Sackheim Consulting provides a cost-effective option for complying with Federal Energy Regulatory Commission and Comprehensive Emergency Action Plan Exercise Requirements

Sackheim Consulting was founded in 1999 to provide FERC hydro licensees and other project operators with options to ensure optimum performance of their projects while meeting government requirements. Since 1997, principal Kelly Sackheim has been responsible for the administration of more than two dozen FERC-mandated emergency action plan functional exercises conducted to the satisfaction of project operators, emergency responders, and FERC personnel from four different regional offices.

The FERC has recently notified dozens of licensees that they have been selected to conduct a comprehensive test of a project emergency action plan (EAP) in 2007. The FERC offers a two-day course that licensees can attend in either Austin, Texas or San Francisco, California so that licensee staff can learn exercise requirements and the design process. In addition to the course, the FERC recommends that licensees consider attending one or more of the functional exercises held by other licensees as they provide practical training on how the exercise is conducted.

The FERC strongly suggests that licensee staff avail themselves of these “opportunities” before providing an estimated date to conduct exercises prior to September 30, 2007. For most FERC licensees, spending three days or more to learn how to plan for an exercise that occurs once every five years is not an efficient use of time. Exercise administration is not a critical function that project owners and operators need to be able to perform – but participation in a well-run exercise may provide invaluable insights should an emergency situation occur at a hydroelectric facility.

Sackheim Consulting plans for, administers, and reports on these exercises on behalf of licensees. Comprehensive services relieve licensee staff of all responsibility for managing the exercises, so that individuals may focus on practicing their roles in an actual emergency. Similar to other entities identified on EAP notification flow charts, licensee staff is only required to attend a one-day meeting and share information about the roles they fulfill in their organization on a regular basis.

Although FERC usually recommends that the table top exercise be conducted on a separate day, in order to reduce licensee costs and ensure continuity between the exercises that is often lost when busy agency staff do not attend events on two different days, Sackheim Consulting generally conducts both exercises in a single day. Rarely does a project have such a large number of EAP copies distributed or a notification list that so complex that any adjustments that may be recommended during the morning table top exercises cannot be prepared over a lunch break. For past exercises, the table top has been conducted from 9:30 a.m. to noon, and the functional exercise from 1:15 to 3:30 p.m., including the evaluation following the simulation, so there would be some time to expand the schedule to meet most projects’ specific circumstances, if necessary.

The services of Sackheim Consulting include provision of all meeting correspondence, materials, and logistical arrangements. An invitation letter is sent approximately six weeks before the exercise date to each entity holding an EAP or notified on the EAP flowcharts, followed by a telephone call to all parties that have not responded by two weeks before the scheduled exercise date. Sackheim Consulting prepares the agenda, background and objectives materials for the table top exercise. Sackheim Consulting develops a scenario for the functional exercise, and provides all necessary copies of message and evaluation forms. Kelly Sackheim generally personally administers the exercise at a location of the licensees choosing, and makes provisions for additional staffing support that may be necessary during the exercise. Finally, Sackheim Consulting completes a report to FERC on the exercises within 45 days of the exercise date in accordance with the EAP guidelines, so that the licensee can review and submit the report by the deadline (60 days following the exercise). A letter is transmitted concurrently by Sackheim Consulting to EAP holders and participants summarizing the results of the exercise and any minor changes to the EAP that may result. (In the unlikely event that major revisions to the EAP are deemed necessary following the exercises, these may be provided at additional cost.)

Sackheim Consulting provides the services described above for a fixed fee to be finalized after review of the notification flow chart and mailing list for the client’s EAP and determining whether FERC will approve conducting both exercises on the same day. The most common fixed fee for calendar year 2006 is $6,500; rates for calendar year 2007 will generally be $500 higher. Another advantage of completing an FY2007 exercise between October 1 and December 31, 2006 is that annual exercise and drill requirements for calendar year 2006 are met at the same time. Generally payment is requested in 3 installments: 25% due upon authorization to proceed, 50% (plus expenses) following completion of the exercise, and the final 25% upon submission of the final report on the exercises. The only out-of-pocket cost excluded from the above fee would be actual travel and economical meals and lodging costs incurred by the exercise administrator (usually under $500 for travel from Sacramento, Califo rnia to spend no more than 3 days at the client site), rental fees (if the client is unable to arrange for a free meeting location), and hospitality items (usually the project operator provides lunch for participants who attend all day).