Unstructured Data Analysis for Risk Management of Electric Power Transmission Lines^†

Round 1

Reviewer 1 Report

1) The current abstract is too plain. It is recommended to indicate the significant scientific contribution and novelty of this work. The current abstract only introduces that the authors conduct a case study and achieve some results. But the scientific contribution is not clear. What is the exact scientific problem solved in this paper? Some necessary descriptions should be included.

2) In the introduction, the necessity of conducting the risk management for transmission line networks can be expanded to similar application fields, such as the traction power network in railway engineering [1-2], which may attract readers from a wide range.

[1] A traction network chain-circuit model with detailed consideration of integrated grounding system in tunnel path. IEEE Trans Transp Electrif. 2019;5:535–551.

[2] Contact wire irregularity stochastics and effect on high-speed railway pantograph-catenary interactions. IEEE Trans Instrum Meas. 2020;69:8196–8206.

3) The literature review regarding the current risk management method should be introduced in more detail. From the current version, the literature review looks quite insufficient, which may not be helpful to highlight the motivation of this work. The literature review in Section 3 is recommended to be moved a bit earlier to facilitate the readers’ understanding.

4) Is the size of texts in Figure 2 relevant to the priority of the keyword in the word cloud?

5) Is there any other evidence to prove the effectiveness of the present method? The feasible evidence can be the comparison with the previous method or the validation of the accuracy through a case study.

Generally, I think the topic of this work is quite interesting. But the above issues should be properly addressed before the publication of this paper.

Author Response

Response to Reviewer 1 Comments

Point 1: The current abstract is too plain. It is recommended to indicate the significant scientific contribution and novelty of this work. The current abstract only introduces the authors conduct a case study and achieve some results. But the scientific contribution is not clear. What is the exact scientific problem solved in this paper? Some necessary descriptions should be included.

Response 1: This paper is the first to calculate risk probabilities in the implementation of transmission lines based on unstructured text. This proposed method differs from previous ones which used structured data (numerical and/or categorical) from single or multiple sources. We addressed this point by adding the following clarifications in the abstract: … Instead, in this paper, we propose a novel method to calculate risk probabilities in the implementation of transmission lines based on unstructured text from a single source. … This method differs from previous works which were based on structured data (numerical and/or categorical) from single or multiple sources.

Point 2:  In the introduction, the necessity of conducting the risk management for transmission line networks can be expanded to similar application fields, such as the traction power network in railway engineering [1-2], which may attract readers from a wide range.

[1] A traction network chain-circuit model with detailed consideration of integrated grounding system in tunnel path. IEEE Trans Transp Electrif. 2019;5:535–551.

[2] Contact wire irregularity stochastics and effect on high-speed railway pantograph-catenary interactions. IEEE Trans Instrum Meas. 2020;69:8196–8206.

Response 2: We added those references in the introduction and this piece of text: Even other related fields in the energy sector such as traction power networks in railway engineering can benefit from risk management. 

Point 3:  The literature review regarding the current risk management method should be introduced in more detail. From the current version, the literature review looks quite insufficient, which may not be helpful to highlight the motivation of this work. The literature review in Section 3 is recommended to be moved a bit earlier to facilitate the readers’ understanding.

Response 3: We moved the related work section 2. We also included part of the Point 1 explanation to the end of the related work section. To the best of our knowledge, we couldn’t find other related work that used unstructured data (text) to calculate risk probabilities in the implementation of transmission lines. In this case, we presented the closest ones we could find that are more related to traditional data science approaches for risk assessment.

Point 4:  Is the size of texts in Figure 2 relevant to the priority of the keyword in the word cloud?

Response 4: The bigger the text size, it means that the word appeared more times on the weekly reports. This doesn’t mean that more frequent words get a higher weight in the probability calculation. However, since they appear more frequently, they will probably impact more risks than smaller ones. This explanation has been added to the text.

Point 5: Is there any other evidence to prove the effectiveness of the present method? The feasible evidence can be the comparison with the previous method or the validation of the accuracy through a case study.

Response 5: Previous methods were not based on text and were not applied to the same risks that our method was applied to. We validated our method accuracy through the presented study case. All our results were validated by industry experts in the field, since this work is sponsored by a R&D project with companies from the energy sector.

