At the request of the Council of the Town of Fort Macleod (“Fort Macleod or “the Town”),

Forew ord

FortisAlberta Inc. (“FortisAlberta” or the “Company”) prepared the following report (the “Assessment”) at the request of the Town of Fort MacLeod (the “Town”). It contains an assessment of the current condition of the Town’s electricity distribution system combined with FortisAlberta’s recommendations for improvements to the municipality’s existing maintenance programs and suggestions for future system planning priorities. This report has been prepared as a courtesy. It is not intended to be relied on by the Town as constituting engineering, legal or other advice obtained for operational or risk management purposes. FortisAlberta based its initial assessment of the Town’s electric utility infrastructure on information obtained from the Town’s Director of Operations and Director of Financial Services. This information was supplemented by the results of a line patrol performed by one of FortisAlberta’s experienced Power Line Technician (PLT) working in conjunction with the Company’s Maintenance Coordinator, a Designer, and an Environmental Advisor. A FortisAlberta Safety Code Officer conducted an examination of the infrastructure to assess compliance with applicable code provisions. The information gathered in this process was also reviewed by a senior FortisAlberta Asset Maintenance Engineer. FortisAlberta assessed the overall condition of the Town’s distribution system using its own current electric utility construction and maintenance standards. FortisAlberta has, at the Town’s request, offered several recommendations to address identified deficiencies in the condition of its distribution system assets and improve maintenance practices.

i

Table of Contents

FOREWORD ____ i EXECUTIVE SUMMARY 1

INTRODUCTION 4

1.0 CONDITION ASSESSMENT OF ELECTRIC UTILITY INFRASTRUCTURE 5

WOOD POWER POLES 7 TRANSFORMERS 8 OVERHEAD CONDUCTOR 10 UNDERGROUND SYSTEM 13 STREETLIGHTS 15 EASEMENTS 17 SYSTEM DESIGN AND PLANNING 18

2.0 SAFETY REVIEW 19

3.0 ENVIRONMENTAL REVIEW 20

4.0 REVIEW OF CONSTRUCTION AND MAINTENANCE STANDARDS 21

RECOMMENDED DISTRIBUTION SYSTEM MAINTENANCE PROGRAMS 21 LINE MAINTENANCE PROGRAM 21 POLE MANAGEMENT PROGRAM 21 GROUND TESTING 22 SYSTEM RELIABILITY ASSESSMENTS 22 AIR BREAK SWITCH MAINTENANCE PROGRAM 22 RE-TIE CONDUCTOR PROGRAM 22 INSULATOR WASHING PROGRAM 22 LARGE TRANSFORMER MAINTENANCE PROGRAM 23 PADMOUNT TRANSFORMER MAINTENANCE PROGRAM 23 VEGETATION MANAGEMENT PROGRAM 23 REPAINTING 23 BULK LAMP REPLACEMENT 23

5.0 RECOMMENDED ELECTRIC UTILITY ACTIONS AND COSTS 24

ALTERNATE SOURCE OF ELECTRICITY 24

SYSTEM UPGRADE 24

ADDRESS NON-COMPLIANCE RISKS 24

COMPLETE URGENT MAINTENANCE 25

CREATE A MAINTENANCE PROGRAM WITH BUDGET ALLOCATIONS 26

Executive Summary

FortisAlberta is pleased to provide its assessment about the Town of Fort Macleod’s electric distribution system along with its recommendations for upgrading and ongoing maintenance, as a courtesy to the Town.

FortisAlberta has prepared this infrastructure and practices assessment utilizing extensive industry knowledge and expertise developed over many years of operating its own electric distribution system in accordance with good utility practice. This assessment also includes FortisAlberta’s recommendations for improvement of the Town’s existing utility construction and maintenance standards.

Background

The Town of Fort Macleod’s electric utility, consists of 99 kilometres of line, 963 power poles, 239 transformers and 428 streetlights (excluding streetlights owned by Alberta Transportation situated within the Town) and delivers power to 1,671 sites. The system is comprised of 56 per cent overhead and 44 per cent underground construction.

FortisAlberta owns and operates a portion of the electric distribution system within the Town of Fort Macleod, delivering electricity to 48 customers, or approximately three per cent of customers in the area. These customers are mainly commercial customers located in the south-east corner of the Town.

Summary of Electric System Assessment

FortisAlberta completed its condition assessment of the Town’s electric distribution system in the second quarter of 2016. Overall, the Town of Fort Macleod’s electric utility system currently appears to be functioning at required levels. However, FortisAlberta identified a number of areas of concern during the course of its review. For example, the Company was unable to find any indication that the Town is currently employing documented maintenance programs. The absence of such programs indicates to FortisAlberta that the Town’s system may currently be operating to “run-to-fail.” In FortisAlberta’s view, “run-to-fail” approaches, which do not actively manage assets result in higher long-term maintenance costs and lower customer satisfaction. They also leave systems vulnerable to more frequent and extended power outages.

1

The Town of Fort Macleod’s electric distribution assets are summarized in the table below.

Fort Macleod Customer Count (based on 2015 report) 1,671 Poles 963 Transformers 259* Overhead Conductor (metres) 55,789 Underground Conductor (metres) 43,072 Primary Conductor (metres) 45,872 Secondary Conductor (metres) 52,990 *Note: Total Transformer count includes units located in storage yard.

