Maintenance Plan for Transmission and Distribution Overhead and Underground Lines - Docket No.

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Maintenance Plan for Transmission and Distribution Overhead and Underground Lines - Docket No.
THE UNITED ILLUMINATING COMPANY

         Docket No. 20-12-44

     Maintenance Plan for
 Transmission and Distribution
Overhead and Underground Lines

                                Revised: 1/27/2021

            Table of Contents
                     1
Maintenance Plan for Transmission and Distribution Overhead and Underground Lines - Docket No.
1. Executive Overview .........................................................................................................3
2. Introduction ......................................................................................................................4
3. System Description ..........................................................................................................4
4. Vegetation Management...................................................................................................7
5. Maintenance Practices .....................................................................................................9
   5.1. Construction and Maintenance Workforce Organization .........................................10
   5.2. Maintenance of Assets and Systems by Area ...........................................................12
       5.2.1. Overhead Distribution System .......................................................................12
       5.2.2. Underground Distribution System .................................................................15
       5.2.3. Overhead Transmission System .....................................................................17
       5.2.4. Underground Transmission System ...............................................................18
       5.2.5. Substations .....................................................................................................19
       5.2.6. Vegetation Management ................................................................................21
       5.2.7.General .............................................................................................................21
6. Summary of Updated Maintenance Practices ..................................................................22
   6.1. Overhead System Changes .......................................................................................23
   6.2. Substation Changes ...................................................................................................23
   6.3. Vegetation Management Changes.............................................................................23
   6.4. Underground Transmission System Changes ...........................................................23

7. List of Attachments ..........................................................................................................24
     1: United Illuminating Service Territory Map ...........................................................25
     2: Vegetation Management Specification ..................................................................26

List of Tables
      1: System Peak Loads ..................................................................................................4
      2: MWHR sales mix for the period 2017-2020 ...........................................................6
      3: Breakdown of customers by class for the period 2017-2020...................................6
      4: System Miles by Construction Type and Voltage Level ..........................................7
      5: Construction / Maintenance Work Force Organization ...........................................11
      6: Maintenance Practices, Overhead Distribution System ...........................................12
      7: Maintenance Practices, Underground Distribution System .....................................15
      8: Maintenance Practices, Overhead Transmission System .........................................17
      9: Maintenance Practices, Underground Transmission System ...................................18
      10: Maintenance Practices, Substations .......................................................................19

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Maintenance Plan for Transmission and Distribution Overhead and Underground Lines - Docket No.
1. Executive Overview

   Goals and Objectives
   Proper maintenance of The United Illuminating Company’s (UI or Company) transmission
   and distribution facilities has played a major role in achieving high reliability, public safety,
   and customer satisfaction, and is a key element of the UI corporate strategy. The Company
   continues active development and implementation of maintenance processes to drive
   efficiencies into maintenance activities. UI’s electric system maintenance practices focus on
   cost effectiveness while maintaining high levels of service to our customers.

   The United Illuminating Company’s Maintenance Program Goals are to:

          o Work safely everyday
          o Maintain reliability performance at 1998 levels
          o Achieve these goals at the minimum cost to our customers

   The United Illuminating Company’s Maintenance Plan addresses assets in six subsections:

          o   Overhead Distribution System
          o   Underground Distribution System
          o   Overhead Transmission System
          o   Underground Transmission System
          o   Substations
          o   Vegetation Management

   Reliability Centered Maintenance
   Since 1997, UI has employed a Reliability Centered Maintenance (RCM) program approach
   to system maintenance. In general, this approach applies equipment inspection, diagnostic
   testing, analysis of historical data, and other techniques, to determine the nature and timing
   of preventive maintenance actions. Hence, in RCM, traditional “time-based” maintenance is
   supplemented or replaced by predictive or “condition-based” maintenance. The specific
   strategy for the UI electric system is to move toward condition-based maintenance while
   continuing appropriate traditional time-based maintenance activities.

   At UI, the Reliability Centered Maintenance program is a continually evolving process that
   strives to understand an asset’s potential for failure by focusing resources on preservation of
   system function, as opposed to traditional maintenance to preserve individual equipment
   operation. This approach improves cost effectiveness by reducing unwarranted corrective-
   reactive maintenance.

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Maintenance Plan for Transmission and Distribution Overhead and Underground Lines - Docket No.
2. Introduction

   Maintenance is a dynamic process that combines analysis of historical data, carefully
   developed procedures that use proven predictive maintenance techniques, and cost effective
   time-based maintenance tasks. The judgment of experienced operating and engineering
   personnel is continually sought out and incorporated into the Reliability Centered
   Maintenance Program. UI has developed a work routine that strives to make preventive
   action a daily responsibility. Electric System Operations personnel traveling in the territory
   are encouraged to report any abnormal system conditions to the operating department in a
   proactive manner. The goal of UI’s Maintenance Program is to maximize safety and
   reliability of the distribution and transmission systems in a cost effective manner.

3. System Description

   The United Illuminating Company is located in the southwest area of Connecticut on the
   north shore of Long Island Sound. UI serves seventeen cities and towns surrounding the
   principal cities of New Haven and Bridgeport. The service territory is approximately 335
   square miles with a population of approximately 762,856 people (2019 estimates as reported
   on the State of Connecticut Department of Public Health website http://www.ct.gov/dph/cwp/
   view.asp?a=3132&q=388156).

   System peak load for recent years is shown in the following table:

  Table 1: System Peak Load, 2015 to 2020

                           2015       2016      2017       2018         2019    2020
            Peak            1230      1264      1193       1274         1217    1222
            Load
            (MW)
            Date of       9/08/15 8/12/16 7/20/17 8/29/18 7/21/19 7/28/20
            P e a k
            Load

   The map provided in Attachment 1 shows the UI service territory and the municipalities
   supplied within the service area.

   To serve its customers, the UI Company owns, operates and maintains the following:

   •   28 - 115/13.8 kV bulk distribution substations with a capacity of 1,980 MVA
   •   4 - 115 kV transmission switching stations
   •   2 - 345/115 kV transmission substations
   •   1 – 115 kV generator interconnection station
   •   115 kV interconnection station to railroad owned 115/26.4 kV
   •   2 - 13.8/4.16 kV distribution substations with a capacity of 15 MVA
   •   Approximately 3,281 pole line miles of overhead distribution lines (1φ and 3φ).
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Maintenance Plan for Transmission and Distribution Overhead and Underground Lines - Docket No.
o This includes primary, secondary and aerial cable, excludes service conductors.
•   216 miles of underground conduit banks.
•   703 miles of underground primary cables (1φ and 3φ) consisting of direct-buried as well
    as underground duct and splicing chamber construction.
•   A majority of the distribution system is fed at 13,800 volts, with the remaining load
    supplied at 4,160 volts.
•   Two underground network systems in the downtown areas of New Haven and Bridgeport
    utilize interconnected secondary cables (120/208Y volt) designed primarily for high-
    density urban areas.
•   Some of the larger downtown loads are supplied by 277/480Y volt systems that are not
    interconnected and are called “spot networks”.
•   The UI transmission system consists of 16 circuit miles of overhead 345,000-volt line, 94
    circuit miles of overhead 115,000-volt line, 18 circuit miles of underground 115,000-volt
    line, and 11 circuit miles of underground 345,000-volt line.

A summary of the conductor types used in the UI system is found in Table 4 at the end of this
section. This table contains mileage of conductor types categorized by voltage level. The
data for this table was obtained by using the Company’s Geographical Information System
(GIS).

The Company’s service area is composed of urban, suburban, and to a lesser extent rural
areas. The urban areas are located in the downtown centers of Bridgeport and New Haven,
as well as in the smaller cities and towns, including Fairfield, Shelton, Derby, Ansonia,
Stratford, Milford, West Haven, Hamden, and East Haven. The remaining service area is
mostly suburban.

Most of UI’s commercial customers occupy land adjoining the major inter-city highways,
such as I-95 and US #1 from Fairfield to East Haven, Route #8 from Bridgeport to Ansonia,
I-91 and US #5 from New Haven to North Haven and Routes #10 and #15 from New Haven
to Hamden. Most of the large industrial customers are situated along the Railroad Rights-of-
Way on the shoreline, and in the Housatonic and Quinnipiac River Valleys.

