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Statement from NARUC During its Summer 2018 Committee Meetings

IEEE Education & Healthcare Facilities Committee

Draft Proposals for the 2028 National Electrical Safety Code

Representative State Level Service Quality Standards

MI Power Grid

The National Electrical Safety Code® sets the ground rules and guidelines for practical safeguarding of utility workers and the public.

Submit your changes and review proposals by 15 May 2024: https://t.co/kpf4JyhJSY pic.twitter.com/926L1g8Vxj
— IEEE Standards Association | IEEE SA (@IEEESA) April 21, 2024

Relevant Research

PROCESS, PROCEDURES & SCHEDULE

2025-2026 NESC Revision Schedule

Mike Anthony is ID Number 469 | Proposal period closes 11:59 PM US Pacific Time | May 15

Meeting Notes in red

Loss of electric power and internet service happens more frequently and poses at least an equal — if not greater threat — to public safety.  So why does neither the National Electrical Code or the National Electrical Safety Code integrate reliability into their core requirements?  Reliability requirements appear in a network of related documents, either referenced, or incorporated by reference; sometimes automatically, sometimes not.

NESC Main Committee Membership: Page xii

Apart from the IEEE as the accredited standards developer, there are no “pure non-government user-interests” on this committee; although ANSI’s Essential Requirements for balance of interests provides highly nuanced interpretation.  The Classifications on Page xiii represents due diligence on meeting balance of interest requirements.

In our case, we are one of many large universities that usually own district energy plants that both generate and purchase generate electric power (as sometimes provide var support to utilities when necessary; as during the August 2003 North American outage).  For University of Michigan, for example, has about 20 service points at 4.8 – 120 kV.  Its Central Power Plant is the largest cogeneration plant on the DTE system.

Contents: Page xxviii | PDF Page 29

Absence of internet service is at least as much a hazard, and more frequent, than downed wires.   Is there a standards solution?  Consideration of interoperability of internet service power supported on utility poles  should track in the next revision.

No mention of any reliability related IEEE reliability standards in the present edition.  Why is this?

Section 2: Definitions of Special Terms | PDF Page 46

In the 2023 Handbook, the term “reliability” shows up 34 times.

availability (from Bob Arno’s IEEE 3006-series and IEEE 493 Gold Book revision)

reliability (Bob Arno)

utility (PDF Page 57)

communication | PDF Page 47

list of terms defined in the 2023 National Electrical Code that are new and relevant to this revision: (Article 100 NEC)

Bonding jumper, system and supply

Survivability of communication network signaling

Fiber optic cable mounted on common poles with a medium voltage overhead line standardizing procedure

municipal broadband network, digital subscriber line, surveillance cameras

wireless communication system

010. Purpose | PDF Page 40

Looks like improvement since last edition.  Suggest explicit Informational Note, as in the NEC, using “reliability” and referring to other agencies.  “Abnormal events” could be tighter and refer to other standards for abnormal, steady-state events.   The clarification of purpose is welcomed although a great deal remains uncovered by other best practice literature; though that can be repaired in this edition.

Legacy of shared circuit path standards. Should provisions be made for municipal surveillance, traffic and vehicle control infrastructure.  What would that look like?

011. Scope | Covered PDF Page 40

3. Utility facilities and functions of utilities that either (a) generate energy by conversion from
some other form of energy such as, but not limited to, fossil fuel, chemical, electrochemical,
nuclear, solar, mechanical, wind or hydraulic or communication signals, or accept energy or
communication signals from another entity, or (b) provide that energy or communication
signals through a delivery point to another entity.

5. Utility facilities and functions on the line side of the service point supplied by underground or
overhead conductors maintained and/or installed under exclusive control of utilities located on
public or private property in accordance with legally established easements or rights-of-way,
contracts, other agreements (written or by conditions of service), or as authorized by a
regulating or controlling body.
NOTE: Agreements to locate utility facilities on property may be required where easements are either
(a) not obtainable (such as locating utility facilities on existing rights-of-way of railroads or other entities,
military bases, federal lands, Native American reservations, lands controlled by a port authority, or other
governmental agency), or (b) not necessary (such as locating facilities necessary for requested service to a
site).

012. General Rules | Covered PDF Page 42

For all particulars not specified, but within the scope of these rules, as stated in Rule 011A, design,
construction, operation, and maintenance should be done in accordance with accepted good practice
for the given local conditions known at the time by those responsible for the communication or
supply lines and equipment

General purpose clause could use some work since no definition of “accepted good practice”.  Refer to IEEE bibliography.

Section 2: Definition of special terms | PDF Page 46

Recommendations elsewhere should track here.