Point 6:  Generally, I think the topic of this work is quite interesting. But the above issues should be properly addressed before the publication of this paper.

Response 6: They were addressed in the previous points.

Reviewer 2 Report

The paper is well written and emphasizes the strongest research points. Please, check up Figure 10 location, it is in the middle of references.

Author Response

Response to Reviewer 2 Comments

Point 1:  The paper is well written and emphasizes the strongest research points. Please, check up Figure 10 location, it is in the middle of references.

Response 1: Figure 10 moved to just before the Conclusion section.

Reviewer 3 Report

Title: "Analysis of unstructured data for power line risk management" deals with the analysis of unstructured data.
Comments:
- align "bullets" with the requirements of the template
- Figures should be placed in the main text near to the first time they are cited. 
- Fig.10 is located in the "Literature" section.
- r.271 - it states "The reports with the highest occurrences presented 21 different risks, ID 12.696, made in April ......" - such ID is not in the picture, the same "The meeting report, ID 12.815, ...."

The paper is processed at a high level and deals with the current problem, namely risk analysis. The source data for the experiment were obtained through "reports" from the website.
The whole post looks compact. The individual parts follow each other logically. From my point of view, it might be appropriate to describe some parts in more detail
- e.g. show the format of the source text file downloaded from the website.
- chap. 4.1 - The keyword search method and algorithm can be described in more detail
- The authors state that - "The script downloads the corresponding HTML page for each report and extracts the report content..." - in what form? where?
- chap. 4.3 - maybe more details- the authors write that they created a map linking the reports to one or more risks- perhaps an example of the result view 
In the end, the authors state what their future work will be in this area. There is a mentioned database, which they do not write about in detail (structure would suffice).

Author Response

Response to Reviewer 3 Comments

Point 1: Title: "Analysis of unstructured data for power line risk management" deals with the analysis of unstructured data. Comments: - align "bullets" with the requirements of the template

Response 1: We fixed the bullets to numbers according to the template just before the Methodology section.

Point 2: - Figures should be placed in the main text near to the first time they are cited. 

Response 2: We placed the figures as close as possible to the first time they are cited.

Point 3: - Fig.10 is located in the "Literature" section.

Response 3:  Figure 10 moved to just before the Conclusion section.

Point 4: - r.271 - it states "The reports with the highest occurrences presented 21 different risks, ID 12.696, made in April ......" - such ID is not in the picture, the same "The meeting report, ID 12.815, ...."

Response 4: The graph labels size on x axis were too big, so it omitted some IDs to fit the whole text (unfortunately the ones we referred to). We found it better to remove the specific IDs from the text, and just make reference to the reports as the ones with the highest number of occurrences (21 risks), since reducing the size of the label size would make them unreadable.

Point 5:  The paper is processed at a high level and deals with the current problem, namely risk analysis. The source data for the experiment were obtained through "reports" from the website. The whole post looks compact. The individual parts follow each other logically. From my point of view, it might be appropriate to describe some parts in more detail  - e.g. show the format of the source text file downloaded from the website.

Response 5: We added more detailed information about the reports’ structure in section 4.1.  “The HTML pages have a header with the following fields: information about the meeting, date, time and place. The content is also identified by the process ID tag and each process is split into: relevant area, rapporteur, and final decision.”

Point 6:  - chap. 4.1 - The keyword search method and algorithm can be described in more detail

Response 6: We added a more detailed explanation about the keyword search method in section 4.1. “The keyword search method splits each document per process. Each process is extracted and its content is stored in the database with a respective ID. The content itself is composed of a topic and a final decision regarding the process. Aside from storing the full text of each process, each individual keyword is also stored on another table, discarding the stop words. Those keywords are used to calculate their occurrence frequency and relevance during the generation of relevant keywords.”

Point 7:  - The authors state that - "The script downloads the corresponding HTML page for each report and extracts the report content..." - in what form? where?

Response 7: Each link displays the report on a single HTML page. The developed script traverses each report’s HTML page, downloads it and parses the HTML page to remove irrelevant information and store only the data/text regarding the report itself.  This explanation has been added to the paper.

Point 8:  - chap. 4.3 - maybe more details- the authors write that they created a map linking the reports to one or more risks- perhaps an example of the result view 

Response 8: Figure 2 has been added to section 4.3. Also the following text to add more detail on how the keywords are linked to the reports. “Figure 2 shows how the words are extracted from the reports database and grouped into keywords. Then The incidence of keywords on risks is checked in the risks/causes database. Finally, the most relevant keywords are generated and their frequency calculated in the reports.”