Almost all of the non-commercial areas are suburban residential tracts. The only true rural
area left in the service territory is in Easton, except for scattered farms in North Haven, North
Branford, and Orange, as well as state and local parklands. Much of the territory, including
the rural, suburban, and residential area just outside the urban centers, is heavily treed.

Service reliability, without question, is of vital importance to the viability of the Company as
well as the local economy and remains extremely important to the Company and all of our
customers. In particular, the very existence of our commercial and industrial customers,
which comprise approximately 58% of our sales base, depends on UI’s ability to provide
reliable service.

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Maintenance Plan for Transmission and Distribution Overhead and Underground Lines - Docket No.
The following table summarizes the MWHR sales mix for the period 2017-2020:

Table 2: MWh Sales Mix for the Period
2017-2020
Customer Class                                              2020
                                                            Original
                       2017        2018        2019         Budget
                                                            Forecast

Residential            41.52%      42.40%      41.80%       42.75%
Commercial             49.03%      48.41%      48.76%       48.32%
Industrial             8.70%       8.53%       8.74%        8.48%
Street Lighting        0.75%       0.65%       0.70%        0.45%
Total                  100.00%     100.00%     100.00%      100.00%

Note: Sums may not add exactly due to
rounding

The following table summarizes the breakdown of customers by class for the period 2017- 2020:

              Table 3: Breakdown of Customers by Class for the Period 2017 - 2020
              Customer Class                                           2020
                                                                       Original
                                  2017         2018        2019        Budget
                                                                       Forecast

              Residential         300,681      302,811     304,132     305,887
              Commercial          30,653       30,998      31,062      31,191
              Industrial          1,009        964         975         935
              Street Lighting     1,120        1,125       1,113       1,109
              Total               333,463      335,898     337,283     339,122

              Note: Sums may not add exactly due to
              rounding
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Maintenance Plan for Transmission and Distribution Overhead and Underground Lines - Docket No.
The following table summarizes transmission and distribution system miles by construction type
          and voltage level:

          Table 4: Transmission and Distribu on System Miles by Construc on Type and Voltage Level
                                                                     Circuit Miles
                   Construc on Type
                                                15kV or less         115kV           345kV & Higher
                         Tree Wire                  2482                0                  0
                     Non-Tree Wire                   167               94                 16
                      Aerial Cable                   206                0                  0
                 Self-Suppor ng Cable                 1                 0                  0
                 Underground Cable*                  703               18                  11
                          Totals                    3559               112                 27

          Definitions:
          Tree Wire:
          All primary wire used in open wire construction that is covered with a 10/64 polyethylene
          coating.
          Non-Tree Wire:
          All primary wire used in open wire construction that either has no insulation (bare) or is covered
          with a material having little or no insulation value.
          Aerial Cable:
          Shielded primary cable suspended from a messenger attached to poles.
          Self-Supporting Cable:
          Unshielded insulated primary wire triplexed around a messenger attached to poles.
          *Underground Cable:
          Distribution: Includes both shielded primary cable in a splicing chamber and duct system, and
          direct buried cable.
          Transmission: Includes pipe type, gas insulated, fluid filled and solid dielectric in a splicing
          chamber and duct system.
          *Secondaries and services excluded

          4. Vegetation Management

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The United Illuminating Company remains committed to providing safe, reliable and cost
effective electric service. In January of 2014, UI began a Utility Protection Zone Program
with the goal of establishing a clearance zone extending 8 feet horizontally and ground-to-
sky vertically around all of its primary distribution lines. This plan was to be completed over
8 years. As a result of Docket No. 16-06-04, the program has been extended from 8 to 12
years.

In addition to the UPZ planned circuit miles program, the Company implements the
following vegetation management strategies to maintain or enhance the reliability of the
electric distribution system:

   •   Reliability Maintenance – The reliability maintenance program is designed to address
       emergent customer and other third party identified tree conditions that may affect
       electric reliability and tree work required to restore service.

   •   Direct Contacts the minimum level of pruning and removal needed to resolve direct
       contact with energized electrical equipment, or visible signs of burning.

   •   Vine Management: Vine Management is the removal of climbing vines from poles
       and guy wires.

   •   Distribution Rights-Of Way Line Clearance: Rights-of-Way Line Clearance is the
       removal of trees and non-compatible shrubs on off-road distribution rights-of way.
       Typically, such work is identified and generated during cycle maintenance and
       through ROW inspections.

Distribution Line Clearance Specification – UPZ

The UPZ tree work specification is the only UI vegetation management specification for
planned UPZ circuit miles. For trees that are pruned for Reliability Maintenance, the
clearance zone will normally be 8 feet to the side, 10 feet below and 15 feet above primary
conductors. For trees that are pruned for Direct Contact, the minimum level of pruning will
be executed to resolve the direct contact or visible signs of burning.

The Distribution Line Clearance Specification establishes vegetation management clearance
within the UPZ in a rectangular area extending horizontally for a distance of eight feet from
any outermost electrical conductor or wire installed from pole to pole and vertically from the
ground to the sky. Desirable low height or ornamental trees that are already in the zone or
those that are planted under the Right Tree – Right Place program will remain. Compatible
trees and shrubs listed in the State Vegetation Management Task Force Report or added by
the DEEP may remain in or may in the future be planted within the UPZ.

The UPZ creates greater distance between the vegetation and conductor in order to reduce the
likelihood that vegetation would impact the electric system during extraordinary weather
events. This specification reduces the amount of vegetation that may come in contact with
the electric infrastructure and will improve the overall performance of the electric system.
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In January of each year, UI reports Vegetation Management performance metrics to PURA as
required in Docket No. 12-01-10 and Docket No. 16-06-04. UI provides the tree warden in
each town in its service territory a plan detailing the proposed roads where UPZ vegetation
management will take place in the forthcoming calendar year and an estimated time schedule
for the planned vegetation management.

UI’s strategy is to obtain abutting property owner consent for all non-emergent or non-direct
contact tree work far enough in advance of the work to optimize the use of the line clearance
crews. This method requires UI’s contractors to begin the notification process at least three
months in advance to achieve this strategy and fully implement the requirements of Public
Act 14-151.

UI continues to work with local tree wardens, as well as civic and professional groups, to
help educate customers about the proper selection and care of trees that may be planted near
UI’s electric facilities. In addition, safety brochures are distributed annually through bill
inserts, and other events are held to educate the public on the dangers associated with
energized wires and the importance of having qualified tree contractors or UI line clearance
crews remove hazardous tree growth. We believe that we can continue to provide safe,
reliable service in a cost-effective manner by working together with our customers in matters
of line clearance and vegetation management.

Transmission Vegetation Management Program

Transmission lines are maintained on a four year cycle (approx. 25% per year). The cycle
based tree and brush work is supplemented with inspection of 100% of the overhead
transmission lines. UI’s Transmission Vegetation Management Program (TVMP) complies
with the North American Electric Reliability Corporation (NERC) FAC-003-4 Standard,
covering all the transmission lines operated at 200kV and above, and specific lower voltage
lines designated by the Northeast Power Coordinating Council (NPCC) as being critical to
the reliability of the electric system in the region. Transmission line ROW are inspected
annually by foot patrol for the purpose of identifying vegetation conditions that could breach
the vegetation to conductor clearance requirements, impact electric service reliability or
create a hazard to the public. UI has implemented the use of Light Detection and Ranging
(LiDAR) imaging and processing capabilities to improve the inspection program. The
LiDAR survey identifies vegetation conditions that are prioritized and scheduled within the
annual planned right-of-way maintenance. Any vegetation conditions which are an imminent
threat to the operation or maintenance of the lines are addressed immediately. All data from
the inspections is captured electronically and then imported into a tracking database. Reports
are generated from this database to assist in developing work schedules and tracking work to
completion. The UI Transmission Arborist re-inspects all reported vegetation items, develops
the maintenance trimming schedule, prioritizes work and coordinates with the railroad
companies when work is performed along the Metro North or Amtrak railroad tracks. Field
audits are completed to ensure the work performed meets the TVMP requirements.

