Order 25605 - RI Energy: Contact Voltage Detection and Repair Program

On August 1, 2025, The Narragansett Electric Company (RIE or Company) filed with the Public Utilities Commission (Commission or PUC) its 2025 Contact Voltage Annual Report (Report).^[1]  R.I Gen. Laws § 39-2-25 directed the Commission to establish a contact voltage detection, repair, and reporting program to be implemented by Rhode Island Energy. The program developed procedures to detect contact voltage on publicly accessible surface areas that are caused by faults in the underground distribution system and to remedy any defects found.  The program requires the Company provide an annual report to the Commission detailing the results of the surveying and testing as well as program costs.   The program also requires the Company to check electric facilities not owned by the Company that are located in public areas and notify owners of any voltage detection.  These non-Company owned assets are typically municipal-owned streetlights.  However, any repairs in such cases are left to the owner to address and any repairs are outside of the Company’s control and the Commission’s jurisdiction.

On November 5, 2025, the Company refiled the 2025 Report to correct errors in the August 1 version.[2]  The Division of Public Utilities and Carriers (Division) filed a letter from its consultant, Gregory L. Booth, dated  September 3, 2025 and addressed to Commission Clerk Stephanie De La Rosa, concluding that the Report met the statutory requirements of R.I. Gen. Laws § 39-2-25(b)(6) and incorporated all prior Commission orders.  Mr. Booth made other recommendations which are discussed below.^[3] 

At an Open Meeting on January 20, 2026, the Commission unanimously approved the Report and adopted the Division’s recommendations regarding future administration of the Contact Voltage Mobile Surveys.

The Report identified Osmose Utilities Services, Inc. (Osmose) as the company that performed the surveying and testing of the previously established Designated Contact Voltage Risk Areas (DCVRA) from February 15, 2025 to February 25, 2025.  The surveys were conducted during the nighttime, included the testing of streetlights, and covered approximately 55 miles.  RIE was available to mitigate any high voltage discoveries during the surveying and testing if necessary.  In addition to the testing in the DCVRA, the Company conducts a total harmonic distortion (THD) test.  Voltage level readings above 1 volt and less than 4.5 volts with a THD of greater than 10% are considered contact voltage and require mitigation.^[4]

Fifty-nine mobile events having one volt or greater were recorded during the mobile scanning survey. Of the sixteen stops made to investigate elevated voltage readings^[5], 29 events were greater than one volt and less than 4.5 volts and 30 events were greater than 4.5 volts.  However, only two of these were considered to be contact voltage because of THDF’s of greater than 10%.Company assets accounted for 9 of the events while customer assets were responsible for the remaining 50 elevated voltage readings.  The Company noted that like the 2024 experience, manhole and streetlights were responsible for most of the elevated voltage readings.  Streetlights have been consistently responsible for elevated readings in prior years and since the inception of the program.^[6]  In addition to the testing, the Company was previously ordered to conduct manual post mitigation testing to ensure repairs were addressed which it did in November of 2024.  The Company documented and made safe elevated voltage on eight customer assets identified after the FY 2024 mobile survey and notified the municipality.[7]  

Total cost was $78,000 for the FY 2025 contract voltage testing and repair during which four repairs were required which will be reconciled with the Company’s FY 2025 Electric Infrastructure, Safety, and Reliability Plan filing.^[8] 

For the reporting period, October 27, 2024 through June 26, 2025, the Company did not receive any calls of elevated voltage to its Shock Line.[9]  Included as an exhibit with the Report was an updated Electric Operating Procedure (EOP)-G016 that outlines the requirements for the equipment elevated voltage testing on the Company’s facilities and has not been updated or modified since January 6, 2025.[10]

The Company plans to continue the THD pilot program during the FY 2026 mobile surveying.  It noted that the costs of this program are minimal, and the additional information provided by the program will be beneficial to possible future modifications or changes to the Contact Voltage Program.[11]  The Company did not recommend any changes to the list of fourteen DCVRAs that are currently surveyed.  The Woonsocket and Newport DCVRA areas will be tested beginning in February 2026.[12]  It reported that the standard P1695, Guide to Understanding, Diagnosing and Mitigating Stray and Contact Voltage, was recently edited and published in December 2024 by the Institute of Electrical and Electronics Engineers (IEEE) Standards Board and that changes  included adding case studies and information on troubleshooting swimming pool shocks.  None of the expected changes impact test methods or process.  The Company is not aware of any changes to the mobile testing technology and plans to continue to use its existing manual technology and chosen vendor technology.[13]

As set forth above, Osmose conducted the surveying and testing for FY 2025.  The Company will evaluate the results of the testing and determine whether to continue to use Osmose or use another vendor for future testing.  The Company recommended continuation of the 20% sampling.  The Company noted that although contact voltage readings have fluctuated over the past years, streetlights have remained the most common when measuring voltage.  It notified the City of Providence by certified mail and email on April 1, 2025 of city assets, the majority of which were streetlights, that had elevated voltage.  It maintained that it will continue to notify municipalities that own streetlights of this trend when contact voltage scans are scheduled to be performed in those DCVRAs.^[14]

