January 14, 2008

Blair Bales, Assistant Secretary
Public Service Commission
2515 Warren Avenue, Suite 300
Cheyenne, Wyoming, 82002.

RE:    Comments of the Wyoming Rural Electric Association Specific toThe Wyoming   Public   Service Commission’s Intent to Adopt Rules and Regulations Related to    Service Interruption and Reporting

I respectfully submit the following comments on behalf of the 11 distribution cooperatives that are members of the Wyoming Rural Electric Association (WREA) with regards to the Public Service Commission’s (PSC) proposed rules; Sections 238 and 325 specifically.

Along with other members of the Electric Utility Industry (Industry) in Wyoming, representatives of the Wyoming Rural Electric Cooperatives (Cooperatives) attended several Technical Workshops hosted by the PSC in 2006 and 2007. The purpose of these Technical Workshops was to address and work toward a joint resolution specific to the Commission’s proposed changes in its rules and regulations related to Service Interruptions and Reporting Requirements Section 238.

At the onset, all representatives from the Industry agreed and expressed their joint concern that; because of differing operational characteristics, technical capabilities and diversity of size, they were opposed to a “one size fits all” approach to the Commission’s proposed changes. In addition to opposing the “one size fits all” approach, the Cooperatives along with the Industry expressed its concerns regarding Section 238 (part a) of the original draft rules that attempted to include specifics related to “end use services” such as; …significant local, state or federal governmental buildings or services,, or affects any hospitals, nursing homes, or health care clinics. This component of the draft rules was thoroughly discussed and agreed to by all…including the Commission’s Technical Staff, that these “specifics” associated with “end use services” could be broadly defined and therefore lead to questionable reporting requirements.

At the conclusion of these technical workshops and after considerable time invested by all in attendance, it was the understanding of the Cooperatives that a workable outline had been developed and agreed upon by all parties (including the Commission’s Technical Staff). That outline included;

1) Each electric utility shall file a service interruption reporting plan for Commission approval that defines both major and minor service interruptions specific to their respective systems and timelines for reporting both types of service interruptions to the Commission. Each electric utility’s reporting plan will be reviewed biannually by the Commission Staff and the utility to determine the plan’s effectiveness in keeping the Commission and staff informed about the utility’s service interruptions. If changes are made to the reporting plan, they will be submitted to the Commission for approval. Additionally, quarterly reporting of all service interruptions, as defined in IEEE 1366 as a sustained outage shall be submitted to the Commission.

2) The Commission shall be notified in advance of all planned major service interruptions.

3) Except in the case of an emergency, the utility shall make every reasonable effort to notify customers affected by planned service interruptions at least (2) business days prior to the service interruption.

Whereas, the Cooperative’s are pleased that the Commission’s Notice of Intent and Order to Commence Rule Making under Docket No. 90000-100-XO-07 includes the agreed upon provision under Section 325- Electric Utility Service Interruption Reporting ( part a) which allows the Cooperatives to proceed with the development of their individual reporting plans…we are however, concerned that the Commission has once again included under (part b) of this section, which defines the outage reporting requirements of specific “end use services”.

We are also concerned with Section 325 (f) which states that “Quarterly reports of all service interruptions shall be filed with the Commission within thirty (30) days of the end of each calendar quarter or as authorized by the Commission in the form of Section 901(l) (Form No. 12) in Chapter IX.” This requirement appears to be redundant and unnecessary as the utilities will report the outage the first time when or after it occurs and then a second time in our annual reports to the PSC. This requirement not only creates unnecessary work for the cooperatives but for the PSC staff as well. We would suggest that Section 325 (f) also be removed. If this accommodation cannot be met we would at least request that the quarterly reporting be allowed to be made electronically.

Wyoming’s cooperatives range in size from 43 square miles and 1,776 meters, to 16,200 square miles and 26,431 meters. It is because of this diversity just among co-ops that we urged the Commission and staff during the technical conferences that we be allowed to develop our own plans and not have a once-size-fits all approach forced on us.

In conclusion, the Cooperatives would ask that the Commission follow the recommendations of the Technical Workshops and consider under its rule making process the elimination of Sections 238 (b) and 325 (b), as well as Section 325 (f). In the event that the Commission’s findings are such that these Sections cannot be eliminated, the Cooperatives would ask that a public hearing be held on the matter. Thank you for this opportunity to comments.

Sincerely,

Shawn Taylor

Executive Director

Wyoming Rural Electric Association

        Danny Eyre, Bridger Valley Electric Association, Inc.

        Chuck Larsen, Carbon Power and Light, Inc.

        Mary Ann Keeler, Garland Light and Power

        Jeff Hohn, High Plains Power Corporation

        Don Brunner, High West Energy, Inc.

        Jim Webb, Lower Valley Energy

        Sheldon Albertson, Niobrara Electric Association, Inc.

        Mike Easley, Powder River Energy Corporation

        Chuck Witte, Wheatland Rural Electric Association

        Rollie Miller, Wyrulec Company