Table 1 – Represents the breakdown of the Town’s infrastructure

Key issues identified during the on-site assessment include:

 the poor condition of some identified power poles;  instances of exposed and improperly protected ground rods;  several instances of insufficient power line clearances;  missing security locks and safety decals on underground equipment; and  no evidence found of a procedure for the recording and reporting of oil spills from system assets.

FortisAlberta’s assessment also confirmed that the Town does not currently administer a scheduled maintenance program for its electric distribution assets. FortisAlberta recommends that a program with the following attributes should be implemented as soon as possible:

 regularly scheduled detailed line patrols;  wood pole testing and treatment;  Polychlorinated Biphenyl (PCB) transformer labeling program;  steel streetlight pole testing and lamp replacement; and  repainting of weathered and rusted steel streetlight poles, transformers, and cubicles.

The Town of Fort Macleod is in the process of upgrading its existing 4,160 V infrastructure to the current industry standard electric system voltage of 25 kV. FortisAlberta’s assessment confirms that good progress has been made to date on this initiative. However, approximately 38 per cent of the Town’s existing infrastructure is still operating at a voltage of 4,160 V or less.

2

FortisAlberta recommends that the Town continue upgrading its system and that it place a high priority on implementing current design and construction standards while doing so. The Company also recommends that the Town should adopt maintenance programs that align with best practices on a go-forward basis. The Company notes that additional efficiencies might be realized through scheduling coordination between remedial and maintenance activities e.g., poles of a vintage more than 40 years that are replaced, as part of the overall system upgrade would not be included in the testing and treatment aspect of the maintenance program.

Summary of Standards and Construction Maintenance Review

FortisAlberta’s review of the Town of Fort Macleod’s electric system standards and programs revealed no evidence that construction standards or maintenance programs and practices are currently being applied. Similarly, FortisAlberta was not provided with evidence that the Town is currently implementing any documented safety programs or policies. The Town does not currently appear to maintain its electric system using formal programs that require the adoption of standardized practices/or generate a complete documentary record of all maintenance activities performed to facilitate ongoing asset management.

Good electric utility management practice includes the adoption of standardized maintenance and record keeping programs, which are important features of an effective overall maintenance policy.

FortisAlberta is recommending the Town initiate:

 implementation of a Health and Safety Management System;  development of comprehensive environmental management system;  adoption and implementation of “good utility practice”based engineering standards;  adoption of minimum construction standards, ensuring as the system is upgraded and new additions are built in accordance with current system codes and regulations; and  creation of a database of easements and registered right-of-ways for the utility’s infrastructure located on private property.

FortisAlberta also recommends that the Town immediately take steps to address the fact that its electric system is currently sourced on a single breaker at a substation located to the north west of the Town. The practical consequence of the current arrangement is that the Town’s entire electrical system has a single source of supply. An outage at this substation, or at any point along the feeder coming out of the substation, would result in a community-wide power outage. The best solution to the current problem would be to implement an alternate feeder solution to minimize the potential for wide-spread outages resulting from a failure at this single system location.

3

Introduction On May 9, 2016, the Town of Fort Macleod requested that FortisAlberta undertake an assessment of its self-operated electric distribution system. FortisAlberta completed the requested assessment based on its understanding of: 1. the results of a condition assessment conducted on the electric utility infrastructure; and

2. current electric utility construction and maintenance standards including best practices employed by the Company.

The Town provided FortisAlberta with basic financial information related to the operation of its electric distribution system, records relating to tests performed on wood power poles and Polychlorinated Biphenyl (PCB) assessments of transformers, and comprehensive documentation about its metering system. The Town was, however, unable to provide the Company with documentation related to the past or current operation and maintenance of its electric distribution system e.g., maintenance logs or asset records.

During the week of June 13, 2016, six FortisAlberta employees performed an on-site assessment of the electric system. FortisAlberta’s on-site team consisted of:

 Senior Planner, Asset Management,  Design Specialist/Technologist,  Power Line Technician (PLT) performed an inspection of the system for operational concerns,  Supervisor of Environment who performed an inspection of the system for environmental concerns, and  Safety Code Officer, who was tasked with identifying safety compliance concerns or potential safety issues.  Manager, Major Accounts, who was tasked with gathering data and identifying outstanding information.

In addition, an Asset Management Engineer reviewed the information gathered and contributed to the completion of the assessment.

4

1.0 Condition Assessment of Electric Utility Infrastructure The information provided to FortisAlberta indicated the Town currently serves 1,671 metered sites including 1,394 residential, 261 small commercial, and 16 large commercial. The assessment included all poles, transformers, conductor and streetlights.

The Town, like all owner-operators of electric utilities, is required to construct, maintain and operate its system in accordance with applicable laws, which include:

 Occupational Health and Safety Act (Part 40 - Utility Workers)  Alberta Electric Utility Code (AEUC)

In practice, utilities also adopt various industry standards and best practices, as endorsed by some or all of the following:

 Canadian Standards Association (CSA) Standards  Institute of Electrical and Electronics Engineers (IEEE) Standards  Illuminating Engineering Society of North America (IESNA) Standards

Part of the function of this report, as requested by the Town, is to identify where the Town’s electric utility system may potentially be at risk of non-compliance with one or more of these best practices.

For the purposes of this assessment, one of the most important documents to be considered is the Alberta Electric Utility Code (AEUS). Its provisions are followed by all high-voltage overhead utility system owners operating in Alberta. One of the objectives of the code is to establish minimum safety standards for the installation and maintenance of electrical utility systems. Ongoing documentation of maintenance activities is an important aspect of operations and helps to ensure that an electrical system is continuously operated in accordance with the AEUC.