UI’s Vegetation Management Specification is appended to this document as Attachment 2.

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5. Maintenance Practices

   The primary goal of Reliability Centered Maintenance (RCM) is to keep equipment operating
   properly while minimizing total maintenance costs. RCM uses proven predictive
   maintenance techniques to schedule cost effective maintenance only when needed (based on
   experience, inspection and testing results, manufacturers’ data, etc.) to prevent critical
   failures.

   It should be understood that the term maintenance, as used at UI, includes both inspection
   and maintenance activities. UI crews perform construction, inspection and maintenance
   activities, thereby developing a balanced, well-rounded work force and minimizing costs.

   UI employees perform the majority of maintenance work on the distribution system, with the
   exception of tree trimming, and pole inspection and treatment which are done by outside
   contract crews. During peak constructions periods, outside contract crews may augment UI
   crews on construction projects. Outside contract crews are also used on UI’s transmission
   system for both major construction and maintenance functions.

   Maintenance practices in the following sections are organized as noted below:

      ▪ Construction / Maintenance Work Force Organization
      ▪ Maintenance of Assets and Systems by Area
      • Overhead Distribution System
      • Underground Distribution System
      • Overhead Transmission System
      • Underground Transmission System
      • Substations
      • Vegetation Management (Attachment 2)
      • General

   5.1.Construction and Maintenance Workforce Organization The following is a staffing
        summary by section and grade of UI’s construction and maintenance departments:

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Table 5: Construc on and Maintenance Work Force Organiza on:

                                           Department                                           Posi on   Number

                                                              Manager, System Maintenance                   1

                                                              Maintenance Engineer                          5
                                   System Maintenance
                                                              Civil/Structural Engineer                     1

                                                              Total System Maintenance                      8

                                                              Manager, Vegeta on Management                 1

                                                              Line Clearance Arborist, Lead                 3

                                  Vegeta on Management        Line Clearance Technician                     1

                                                              Lead Analyst – Contract Administra on         1

                                                              Total Vegeta on Management                    6

                                                              Chief Line Group Leader                       14

                                                              Construc on Manager-UG                        3

                                                              Elec Syst Const Scheduler                     2

                                                              Lead Supv, Const Opers                        3

                                                              Line Group Leader                             24

                                                              Line Restora on Leader                        14

                                                              Sr Line Worker 1st Class                      23

                                                              Line Worker 2nd Class                         19

                                                              Line Worker 4th Class                         7

                                        Power Delivery (PD)   Mgr - Pwr Del OH/UG                           1

                                                              Sr Admin Clk Opers                            2

                                                              Sr Bus Systems Analyst UG                     1

                                                              Supv Pwr Del/Transm&Subst                     7

                                                              UG Cable Splicer 3rd Cls                      3

                                                              UG Cable Splicer First Class                  9

                                                              UG Inspector                                  3

                                                              UG Working Leader                             2

                                                              Underground Specialist                        3

                                                              Total Power Delivery (PD)                    140

                                                              Glove Lab Tech                                2

                                                              Lead Supv, Const Opers                        1

                                                              Lead U lity Worker                            2

                                                              Sr Admin Clk Opers                            0

                                                              Substa on Elec 2nd Class                      0

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Subst Electr Const&Maint                        13

                                  Transmission & Substa on (T&S)      Subst Electrician Spec                          10

                                                                      Substa on Electrician First Class               4

                                                                      Substa on U lity Worker A                       2

                                                                      Substa on U lity Worker B                       1

                                                                      Supv Pwr Del/Transm&Subst                       4

                                                                      U lity Worker B RC                              0

                                                                      Total Substa on (T&S)                           39

                                                                      Electrical Test Assistant                       7

                                                                      Electrical Test Assistant B                     0

                                                                      Electrical Test Asst A                          0

                                                                      Engineer - Test                                 0

                                                                      Engineer - Test Comm Systems                    0

                                                                      Lead Electrical Test Tech                       7
                                         Test Department
                                                                      Lead Engineer - Test                            0

                                                                      Mgr - Pwr Del/T&S/Test                          1

                                                                      NERC Coordinator ESO                            1

                                                                      Principal Engineer - Test                       2

                                                                      Supv T&S Test                                   1

                                                                      Total Test                                      19

                              Total Construc on & Maintenance Work Force                                             206

                                 2. Maintenance of Assets and Systems by Area

                                    The Company’s new work management system called SAP® has a module to manage the
                                    maintenance of equipment. SAP® serves many functions, as it contains asset record data
                                    along with an asset registry, and also generates work orders associated with preventive and
                                    corrective maintenance plans. Several other databases are utilized in conjunction with
                                    SAP® for implementing the RCM plan. These databases are linked where possible. The
                                    Maximo® software application is no longer used to implement maintenance activities and is
                                    only being used to store historical records.

                                    UI visually inspects its overhead equipment in accordance with defined RCM programs
                                    and whenever work is being performed on the system. The major components of UI’s
                                    Overhead Distribution System are identified below. Details of maintenance and inspections
                                    are noted in each asset category.
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It should be noted that, in the course of any inspection and maintenance process described
                                      in this report, all hazards, damage, and other abnormal conditions affecting equipment on
                                      the UI system, are immediately reported to appropriate supervision, who then analyze the
                                      situation and coordinate corrective actions. Also, additional attention is given to any
                                      equipment as deemed appropriate by Substation Maintenance and T&D Networks
                                      Maintenance.

                                      The following tables list maintenance practices for major components of the overhead and
                                      underground distribution and transmission systems

                          2.1.         Table 6: Maintenance Prac ces, Overhead Distribu on System
                                 Category          Sub Category          Frequency         Task Descrip on                  Notes

                                                                                                                    Includes poles, ancillary
                                                                                                                 equipment, wire and cable,
                                                                      During pole
                                                                                                                  hardware, fault indicators,
                                                                    inspec on and
                                 General                                                   Visual Inspec on      lightning arresters, switches
                                                                   when working on
                                                                                                                     and other equipment
                                                                         pole
                                                                                                                       associated with an
                                                                                                                          installa on.

                                                      Poles,       6 Years and when        Above ground line
                                                   10 years old    working on pole
                                                                                         remedial treatment      applying wood preserva ve
                                                                                       for decay if necessary.    and internal fungicide for
                                                                                                                           decay.

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Table 6: Maintenance Prac ces, Overhead Distribu on System (con nued)
                                                                                                          Category         Sub Category              Frequency            Task Descrip on                Notes

                                                                                                                                                 During pole
                                                                                                                               Wire,           inspec on and
                                                                                                                                                                         Visual Inspec on        Problems reported in the
                                                                                                                                All           when working on
                                                                                                                                                    pole                                            Circuit Interrup on
                                                                                                                                                                                                   Repor ng System are
                                                                                                       Overhead Wire
                                                                                                                               Wire,                                                               reviewed for further
                                                                                                                                                      Annual             Infrared Inspec on
                                                                                                                           3 phase lines                                                       inves ga on and correc ve
                                                                                                                                                                                                           ac on
                                                                                                                               Wire,                Performance
                                                                                                                                                                         Infrared Inspec on
                                                                                                                         Single phase lines            Based

                                                                                                                                                                                                   A dielectric test is
                                                                                                                                                                                                 performed whenever a
                                                                                                                                                                          Dielectric test of
                                                                                                                                All           Upon Installa on                                   sec on is replaced or a
                                                                                                                                                                         insula on integrity
                                                                                                                                                                                               cable termina on or splice
                                                                                                                                                                                                       is replaced.