Point 9:  In the end, the authors state what their future work will be in this area. There is a mentioned database, which they do not write about in detail (structure would suffice).

Response 9:  The database mentioned is the current one of ANEEL reports. We improved the aforementioned future work paragraph. The new text is: “As future work, it is intended to feed the current database of reports with other data sources such as the electoral court reports which impacts the concession of energy transmission lines. Those data sources could have their keywords extracted, crossed with the current database so the risk weight and probability calculations could be more precise by including different information sources, and the relevant information would be made available to managers responsible for decision-making.” 

Reviewer 4 Report

The authors present the paper in a clear and extensive way. 

The presentation is well organized and structured. Here my major comments: 

-lines 8-9 please add more description to the results in the abstract section. 97/233 is not clear what is meant 

-line 30: why is an "essential database" ? Please specify 

-line 37: "this paper uses NLP techniques"

-line 40: the first using this dataset? Or the first in general? Please specify 

-Also in the introduction please specify what 97/233 means in a more clear way 

-lines 121: the 233 risks should be added in a  table (in the supplementary material) for the sake of completeness

-How were the 233 factors identified? Please specify also here (not only in section 4.2)

-Figure 1: Add more description of the workflow to the caption 

-I think a numerical example could be added to the formulation of the problem in section 4.4. for the sake of clarity

-Role of words clouds should be better specified. How were they used? 

-Figure 3-4-5-6-7 needs more details and description in the caption 

-I think the Dashboard should be represented with a better figure in the paper. Figure 8 and 9 are not so clear, and should be improved/merged 

Author Response

Point 1: The authors present the paper in a clear and extensive way.  The presentation is well organized and structured. Here my major comments:  -lines 8-9 please add more description to the results in the abstract section. 97/233 is not clear what is meant

Response 1:  We added the following text to add more detail to the abstract results “Our results show that we were able to extract relevant keywords from the ANEEL reports that enabled our proposed method to  estimate the probability of 97 risks out of 233 listed by an expert.”

Point 2:  -line 30: why is an "essential database" ? Please specify 

Response 2: We changed the word from “essential” to “important” which is more appropriate.

Point 3: -line 37: "this paper uses NLP techniques"

Response 3: Word “techniques” added in the mentioned sentence.

Point 4:  -line 40: the first using this dataset? Or the first in general? Please specify 

Response 4: We meant the first scientific research to use that particular database to assess risk. We made the statement more specific: “this is the first scientific work to use those particular weekly reports to estimate the probability of risks in the implementation of transmission lines.”

Point 5:  -Also in the introduction please specify what 97/233 means in a more clear way 

Response 5: We added the following explanation to make it clearer:  “These risks are related to weather, environmental conditions, land constraints, costs and investments (e.g. Non-approval of the study of the regions with indigenous settlements, increase in the number of malaria cases registered, political changes in local governments etc.). Based on specialist knowledge, 233 risks were identified during the acquisition and implementation of energy transmission lines. The specialist wrote down a list of possible causes related to each risk.”

Point 6:  -lines 121: the 233 risks should be added in a  table (in the supplementary material) for the sake of completeness

Response 6: We added the full list at the end of this rebuttal.

Point 7: -How were the 233 factors identified? Please specify also here (not only in section 4.2)

Response 7: Addressed in Point 5.

Point 8: -Figure 1: Add more description of the workflow to the caption 

Response 8: The following description has been added: “Diagram representing the methodology steps. Firstly, the weekly reports are extracted from the ANEEL's website through web crawling. Secondly, the risks and causes are listed by an expert. Then the unstructured reports are processed using NLP techniques and keywords are extracted from the risks' causes. Finally, the risk probability is estimated.”

Point 9: -I think a numerical example could be added to the formulation of the problem in section 4.4. for the sake of clarity

Response 9: This example has been added to the text.