FortisAlberta’s review also revealed other deficiencies relating to pole installation and maintenance that were evident on visual inspection. These included, but were not limited to, field observations of identified ground rods that were completely exposed (or otherwise did not have adequate protection) and instances of inadequate line clearances.

The Company’s review of underground facilities, which was limited to surface-accessible structures, revealed cases of missing security locks and safety decals. In FortisAlberta’s view the equipment identified in these cases is potentially non-compliant with applicable safety codes and standards.

5

FortisAlberta field representatives also identified locations where tree trimming is urgently required. In some cases, it appeared that inadequate line clearances had already resulted in burns to tree branches. These sites present serious and immediate safety hazards.

The Company also identified several instances of potential non-compliance with applicable environmental regulations. For example, its review could not confirm that the Town currently has a policy or program in place to ensure that any oil spills occurring within its distribution system are adequately reported to Environment Canada.

FortisAlberta’s review of the Town’s electric utility system indicates that a significant portion of the system has reached, or is nearing, the end of its service life. The deterioration of this equipment has been accelerated due to the lack of adequate maintenance practices.

The Town should be commended for its continuing efforts to upgrade the existing 4,160 V infrastructure to the modern 25 kV standard. Notwithstanding the progress that has been made to date, FortisAlberta has calculated that approximately 38 per cent of the Town’s infrastructure is still operating at 4,160 V, or less.

The Company agrees that the continued upgrade to the modern 25 kV electric distribution system standard will provide multiple benefits to both the Town and its customers. The use of outdated system components can result in low voltage, and voltage fluctuation issues at customer sites. If unresolved, both these problems can result in damage to customer equipment, including appliances and other household items. Power quality improvements will also result from the adoption of the 25 kV standard because it promotes maintenance of stable voltage and limits line loss. Upgrading to a more modern system will also facilitate system expansion to allow for future customer growth and demands. Finally, the adoption of modern distribution voltage equipment will permit easier access to replacement part inventories and permit the operator to take advantage of related cost efficiencies. In FortisAlberta’s view, special consideration should be given during the system upgrade planning as the Town’s electric system facilities are currently fed from a single source direct transmission connection. Consequently, the entire reliability of Fort Macleod’s electric system is essentially based on a single breaker found on a feeder originating from the 41S substation to the northeast of the Town. Instances of Town-wide outages, and the related effects on residents and businesses were identified in the February 2016 Municipal Inspection Report released to the public through the Town’s website. To mitigate the impacts of a Town-wide power outage, FortisAlberta recommends the Town consider an alternate feeder option or distributed generation option to reduce its electrical dependency on a single substation breaker.

The following sections of this assessment will address each of these areas of concern in more detail.

6

Wood Power Poles The Town was unable to provide asset records for power poles. Consequently, FortisAlberta created estimates for the age of many poles based on their observed condition and the age of the subdivision they are located in. FortisAlberta’s assessment indicates that Fort Macleod’s electric system includes 963 poles ranging in an estimated age of two years to 61 years old. In the Company’s experience, the life expectancy of a wood power pole that undergoes regular testing and maintenance is 50 years, without regular maintenance their life expectancy is reduced to 40 years.

FortisAlberta was provided with records from a pole test completed by a third party in 2009. The 2009 test report concluded that 51 poles of the poles inspected had failed and required replacement within one year, and that 94 poles would need to be replaced within five years. FortisAlberta’s review of the 2009 testing notes raised concerns that standard pole testing practices were not followed in the earlier review. Consequently, the review may have not identified all the poles with structural issues.

In any event, FortisAlberta’s current assessment revealed that many poles tagged in the last review with a red marker indicating a failed pole, or with a yellow marker indicating near failure, still remain in service. Some of these failed pole markers were found on critical pole structures, such as those found at the river crossing. FortisAlberta was unable to locate any evidence that action was taken following the completion of the 2009 study to remove the failed poles or to perform additional maintenance on poles to extend their useful life. The Company notes that Canadian Standards Association (CSA) Code requirements dictate that “when the strength of a wood pole structure has deteriorated to 60 per cent of the required design capacity, the structure shall be reinforced or replaced.” Figure 1: Pole marked with red tag indicating a pole failure

Based on the information available at the time of FortisAlberta’s assessment, the Company concludes that including the above mentioned 145 previously tested wooden power poles, 428 currently in service have already reached the end of their service lives and a further 77 poles will reach the end of their service life within the next 10 years.

7

During the on-site field assessment, it was noted that many poles have been installed directly into the driving surfaces of roads. This practice exposes the structures to additional risk of damage, thereby reducing the anticipated operating life of these assets. Poles damaged as the result of this kind of placement also present challenges to future maintenance because they may be unsafe for PLTs to climb and, consequently, require the use of bucket trucks for routine maintenance. Furthermore, from an operations perspective, poles surrounded by asphalt and concrete severely limit access opportunities when trying to connect future facilities. Figure 2: Pole set in driving surface with visible damage Adoption of standardized construction practices that to the underground cable guard follow engineering standards would limit future occurrences of poles being placed in roadways or guy wires constructed in driving surfaces. Where they already exist, these placements should be corrected to improve asset life expectancy and minimize public safety concerns. Another benefit of the relocation of poorly placed system assets is the facilitation of future testing and maintenance activities.

