DTE Electric Company One Energy Plaza, 688 WCB Detroit, MI October 21, 2016

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1 DTE Electric Company One Energy Plaza, 688 WCB Detroit, MI Michael J. Solo, Jr. (313) October 21, 2016 Kavita M. Kale Executive Secretary Michigan Public Service Commission 7109 West Saginaw Highway Lansing, MI RE: In the matter, on the Commission s Own Motion, To Commence an Investigation into a September 7, 2016 Accidental Electrocution in Detroit MPSC Case No: U Dear Ms. Kale: Please find attached DTE Electric Company s Investigation Report as required by the Commission s September 23, 2016 Order in the above referenced case. Also attached is a Proof of Service. If you have any questions, please feel free to contact me. Very truly yours, MJS/lah Encl. c: Service List Brian Ballinger, MPSC Staff Michael J. Solo, Jr.

2 DTE Electric Company s Report in Response to The Michigan Public Service Commission s Opinion and Order On the Investigation into a September 7, 2016 Accidental Electrocution in Detroit On September 23, 2016, the Michigan Public Service Commission ( MPSC ) issued an opinion and order in Case No. U in response to an accidental electrocution in the City of Detroit on September 7, Specifically, the MPSC order directed: (i) DTE Electric Company ( DTE ) to investigate the circumstances surrounding the electrocution and to file a report by October 21, 2016; (ii) DTE and the Commission Staff ( Staff ) to develop a plan for DTE to eliminate similar situations throughout Detroit where an abandoned City of Detroit Public Lighting Department ( PLD ) power line could become energized by a DTE line; (iii) the Staff to file a summary of the plan and estimated completion date for the plan work by November 23, 2016; and (iv) DTE to file a report within 30 days after implementing the plan to explain any material deviations from the summary of the submitted plan. DTE appreciates the Commission and the Staff s focus on this matter and is committed to investigating this tragic event and working with the Staff to frame a solution. Following, please find DTE s investigation report as required by the Commission s Order. Chronology On July 27, 2016, a DTE Electric Field Operations (EFO) employee (not a line crewmember) en route to another location visually observed two PLD street lighting (arc) circuit 1 power lines hanging down across DTE s primary lines. The PLD lines ran north and south and were hanging from a cross arm attached to a pole located south of Grove Street behind St. Marys Street in Detroit. The PLD lines were hanging from a location above DTE primary power lines running east and west from that same pole. The PLD lines appeared to have detached from a second pole located behind St. Marys Street. The DTE employee surveyed the area and noticed that the lines were hanging down into the trees and one was on the ground in the rear of St. Marys Street. The DTE employee taped the area off with yellow caution tape and knocked on the door of a number of homes in the area, warning those residents who answered of the downed power lines. In particular, he advised an adult and some girls at St. Marys Street of the downed lines. A written warning was also left at one home where no one answered. Upon completing the taping of the area and notifications to residents, the DTE employee reported the downed PLD arc circuit lines to DTE dispatch who logged in the information at 11:45 a.m. 1 When active, it is DTE s understanding that the PLD arc circuit operated at 7200 volts.

3 At 11:45 a.m., DTE dispatch transferred the information to PLD in an information system that is shared by DTE and PLD. Since DTE began serving PLD customers in 2014, DTE has utilized this shared system to transfer hundreds of jobs to PLD when an identified problem in the field involves PLD equipment. At 11:46 a.m., PLD acknowledged the job in the shared system. At 11:54 a.m., PLD entered event comments of PLA follow up needed and complete and then closed the job in the shared system. PLA is the Public Lighting Authority ( PLA ) of the City of Detroit. DTE s routine at that time was to monitor whether PLD acknowledged a transferred job. It was the routine of PLA to contact DTE or PLD in the event that they needed to transfer a job back to DTE or PLD. In this instance, DTE was not notified by PLD, PLA or anyone else that repairs had not been made with respect to the downed PLD lines. After the September 7, 2016 incident, DTE learned that upon receiving the transferred job, PLD reviewed area maps and concluded that it had no active distribution lines at that location. PLD then transferred the service request to PLA which dispatched a crew to the scene at an unknown time on July 27, The PLA crew took pictures at the scene, which included the yellow caution tape. 2 However, the PLA crew did not make any repairs or remove the downed PLD lines. After the September 7, 2016 incident, DTE learned that on July 27, 2016, PLA incorrectly noted in its own internal system that it was a DTE line. PLA also noted in it s own internal system that DTE had made it safe. That information was never shared with DTE prior to the incident. No one at PLD or PLA contacted DTE between July 27, 2016 and the date of the incident to advise that the work had not been completed. DTE does not have access to PLA s internal system. From July 27, 2016 through September 7, 2016, DTE had no reason to suspect that 2 Picture believed to be taken by a PLA crew on July 27, Picture is taken facing south from near Grove Street towards the alley and rear of Murray Hill Street. 2