“In order to illustrate how the probability is calculated, we provide two examples. For Equation 1, given a given risk \textit{i} in a report \textit{j}, if unique keywords $K_{ij} = 10$ were found and the maximum number of unique keywords were $max(K) = 222$, the report's weight would be $W_{ij} = 10/222 = 0.045$. For Equation 2, if the sum of all report's weight for a particular risk $\sum{W_{ij}} = 1.206$, and the number of reports linked to the risk $N_{i} = 82$, the risk probability would be 0.015 = 1.5, a low risk in this case.”

Point 10: -Role of words clouds should be better specified. How were they used? 

Response 10: The word cloud was just an illustration to visualize the most frequent keywords found in the weekly reports. It is not part of the NLP technique proposed.

Point 11: -Figure 3-4-5-6-7 needs more details and description in the caption 

Response 11: The following detailed explanations were added to each Figure. It is important to note that in the reviewed version, a new figure was included, so the figure numbers will be increased by 1 (Figure 3 in the original submission will be Figure 4 in the reviewed version).

“Figure 3 - Number of unique risks per year. When at least one keyword from the causes of a specific risk is found in a report from a particular year, this risk is accounted for in the unique risks per year shown in this graph. It is important to note that if keywords are found on different reports for the same risk, still that risk is counted only once for that particular year.”

“Figure 4 - Number of distinct risks per report.  It shows how many risks are found on each report, represented by their IDs. Some reports in the year 2020 have up to 21 risks linked to it.”  

“Figure 5 -Risk probabilities by each identifier. It shows the 9 risks with the highest probability. Probabilities are calculated based on Equation 2.”

“Figure 6 - Risk probability per area of interest. Those areas are: Engineering, O&M Engineering, Land, Environment, Regulatory and Investors. It accounts for the average risk probability for all risks that fall on each particular area.”

“Figure 7 -Risk probability per phase. Those project phases are: Implantation, Operation, Pre-Auction and Viability. It accounts for the average risk probability for all risks that fall on each particular project phase.”

Point 12:  -I think the Dashboard should be represented with a better figure in the paper. Figure 8 and 9 are not so clear, and should be improved/merged 

Response 12: We removed Figure 8 and increased the size of Figure 9 for better visualization. We adjusted the respective text as follows: “Lastly, a web-based \textit{Dashboard} system was developed for the management and visualization of the risk probability. It enables users to interact with graphs and calculate risk probabilities and impacts on transmission line implementation projects. Figure \ref{fig:dashboard-01} shows the risk trend interface. This graph can be customized by many filters, including time intervals, areas, and phases, to select and generate the results for analysis.” 

List of 233 risks:

1. Non-approval of the Quilombola Component Study (ECQ) by The Palmares Cultural Fudanção (FCP) / INCRA
2. Non-approval of the Quilombola Basic Environmental Plan (PBAQ) by Fudanção Cultural Palmares (FCP) / INCRA
3. Conflict with the Maroon Remanecent Communities (CRQs) in relation to the layout of the LT
4. Non-approval of the Final Report of the Quilombola Basic Environmental Plan (PBAQ) by Fudanção Cultural Palmares (FCP) / INCRA
5. Non-approval of the Indigenous Component Study (ECI) by FUNAI
6. Non-approval of the PBAI Indigenous Basic Environmental Plan) by FUNAI
7. Occurrence of unidentified environmental liabilities related to erosive processes
8. Identification of natural cavities less than 250m away from the servitude range after the construction of the LT
9. Conflict with Indigenous Communities (ICs) in relation to the tG
10. Existence of paleontological sites in need of rescue or monitoring
11. Need to establish speed plates or reducers beyond what is foreseen
12. Existence of pending or demands with the Communities (ICs) at the time of the request of the LO
13. Presence of migratory routes of birds on the route foreseen for lt
14. Need to change the travel times of works on roads and access roads
15. Need for development and implementation of a specific monitoring program for flora species
16. Existence of expired documentation or authorisations at the end of the deployment phase
17. Existence of expired documentation or authorisations at the operating stage
18. Need for the development and implementation of a specific monitoring program for wildlife species
19. Non-approval of the Report on Potential Impact on Archaeological Heritage (RAPIPA) by IPHAN
20. Non-approval of the Archaeological Heritage Impact Report (RAIPA) and the Archaeological Heritage Management Program (PGPA) by IPHAN
21. Non-approval of the Final Report of implementation of the Archaeological Heritage Management Program (PGPA) by IPHAN
22. Presence of areas with high or very high paleontological potential in the planned tracing for LT
23. Existence of concrete interference (raised in the field) of lt with areas of protection ambienal in need of suppression
24. Existence of a large number of municipalities crossed by the LT tracing with high rates of malaria cases
25. Non-approval of the MalayIan Potential Assessment Study (PMA) by the Secretariat s.O. Health Surveillance (SVS)
26. Non-approval of the Malaria Control Plan (PACM) by the Secretariat of Surveillance and Health (SVS)
27. Increase the number of malaria cases reported in the municipalities covered by the LT
28. Non-approval of the Environmental Programme by funding agents
29. Non-approval of the Malaria Control Plan (PACM) Implementation Report by the Health surveillance secretariat (SVS)
30. Failure to issue the Final Opinion of the regulatory body in relation to the incompatibility of mining activities until the end of the implementation phase
31. Media field campaigns do not cover all municipalities covered by lt
32. Change in the organisational structure of licensing agencies and actors during the Auction-Prior License phase
33. Change in municipal governments during the Prior License phase - Installation License
34. Presence of urban or periurban areas of industrial expansion in the project region
35. Significant increase between the value of the Evaluation Reports and those effectively
36. Very high CAPEX and OPEX cost
37. Project cost is higher than foreseen in the Business Plan in the Environmental Feasibility phase (Auction-LP)
38. Opening of cvm administrative proceedings in the Environmental Feasibility phase (Leilão-LP) for the leakage of information in the media or use of inside information
39. Project cost is higher than foreseen in the Business Plan in the Environmental Feasibility phase (LP-LI)
40. Opening of cvm administrative proceedings in the Environmental Feasibility phase (LP-LI) for the leakage of information in the media or use of inside information
41. Opening of cvm administrative proceedings in the Implementation phase (LI-LO) for the leakage of information in the media or use of inside information
42. Opening of cvm administrative proceedings in the Implementation phase (LI-LO) for the non-disclosure of relevant information to the market
43. Non-compliance with the Conditions of the LO
44. Cost of operation and maintenance to be higher than expected in the Annual Budget of the Operation Phase (O&M)
45. Financial health of the entrepreneur weakened in the Feasibility phase (Auction-LP)
46. Financial health of the entrepreneur weakened in the Feasibility phase (LP-LI)
47. Financial health of the entrepreneur weakened in the Implementation phase (LP-LO)
48. Financial health of the entrepreneur weakened in the Operation phase (O&M)
49. Variation of the basic interest rate provided for in the Business Plan for financing the work in the Feasibility phase (Auction-LP)
50. Variation of the basic interest rate provided for in the Business Plan for financing the work in the Feasibility phase (LP-LI)
51. Variation of the basic interest rate provided for in the Business Plan for financing the work in the Feasibility phase (LI-LO)
52. Need to install anti-collision flags of birds in many sections of the track
53. Estimates of vegetation suppression from the Forest Inventory are above the initial forecast
54. Existence of stretches of LT embargoed for environmental reasons for long periods
55. Non-approval of the Environmental Study (EIA/RIMA, RAS etc.) by the licensing body
56. Non-approval of the Basic Environmental Plan (PBA) by the environmental agency
57. Non-approval of the Consolidated Lo Request Report by the environmental agency
58. There are medium, severe or very serious non-conformities (NC's) identified
59. Unresolved environmental backlogs before LT's entry into operation
60. Non-approval of the Forestry Infentário (IF) by the environmental agency
61. Do not perform plant suppression in accordance with the methodology provided for in the Forestry Infentário (IF) or the Plant Suppression Authorisation (ASV)
62. Estimates of vegetation clearing/replacement of the Forest Inventory are above that initially predicted
63. Low productivity of the field team for the preparation of topographic surveys of properties
64. Large number of Unfinished Evaluation Reports
65. Existence of mining research areas incompatible with LT's operation and with advanced licensing processes in the regulatory body
66. Values of Apprealist Reports higher than the budgeted value for the project