Transformers The Town’s system currently utilitzes 144 pole- mounted and 115 padmount transformers. The documents reviewed by FortisAlberta were missing Figure 3: Unconventional placement of guy wire allows numerous transformer vintage records and many for increased risk of damage manufacturer labels on the transformers were not legible or visible during the field assessment. Because FortisAlberta was unable to access name plate data, it relied on the assumption that the age of a given transformer is either the same as the pole it is mounted on, or in some cases, equivalent to that of the subdivision in which it is located.

Based on this assumption, FortisAlberta estimates that approximately 26 per cent of the transformers currently in service are more than 30 years old. FortisAlberta’s experience is that transformers have an average service life of 30 years. However, the majority of FortisAlberta transformer retirements are caused by drivers such as increased capacity requirements,

8

obsolescence, storms, lightning strikes, and forest fires. Given Fort Macleod’s environment, FortisAlberta anticipates that transformers could display a service life more than 30 years with proper maintenance practices being applied.

FortisAlberta noted that many transformers located in the Town are showing signs of long-term wear. During the visual inspection, some transformers were found to display signs of potential oil seepage.

Due to the age of transformers on the Fort Macleod system, there is a risk that Polychlorinated Biphenyl (PCB) contaminated oil may be present in some transformers. This may significantly heighten the environmental consequences of a spill, should one occur. Oil-filled Figure 4: Oil staining on base of padmounted transformer in a residential transformers manufactured prior to area 1983 may have been contaminated with PCBs if the manufacturer also made other PCB-filled apparatus. Federal environment regulations currently require owners to identify assets that display a PCB concentration of greater than 50 ppm, and remove them from service by 2025.

FortisAlberta understands that the Town completed a PCB testing program in 2000, and that several transformers were identified as having unacceptable PCB concentrations present at that time. The Company was not able to determine what became of some of these contaminated transformers based on its review of the documentation it was provided with. The Company is therefore recommending that an audit be performed to ensure all PCB transformers were removed from service and that corresponding documentation matches that the transformer PCB oil was properly disposed of. New signage should also be installed on the existing transformers as the original testing information is either missing or the signage has faded.

Finally, FortisAlberta recommends the adoption of a tagging program that would allow staff to respond appropriately in the event of a transformer failure, where the affected asset is potentially contaminated by PCBs. The level of PCBs in a failed transformer determines the level of response required for area cleanup and subsequent transportation and disposal of equipment.

9

Overhead Conductor During the site check, both primary and secondary overhead conductor was assessed, with several vertical and horizontal clearance issues being identified. There were instances where secondary heights were determined to be unacceptable on visual inspection.

FortisAlberta notes that while some line clearances may meet the grandfathered height requirements based on the age of the system, today’s AEUC code requires greater power line clearances to accommodate the height and size of modern day equipment. Any future modification or upgrading to the system should be completed in accordance with AEUC

requirements, where safety hazards exist.

y

Figure 5: Orange ribbon used to mark low hanging secondary conductor

10

The Company identified some significant brushing concerns. In several locations, trees displaying burn marks resulting from contact with conductor were observed. This is indicative of a serious fire hazard and also creates a potential for electrical shock and power quality issues. Tree trimming in these areas should be made a priority.

Figure 6: Tree branches rubbing power lines some with burn Figure7: Tree having overgrown the power lines marks

FortisAlberta also observed instances of insufficient clearance to buildings. Current standards require a minimum of three metres horizontal and five metres vertical clearance around from power distribution lines. For example, the three-phase line displayed in the photo below, which is located adjacent to the Town’s Sports Centre, requires taller poles in order to meet current AEUC requirements and mitigate associated safety risks.

Figure 8: Non-compliant line clearance – Too close to building

11

FortisAlberta also discovered cases where guy wire connections to a pole were attached above the live conductor. This creates a potentially dangerous situation because the structure could become energized if a failure were to occur. Additionally, some identified guy wires were not fitted with appropriate plastic shielding. Provision of such protective shielding is a code requirement except in locations where cross-country, vehicular or pedestrian traffic is not expected. FortisAlberta’s standard is to install plastic guards over all guy wires.

The system assessment also discovered old poles with unprotected ground rods. In some cases, ground rods were totally exposed to the air, which will result in premature aging of the asset and potential safety issues. There were also several instances where anchors were found to have been overgrown. This will result in the rusting away of the anchor over time. Anchors are vitally important to overhead infrastructure because they keep the power line under tension and prevent the Figure 9: Anchor is overgrown and beneath ground distribution line from falling over. cover

FortisAlberta’s review also revealed several access issues resulting from insufficiently sized utility right-of-ways and the use of non-standard structures and line arrangements e.g., secondary line installed above the primary. These circumstances create locations that are difficult to safely work

on, and will add to the length of time required to restore power in the event of an outage.

The fact that standardized engineered construction practices were not followed in the past has resulted in some areas of the system not being constructed to minimize safety and reliability concerns. FortisAlberta’s system patrol identified some congested overhead construction areas, which make working on the system difficult and potentially result in larger number of customers being without power for an extended period of time in the event of an outage. Instances of using non-standard methods to maintain old structures, such as using wood screws to hold up structures and keep them operating, were also identified.

Figure 10: Congested Overhead Construction 12

Based on conversations with Town staff, FortisAlberta understands that a detailed line patrol has not previously been performed on the municipality’s assets. The completion of regular detailed line patrols is a standard practice that identifies maintenance requirements including immediately required repairs related to safety issues. These patrols also enhance asset management and safety programs by providing owners with ongoing insight into the condition of their systems.

For example, during a properly documented line patrol, employees would be expected to note situations such as the one illustrated in the photo below, where a pole is built into a meter shack and identify it for remediation. FortisAlberta’s practice is to maintain five metres clearance around poles to ensure employees can safety climb or operate equipment at the pole.