                                                                                                         Aerial Cable                                                In addi on to a visual       Aerial PILC Cable s ll
                                                                                                                                                                        inspec on when         remains a ached to bridge
                                                                                                                          Paper Insulated
                                                                                                                                                                       working on a pole.          overpasses where
                                                                                                                           Lead Covered             As above for
                                                                                                                                                                      The majority of this       installa on of splicing
                                                                                                                           (PILC), 13.8kV           Aerial Cable
                                                                                                                                                                    type of cable has been     chambers and ductline are
                                                                                                                               Circuits
                                                                                                                                                                          replaced on a           required to facilitate
                                                                                                                                                                      programma c basis.              replacement

                                                                                                         Insulators,
                                                                                                          Lightning
                                                                                                          Arresters,
                                                                                                                           3 phase lines              Annual             Infrared Inspec on
                                                                                                       Hotline Clamps,
                                                                                                        S rrups and
                                                                                                           Splices

                                                                                                                           3 phase lines              Annual             Infrared Inspec on
                                                                                                          Switches,
                                                                                                       Disconnects and                              Performance
                                                                                                        Fused Cutouts    Single phase lines                              Infrared Inspec on
                                                                                                                                                       Based

                                                                                                                                                                                                Failed units are replaced
                                                                                                                                                                                               when found. System wide
                                                                                                       Overhead Fault                                                                          replacement will be based
                                                                                                                                All                  See Notes                Replace
                                                                                                         Indicators                                                                             on failure rate, expected
                                                                                                                                                                                               ba ery life and technology
                                                                                                                                                                                                     advancements

                                                                                                                                                                                                Transformers whose PCB
                                                                                                                                                                                                 content is unknown, are
                                                                                                                                                                                                     loaded at or near
                                                                                                                                                                                                  nameplate ra ngs and
                                                                                                                             U liza on
                                                                                                                                                     See Notes                                     those found in poor
                                                                                                                           Transformers
                                                                                                       Pole Mounted                                                                                condi on have been
                                                                                                       Transformers                                                                            iden ed and are included
                                                                                                                                                                                                  for replacement in the
                                                                                                                                                                                                 Company's 10 Year Plan

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Electronic monitoring
 Step-down     Monitored as
                               devices monitor phase
Transformers    Required
                                      loading

                              15
Table 6: Maintenance Prac ces, Overhead Distribu on System (con nued)
                                                                            Category    Sub Category    Frequency               Task Descrip on               Notes

                                                                                                                          Signal tested through
                                                                                                                              SCADA during
                                                                                           Radio        As Needed
                                                                                                                           commissioning and
                                                                                         Controlled                          troubleshoo ng
                                                                   Pole Mounted
                                                                  Capacitor Banks                             Annual           Visual Inspec on

                                                                                           Fixed              Annual           Visual Inspec on

                                                                                             All              Annual           Infrared Inspec on

                                                                                                                        Opera onally tested and
                                                                                                                              inspected.
                                                                                                                                                     Ac on taken based on
                                                                                                                          Opera ons counter
                                                                       Pole Mounted                           Annual                                current RCM criteria and
                                                                                                                         recorded, voltage and
                                                                          Voltage            All                                                          data review.
                                                                                                                        se ngs con rmed with
                                                                        Regulators
                                                                                                                             asset records

                                                                                                              Annual           Infrared Inspec on

                                                                                                                          Gas pressure, Ambient
                                                                                                                                                      The control ba ery is
                                                                                                                        temp, Opera ons counter
                                                                                                                                                    replaced on 4 year cycle,
                                                                                                        Bi-annual       recorded, ba eries tested
                                                                                                                                                     or when ba ery tes ng
                                                                                             All                          and recorded for asset
                                                                       Pole Mounted                                                                           fails.
                                                                                                                                 tracking.
                                                                         Reclosers
                                                                                                        Annually               Infrared Inspec on

                                                                                                                        Internal and Opera onal      Based on current RCM
                                                                                        Oil Insulated    10 Years
                                                                                                                                 tes ng                     criteria

                                                                                                                                                        Each municipality is
                                                                                                                                                    responsible for repor ng
                                                                                                                                                     lights that are out. UI is
                                                                                                                          Repair or Replace as      responsible for repairing
                                                                                                              Failure
                                                                                                                               required               the lights once they’re
                                                                                                                                                      reported. Failures are
                                                                                                                                                     reported by customers,
                                                                       Street Lights         All                                                    police and UI personnel.

                                                                                                                                                     The Company began a
                                                                                                                                                     LED head replacement
                                                                                                                                                     program for municipal
                                                                                                        See Notes                   Re-lamp
                                                                                                                                                     lights in 2015. Private
                                                                                                                                                    Area Ligh ng re-lamping
                                                                                                                                                       will begin Q1 2020.

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2.2.        Table 7: Maintenance Prac ces, Underground Distribu on System
                                           Category        Sub Category       Frequency            Task Descrip on                 Notes

                                                                           During inspec on      Visual Inspec on of
                                                                               and when       electrical components and
                                                             General
                                                                              working at a     hardware, and structural
                                                                            speci c loca on            elements

                                                                                               Visual inspec on of the       Equipment includes
                                        Splicing
                                                                                                electrical and physical    grounding, cable racks,
                                       Chambers               Splicing
                                                                               10 Years       condi on of the structure    cable supports, covers,
                                          and                Chamber
                                                                                              and equipment contained      roofs, frames and other
                                       Secondary
                                                                                                        therein.             structural elements.
                                     Network Vaults
                                                                                               Visual inspec on of the       Equipment includes
                                                                                                electrical and physical    grounding, cable racks,
                                                            Secondary
                                                                               Annual         condi on of the structure    cable supports, covers,
                                                           Network Vault
                                                                                              and equipment contained      roofs, frames and other
                                                                                                        therein.             structural elements.

                                                                                              Visual Inspec on including
                                                                                              protector status, nitrogen
                                                             Network
                                                                               Annual            blanket pressure and
                                                            Protectors
                                                                                                   overall condi on
                                        Network                                                       assessment
                                      Transformers
                                                                                              Visual Inspec on including
                                                             Network
                                                                                                oil level inspec on and
                                                           Transformers        Annual
                                                                                                 recording and overall
                                                           and Switches
                                                                                                 condi on assessment

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Table 7: Maintenance Prac ces, Underground Distribu on System (con nued)
                                                                Category         Sub Category         Frequency               Task Descrip on                     Notes

                                                                                                   When any work to
                                                                                  All Primary         the electrical
                                                                                                                              Dielectric Tes ng
                                                                                     Cable           insula on of a
                                                                                                   cable is performed

                                                                                                                                                             Replacement of
                                                                                Primary Cable,
                                                                                                                                                          remaining PILC cable
                                                                                Paper Insulated                          Some of the PILC has been
                                                                                                      As above for                                        will be done based on
                                                                                 Lead Covered                                 replaced on a
                                                              Wire and Cable                         Primary Cable                                          performance and
                                                                                 (PILC), 13.8kV                            programma c basis.
                                                                                                                                                         poten al failure impact
                                                                                     Circuits
                                                                                                                                                          on system reliability.

                                                                                Solid Dielectric      As above for                                           Replacement is
                                                                                Primary Cable        Primary Cable                                         performance based

                                                                                                   During inspec on
                                                                                 Distribu on
                                                                                                    of the splicing           Visual inspec on
                                                                                    Cable
                                                                                                   chamber or vault

                                                              Padmounted
                                                                                                                         Visual inspec on for safety
                                                              Transformers
                                                                                                        5 Years          hazards, security, electrical
                                                              and Junc on
                                                                                                                            integrity and damage
                                                               Enclosures

                                                                                                                         Visual inspec on for safety
                                                                                 PME, PMH &
                                                                                                        Annual           hazards, security, electrical
                                                                                   G&W
                                                                                                                            integrity and damage
                                                               Padmounted
                                                                 Switches                                                Visual inspec on for safety
                                                                                     Vista              2 Years          hazards, security, electrical
                                                                                                                            integrity and damage

                                                                                                                         Visual inspec on for safety
                                                                                                                                                          Second physical barrier
                                                                                                                         hazards, security, electrical
                                                                                 Transclosures          5 Years                                          installed on all loca ons
                                                                                                                            integrity and damage

                                                                                                                                                           Abnormal condi ons
                                                                                 Transformer                                                                are brought to the
                                                                                                        4 Years          Visual inspec on for safety
                                                                                    Vaults                                                               customer's a en on for
                                                                                                                         hazards, security, electrical
                                                                                                                                                          remedia on and work
                                                                                                                            integrity and damage
                                                                                                        Annual                                                 is scheduled
                                                                                                                                                              appropriately
                                                                Customer-

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Customer-                                              These installa ons are
                         Owned Facili es                                             being replaced or
                                                                                    upgraded to meet
                                                                                 current NESC Standards
                                           Transformer
                                                                                  based on priori za on
                                              Cages
                                                                                   established from the
                                                         On-going program
                                                                                   inspec on program,
                                                                                   when the customer’s
                                                                                  service is abandoned,
                                                                                     at the customer’s
                                                                                 request or when system
                                                                                  upgrades are required.