67. The need to make indemnification sums to holders of mining rights incompatible with LT
68. Existence of a large number of embargoes on the work within land control
69. Large number of unfinalized negotiations
70. Significant increase between the value of the Apprealist Reports and those effectively negotiated with the owners
71. Large number of legal proceedings for Possession Of
72. Legal proceedings not finalized until the start of the operation of the enterprise
73. Land registrations and regularizations not completed until the beginning of the operation of the enterprise
74. Delay of ccis signature events, CCTs or Commercial Operation of projects under implementation that will be accessed by the new LT to be built
75. Existence of pending or demands with the Quilombola Remancentes Communities (CRQs) at the time of the lo's request
76. Non-approval of the Final Report of the Basic Indigenous Environmental Plan (PBAI) by FUNAI
77. Need to implement many PRADs
78. Existence of a large number of erosive processes with control measures not implemented
79. Existence of erosive processes and/or PRADs without completion of the proposed measures at the end of the implementation phase
80. Do not install all the anti-collision flags provided in a timely manner
81. Non-service of lp constraints
82. Presence of areas for the cultivation of reproductive improvements in the project region
83. Non-compliance with li conditions
84. Existence of unidentified critical points in the pre-auction phase
85. Change of the Basic Engineering Project according to the new alternative of tracing proposed by the land
86. Non-compliance with ASV Conditions
87. Existence of a large number of archaeological sites with rescue and/or monitoring actions
88. The need for a new alternative to the as a function of the progress of the negotiations
89. Amendment of the Executive Engineering Project according to the new alternative of the layout proposed by the land
90. Do not finalize forest compensation/relocations during the implementation phase of the enterprise
91. Increase the number of re-indemnities relating to indemnification
92. Increase the number of serious unanswered complaints within the
93. Increase the number of claims relating to damage caused to property
94. Change in municipal governments during the Auction phase - Prior License
95. Change in the organizational structure of licensing agencies and actors during the Prior License phase - Installation License
96. Change in the organisational structure of licensing agencies and stakeholders during the Deployment phase
97. Change in municipal governments during the Implementation phase
98. Contractual warranty periods for non-existent or very short works and equipment
99. Acquisition of equipment with a real service life shorter than the regulatory service life established in the MCPSE
100. Critical pending in guidelines established in the ONS and CUST Network Procedures
101. Crossing the track with others with existing TLs
102. Presence of existing infrastructure conflicting with lt tracing
103. Lack of spare parts and spare parts for rapid replacement of transmission-in-service functions.
104. Difficulty in accessing water for works
105. Substations located on land with unknown soil (Geological risk)
106. LT towers located on land with unknown soil (Geological risk)
107. Crossing large watercourses to the logo of the route
108. Crossing navigable waterways along the route
109. High rainfall (rainfall)
110. Lack of historical data for estimating costs and deadlines
111. Existence of aggressive environments along the transmission line tracing that accelerates asset degradation
112. Lack of registration of the modular composition of transmission functions with respective identifier codes of SIGET ANEEL.
113. Do not consider the physical assets and their configurations, in accordance with the established in the auction, as the main scope of the project of implementation of the enterprise.
114. Do not charge the costs associated with the determination of previous auction reports R1, R2, R3, R4, R5 (ANEEL)
115. ANEEL SIGET System Update Failed
116. Lack of registration of physical assets in the company's engineering system
117. Non-inclusion of modules obtained in non-onerous assignment in the list of modules with active revenue
118. Misappropriation or incomplete appropriation of implementation expenses, in disagreement with the MCSE, MCPSE and PRORET, generating physical leftovers and/or accounting leftovers.
119. Delay in the passage of completed assets and in Operation of condition AIC (Fixed Assets in Progress) to condition AIS (Fixed Assets in Service)
120. Pending in the registration of the assets of the enterprise in the SAGIT system (administration of transmission installation) of the ONS (transmission function)
121. Do not have a firm proposal for the supply of critical items: Conductive cables, metal structures, static compensators, synchronous compensators, HVDC system
122. Do not specify the requirements of the notice in pre-contracts with suppliers
123. Enter into pre-contract with suppliers iniveor no delivery capacity within agreed time and prices
124. Incompatibility of time limits between supplier contracts
125. Inadequate division of scope between suppliers
126. Accept unenforceable time limits on the part of suppliers
127. Owner Engineering services are not performed by the entrepreneur's own teams or by outsourced companies with experience
128. Expectation of increase in exchange variation R$/US$ for the acquisition of imported equipment
129. Design decisions affecting system unavailability time. Ex: Three-phase transformers x Single Phase Bank
130. Schedules of contractual disbursements conflicting with the disbursement curve of the model
131. Fail to consider any technical or operational requirement of the notice in the formation of the price. Error in modeling business risks: Model; Level of impact; Probability of occurrence.
132. Do not have firm prices for the supply of cables and metal towers
133. Hidden defects in works and equipment.
134. Vandalism of the installations in operation
135. Observed (actual) failure rate of equipment above the limit required for the enterprise
136. Accelerated (early) aging of equipment
137. Forecast of occurrence of atmospheric discharges in the region where LT is located
138. Operation error with transmission impact
139. High incidence of atmospheric discards in the enterprise region
140. Deficiency in information systems for construction management

