NERC: Help me analyse this. ALERT TO ALL PLEASE READ

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Received this from Bruce Beach via email list. I'll quote his email, then let it sink in for replies. (Here's hoping my HTML is not too screwed up)--- Chris

"NERC is going to test the Electrical grid on April 9th.

This week I downloaded the NERC document. How I got it was to first go with the browser to: ftp://www.nerc.com/pub/sys/all_updl/docs/

There I selected: y2k

and then from that page:
(the following 5 documents
you have to look for them - it is a long list)

"contingency.pdf"
"y2k-reporting-changes-1-12-99.pdf
"y2k-exceptions-instructions.pdf"
"drillfinal.pdf"
"planning-a-drill-4-9-99-final.pdf"

These I then saved to a folder and opened with my pdf reader.

To quote my original source:

"These detail NERC's information blackout strategy to WITHHOLD DATA FROM DOE AND THE PUBLIC

In "y2k-reporting-changes-1-12-99.pdf" NERC states that utilities attempting to conform but which will miss the due dates because of "readiness exceptions" will be allowed to report their mission-critical systems as "y2k ready"

(How can you call that anything but a plan to LIE? Where is Kenneth Starr when you need him?)

and will be listed on reports to DOE and the public as "Y2k ready" for the target industry deadlines of May 31, 1999 and June 30, 1999, as long as these utilities report y2k deficiencies to NERC in secret, "confidential" emails.

---------------------

The following is the result of my personal review of the documents-

Look at this quote:

"All identified exceptions will be held in strict confidence and will not be reported to DOE or the public."

(This at the beginning of unnumbered paragraph 5 and STRONGLY re-iterated in paragraph 6).

In other words they are going to lie to Me, You AND the GOVERNMENT. Nothing here about telling the TRUTH, the whole TRUTH and nothing but the TRUTH. This is not about private sex, this is about a life threatening situation that personally threatens You and Me.

And if you think THIS is bad, it gets MUCH worse.

In the next to last paragraph of:

"y2k-exceptions-instructions.pdf"

We find this statement:

"All information provided in the exception list will be handled confidentially by NERC. This information will not be included in the NERC report to the Department of Energy nor will it be released to the public. The information will be used by NERC to evaluate reliability risks associated with Y2."

In other words, who is going to watch how NERC does its evaluations. I wonder if you could sell the IRS on this arrangement, that your accountant would not send any exceptions that you are making in regards to compliance with the tax code, but will personally evaluate your compliance. I am not a very sophisticated person, so maybe I am wrong. Maybe accountants are "authorized" liars, just like NERC is.

Nevertheless, I don't know how you feel about this. But it makes me just a mite frosted.

Now, let us look at the April 9th Drill itself. Here is a neat little quote in:

"planning-a-drill-4-9-99-final.pdf"

"This guide deliberately does not prescribe the parameters of scenarios to be simulated. Each Region and organization should determine the scope and content of its drills to make the most effective use of the exercise. Below is a list of interfaces to be considered for inclusion in the drill, although it may not be necessary to exercise all of these interfaces."

I am sure that you would be impressed (sarcasm) in a parent/teacher conference meeting if you remarked how well your children were doing on all their tests and the teacher replied: "Oh, yes, we let the little darlings make up their own tests so that they will be sure to do well on them".

Further on in the same document we find:

"If your system has not run drills testing the backup communication system and plans recently, it may be best to choose simple scenarios that allow you more time to implement the drill."

In other words, the teacher is saying,

"Now, then students, be sure that you do not make the test too difficult for yourself".

These reports are full of this type of information, but this is enough to make the point. However, just look at the tough quantified (Hah!) questions for the participant's final report to NERC.

"APRIL 9, 1999 NERC Y2k DRILL EVALUATION SUMMARY

1. Briefly describe the scenario(s) used in the drill.
2. What back-up communication systems were used during the drill?
3. What types of essential sites and facilities were included in the drill?
4. How many people directly participated in this drill? How many additional people supported the design, development, implementation, and evaluation of this drill?
5. Did this drill meet your organizations objectives?
6. What improvements do you anticipate may be made to communications systems and procedures as a result of the drill?
7. What else did your organization learn from this drill?"