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2.3.                    Table 8: Maintenance Prac ces, Overhead Transmission System
                                                                         Category               Sub Category       Frequency            Task Descrip on               Notes

                                                                                                                                    Inspected by outside
                                                                                                                                   contractors. Inspec on
                                                                                                                               includes items such as ground
                                                                                                     All            5Years
                                                                                                                                 conductor integrity, paint
                                                                                                                                  condi on, installa on of
                                                                                                                                     proper signage, etc.

                                                                                                                                 Above ground visual and        Climbing inspec ons
                                                                               Towers                                              below ground level             are performed as
                                                                                                    Wood            10Years     excava on to depth of 18”             required.
                                                                                                                                with remedial treatment if
                                                                                                                                        necessary

                                                                                                                                Test and review results for
                                                                                              Cathodic Protected                 proper opera on of the
                                                                                                                    2 Years
                                                                                               Steel Structures                 passive cathodic protec on
                                                                                                                                          system

                                                                                                                    5 Years            Visual inspec on

                                                                                                                                  Visual inspec on by air
                                                                                                                               (helicopter) which includes an
                                                                        Connectors,                                 Annual
                                                                                                     All                           infrared thermography
                                                                        Conductors,                                                       inspec on
                                                                       Termina ons
                                                                       and Insulators                              Condi on-
                                                                                                                                        Corona Imaging
                                                                                                                     based

                                                                                                  Substa on                         Visual and thermography
                                                                                                                   Bi-annual
                                                                                                 Components                                 inspec on

                                                                                                     All            5 Years    Visual inspec on of condi on

                                                                                                                                Test and review results for
                                                                       Founda ons             Cathodic Protected                 proper opera on of the
                                                                                                                    2 Years
                                                                                                   Caissons                     passive cathodic protec on
                                                                                                                                          system

                                                                                                  Vegeta on         Annual             Visual Inspec on

                                                                       Right-of-Ways                                               Iden fy and measure
                                                                                              Light Detec on and
                                                                          (ROW)                                                  vegeta on clearances to
                                                                                              Ranging Inspec on     2 Years
                                                                                                                                conductors on and along UI
                                                                                                    (LiDAR)
                                                                                                                                           ROW

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2.4.            Table 9: Maintenance Prac ces, Underground Transmission System
                                                                           Category         Sub Category           Frequency              Task Descrip on                  Notes

                                                                                                                                                                           Addi onal
                                                                                                                                                                        inspec ons are
                                                                      Termina on                                                                                      performed through
                                                                                                                     Annual               Visual inspec on
                                                                   Support Structures                                                                                      bi-monthly
                                                                                                                                                                       substa on patrol
                                                                                                                                                                          inspec ons.

                                                                                                                 When working
                                                                                                                                         Visual inspec on of
                                                                                           All Components         in a speci c
                                                                                                                                         accessible por ons
                                                                                                                    loca on

                                                                                                                                     Visual and Thermography
                                                                                             Termina ons            Bi-annual
                                                                                                                                             Inspec on

                                                                                          High Pressure Fluid
                                                                                          Filled (HPFF) Cable        3 Years
                                                                                           and Termina ons
                                                                                                                                                                          Addi onal
                                                                                          High Pressure Fluid                                                           inspec ons of
                                                                                           Filled (HPFF) GIS                                                              accessible
                                                                        Cable and Cable                              6 Years
                                                                                                Enclosed                                                                equipment are
                                                                         Termina ons                                                 Fluid is tested for dielectric
                                                                                             Termina ons                                                              performed during
                                                                                                                                        quality and dissolved         various substa on
                                                                                          Low Pressure Fluid                                    gasses.                  inspec ons.
                                                                                          Filled (LPFF) Cable        2 Years
                                                                                           and Termina ons

                                                                                          Low Pressure Fluid
                                                                                           Filled (LPFF) GIS
                                                                                                                     6 Years
                                                                                                Enclosed
                                                                                             Termina ons

                                                                                            Solid Dielectric
                                                                                                                     2 Years              Visual inspec on
                                                                                                 Cable

                                                                                                                  5 Years, during
                                                                                          High Pressure Fluid
                                                                                                                 cable inspec on
                                                                                           Filled (HPFF) and
                                                                                                                     or when
                                                                                          High Pressure Gas
                                                                                                                   working in a
                                                                                             Filled (HPGF)                           Condi on assessments are
                                                                                                                 speci c loca on
                                                                                                                                       done when inspec ons
                                                                                          Low Pressure Fluid                           indicate further ac on,
                                                                                                                     2 Years              which includes an
                                                                                           Filled (LPFF) Lines
                                                                                                                                       accelerated systema c
                                                                   Splicing Chambers      115kV and 345kV                             evalua on of the present
                                                                                                                     2 Years
                                                                                           Solid Dielectric                             condi on and future
                                                                                                                                     maintenance/replacement
                                                                                                                  In accordance
                                                                                                                                        requirements for the
                                                                                                                     with the
                                                                                             345kV Solid                                     underground
                                                                                                                 requirements of
                                                                                          Dielectric Lines in                               infrastructure.
                                                                                                                  the Conn DOT
                                                                                          ConnDOT Right-of-
                                                                                                                      Bridge
                                                                                                Ways
                                                                                                                    Inspec on
                                                                                                                      Manual

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All          Monthly                     Visual inspec on

                                                                                                                                                  These are the sample
                                                                               Cable
                                                                                                      Dielectric Fluid        3 Years           points for the HPFF Cable
                                                                         Pressuriza on and
                                                                                                                                                      noted above
                                                                         Pumping Systems
                                                                                                       High and Low
                                                                                                                              2 Years             Tested and Calibrated
                                                                                                    Pressure Set points

                                                                        Table 9: Maintenance Prac ces, Underground Transmission System (con nued)
                                                                                  Category            Sub Category           Frequency                   Task Descrip on            Notes

                                                                                                                                                   Output is veri ed at
                                                                                                                                                intermediate test points
                                                                                                                              2 Years           and at the underground
                                                                                                                                                 cable extremi es in the
                                                                           Ac ve Cathodic                                                              substa on.
                                                                         Protec on Systems
                                                                                                                                                Rec er visual condi on
                                                                                                                                                assessment. Voltage and
                                                                                                                             2 Months
                                                                                                                                                    current values are
                                                                                                                                                 recorded and reviewed.