141 . Inadequate integration between construction management processes

142. Not having provided logistics for the transport of special cargo
143. Fixing transmission towers shafts failure
144. Untreated failure modes in the Maintenance Plans Program
145. Mechanic and/or electrical incompatibilities between the physical assets that are constituent sums of a module
146. Lack of tools and resources for agility of maintenance in occurrences affecting transmission functions.
147. Maintenance error with transmission impact
148. EPCista stop teams at the contractor's fault (for failure to release supplies, land clearance, environmental blocks or approved projects)
149. Accidents at work (even transferred to subcontractor)
150. Accidents involving third parties
151. Supply Chain Delays
152. Activities performed with outdated versions of projects
153. Deterioration of the financial health of contracted companies
154. Persistent (recurrent) deviations in the physical schedule of the works
155. Claims for economic-financial rebalancing.
156. Accidents or serious failures during attempts to recover schedule delays
157. Advance of the schedule accumulating pending for energization
158. Delay in the authorization of services (ONS, Contract for sharing and coexistence of CCI facilities, Connection contract to CCT transmission facilities) that require intervesm in third-party facilities or shutdowns of TLs or SEs. Long service times in the relationship with other agents of the interagent sector (accessed and accessible)
159. Failure in the approval of Executive Projects by epcista/contractor (approval of projects that present sizing errors/calculations/etc.)
160. Barriers to the flow of information that delay the process of processing and approval of projects (in the executive project)
161. Occurrence of natural disasters (seismic shocks, floods and sales) during the execution of the works
162. Estimate of unreliable and inconsistent operating and maintenance costs (the value that ANEEL highlights for OPEX is 2% of the Asset's New Replacement Value (VNR)
163. Capture of significantly higher than expected percentages of revenues associated with segregated activities such as Other Revenues (Provision of Project Services, Supervision, Telecommunications, O&M, etc.) by misunderstandings in the interpretation or ignorance of the guidelines established in PRORET Submodules 9.2 and 9.1.
164. "Portion of O&M remuneration below the remuneration provided by ANEEL.
165. On this date (October/2020), the revenue to offset O&M expenses is 2% of the VNR - New Replacement Value of each module of a transmission undertaking.
166. In the tariff review processes of tendered undertakings, the amounts of O&M revenues, determined from the reference auction price, are multiplied by the ratio between the final value offered and the reference value, establishing the benchmark for O&M remuneration thereafter. See PRORET Submodule 9.2."
167. Errors in the appropriation of expenses with replacement of equipment that are considered investment according to the MCPSE.
168. Existence of impediment requirements in the checklist for Commercial Operation
169. Technological obsolity or lack of spares before the end of regulatory life
170. Presence of areas with high slope or bumpy relief
171. O&M costs above the limit set by ANEEL (2% of VNR - New Replacement Value)
172. Presence of areas susceptible to erosion in the tracing provided for LT
173. Presence of areas with the possibility of flooding in the layout provided for the LT
174. Difficulties in accessing the lack of road infrastructure
175. Do not have projects "as built" fidedígnos.
176. Failures in the design and execution of the grounding system
177. Substation design conceptions that hinder or prevent preventive or corrective maintenance from being carried out efficiently.
178. Repair times above the limits necessary for the enterprise (Poor maintenance).
179. Vibration damping system due to poorly designed or poorly installed wind
180. Error in prioritizing equipment replacement
181. Pressings for connection of poorly executed LT conductor cables
182. Project preparation failure in equipment replacement: FT, Modules, Expense Collectors
183. Failure to observe the limits of the ANEEL Price Bank in the replacement of equipment
184. Do not follow the rites established in the MCSE and MCPSE in the replacement of
185. Do not meet the replacement deadlines for equipment already approved by the ONS
186. Do not meet ons requirements for delivery of Transmission functions to operation in equipment subsonia
187. Presence of areas with a very high history of fires in the layout foreseen for lt
188. Increase in the average number of fires in areas where LT was deployed
