For these and other reasons, broad reliability metrics may be most useful not for comparison with other utilities, but rather as a benchmark against which to measure both the performance of each utility over time and the performance in specific geographic areas within the utility's service territory. Grid-wide statistics will not reveal much by themselves, but could be instrumental in identifying areas where reliability is a chronic problem. After an unusual number of customer complaints, the Commission might require the utility to measure reliability in a specific area for a period of time, and compare the result to the company-wide measures, with a large enough deviance requiring the utility to take some corrective action. After some experience has been developed with the application of these types of metrics, the Commission could consider whether they would appropriate to incorporate into utility performance agreements. Summary and Conclusion CTED thanks the Commission for the opportunity to comment on distribution system reliability and power quality issues.
Reliability is valuable, but achieving it can be costly.
Effective utility regulation should seek to balance the costs and benefits of achieving additional increments of reliability. Most reliability investments are appropriately made collectively, with broad cost recovery. These investments should be made on a least-cost basis. However, new technologies are making it possible for customers to invest in systems that provide either backup generation, improved power quality, or both. Finally, the Commission may require new reliability metrics to determine whether incremental reliability activities meet a cost-benefit test.