4 the downed PLD lines in question had not been repaired or removed. Media reports following the electrocution suggested that residents near the downed lines made telephone calls during that period to inquire about when the lines would be repaired. DTE has no record of any such calls. At approximately 8:00 p.m. on September 7, 2016, a young girl was playing in the backyard of St. Marys Street with a friend and was electrocuted after coming into contact with a PLD line. At approximately 8:08 p.m., DTE received a call from a Detroit Police Department Officer, and a number of DTE employees, including an area supervisor, overhead line crews and legal investigators, were dispatched and arrived on the scene. A DTE line crew cut the two downed PLD lines free of the attached ends so that first responders could safely investigate the scene. A section of one downed PLD line was hanging in the trees and foliage and onto the ground behind St. Marys Street. The second PLD line was also in the foliage but was not located on the ground. There was evidence of burning on the ground near the decedent. At approximately 10:40 p.m. that evening, DTE dispatch informed PLD of the incident involving PLD s downed power line. On the night of the incident, yellow caution tape that was different than what was used by DTE on July 27, 2016 was observed in a large black garbage bin located in front of the garage at St. Marys Street. The caution tape was lying on top of other garbage inside the bin and hanging partially out of the bin. 3 It is unknown where that caution tape had been placed previously, when that tape was removed, or who removed it. Yellow caution tape was found to be stretched out and faded at the base of the first pole south of Grove Street, and more caution tape was found along the route in which it was originally applied. 3 Picture taken by DTE on September 8, Picture is taken facing the garage at St. Marys Street. 3

5 4 5 PLD Follow Up Following the incident, DTE met with PLD representatives on September 12, 2016, to review PLD s processes as they relate to certain PLD jobs that are transferred by DTE to PLD in the shared information system. Hundreds of previously transferred jobs were reviewed in an effort to ensure that those jobs had been completed. DTE also performed field audits of those jobs and reported its results to PLD. For new PLD jobs that DTE transfers to PLD, PLD is now sending a crew out to each location reported regardless of whether their maps indicate PLD lines in the area. Crews report back to PLD about what was identified at the location and what work 4 Picture taken by DTE on September 8, Picture is taken facing the first pole south of Grove Street. 5 Picture taken by DTE on September 8, Picture is taken facing south in the alley and the rear of Murray Hill Street. 4

6 was done or needs to be done and PLD is now inputting that data in the shared information system. If a job needs to go to PLA, PLD then contacts PLA and inputs the name of the PLA contact in the shared information system. In addition, certain new jobs are being reviewed weekly to ensure that a crew took appropriate action as needed and that PLD has input the appropriate data. PLD is also now performing field audits of all of its completed jobs. DTE has also begun auditing the completion of many PLD jobs. DTE is committed to continuing to provide PLD with appropriate assistance to help ensure that a similar tragedy is avoided in the future. Attached to this report are answers to 35 questions provided by the Staff that can be reviewed for additional information. 5