 The word “installation” appears 256 times and is generally understood in context by experts.  Suggest borrow from NEC to clarify our concern for including co-linear/communication circuits. 

conduit.  exclusive control, lines, photovoltaic, NEC interactive. qualified

Section 3: Reference

NFPA 70®, National Electrical Code® (NEC®). [Rules 011B4 NOTE, 099C NOTE 1, and 127

IEEE Std 4™-1995, IEEE Standard Techniques for High-Voltage Testing. [Table 410-2 and Table 410-3]
IEEE Std 516™-2009, IEEE Guide for Maintenance Methods on Energized Power-Lines. [Rules 441A4
NOTE 2, 446B1, and 446D3 NOTE, and Table 441-5, Footnote 4]
IEEE Std 1427™-2006, IEEE Guide for Recommended Electrical Clearances and Insulation Levels in
Air-Insulated Electrical Power Substations. [Rule 124A1 NOTE, Table 124-1, 176 NOTE, and 177 NOTE]
IEEE Std 1584™-2002, IEEE Guide for Performing Arc Flash Hazard Calculations. [Table 410-1,
Footnotes 1, 3, 6, and 14]
IEEE Std C62.82.1™-2010, IEEE Standard for Insulation Coordination—Definitions, Principles, and Rules.
[Table 124-1 Footnote 5]

Add references to Gold Book, 1386, etc. IEC since multinationals conform.

Safety Rules for the Installation and Maintenance of Overhead Electric Supply and Communication Line | PDF Page 111

Has anyone confirmed that these tables match NEC Table 495.24 lately?  If it helps: there were no meaningful changes in the 2023 NEC in Article 495, the high voltage article

Section 11. Protective arrangements in electric supply stations | PDF Page 77

A safety sign shall be displayed on or beside the door or gate at each entrance. For fenced or
walled electric supply stations without roofs, a safety sign shall be displayed on each exterior
side of the fenced or wall enclosure. Where the station is entirely enclosed by walls and roof, a
safety sign is required only at ground level entrances. Where entrance is gained through
sequential doors, the safety sign should be located at the inner door position.  (A clarification but no change.  See Standards Michigan 2017 proposals)

Recommend that all oil-filled cans be removed and services upgraded through energy regulations with new kVA ratings

Section 12: Installation and maintenance of equipment

093. Grounding conductor and means of connection

Fences
The grounding conductor for fences required to be effectively grounded by other parts of this
Code shall meet the requirements of Rule 093C5 or shall be steel wire not smaller than Stl WG
No. 5.

D. Guarding and protection | PDF Page 67

124. Guarding live parts| PDF Page 85

Propose roofs required for exterior installations

Part 2. Safety Rules for the Installation and Maintenance of Overhead Electric Supply and Communication Line | Page 72

Section 22. Relations between various classes of lines and equipment | Page 80

222. Joint use of structures | Page 82

Where the practice of joint use is mutually agreed upon by the affected utilities, facilities shall be subject to the appropriate grade of construction specified in Section 24. Joint use of structures should be
considered for circuits along highways, roads, streets, and alleys. The choice between joint use of structures and separate lines shall be determined through cooperative consideration with other joint
users of all the factors involved, including the character of circuits, worker safety, the total number and weight of conductors, tree conditions, number and location of branches and service drops, structure
conflicts, availability of right-of-way, etc.

Reliability considerations for sustaining internet service when power supply is absent. 

Par2 Section 20 Safety Rules for the Installation and Maintenance of Overhead Electric Supply and Communication Line | PDF Page 111

Has anyone confirmed that these tables match NEC Table 495.24 lately?

Part 3. Safety Rules for the Installation and Maintenance of Underground Electric Supply and Communication Lines | Page 220

Renewable energy for internet access

311. Installation and maintenance

A. Persons responsible for underground facilities shall be able to indicate the location of their facilities.
B. Reasonable advance notice should be given to owners or operators of other proximate facilities that
may be adversely affected by new construction or changes in existing facilities.
C. For emergency installations, supply and communication cables may be laid directly on grade if the
cables do not unreasonably obstruct pedestrian or vehicular traffic and either:

1. The cables are covered, enclosed, or otherwise protected, or
2. The locations of the cables are conspicuous.
Supply cables operating above 600 V shall meet either Rule 230C or 350B.
NOTE: See Rules 014B2 and 230A2d.

Part 4. Work Rules for the Operation of Electric Supply and Communications Lines and Equipment | PDF Page 289

When and why was the term “Work” added to the title of this section?   

Core text for the definition of wireless communication system reliability

Appendix E Bibliography| PDF Page 355

Index | PDF Page 398

The word “reliability” appears only three times.  Should it track in the NESC or should it track in individual state requirements.  So neither the NEC nor the NESC couples closely with power and communication reliability; despite the enormity and speed of research.