Underground System The Town was unable to produce any Underground Residential Development (URD) construction drawings documenting their underground electrical system. During its assessment, FortisAlberta learned that there is potentially a portion of the existing underground system where 15 kV underground cable was installed. FortisAlberta cannot validate this information without being provided with additional documentation. In the event that the Town is able to confirm that 15kV cable has been installed in any portion(s) of its underground system, it should consider replacing it with 25 kV-rated materials to both limit the potential for future failures Figure 11: Power pole built into meter shack in the event that it is ever energized at 25kV, and facilitate ongoing system development.

The current lack of URD-engineered drawings for the Town’s underground system may complicate future planning efforts, especially if the use of various conductor types is confirmed in different portions of the system.

The Town has historically assigned responsibility for underground conductor choice to individual land developers. This practice should be avoided if possible because it can lead to inconsistent use of equipment across the system and hamper the Town’s future system planning efforts.

During its field assessment, FortisAlberta noted that many of the system’s transformers do not have proper decals, such as “Do Not Climb” and “High Voltage” signage. Additionally, some underground pedestals did not have proper security locks. The Town should address the absence of signage and locks as soon as possible.

13

Unconventional construction practices were also identified. For example, the placement of some padmount transformers is not ideal e.g., in roadways. In addition, some transformers were set on a “poured in place” concrete base, which makes future maintenance more difficult.

Transformers are critical to the reliability of an electrical system and represent a significant portion of the value of the system. Many of the transformers in the Town are in need of immediate attention due to the lack of previous maintenance. Examples of required maintenance include painting Figure 12: Transformer constructed in roadway and without any and ground testing. decals

Figure 13: Underground equipment in need of paint and Figure 14: Damaged underground equipment missing safety decals

FortisAlberta observed that several padmount transformers located in the downtown were constructed without any bollard protection. This must be corrected because the lack of these safeguards leaves these assets susceptible to preventable damage, and unnecessarily risks both the transformers’ asset life and public safety.

14

The Company’s assessment also identified 4,160 V switch gear located on the western side of the Town that current safety regulations dictate can only be serviced by personnel equipped with full arc flash suit Personal Protective Equipment (PPE).

Figure 15: Transformer without any bollard protection Figure 16: Switch owned by the Town of Fort Macleod located in Substation

Streetlights Information received from the Town indicates it currently owns 428 lights. FortisAlberta’s review also noted that the Town operates an additional 148 highway lights owned by Alberta Transportation, which were not included in the assessment.

A variety of different styles of streetlights are installed across the system, including many non-standard lighting configurations. FortisAlberta’s review indicates that many current lighting levels do not conform to Illuminating Engineering Society of North America (IESNA) standards.

Application of lighting types is also inconsistent. For example, some streets were lit with non-roadway lighting, such as the flood lights found on Main Street, and some

streetlights were being used to light private property, such Figure 17: A post top luminaire used for parks or as a car dealership. pathway lighting. It does not meet streetlight IESNA standards for roadway lighting use.

15

Placement of some streetlighting is also not ideal. Some streetlights were found to be installed in roadways, some are located in sidewalks, and still others are situated in the middle of residents’ front yards. These kinds of placements create unnecessary risks of asset damage.

Streetlights with break-away bases were found in residential areas. This type of construction is Figure 18: Streetlight installed in roadway intended to be used in highway applications where the speed limit is greater than eighty kilometers per hour. It is a safety feature for potential high-speed impact areas that is not appropriate for residential traffic. In the event that a car collides with one of these break-away base streetlights, the pole may fall and cause unnecessary damage to property, equipment or a pedestrian.

There was also evidence of streetlights being set on poured-in-place concrete bases. This is more costly than using pre-formed bases, and makes future maintenance more difficult.

During the visual inspection, it was noted that many steel streetlight structures are in need of paint. No streetlight testing data was obtained by FortisAlberta. However, all steel structures should be tested prior to painting to determine the integrity of the asset. A standard industry practice is to test the steel poles on a regular cycle prior to painting, to ensure each is structurally sound and safe.

Due to the close proximity of steel streetlight standards to roadways, road spray can cause steel streetlight structures to age prematurely and fail unexpectedly.

No documentation was provided to FortisAlberta concerning the age of the street lights or the presence of a bulk lamp replacement program. A bulk lamp replacement program is a standard maintenance practice where each bulb is replaced on a five-year cycle.

High Pressure Sodium (HPS) light bulbs of the kind currently used by the Town typically have a manufacturer’s rated life of 24,000 hours (or approximately six years) under typical conditions in Alberta. Although some HPS bulbs will last longer than this, their failure rate increases and light output decreases as they reach the end of their projected service lives.

FortisAlberta understands that the Town has started converting some of its streetlight fixtures to LED technology. The Company expects that the Town will see benefits from these conversions in the form of reduced energy consumption. FortisAlberta recommends that the scheduled LED conversion also be used as an opportunity to review lighting design and improve lighting levels to meet IENSA standards.

16

During its assessment, FortisAlberta discovered that the Town has already installed new LED fixtures on the streetlights along Highway 3. However, while the Town currently pays and maintains these fixtures, they are actually owned by Alberta Transportation. Situations such as this can be avoided in the future by adopting a comprehensive streetlight mapping program, including a regularly updated database.

