dead or at risk for fire issues is managed

through and as part of the regular annual Vegetation Management Plan. AEP Texas does not

currently have a separate approach identified as a drought or wildfire management program. As the work associated with the annual plan is performed, the AEP Texas companies look for hazard trees and remove them at the time they are identified. Vegetation identified for removal may be located inside and/or outside of the ROW. The identification and mitigation of at-risk trees is part of the day-to-day operations and maintenance of AEP Texas. At-risk tree work is budgeted as part of the long-term and short-term vegetation management work plan budget.


Emergency situations that cause power outages or threaten power outages are managed with a matrix team. The service area being impacted will send out an assessment team to determine restoration needs or potential power outage hazards. If vegetation is an issue from an emergency situation, the Companies' forestry team will be called into action. The Companies' service areas differ when comparing the geography between south and west Texas and thus may entail employing particularized methods of addressing emergency situations caused by the pertinent vegetation in the service area. As potential occurrences develop that could impact the AEP Texas facilities, it is addressed with the appropriate mitigation plan to help limit the number of outages.

VIII. Potentially Severe Weather Plan

AEP Texas uses its ERP to address outages related to all severe weather experienced in its service areas such as ice, snow, drought, wind storms, hurricanes, tropical storms, and smaller local storms that causes significant damage to the AEP Texas transmission and distribution systems. Also, please see Section XI, Hurricane Plan Summary.

IX. Inventory of Pre-arranged Supplies Plan

As part of the normal day-to-day business activities, AEP Texas maintains supplies through storefronts throughout its service areas. The supply levels are maintained with the intent to adequately respond to any size or type of severe weather. If supplies are limited in an area that is hit with severe weather, AEP Texas will take action in moving the required supplies to that specific area. In the event of a larger hurricane, if supplies are limited, AEP Texas will reach out to its sister companies to request supplies needed for the restoration process.

X. Staffing Plan

AEP Texas has incorporated the Incident Command System (ICS) to command, control and coordinate severe weather emergency events. AEP Texas uses its local employees to respond to emergency events as well as local contractors. Depending on the size of the emergency event. AEP Texas has the capability of requesting employees from its sister companies to provide assistance in the restoration process. Also, if needed, AEP Texas has the ability to request assistance from other non-AEP utilities through mutual assistance groups in


which AEP Texas participates. Staffing during severe weather events is discussed further below in Section XI, Hurricane Plan Summary.

XI. Hurricane Plan Summary

In the event of a hurricane, the AEP ERP is followed to complete the restoration process. The Plan has individual sections that will guide the AEP Texas emergency management staff to successfully complete the restoration process. A complete copy of the AEP ERP can be viewed at the AEP Texas offices in Austin, Texas.

XII. Conclusion

The AEP ERP is a comprehensive set of procedures and outlined responsibilities to be used before, during and after a major emergency. AEP Texas utilizes its own resources, those of its affiliates within the AEP system and calls upon other utilities and contractors as needed during emergency situations in order to restore electric service to all of its end-use customers promptly and in a safe manner. Although it is impossible to anticipate all potential emergency situations, AEP Texas is dedicated to minimizing the risk and alleviating the effects of any situation that may arise.



I, A. Wade Smith am the President and Chief Operating Officer of AEP Texas Central Company and AEP Texas North Company (collectively known as AEP Texas) and in such capacity, I am qualified and authorized to attest that all relevant AEP Texas personnel are familiar with the contents of the Emergency Response Plan (also known as the Emergency Operations Plan); and such personnel are committed to implementing the plan and provisions contained therein in the event of a system-wide or local emergency that arises from natural or manmade disasters except to the extent deviations are appropriate under the circumstances during the course of an emergency.

I attest that the AEP Texas transmission and distribution emergency management personnel who are designated to interact with local, state and federal emergency management officials during emergency events have received Federal Emergency Management Agency (FEMA) National Incident Management System (NIMS) training, specifically 700.a, 800.b, 100.b, and IS-200.b.


SUBSCRIBED AND SWORN TO BEFORE ME on this.3 0 day of April, 2015.


Notary Public Lorraine R. Harris

_+r Notary Public-State of Ohio s c My Commission Expires

April 5, 2016





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