Prior to submitting its recommendations, the Division issued a number of data requests questioning the increase in detected events.  In response to the Division’s questions, the Company provided possible reasons for the increase in mobile events which included a wider assessment area and enhanced technology.[15]

Mr. Booth discussed both the events related to streetlights and those related to manhole covers.  He noted that recent surveys revealed a similar number of events associated with streetlights and manhole covers.  With regard to Company owned streetlights, he highlighted that about half of the voltage events detected on Company assets are the result of municipal owned equipment.  Mr. Booth also noted that municipalities are not statutorily required to remedy a contact voltage occurrence, nor does it require the Company to follow-up with a municipality as to whether it remedied the situation.  He stated that the Company is now sending certified letters to the municipalities to ensure notification is received and continues to work with municipalities.  In addition, the Company is providing guidance to municipalities with the hope that it will mitigate contact voltage events.[16] 

On behalf of the Division, Mr. Booth supported the Company’s recommendations to the continuation of surveying 20 percent of the DCVA areas, continuation of post-mitigation annual testing, and the practice of utilizing THD readings for contact voltages between 1 and 4.5 volts continue.  He also stated that the Division supports the Company’s continued monitoring of IEEE developments and if changes are made to standards notifying the Division and the Commission of those changes.  He stated that the Division supports the Company’s process of evaluating bids for the next cycle of testing with including components other than just price.[17]

In addition to the above agreement with the Company’s recommendations, Mr. Booth recommended continued inclusion of the Commission’s directives from prior Commission Orders which includes:  1) that the Company develop a comparison of results from the same DCVRA once all five 20 percent area assessments are complete using the advanced technology; 2) that the Company communicate contact voltage detection results with a municipality by certified mail, return receipt requests and with copies to the Commission and the Division and to notify the Commission and the Division if the municipality fails to respond to that correspondence; 3) that the Company continue to communicate and work with municipalities; and 4) that cycle testing continue to occur each February with a report filed with the Commission in August or September of each year.[18]

At an Open Meeting on January 20, 2026, the Commission reviewed the Report, the responses to data requests and Division questions, and the Division’s recommendations.  It found the Report to be in compliance with R.I. Gen. Laws § 36-2-25(b)(6).  The Commission ordered RIE to continue to conduct testing for 20% of the DCVRAs in FY 2026 and to monitor IEEE Standard P1695 and to inform the Commission of any changes or other actions involving P1695.  Verification of prior remediation is helpful in ensuring work previously performed was done properly.  To accomplish this, the Commission ordered RIE to continue to perform post-mitigation testing on Company-owned assets by manually testing where previous remediation work was completed after the prior year’s mobile survey.  It ordered the Company to continue to compare current year survey results in the Designated Contact Voltage Risk Areas with Company-owned assets against results from the same DCVRAs from prior years. 

Because most municipalities own the streetlights within their borders, the Commission finds that these municipalities should be notified that mobile events are increasing.  In order to ensure the municipalities are notified, the Commission ordered the Company to send notification of a mobile event on a municipally owned asset to the municipality by certified mail, return receipt requests with both the Commission and the Division copied on the correspondence.  It also ordered the Company to notify the Commission and the Division should the municipality fail to respond to the correspondence. 

It is important to understand the reasons for the dramatic increase in events from previous years.  The Commission finds the number of stops and events have been consistent over the past few years.  The Company’s explanation that new and improved equipment is producing the increase in events is satisfactory to the Commission.  It is understandable that the better technology is attributing to more events being identified from far off.  In addition to continuing the Company’s reporting requirements, the Commission ordered the Company to develop a comparison of results from the same DCVRA between new results and prior results for the DCVRA with the goal of gaining more insight into even differences between testing technologies. 

Accordingly, it is hereby

1. The Narragansett Electric Company shall continue the testing schedule for completing 20% of the Designated Contact Voltage Risk Areas in FY 2026.
2. The Narragansett Electric Company shall continue its current process for conducting mobile surveys.
3. The Narragansett Electric Company shall monitor IEEE Standard P1695 and inform the Commission and Division of any changes or other actions involving P1695.
4. The Narragansett Electric Company shall perform post-mitigation testing on Company-owned assets by manually testing the areas where previous remediation work was completed after the prior year’s mobile survey.
5. The Narragansett Electric Company shall develop a comparison of results from the same DCVRA between new results and prior results for the DCVRA once the current vendor using the advanced technology has completed all five 20 percent area assessments so comparable data is being used.
6. The Narragansett Electric Company shall notify municipalities that own streetlights of the increasing trend in mobile events and that a mobile event has been detected on one of its assets by email and certified mail, return receipt requested and copied to the Commission and the Division.
7. The Narragansett Electric Company shall notify the Commission and the Division if a municipality does not respond to the written notification of the detection of a mobile event(s).
8. The Narragansett Electric Company shall conduct future testing in February and reporting shall be by August of each year.
9. All directives contained in this Order shall remain in full force and effect for subsequent years unless modified by the Commission.

EFFECTIVE AT WARWICK, RHODE ISLAND ON JANUARY 20, 2026, PURSUANT TO AN OPEN MEETING DECISION ON JANUARY 20, 2026.  WRITTEN ORDER ISSUED FEBRUARY 6, 2026.