FortisAlberta also identified safety concerns relating to unsalvaged streetlight bases. It appears these streetlight bases are no longer in use, but have not been removed. These situations present tripping hazards for pedestrians. Typically, locations like this would be marked with a safety cone or metal enclosure that houses the wire and bolts to the existing concrete structure. Multiple locations similar to the images below were found within the system.

Figure 21: Streetlight base with bolts present Figure 22: Streetlight base with cable looped

Easements FortisAlberta’s on-site assessment identified a number of concerns related to overhead trespass issues within the Town. FortisAlberta understands that the Town staff are aware of this issue. Securing easements is a standard construction process implemented by utility owners to limit risks and liabilities surrounding the use of real property. If the landowner will not grant an easement, it is normally the utility owner’s responsibility to remove its assets from the property at its own expense.

17

As shown in the picture below, secondary poles have been installed to keep the secondary line high enough that it does not create a safety issue for vehicles traveling down the road. However, this solution has created other issues because the additional poles are now located on both sides of the street. Additionally, a potential trespass caused by the secondary lines traveling over one property to another customer’s site has not been resolved.

Split secondary

Figure 23: Low secondary overhead lines, with poles planted on customer property

System Design and Planning FortisAlberta understands that Fort Macleod has been constructing loops within its system to improve the reliability of the electric distribution system by allowing alternate flows of electricity. A loop feed provides the flexibility of directing electricity in different directions during a planned or unplanned power outage. FortisAlberta considers this a good system practice that will improve overall system reliability within the Town.

As previously noted, the Town’s electric system is directly connected to the transmission system on a dedicated breaker located within the 41S substation. This system design has the potential benefit of reducing certain distribution tariff-associated costs. However, this also means that there is effectively only one source of electricity . Failure at a single site to cause a community-wide outage.

Regardless of the improvements being made to loop feed the Town’s businesses and provide alternate electricity solutions within the community, the single feeder and breaker serving the Town will remain as the only source of supply until another system solution is adopted. This electrical equipment is susceptible to storms, mechanical failures and requires maintenance shut downs that would result in a widespread outage for customers within the Town. FortisAlberta understands that, at one time, the Town did have a secondary feeder but it was subsequently

18

removed due to cost concerns. For reassurance and reliability of the Town’s electrical system, FortisAlberta recommends that an alternate electrical feed should be built.

2.0 Safety Review The system assessment performed by FortisAlberta’s Safety Code Officer, does not constitute a comprehensive safety audit. Nonetheless, certain safety concerns were identified. The table below highlights of the most noticeable potential safety infractions and the corresponding safety code or regulation.

Issue Description Applicable Standard Streetlights may not meet There were several non- IESNA Standard RP-8-14 Roadway IENSA Standards standard lighting Lighting configurations identified including the use of non- streetlight type fixtures

Pole Testing Numerous poles identified as CSA.C22.3 no. 1-15 Clause 8.3.1.3 “fails” during testing completed seven years ago are still in service

Padmount electrical No, or insufficient, warning CSA.16.5.1 Identification of apparatus, underground equipment labelling devices, and enclosures (warning labels)

Guy wire guards Several guy wires are not CSA. C22.3 no. 1-15 Clause 4.2.8 adequately guarded

19

3.0 Environmental Review The system assessment performed by FortisAlberta’s qualified Environmental Advisor, does not constitute a comprehensive environmental audit. Nonetheless, certain potential environmental concerns were identified during the assessment. The table below highlights of the most noticeable environmental concerns and the corresponding regulations.

Issue Description Regulation or Legislation Potential Transformer Possible oil spill in the transformer Environmental Protection and Storage Area Oil Spill storage area behind the shop. Enhancement Act. Section 109 and Section 110. Transformer Storage Numerous old transformers stored Environmental Protection and behind the shop. Some are stored in Enhancement Act. Section 109 secondary containment others are and Section 110 not. The transformers are old and may contain PCBs. PCB Testing Records Equipment was tested in 2000 Environmental Protection and however, documentation is lacking Enhancement Act. Canadian about how the Town has addressed Environmental Protection Act, the identified PCB equipment Section 15. Transformer Oil Seepage Both pole mounted and padmount Environmental Protection and transformers display evidence of Enhancement Act. Section 109 potential leaks and Section 110. Employee Training No documented evidence of PCB Canadian Environmental training and handling procedures Protection Act, Section 28 states having been developed or what employees must know to implemented. work in areas containing PCBs. Improper labeling of drums Two suspect drums identified. No Applicable standards will vary adequate labeling is present. according to drum contents. Please see note below. Environmental Policy No evidence of environmental policy This is an industry best practice. or processes having been developed or implemented.

20

4.0 Review of Construction and Maintenance Standards In FortisAlberta’s view, the Town should consider implementing construction standards and maintenance programs that are similar to those highlighted in the following section. If implemented and adhered to, these programs and practices will ensure the condition of the Town’s electric distribution system assets is known and documented.

Under maintenance programs, assets are assigned a frequency that inspections and, where appropriate, diagnostic testing is performed. These maintenance programs are essential in the provision of reliable service to customers in a safe and environmentally responsive manner.

Maintenance programs are designed to:

 minimize failure causes and their effects;  comply with provincial and federal regulations;  address safety and environmental concerns;  improve system reliability; and  minimize cost by restoring equipment through a planned process prior to failure, thus reducing costs and extending life.