7 Responses to MPSC Questions 1. Please describe the aerial utility facilities and structures on the block of St. Marys Street near Greenfield and West McNichols in Detroit. Include all attachments, types of service, authorities, and ownerships. The following utility facilities are attached to wood pole construction on the block of St. Marys in the alley to the west of St. Marys: 1. DTE 4800 volt single phase primary circuit 2. DTE 120/240 volt secondary circuit 3. Detroit PLD series street lighting circuit (Arc circuit) 4. AT&T communications circuits 5. Comcast cable circuits Also see the attached Exhibit. 2. Please describe in greater detail the overhead lines and attachments at the rear or St. Marys, Detroit, MI. Indicate ownerships and the operational status of respective lines. A DTE-owned 40 foot wood pole, installed in 2003, is in the alley at the southwest corner of the property at St. Marys with the following attachments: 1. DTE 4800 volt single phase primary lateral circuit consisting of two #6 Cu covered conductors installed on the west side of an 8 foot wood cross arm. This lateral circuit originates at the next pole to the north that is located on the south side of Grove St. This circuit is operational and supplies a distribution transformer that is located two poles to the south of St. Marys. 2. DTE 120/240 volt secondary circuit consisting of three #2 Cu covered conductors attached to a secondary rack mounted on the west side of the pole. There are six overhead secondary services feeding four homes on St. Marys and two homes on Murray Hill. One of the overhead secondary services is for St. Marys. These secondary circuits are operational. 3. Detroit PLD series street lighting circuit (Arc circuit) consisting of two conductors on the east side of the same cross arm for the DTE primary conductors. These two conductors were between the pole behind St. Marys and the next pole to the north that is located on the south side of Grove. These same two conductors were down and hanging from the next pole to the north. It is believed that this series street lighting circuit was not operational at the time that the wires were down. 4. AT&T communications circuits are believed to be operational. 5. Comcast cable circuits are believed to be operational. Also see the attached Exhibit. 3. Provide a diagram or map indicating poles, lines and services at and adjacent to St. Mary s Street. Include voltage and configuration (delta/wye, primary/secondary, open wire/triplex, etc) See the attached Exhibit.

8 4. Describe how DTE Electric believes the Detroit Public Lighting Department (PLD) line became energized. The PLD lines were running north and south in the alley west of St. Marys Street and located above DTE Electric primary lines that ran east and west at the pole just south of Grove Street and west of St. Marys Street. The PLD lines became detached from the pole in the rear of the residence of St. Marys Street and, as a result, came into contact with the DTE lines while hanging down from the pole south of Grove Street that they remained attached to. 5. Did the PLD line that became energized on DTE Electric line touch or lay on the ground? The DTE employee who located the downed lines on July 27, 2016 stated that they were hanging up in the trees and one line was on the ground at the time he located and reported them. 6. Describe the vegetation in the pole to pole area where the arc circuit conductor fell. Vegetation near the ground was generally overgrown in that area. The area included trees, brush, overgrown grass and weeds and saplings. Trees are not believed to have been involved in the PLD lines becoming detached. 7. When was the last time DTE Electric performed vegetation management on the line at rear of St. Mary s Street? Line clearance was performed in Describe any other visual obstruction to seeing the downed overhead line at the site of incident. Other than vegetation, no other visual obstructions were identified on July 27, Was the yellow caution tape still in place on September 7, 2016? It is unknown whether the yellow caution tape was in place as it had originally been placed on July 27, On the night of the incident, yellow caution tape that was different than what was placed on July 27, 2016, was observed in a large black garbage bin located in front of the garage at St. Marys Street. The caution tape was lying on top of other garbage inside the bin and hanging partially out of the bin. Another portion of yellow caution tape was found at the base of the first pole south of Grove Street in the alley west of St. Marys Street. Caution tape also remained in the alley and the rear of homes. 10. Who owns the pole on which the downed wire at the site of incident is/was attached? DTE. 11. If DTE Electric owns the poles on the block of St. Mary s, when were the facilities last inspected? The facilities were last inspected on July 27, 2016 by the DTE EFO employee who located the downed PLD lines. Prior to that, in December 2015, a DTE contractor would have inspected the facilities at the first pole south of Grove Street in the course of replacing that pole. A patrol of the subject circuit was completed in May, 2015 and no concerns were identified with respect to the poles in question. 12. Approximately how long have the PLD facilities on the line in question been abandoned? The exact date of abandonment is unknown, but the estimated date is during the 1990s.

