locomative

Good _____( morning/ afternoon) could you please introduce yourself to the members of the jury?

Hello! My name is Sage Everly.

1. What do you do for a living? 

1. I’m an engineering consultant and I’m the owner of Power Consulting. We help investor owned utilities (also known as IOU’s) review their procedures. 

1. How did you get into this line of work?  

1. … I was born on a locomotive. Specifically the Shinkansen 100 series, make 51, cart 7. So from the moment I was born, I knew what true exuberance was. I've never felt more alive than on a locomotive, that's why I became an engineer, to understand the majesty behind the magic of a locomotive.

1. What is your educational background?

1. I studied Mechanical Engineering at Case Western Reserve University in OH, where there happens to be THE Ohio Railway Museum. It's a thrilling way to spend a Saturday.

1. What is your educational background?

1. I studied Mechanical Engineering at Case Western Reserve University in OH, where there happens to be THE Ohio Railway Museum. It's a thrilling way to spend a Saturday.

1. Do you know why you are in court today?

1. Yes. I’m here because I was asked to conduct an expert review and analysis of MG & E to see if their actions were in line with industry standards.

1. Why are you reviewing MG&E as an engineering consultant for IOUs?

1. That’s because MG&E is an IOU, meaning it's a privately owned and for-profit company, which I take into account when conducting my analysis. 

1. Did you have enough information to reach a conclusion on this case today?

1. Yes, I had access to police and inspection reports and both of the standards manuals for MG&E and the overall industry.

1. Did you use any method in today’s case?

1. Of course! I used a comparative analysis method wherein I reviewed the actions of MG&E and compared it to MG&E’s standards and industry standards. 

1. Are those methods reliable?

1. Yes, this method is widely used by experts in this industry, and I have used this dozens of times to evaluate IOUs.  

Then let’s talk about the first category you mentioned, MG&E’s equipment.

1. What did you do?

1. I reviewed four main pieces of equipment in today’s case: the utility pole, the SCADA, which is a system that reports any electrical issues, the EMS sensor, and the transformer on the pole.

1. What did you find when reviewing the equipment?

1. I couldn’t come to a conclusion about the transformer, but I determined the first three, the utility pole, the SCADA, and the EMS were within industry standard and chugging along perfectly. 

1. Why weren't you able to make a conclusion about the transformer’s equipment quality?

1. The transformer was particularly damaged due to the fire, so I wasn’t able to learn if the transformer was out-of-date or improperly functioning before the fire. Since my conclusion is a little difficult to explain I brought a demonstrative to help.

Permission for the witness to make use of a demonstrative.

1. Ma’am what do we have here

1. This is a breakdown of my analysis. I put MG&E’s actions into three categories I assessed, their equipment, their maintenance, and their procedures. Then each of these black lines represents the industry standard and I’ll place a dot to show where MG&E’s actions were on a spectrum of care.

1. Using this demonstrative, can you explain your conclusion about MG&E’s equipment?

1. I found that MG&E’s equipment was in line with and overall above industry standards, even though some of their actions are not what I would consider best practice, which would be at the top of this line. 

Then let’s talk about that second category you mentioned, the maintenance practices

1. How did you assess how well MG&E maintained its equipment?

1. In this case I focused on the inspection and maintenance of the transformer.

1. What did you learn about the maintenance of the transformer?

1. Based on their inspection reports, there was corrosion previously found on the transformer and although I couldn't tell whether it was fixed, I can confirm the transformer was regularly inspected.

1. Then what did you conclude about MG&E’s maintenance?

We can’t confirm if MG&E repaired the transformer earlier and the fire caused the damage, but we know the transformer received regular inspection and was always reliably supplying power before the car crash. That’s why even though I wouldn’t say their actions were in best practice, I concluded MG&E’s transformer and its maintenance was at industry standard. 

Now I want to talk about your third category in your review,

1. How did you assess MG&E’s procedures?

I examined MG&E’s response on the morning of the fire: January 1st. Specifically, I reviewed two big decisions MG&E made that morning.

1. What were those decisions?

1. First: whether to send a technician after a vehicle collided with their pole at 2:10 am. Second: whether to send a technician after the EMS alerted to high temperature and particulate warnings.

1. Then looking at these actions, what did you conclude about MG&E’s procedures?

1. They certainly were not perfect, but their actions were in line with industry standards and reasonable given what they knew at the time, that’s why I concluded MG&E’s maintenance procedures were above industry standard.

Permission for the witness to retake her seat

1. How did you evaluate MG&E’s decisions to reach this conclusion?

1. I looked directly to the MG&E manual as it addresses this situation specifically. It was almost as fun to read as the at ‘the modern locomotive engineers manual.’

1. Was MG&E’s first decision in line with industry standards?

1. In my professional opinion, yes. While the manual would normally require a dispatch in this situation, the fact the SCADA didn’t report any issues in tandem with the extenuating circumstances, such as the time, the storm, and the holiday, make the choice to send dispatch discretionary. In this situation, it's reasonable for the company to choose to send someone later that morning.

1. Then what did you learn regarding their 2nd decision at 3:30 AM.

1. At 3:30 am, the EMS detected temperature and air quality conditions above normal limits, but MG&E did not send a technician to inspect the pole.

1. Was their decision not to respond to the EMS alert reasonable?

1. Yes. Although the manual recommends inspecting an EMS alert, the EMS sensor on this particular pole was unactionable. Meanwhile the SCADA which is the most up-to-date and has never had any issues before, reported no electrical fault.

1. What does it mean for a sensor to be unactionable?

1. It means the sensor is unreliable and has given false alarms. This particular sensor had given more than one false alarm in the previous 90 days.  

1. How does MG&E’s responses to faulty alarms compare to industry standards?

1. MG&E’s actions were reasonable given the circumstances and what they knew, they had the reliable SCADA data, and they also knew how drastic a measure it would be to cut heat on a cold winter night, which is why the decision to wait till later that morning was understandable and within standards.