In general, equipment that has been determined to be at the end of its rated life or service life from an operations perspective is replaced to avoid unplanned failures. FortisAlberta considers rated or service life, along with condition based testing, visual inspections, and outage data to determine when a particular component is near or at the end of its service life and needs to be replaced

Recommended Distribution System Maintenance Programs

Line Maintenance Program Ideally, electric distribution systems should be patrolled annually by PLTs. These patrols identify potential problems and safety issues e.g., broken insulator, lightning damage, line clearance. In addition to annual visual inspection, a detailed line patrol should be conducted on each circuit on a periodic basis e.g., once every five to seven years, field information can then be compared to asset records provide information for required updates. Work required to correct deficiencies should be recorded and prioritized. Work that is assigned a high priority should be fixed immediately; work assigned a medium priority should be completed within two to six months; and work assigned a low priority may be completed the following year.

Pole Management Program A pole testing cycle should be completed on a periodic basis, in conjunction with a detailed line patrol. Wood poles with streetlights should be included in the pole test program. Poles that are

21

fifteen years old, and older, should be subjected to a three-hole drill test to check for decay. Poles should also be assessed for stubbing and replacement requirements based on decay or damage. Pole replacement, stubbing, and external treatment work should normally be completed in the year following the pole test that identified the problem.

FortisAlberta’s experience and industry research indicates that with a Pole Management Program, a wood pole can be expected to last between 50 and 70 years. Without treatment, the life expectancy of a pole is 35 to 40 years.

Ground Testing Resistance testing of distribution system grounds is conducted on a sampling basis, in conjunction with the pole test. All system ground replacement work that is identified is completed in the following year.

System Reliability Assessments System reliability assessments are an important part of good utility management practice. These assessments selectively identify portions of the system experiencing reliability issues based on outage records confirming the number, duration and extent of service interruptions. Regular completion of these assessments can assist the Town in identifying equipment that may require repair or replacement to avoid insignificant or repeated outages in the future.

Air Break Switch Maintenance Program Air break switches are manually operated and are used to isolate sections of distribution lines to perform maintenance or power restoration work. Over time, these switches can become corroded and misaligned due to exposure to weather.

Initial maintenance activity for this equipment should include infrared thermal scanning, lubrication, adjustments, and part replacement. After the initial maintenance work has been completed, the air break switches should be maintained on a pre-defined cycle.

Re-tie Conductor Program Over time, climatic stresses cause conductors to become slack and, in some cases, create clearance issues resulting in reliability and safety hazards. To repair these conductors, they must be untied, re-sagged to engineering specifications, and then re-tied. A program should be put in place to ensure that the Town’s system is monitored to identify cases in which reties are required and ensure that the required work is completed in a timely manner.

Insulator Washing Program Road salt, dust and other pollutants can all cause insulator contamination. Over time, this contamination will render insulators ineffective, resulting in power outages. Outages caused by contamination are typically long duration outages due to the damage caused by insulator flashover and possible pole fires. To reduce the number of outages resulting from insulator

22

contamination, the Town should implement a program to wash overhead structures, insulators and switching cubicles. Detailed line patrols can identify areas where this is a concern.

Large Transformer Maintenance Program All large transformers should be inspected on a routine cycle. These inspections should involve visual assessment, infrared thermal scanning to detect overloads or bad connections, and a dissolved gas oil test to assess the condition of the transformers’ internal insulation.

Padmount Transformer Maintenance Program The Town should implement a maintenance routine for all padmount transformers older than 20 years of age. This program should include cleaning, lubricating, and replacing any components that are found to be faulty on visual inspection.

Vegetation Management Program The Town should implement a vegetation management program incorporating standards and policies endorsed by the Industrial Vegetation Management Association of Alberta and ensure that its power lines conform to AEUC clearance requirements The vegetation management program should be conducted on a three-year cycle. These programs are normally comprised of four work categories: trim, slash, spray and mow. Emergency trimming takes place annually, as and when required.

Repainting Facilities such as steel streetlight poles, padmount transformers, and pedestals, require periodic repainting. A visual inspection program should be implemented to determine the need to repaint steel facilities. Structures such as steel streetlight poles also require physical assessments, including hammer and ultrasound testing to determine the integrity of the steel prior to repainting. Facilities that require repainting may also be identified during the detailed line patrol where the integrity of the structure is assessed, by PLTs, or reported by the public. In many repainting programs, work is normally completed in the year reported, weather permitting.

Bulk Lamp Replacement High Pressure Sodium (HPS) light bulbs have a manufacturer’s rated life of 24,000 hours or about six years. Although most HPS bulbs will last longer than this time frame, their failure rate increases and light output decreases. The Town should implement a program aimed at reducing streetlight outages by changing all bulbs, inspecting ballasts and cleaning fixtures based on the percentage rates of failures for the area.

23

5.0 Recommended Electric Utility Actions FortisAlberta has identified several recommendations for the Town to improve its electric system’s performance and overall reliability.

Alternate Source of Electricity The current configuration of the Town’s system sources electricity from a single dedicated breaker located within the 41S substation. FortisAlberta is recommending the Town investigate an alternate tie line to secure another source of electricity for their community.

System Upgrade The conversion of the existing 4,160 V infrastructure to 25 kV infrastructure is highly recommended. This modernization will eliminate current voltage issues experienced by the Town’s customers and will mitigate risks associated with a lack of replacement materials.