189. Significant increase in the number of areas for roço (servitude range) compared to the previous year
190. Do not prepare the Annual Reports for ANEEL and ONS
191. Do not run anti-burning communication campaigns with the population
192. Occurrence of shutdowns caused by burning in areas whose roço was not executed within the deadline stipulated by ANEEL
193. Occurrence of shutdowns caused by fires whose roço was not registered in ggt vistorias
194. ANEEL's non-acceptance of justifications proving the performance of the roço in areas where fires occurred
195. Existence of non-indemnified damages to property
196. Commercial operation deadlines for projects to be auctioned non-adherent to the schedule of anticipation of the commercial operation of the Business Plan
197. Changes in the Notice or Draft of the Concession Agreement until the Auction
198. ANEEL's divergent understanding of the questions of the Notice
199. Changes to technical standards and regulatory standards for safety at work.
200. Failure in the planning process of the construction actions of transmission projects, aiming to meet the regulatory requirements of the ONS for the fulfillment of the rites for issuing the Terms of Release
201. Failure to build the Transmission projects in accordance with the provisions of the auction notices, Authorizations and Grants
202. Failure to make information available from transmission enterprises to ONS - SAGIT; SGPMR, etc. – within the deadlines established for the fulfillment of the rites for issuing the Terms of Release
203. Delay in the release of the Definitive Release Terms (TLD) or Pending Release Term (TLP)
204. Changes ANEEL regulations, such as Tariff Regulation Procedures (PRORET)
205. Changes in ons network procedures that bring increased obligations to the
206. Lack of understanding and internalization of the regulatory obligations of the Transmission business at all stages of the asset life cycle
207. Lack of planning and implementation of robust and consistent management system to record the relevant points of compliance with regulatory obligations
208. Failure to request and follow up claims with ANEEL
209. Poor relationship with regulatory agencies and other public agents, bringing a tendency to decisions contrary to legitimate (valid only for these) interests of the company
210. Failure to adequately monitor the regulatory agenda of the sector failing to evaluate, in a time-based manner, the impacts of these regulatory changes in the Business Plan
211. Do not comply with ANEEL / ONS standards
212. Not meeting the deadlines for implementation of recommendations of ANEEL / ONS
213. Unfair penalties imposed by regulatory agencies
214. Wrong decisions in M&A proceedings TO acquire a concession, already in commercial operation or still in implementation, from another agent
215. Project cost is higher than expected in the Business Plan in the Implementation phase (LI-LO)
216. Opening of cvm administrative proceedings in the Operation phase (O&M) for the leakage of information in the media or use of inside information
217. Cancellation of the project in the Environmental Feasibility phase (Auction-LP)
218. LT layout impact Quilombola Remanecent Communities (CRQs)
219. Existence of Quilombola Remancentes Communities (CRQs) not registered with the Palmares Cultural Foundation (FCP) in need of study
220. Cancellation of the project in the Environmental Feasibility phase (LP-LI)
221. LT Tracing Impact Indigenous Communities (ICs)
222. Presence of areas with high or very high speleological potential in the predicted tSu
223. Cancellation of the project in the Implementation phase (LI-LO)
224. Existence of natural cavities less than 250 m away from the servitude strip or road of access to work
225. Existence of natural cavities less than 250 m away from the servitude strip or road of access to work not identified in environmental diagnosis
226. Existence of paleontological sites within the servitude range or road of access to work
227. Decision on the sale of the asset in operation
228. Presence of areas with high archaeological potential or large number of sites already found in the planned layout for it
229. Existence of archaeological sites within the servitude range or roads of access to work
230. Existence of many environmental protection areas in need of plant suppression due to interference of the servitude range and other structures in the LT
231. Need for forest compensation/replacement due to interference of the servitude range and LT structures with areas where compensation/replacement is greater than 1 to 1.
232. Existence of mining research areas crossed by the LT tracing
233. Presence of settlement areas in the project region

Round 2

Reviewer 1 Report

All my comments are well addressed in the current version.