9 13. Has DTE Electric requested PLD to remove the conductors in question at any time in the past? If so, when. On numerous occasions dating back to at least 2013, DTE has asked PLD to remove its abandoned street lighting circuit (arc) lines. DTE is not aware of any instance where DTE requested the two specific conductors at issue in this incident be removed. 14. What did the PLD conductors (arc circuit and/or other) on St. Mary s street serve? DTE assumes that the arc circuit conductors served streetlights when active, but PLD could confirm. 15. Please describe the arc circuit conductor in question, its function, location in relationship to other conductors, and any connections to other facilities. DTE does not believe it was actively serving anything. The conductor was located above DTE primary conductors and connected to the next pole north of Grove Street. 16. Provide a timeline of the incident from when DTE Electric first became aware of the hazard to when the hazard was resolved. Include DTE Electric observations, DTE Electric actions, internal communications, communications with PLD, communication with residents, and known PLD actions. See DTE s Investigative Report in Response to the MPSC s Order in Case No. U Please describe an EFO representative and his duties? The Electric Field Operations (EFO) representative who noticed, taped off and reported the downed PLD wires on July 27 was a Field Service Representative, which is an entry level position within EFO. Key accountabilities are to inspect, install, remove, turn-on and disconnect electric meters and service equipment to service customers loads. These employees also observe and report unusual conditions to proper organizational units. They do not work on energized equipment over 480 volts. 18. How did the DTE EFO representative discover the defective arc circuit conductor? The DTE employee was driving between jobs in the area of Grove and St. Marys streets when he visually observed the downed conductors. 19. How did the DTE Electric representative communicate the hazard to the residents surrounding the line? Was it written/verbal? The DTE employee knocked on the door of a number of homes in the area, warning those residents who answered of the downed power lines. In particular, he advised an adult and some girls at St. Marys Street of the downed lines. A written warning was also left at one home where no one answered. Caution tape was also used to warn of the downed lines. 20. Did DTE Electric follow up with the affected residents after the hazard was communicated with PLD? No. DTE was under the presumption that the hazard was being repaired or removed by PLD because PLD had acknowledged the job.

10 21. Did DTE Electric follow up with PLD regarding the downed wire to determine if PLD had fixed, resolved or eliminated the reported hazard? No. DTE was under the presumption that the hazard was being repaired or removed by PLD because PLD had acknowledged the job. 22. Please describe PLD s response to DTE s July 27, 2016 report of downed conductor. It is believed that PLD reviewed area maps and concluded that it had no active distribution lines at that location. PLD then transferred the service request to PLA, which dispatched a crew to the scene at an unknown time on July 27, The PLA crew took pictures but did not make any repairs or remove the downed PLD lines, or communicate to DTE that they did not perform any work. 23. A Detroit Free Press article reports that residents have been calling both DTE and the city s Public Lighting Authority for two months with concerns about the inactive downed line. How does DTE Electric respond to this report? DTE denies those reports and has no record of such calls dating back two months from the date of the incident. 24. Did PLD workers also report to the site at time of incident and if yes, at what time? Not to DTE s knowledge. 25. How many times has DTE Electric reported a hazard to PLD in the last two months? Last six months? In August and September, 2016, DTE reported 203 trouble jobs to PLD. In the last six months (from April through September, 2016), DTE reported 559 trouble jobs to PLD. Not all of those jobs necessarily involved a hazard. 26. What is DTE Electric s procedure for complying with Rule 214, A, 5, a of the National Electrical Safety Code? DTE procedures are designed to promptly correct, disconnect or isolate defects that would reasonably be expected to endanger life or property as required by Rule 214A5a of the 2012 NESC. For the specific case of a reported wire down, the procedure is to promptly dispatch an employee to the location to evaluate the situation and determine the required actions. These actions may include the installation of a barrier that identifies the hazard to the public, guarding the hazard if necessary, informing those individuals in the vicinity of the hazard of its existence, and/or initiating the actions needed to correct, disconnect or isolate the hazard. To correct, disconnect or isolate the hazard will typically require a crew or employee with specific equipment, training and capabilities that will be identified by the first responder to the hazard. 27. What is DTE Electric s procedure for addressing its own abandoned lines and equipment? Overhead equipment and lines are normally removed unless there may be a need for its future use. Lines and equipment that are not removed must be maintained in a safe condition as required by NESC Rule 214B. 28. What is DTE Electric s procedure for addressing other parties abandoned lines on poles or structures also supporting DTE Electric lines? Under a typical joint use agreement, the attaching parties agree to comply with the NESC. In particular, Rule 214 of the 2012 NESC requires lines and equipment permanently abandoned to be removed or maintained in a