                                                                        2.5.        Table 10: Maintenance Prac ces, Substa ons
                                                                                  Category          Sub Category          Frequency                Task Descrip on                 Notes

                                                                               Bulk Substa on         Outside
                                                                                                                                                                            Includes exterior and
                                                                               current carrying      equipment            Bi-annual
                                                                                                                                                                            interior components.
                                                                                 equipment              and
                                                                                                                                               Infrared Thermography         Ac on taken based
                                                                                                     equipment
                                                                             Distribu on                                                              Inspec on                on current RCM
                                                                                                     accessible
                                                                          Substa on current                                Annual                                              criteria and data
                                                                                                     within the
                                                                         carrying equipment                                                                                         review.
                                                                                                      building

                                                                                                                                              Visual inspec on of overall
                                                                                                                                                  condi on including
                                                                                                                                                  electrolyte levels (if      In accordance to
                                                                                                                          2 Months                                           industry accepted
                                                                                                                                                applicable), voltage and
                                                                         Sta onary Ba ery                All
                                                                                                                                              current levels and physical      standards and
                                                                             Systems                Installa ons
                                                                                                                                               condi on of components        applicable NERC /
                                                                                                                                                                            NPCC requirements
                                                                                                                                              Conductance and voltage
                                                                                                                           Annual
                                                                                                                                                tes ng and trending

                                                                                                                                              Oil quality and Dissolved
                                                                                                                           Annual               Gas Analysis (DGA) is
                                                                                                         All                                  performed and reviewed

                                                                                                                          2 Months                Visual Inspec on

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The 345kV
                                                                                                                     Bulk and                                                                   Transformers have
                                                                                                                                          4 Years 115kV        Power factor and excita on
                                                                                                                   Transmission                                                                 on-line monitoring
                                                                                                                                          6 Years 345kV         tes ng for the integrity of
                                                                                             Transformers and       Substa ons                                                                 systems which allows
                                                                                                                                                                    insula ng materials,
                                                                                                 Reactors                                                                                       for the 6 year cycle
                                                                                                                                                                     windings, bushing
                                                                                                                                                                   insula on. Load Tap                Distribu on
                                                                                                                                                                     Changer opera on.                substa on
                                                                                                                                                                   Opera onal tes ng of            transformers are
                                                                                                                    Distribu on                                   external components is       tested only if infrared
                                                                                                                                         Condi on based          performed to ensure the
                                                                                                                    Substa ons                                                                      inspec ons, oil
                                                                                                                                                               proper opera on of alarms          tes ng or a visual
                                                                                                                                                               and monitoring equipment.        inspec on detect an
                                                                                                                                                                                                         issue

                                                                                                                                                                                               Internal inspec ons
                                                                                                                                                                                                and overhauls are
                                                                                                                                                                Timing and mo on, power        condi on based but
                                                                                            Transmission Class
                                                                                                                   Bulk Oil (OCB)            2 Years           factor tes ng and oil quality     typically will not
                                                                                             Circuit Breakers
                                                                                                                                                                         analysis                   exceed the
                                                                                                                                                                                                  manufacturer’s
                                                                                                                                                                                                recommenda on

                                                                                       Table 10: Maintenance Prac ces, Substa ons (con nued)
                                                                                                       Category     Sub Category             Frequency                Task Descrip on                   Notes

                                                                                                                                                               Level 2 (major), 10 year
                                                                                                                                                               frequency: Outage required,
                                                                                                                                                               isola ng switches opened
                                                                                                                                              10 Years         and grounds applied as           Internal inspec ons
                                                                                                                                                               required, Level 1 Items plus      and overhauls are
                                                                                                                                                               Timing and Mo on, Alarm          condi on based but
                                                                                            Transmission Class      Gas Insulated                              points, Contact Resistance         typically will not
                                                                                             Circuit Breakers           (SF6)
                                                                                                                                                               Level 1 (minor) 5 year                exceed the
                                                                                                                                                               frequency: Thorough visual          manufacturer’s
                                                                                                                                                               inspec on, alarm se ngs,          recommenda on
                                                                                                                                               5 Years
                                                                                                                                                               hydraulic uid level and gas
                                                                                                                                                               moisture analysis

                                                                                                                     Air Magne c                                   visual, mechanical, and
                                                                                                                                               7 Years
                                                                                                                         (ACB)                                       electrical inspec on,
                                                                                                                                                                                                Per Manufacturer’s
                                                                                                                                                                    lubrica on, insula on
                                                                                              Distribu on Class                                                                                 recommenda on or
                                                                                                                       Vacuum                                       resistance and contact
                                                                                               Circuit Breakers                                                                                  based on industry
                                                                                                                     Interrupters             10 Years             resistance (measure the
                                                                                                                                                                                                   best prac ce.
                                                                                                                        (VCB)                                    level of atmosphere inside
                                                                                                                                                                     vacuum interrupters)

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Includes tes ng of security
                                                                                                                           systems, security inspec ons
                                                                                                        2 Months and
                                                                                                                               of interior and exterior
                                                                                                         whenever a
                                                                                                                             facili es, re-ex nguisher
                                                                                                       sta on is visited
                                                                                                                               inspec ons, rst-aid kit
                                                                                                                           inspec ons and similar tasks

                                                                                                                                                             NERC standard
                                                                                        Security and                                                        CIP-006 requires
                                                                                           Safety                                                          periodic tes ng of
                                                                                                                                                               the system.
                                                                                                                           Maintenance and tes ng of         Performing this
                                                                                                           Annual           security components and         tes ng with our
                                                                        Buildings and                                           communica ons             exis ng perimeter
                                                                         Structures                                                                           alarm tes ng
                                                                                                                                                            u lizes the same
                                                                                                                                                              resources to
                                                                                                                                                          perform both tests.

                                                                                                                             Facili es are cleaned,
                                                                                                                           opera on counts are taken
                                                                                          General         2 Months
                                                                                                                            and minor maintenance
                                                                                                                            ac vi es are performed

                                                                                                                           Gu ers and downspouts are          Selected
                                                                                                           Annual
                                                                                                                             inspected and cleaned           substa ons
                                                                                        Roof Systems
                                                                                                                               Substa on roofs are
                                                                                                           4 Years
                                                                                                                                    inspected

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Table 10: Maintenance Prac ces, Substa ons (con nued)
                                                                                                      Category         Sub Category         Frequency               Task Descrip on                 Notes

                                                                                                                                                               Electrical integrity tes ng
                                                                                                                                                                 and visual inspec on,          Maintenance is
                                                                                                                                            7 Years
                                                                                                                                                                replacement of cans or        done in conjunc on
                                                                                            Capacitor Bank                  All             OR
                                                                                                                                                               blown fuses, VBM ductor         with ACB and VCB
                                                                                                                                            10 Years
                                                                                                                                                                and hypot test, general        maintenance cycle
                                                                                                                                                                cleaning by Substa on

                                                                                                                                                                 Measure and recording
                                                                                                                                                              secondary voltage to iden fy
                                                                                       CCVT Secondary
                                                                                                                                                              problems while the failure is
                                                                                           Voltage                          All             3 Years
                                                                                                                                                                in its infancy. Inspect the
                                                                                          Trending
                                                                                                                                                              CCVT secondary junc on box
                                                                                                                                                                and internal components.

                                                                                                                                                               Voltage reduc on system
                                                                                                                          All Bulk                              communica on tes ng.
                                                                                  Voltage Reduc on                      Distribu on         Annual            Verify 2.5% and 5% voltage
                                                                                                                        Substa ons                             reduc on can be ini ated
                                                                                                                                                                  from control center.

                                                                                                                                                                                                Systems include
                                                                                                                         Protec ve
                                                                                                                                                                                              protec ve relaying,
                                                                                                                        Systems and
                                                                                                                                                                                                  ba eries and
                                                                                                                       Substa ons as
                                                                                                                                                                                               ba ery chargers,
                                                                                                                      de ned by North                         As described in NERC
                                                                                                                                                                                                circuit breakers,
                                                                                                                      American Electric                       Standard
                                                                                                                                        As speci ed in                                           transformers,
                                                                                                                         Reliability                          PRC-005-6 “ Protec on
                                                                                                                                        NERC Standards                                        protec ve relaying
                                                                                                                       Council (NERC)                         System Maintenance ”
                                                                                                                                                                                              telecommunica on
                                                                                  Protec ve Systems                    Standards and
                                                                                                                                                                                              s, Sudden Pressure
                                                                                                                      Northeast Power
                                                                                                                                                                                                  relaying and
                                                                                                                        Coordina ng
                                                                                                                                                                                                   Automa c
                                                                                                                       Council (NPCC)
                                                                                                                                                                                               Reclosing relaying

                                                                                                                         Non-Bulk                                                              Suspended based
                                                                                                                                               Based on        Test and adjust protec ve
                                                                                                                       (Distribu on)                                                          on current removal
                                                                                                                                            removal program       relaying as required
                                                                                                                          Sta ons                                                                  schedule

                                                                                                  2.6.       Vegetation Management

                                                                                                  The Vegetation Management Plan is described in Section 4. The current “Vegetation
                                                                                                  Management Specification” for 2014 through 2025 is included as Attachment 2.