Addressing Potential Non-compliance Risks PCB Testing The Town has completed PCB testing in the past. At one time, transformers had a label installed on them stating the test date and results. In many cases, the label has faded or has fallen off due to weathering. It is recommended that an audit of the existing data is conducted with the transformers in the field and that these transformers have proper identification of current PCB levels or state that they are non-PCB. Additionally the Town should review the requirements outlined by Alberta Environment and Parks on the storage of PCB equipment and materials. FortisAlberta recommends the Town develop internal policies and practices to identify all types of materials stored in its storage yards ensuring adherence to the legislation

Conductor clearance repair Inadequate clearances were identified on some overhead construction located throughout the Town. This is a safety concern for both the public and Town employees. Options to address this safety non-compliance include relocating the line or underground burial. It is recommended that this concern be addressed immediately.

Vegetation Management The Town’s system requires emergency trimming of trees that are currently encroaching the safe limits of the distribution system. Typically, Vegetation Management takes place on a three-year cycle and involves trimming, slashing, mowing and treatment of trees to maintain clearance to energized wires required for the safety of the public, legal compliance and service reliability. This maintenance activity includes a patrol by circuit for vegetation that has grown into or will affect the system over a period of time. The patroller will identify problematic vegetation and will determine the required treatment.

System Grounding Test the grounds and perform associated repairs to ensure adequate grounding at the pole. Examples of inadequate system grounding were identified during the assessment, and need to be addressed immediately.

24

Wood Pole Replacements A pole test performed in 2009 identified 51 poles as failed and an additional 94 poles projected to fail within five years. From a compliance perspective, replacement of these 145 poles is a priority. Safety Signage The review identified that safety signage was either missing or needs to be replaced on numerous pieces of equipment throughout the Town. Easements and Rights-of-ways Insufficient easements were noted during the system assessment. This is a liability for the Town and needs to be addressed. Additionally, construction processes should be created to ensure easements are secured prior to any electric utility work being performed.

Complete Urgent Maintenance Detailed Line Patrol and Maintenance The patrol of a distribution system involves an evaluation of the integrity of its physical characteristics and conformance to appropriate regulations. Patrols are conducted to identify deficiencies in the electrical system owned or maintained by FortisAlberta that could compromise safety, service reliability, or line integrity. These predictive maintenance patrols provide information in the form of data, statistics, observations, assessments, and recommendations of corrective maintenance to be performed on the distribution system to ensure public and employee safety, provides appropriate reliability, and prevents high consequence failures. Detailed line patrols usually result in the detection of deficiencies within the system. Repairs are typically completed within one year of the patrol.

Wood Pole Testing and Treatments A pole test should be performed on all wooden poles and based on this test, poles should be replaced or treated to extend their life. Aside from the previously identified failed poles, from the 2009 test, 283 wood poles are estimated to be older than 40 years. It is likely that these poles will fail a structural test.

Streetlight standard testing Inspections are completed visually and hammer inspected. If there is visible rust or doubts of integrity of the steel pole, an ultrasound inspection is required.

Bulk Streetlight Lamp Replacement High Pressure Sodium light bulbs have an effective life expectancy of approximately six years. During their life, the quality of the light output diminishes. FortisAlberta is recommending replacement of lamps be completed immediately. Alternatively, the Town might consider converting all of the existing street lighting to LED fixtures. This conversion will require an upgrade to some of the non-standard streetlights currently in use. Streetlight painting Steel streetlight poles are generally repainted every seven years, based on inspections and testing. Primarily this activity is performed to extend the life of a steel pole; however, there is also a cosmetic benefit.

Transformer Painting Rusty transformers were identified as being in need of painting. Regular repainting inhibits additional rust penetration and decay which can potentially extend the service 25

life a transformer. Regular repainting can also reduce customer complaints and concerns relating to the outward appearance of system assets.

Cubicle Painting Rusty cubicles were identified and are in need of repainting. As an alternative, the Town may wish to consider installing cubicle wraps. This 3M product is applied to the cubicle and protects the metal while assisting in beautification of the Town.

Create a Maintenance Program with Budget Allocations Based on information received from the Town, there is little evidence of any regular maintenance activity on the electric system. Reliability is largely a function of the condition of the distribution system assets. FortisAlberta recommends implementing a maintenance program with the appropriate frequency based on the individual activity types.

Tasks Observation Recommendation Frequency

Brushing Hot Spots and Patrol Remove existing hot spots and carry out a Compliance Related Immediately patrol 145 pole replacements. 51 poles Wood Pole Replacements based Immediately previously identified as failed and 94 Compliance Related on 2009 reported failures projected to fail by 2014

Conductor Clearance Address conductor clearance issues Compliance Related Immediately

Ground Testing including repairs Approximately 180 grounds with an Compliance Related Immediately estimated failure rate Safety Signage Missing Safety Signage Compliance Related Immediately

Wood Pole Testing and Test all wooden power poles Urgent maintenance Every 7 years Treatments activity Forecasted pole replacement Replacement based on 283 poles older Priority based on Pole Once than 40 years Test results PCB Audit and tagging program PCB documentation is incomplete and Urgent maintenance Once testing labels on transformers are illegible activity Detailed Line Patrol Estimated 1200 features to be reviewed Urgent maintenance Every 7 years activity Line Patrol Repairs Repairs based on Detailed Line Patrol Priority based on Every 7 years report Detailed Line Patrol Street Light Patrol Patrol and inspect streetlights. Urgent maintenance Every 5 years activity Recommended Steel Street Light Pole Painting Street light Painting maintenance activity Every 7 years Transformer Painting Transformer painting Recommended Every 7 years maintenance activity Recommended Cubical Painting Painting of switching cubicles Every 7 years maintenance activity

Maintenance Program Notes: 1. Some repairs identified during patrols will be deemed high priority and will need immediate attention.

26