11 safe condition. While DTE has been unable to locate a specific, current contractual provision with PLD specifying as such, DTE has always expected PLD to comply with the NESC. 29. Please explain DTE Electric s procedure for addressing a situation where both a PLD line and a DTE Electric line have fallen from a DTE Electric pole during a storm? That would depend on the situation and on what type of DTE resource was on site. DTE first responders not qualified to work on overhead lines would tape the area off to make it safe, warn residents and contact DTE dispatch to report what they found. With respect to line crews capable of working on overhead lines, while generally each utility sends its own crew to make repairs, DTE line crews on site do occasionally cut PLD lines clear to make an area safe. 30. Is there any agreements in place between PLD and DTE Electric for DTE Electric to remove abandoned lines? If so, please summarize. No, not with respect to the abandoned street lighting arc circuit lines. However, DTE has informed PLD on multiple occasions since 2013 that the abandoned street lighting arc circuit lines were PLD s responsibility to remove and that they could begin that work immediately. 31. Does DTE Electric inspect its lines attached to PLD poles? DTE does inspect its lines and equipment attached to PLD poles. These inspections occur during the course of normal operation and maintenance activities, and during inspections of our system for deficiencies as our experience has determined to be necessary. 32. Please explain any arrangement DTE Electric has with PLD for maintaining or repairing PLD facilities. None that is applicable to the abandoned, downed PLD arc circuit lines at issue in this incident. 33. Approximately what percent of poles in Detroit s residential area have both DTE Electric and PLD attachments? Data to answer this question is imprecise and is not delineated by residential versus other areas; however, DTE estimates that with respect to all DTE and PLD poles in Detroit, approximately 57% have both PLD and DTE attachments. 34. For poles that have both PLD and DTE Electric conductors, approximately what percent of the poles have PLD conductors above DTE Electric conductors? DTE does not maintain data to provide a detailed answer to this question. A best approximate answer is that the PLD arc circuit wire is typically located on the same cross arm as the DTE primary, at the top of a pole. When the DTE primary is redirected in another direction (buck pole), a lower or upper gain cross arm could be used depending on the situation. If a lower gain cross arm is used, the PLD arc circuit will be above the DTE wires on the lower gain cross arm at these locations. 35. After the PLD to DTE customer conversion will there be any PLD lines energized in City of Detroit? If yes, please explain. After the conversion, there would be no reason for PLD to maintain any lines in the City of Detroit. It is not expected that the City of Detroit would want any lines to be energized or to remain in place at the end of the project.

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15 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter, on the Commission s own motion, ) to commence an investigation into a September 7, 2016 ) Case No: U accidental electrocution in Detroit. ) STATE OF MICHIGAN ) ) ss. COUNTY OF WAYNE ) PROOF OF SERVICE ESTELLA BRANSON, being duly sworn, deposes and says that on the 21 st day of October, 2016, a copy of DTE Electric Company s Investigation Report as required by the Commission s September 23, 2016 Order, was served upon the persons on the attached service list via . ESTELLA BRANSON Subscribed and sworn to before me this 21 st day of October, 2016 Lorri A. Hanner, Notary Public Wayne County, MI My Commission Expires: Acting in Wayne County

16 SERVICE LIST U Steven D. Hughey Assistant Attorney General Michigan Department of Attorney General 7109 S. Saginaw Highway, Floor 3 Lansing, MI hugheys@michigan.gov