                                                                                                  2.7.       General

                                                                                                  Employee awareness of system conditions constitutes a vital source of information for UI to
                                                                                                  address maintenance requirements. In addition to the maintenance practices described in
                                                                                                  Section 5.2, inspection and maintenance activities incorporate job tasks to identify vandalism
                                                                                                  and theft, and a follow-up reporting mechanism to take corrective action. Employees, as they
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travel to their work locations throughout UI’s territory, are encouraged to be observant and
   report any abnormal conditions to Electric System Operations & Maintenance so that
   appropriate action can be taken. This information, along with reports via telephone or
   written communication from our customers or others regarding abnormal system conditions,
   is captured in the computer-based Customer Request System. It is then forwarded to Electric
   System Operations & Maintenance for investigation and resolution, as required. The trouble
   conditions and subsequent resolution is captured in the customer call system, SAP.

6. Summary of Updated Maintenance Practices

   Inspection and maintenance is currently being performed as described in earlier sections.
   The following tables summarize the recommended changes to the maintenance cycle and
   practices for the major components of the T&D system.

   The Company continues to operate and maintain its system generally using the same
   practices that were in place as of the Maintenance Plan dated December 11, 2018. The
   maintenance practices in use are defined in our Reliability Centered Maintenance program,
   which has been in effect for approximately seventeen years. The Company continuously
   looks for opportunities to improve both operational performance and cost efficiency.

   In response to Docket No. 13-01-19, “Application of The United Illuminating Company to
   Increase Rates and Charges”, PURA approved $100 million for an 8 year plan for vegetation
   management during 2014-2021. In response to Docket No. 16-06-04, “Application of The
   United Illuminating Company to Increase Rates and Charges”, PURA approved $162 million
   for a 12 year plan for vegetation management extending the program to 2025. This storm
   resiliency program is based on Enhanced Tree Trimming (ETT) practices as presented in the
   State’s Vegetation Management Task Force (SVMTF) report. The major components of UI’s
   proposed program are:

      UPZ is UI’s storm resiliency tree work specification, creating an eight-foot side clearance
      ground to sky, retaining desirable low height or ornamental trees within the zone or those
      that are planted under the Right Tree – Right Place program. Additionally, the Company
      will identify and remove whole or parts of hazardous trees from outside of the zone that
      could fall causing damage to utility infrastructure, facilities or equipment.

      UI will document and track all objections, requests for modification and decisions made
      by municipal tree wardens and the State Department of Transportation through the full
      execution of Public Act 14-151 that cause nonconformities, or areas where UI is not able
      to meet these specifications within and outside of the Utility Protection Zone (UPZ).
      Instances of outages caused by nonconforming trees will be documented and considered a
      reportable performance attribute.

      In January of 2019, the Company implemented a Targeted Risk Management program
      where it schedules entire circuits for the pruning and removal of trees that are in direct
      contact with the conductors or have visible signs of burning. This was done to mitigate

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the effects of an extended cycle on safety, visual and physical access to the lines,
                                 equipment damage, and reliability.

                                 As a result of Docket No. 18-12-25 the Company ceased the Targeted Risk Management
                                 program January 1, 2021.

                          In regards to the impact on the schedule, compliance with PA-14-151 has a negative impact
                          on crew productivity and schedule completion because of the disruption it causes to the plan
                          and subsequent flow of work. The process required to resolve property owner objections,
                          requests for modification and no contacts (properties where the owner cannot be contacted in
                          person) is time consuming and results in tree crews working in an inefficient manner rather
                          than systematically moving down the road. The end result is increased non-productive time.

                          Other impacts associated with the implementation of the act are the time and effort necessary
                          to collect and manage the data requirements, and the municipal tree wardens and State
                          DOT’s ability to provide timely decisions on objections and requests for modification.

                          The cost of traffic control performed by municipal police officers continues to impact the
                          program cost and schedule. As the portion of the annual budget that goes towards traffic
                          control continues to increase, fewer scheduled miles can be completed. The cost for police
                          officers and vehicles continue to rise at an alarming rate and are becoming even more
                          disproportionate to the cost of a fully qualified and equipped line clearance tree crew or a
                          certified traffic control specialist. For example, the average cost of an officer and police
                          vehicle is $96 per hour. When compared to the cost of a tree crew with equipment at $128
                          per hour, the cost for municipal police officers paid at overtime and police car is out of
                          balance for a service that can be provided with a certified flagger at $25 per hour. Please
                          note these increases also impact all capital and maintenance costs associated with the
                          electrical Distribution infrastructure for which all costs are borne by Connecticut customers.

                    1.         Overhead System Changes
                               Category         Sub Category            Change                   Ra onale for Change

                         N/A                   N/A             No Changes              N/A

                    6.2. Substa on Changes
                               Category         Sub Category            Change                   Ra onale for Change

                         N/A                         N/A       No Changes              N/A

                    3.         Vegeta on Management Changes
                                Object                         Change                            Ra onale for Change

                                               The Company’s schedule for Vegeta on
                         Vegeta on             Management has been changed from an 8-
                                                                                      Docket No. 16-06-04 PURA Final Decision
                         Management            year (2014-2021) to a 12-year schedule
                                               (2014-2025).

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4.         Underground Transmission System Changes
                                                             Category    Sub Category               Change                    Ra onale for Change

                                                                                                                     Corrosion issues on cable supports have
                                                                                            Visual inspec ons        been corrected and no longer require
                                                       Cable and Cable   Solid Dielectric
                                                                                            changed from Annual to   monitoring. Cycle extension has been
                                                       Termina ons            Cable
                                                                                            a 2 year cycle           jus ed by a review of recent annual
                                                                                                                     inspec on data showing no ndings.

                                                                                                                     Completed in conjunc on with cable
                                                                                            Visual inspec ons        inspec ons (above). Cycle extension has
                                                       Splicing          Solid Dielectric
                                                                                            changed from Annual to   been jus ed by a review of recent
                                                       Chambers               Cable
                                                                                            a 2 year cycle           annual inspec on data showing no
                                                                                                                       ndings.

                                                  7. List of Attachments
                                                     1. UI Service Territory Map
                                                     2. Vegetation Management Specification, November 2014

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ATTACHMENT 1

       The United Illumina ng Company
            Service Territory Map

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Fair eld County           New Haven County

            Bridgeport                   Ansonia
              Easton                      Derby
             Fair eld                   East Haven
              Shelton                    Hamden
             Stra ord                     Milford
             Trumbull                  New Haven
                                      North Branford
                                       North Haven
                                          Orange
                                       West Haven
                                       Woodbridge

                            Internal Use
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ATTACHMENT 2

       THE UNITED ILLUMINATING COMPANY

                    VEGETATION MANAGEMENT
                         SPECIFICATION

                                         Revised November 2014

Table of Contents

                          Internal Use
Vegetation Management Specification

    The table of contents is empty because you aren’t using the paragraph styles set to appear in
    it.

    Introduction
    The United Illuminating Company remains committed to providing high levels of reliability, while
    simultaneously ensuring customer safety and satisfaction, and controlling cost. In 2013, the Company
    completed the sixteenth year of the Performance-Based tree trimming program. All customer requests and
    concerns about tree conditions are investigated and tree work is performed as required to eliminate those
    concerns whether from an electric safety or reliability point of view.

    From 1997 to 2013 the overhead distribution line clearance program consisted of a split four-year and
    eight-year cycle for planned tree trimming. The three-phase portion of the system was trimmed on a four-
    year cycle, while the single-phase portion of the system was trimmed on an eight-year cycle or where
    performance triggered more frequent trimming. Any single-phase portion of the system that experienced
    two or more tree related outages in a 36-month period was, at a minimum, trimmed to minimize the
    potential for future outages. Other system modi ications, such as reconductoring bare wire with covered
    conductor, may also be performed to help minimize the potential for future tree related outages. In
    addition, tree work is completed at new construction sites as needed.

    Beyond the Line Clearance planned circuit miles programs, the Company implements the following
    vegetation management programs to maintain or enhance the reliability of the electric distribution system:

       •   Hazardous Trees: The Hazardous Tree program requires the complete removal to ground of all
           identi ied trees. Hazard trees are identi ied in several ways including; UI vegetation management
           resources, contractor permissions personnel, tree trim crews, town tree wardens and customers.
           The hazard tree removal program is designed to remove trees identi ied as dead, dying, diseased or
           structurally defective and located outside of the normal trim area, but pose a potential hazard to UI
           facilities. The process involves identi ication of hazardous trees through the circuit trimming
           program, reliability engineer, and Line Clearance Arborist and Technicians followed by
           communications with customers, CDOT and/or municipalities to inform them of the hazard and to
           obtain their consent to remove.

       •   Vine Management: Vine Management is the removal of various vines from poles and guy wires.

       •   Distribution Rights-Of Way Line Clearance: Rights-of-Way Line Clearance is the removal of
           overgrowth on the distribution rights-of ways. Typically, such work is identi ied and generated
           through ROW inspections and maintenance trim cycles.

    Transmission lines are trimmed on a four year cycle (approx. 25% per year). The cycle based trimming is
    supplemented with inspection of 100% of the overhead transmission lines. UI’s Transmission Vegetation
    Management Program (TVMP) complies with the North American Electric Reliability Corporation (NERC)
    FAC-003-4 Standard, covering all the transmission lines operated at 200kV and above, and speci ic lower
    voltage lines designated by the Northeast Power Coordinating Council (NPCC) as being critical to the
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Vegetation Management Specification

reliability of the electric system in the region. Transmission line ROW are inspected annually by foot patrol
for the purpose of identifying vegetation conditions that could encroach the vegetation to conductor
clearance requirements, impact electric service reliability or create a hazard to the public.

UI continues to work with local tree wardens, as well as civic and professional groups, to help educate
customers about the proper selection and care of trees that may be planted near UI’s electric facilities. In
addition, safety brochures are distributed annually through bill inserts, and other events are held to
educate the public on the dangers associated with energized wires and the importance of having quali ied
tree contractors or UI line clearance crews remove hazardous tree growth. We believe that we can continue
to provide safe, reliable service in a cost-effective manner by working together with our customers in
matters of line clearance and vegetation management.

Scope
The scope of this speci ication is to provide requirements and guidelines for line clearance pruning and the
removing of trees, brush and other vegetation in close proximity to overhead electric distribution facilities
located on public and/or private rights-of-way.
      General:
      • The Company: The United Illuminating Company (UI)
      • Contractor: The irm that has been awarded a formal contract to perform work

Regulations
All work practices and de initions, except as otherwise speci ied herein, shall be in accordance with all
applicable Industry, Federal, State and Local laws and regulations, approved standards and safety practices.
These include all applicable sections of the following but are not limited to:
    ▪ OSHA 29CFR 1910.269 Electric Power Generation, Transmission & Distribution
       NERC FAC-003-4 Transmission Vegetation Management Program or current standard
    ▪ ANSI A300 “Standard Practices for Trees, Shrubs and Other Woody Plant Maintenance”
    ▪ ANSI Z133.1 “Pruning, Trimming, Repairing, Maintaining and Removing Trees, and Cutting Brush –
       Safety Requirements”
    ▪ NESC
    ▪ Connecticut General Statutes
    ▪ Department of Transportation
    ▪ Local Ordinances
    ▪ “Pruning Trees Near Electric Utility Lines” by Dr. Alex L. Shigo
    ▪ Best Management Practices, Utility Pruning of Trees

Evaluation

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Vegetation Management Specification

Each tree must be evaluated individually at least 10 days prior to any non-emergent or non-DC tree work
being performed by contractor work planners and/or crew personnel. At the time of the evaluation,
consent will be obtained from the property owner. Consideration must be given to the tree species,
condition, growth rate and failure characteristics, PROW limitations, tree location, the potential combined
movement of vegetation and conductors during routine winds, and sagging of conductors due to elevated
temperatures or icing when performing line clearance. This evaluation should include growth rate, species,
shape, condition and location of the tree and the likelihood of encroachment to the UPZ. When requesting
written consent for tree pruning or removal from municipal tree wardens, the State Department of
Transportation, abutting property owners and private property owners, UI’s tree contractor Work Planners
will use the 8 foot line clearance dimension as the starting point for evaluation of the UPZ and will normally
request the removal of all encroaching trees and limbs. The actual distance will result from the required cut
of the tree so that a healthy tree remains.

Pole mounted electrical equipment such as transformers, capacitors, switches, etc. should be provided at
least ten (10) feet of clearance and in accordance with the – UPZ.

Secondary conductors should be cleared such that tree limbs do not rub conductors or entangle the wire.

A.   Distribution Line Clearance Speci ication– Utility Protection Zone

     UPZ establishes the "utility protection zone" which is the rectangular area extending horizontally for a
     distance of eight feet from any outermost electrical conductor or wire installed from pole to pole and
     vertically from the ground to the sky.

     UPZ includes cutting, trimming and removal of tree limbs or trees within the utility protection zone
     and retaining desirable low height or ornamental trees that are already within the zone or those that
     are planted under a Right Tree – Right Place program. Additionally, the Company would identify and
     remove in whole or in part hazardous trees that could fall from outside of the zone causing damage to
     utility infrastructure, facilities or equipment.

     The following drawings illustrate the Utility Protection Zone:

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Vegetation Management Specification

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Vegetation Management Specification

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Vegetation Management Specification

    B.       Other Clearance and Operational Requirements
             Trees or limbs imminently hazardous to any part of the Distribution System shall be patrolled and
             mitigated with noti ication to and approval from quali ied UI personnel. Photographic evidence of the
             imminent threat is secured prior to threat mitigation, where possible or practical.

             Pole mounted electrical equipment such as transformers, capacitors, switches, etc. should be provided
             at least ten (10) feet of clearance in accordance with the UPZ.

             Secondary conductors should be cleared such that tree limbs do not rub conductors or entangle the
             wire.

             Remove hazard trees within the UPZ and on private property after obtaining written consent from the
             abutting private property owner.

             Pruning cuts shall be performed in a manner that retains the structural integrity and health of the
             vegetation.

             Consideration shall be given to critical loads and the number of customers served by the circuit
             segment where tree work is performed.

             No UPZ tree work shall be performed (pruning or removal) within the public right-of-way without a
             permit from the municipal tree warden or the State Commissioner of Transportation.

             Any non-hazardous tree located in whole or in part within the UPZ may be retained, provided that its
             species, condition and growth rate indicate that pruning without removal will reduce the risk of harm
             to the utility infrastructure.

             Written consent shall be obtained from the tree owner to prune or remove a tree on private property.

             “Brush” is de ined as an undesirable woody plant normally maturing at 20 feet or more in height, with
             single or multiple stems, and with a small, minimal, or no crown. It shall have a diameter at breast
             height (DBH, 4.5 feet above ground) of 6 inches or less. Brush shall be cut to the ground line where
             topography and obstructions will permit.

             Vines shall be removed from down guys and poles. If vines are in contact with energized wires, the
             worker while in an aerial lift shall cut out a section of the vine stem measuring approximately one (1)
             foot in length starting at a point approximately 30 inches below the lowest electric wire. Then, the
             worker shall ground cut the vine(s) a minimum 5 feet from pole or down guy.

             Street Lights – The local municipality is responsible to perform routine maintenance trimming to
             maintain street light patterns on sidewalks and roadways. Con licts with energized lines shall be
             referred to UI by the municipality. Limbs in direct contact with street light mast or head shall be
             pruned clear to reduce possibility of equipment damage.

             Private Area Lights – During routine maintenance, pruning should clear any vegetation on the pole
             which is obstructing the pole-mounted ixture.

    C.       Substation Vegetation Maintenance Requirements

             Substation facilities are maintained year-round to ensure security and safety of workers and the
             public. Trap rock within the fenced-in and energized areas must always be kept free of vegetation.

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