These are the ONLY 7 questions the participants HAVE to answer. How would you like your child's final exam to consist of the question,

"Tell me what you did or are going to do on your summer vacation".

These people may all be well intentioned, and I believe they are. My child's teacher, and my child may be well intentioned also, but I really would not want to trust this type of testing if it were in regard to a life threatening situation, such as this is. I hope my doctor or ever licensed plumber was subjected to a bit more rigourous testing.

I had already written all the above when I received the following:--------->

Washington, DC. (March 8) - The March 9 issue of Commerce Business Daily (GovCon.com) reports that the "U.S. Department of Energy, Office of Management and Administration, intends to award a sole source (non-competitive) contract to the North American Electric Reliability Council (NERC) to access its unique knowledge of, and expertise in, electric utility industry reliability issues. This action is in support of the Department's industry oversight responsibilities to assure readiness for an uninterrupted transition at the Year 2000 boundary."

---------------------------

Have you ever heard of anything so nutty. Awarding a contract for the search for truth to someone who has already put in writing that they are going to lie to you.

This has been a week of ASTOUNDING news! I am hearing more and more actual quantified facts that one industry after another has REAL problems. Yet the government and the media is becoming louder and louder about how there is NOTHING to worry about.

To me - that is scary.

Bruce Beach"

-- Chris (catsy@pond.com), March 13, 1999

Answers

To the top.

-- Chris (Catsy@pond.com), March 13, 1999.

I think when they talk about not reporting results to the DOE and the public, they are just saying they will not identify the INDIVIDUAL utility. All of NERC's data is considered "confidential" - that is, they protect the disclosure of a utility, while reporting on the industry as a whole.

-- -- (_@_._), March 13, 1999.

Chris --- Rick Cowles is pretty frosted at the cozy relationship the gov wants to establish with NERC. Also, there have been extensive discussions of this drill over on his forum. Sorry, too rushed to supply the URLs, maybe someone else can.

-- BigDog (BigDog@duffer.com), March 13, 1999.

Please..........

NERC is not going to test the electric grid on April 9th.

Repeat: NOT!

See

The utilities are going to test backup communications. That's all.

See also Rick Cowles thread

On April 10, all the media will report on how well the grid tests went, and that we can expect lights to remain on.

-- De (dealton@concentric.net), March 13, 1999.


After trying the link, I notice that NERC pulled the original instructions off of their web page. Sorry. Suggest you review other threads in Rick Cowles forum. They are only testing backup comm.

-- De (dealton@concentric.net), March 13, 1999.


As for the exceptions, the memo states Recognizing this, the NERC monthly Y2k reporting status will be modified beginning with the January 1999 reports (due on or before January 29) to allow reporting of specific exceptions. Y2k Program Managers should report baseline completion dates for the overall program and note specific exceptions that fall beyond that baseline date. For example, a program expects all mission-critical facilities to complete remediation and testing by May 15, 1999 and to be Y2k Ready by June 15, 1999 with the following exceptions: A, B, and C. The example they use in the Excell spreadsheet (the reporting mechanism) Example Generator One, Units 2 and 3
items not complete - XYZ Controller
reason - Vendor upgrade available 8/31/99; repair during scheduled outage by 9/15/99
I have seen quite a few 10Q statements that point out exceptions for remediating a particular planr and/or system during, for example, a scheduled shut down of a plant for refueling. Another section of the memo Also, beginning in January 1999, any Y2k program meeting any of the criteria listed below will be designated as a Non-Conforming Y2k Program. The Y2k Program Manager will be contacted and provided an opportunity to clarify the reported data. If the issue is not resolved, a letter will be sent from the NERC President to the chief executive of the organization noting the deficiencies. If the issue is not resolved, the status of the program may be reviewed by the NERC Operating Committee or the Board of Trustees. These activities will remain confidential within NERC at least through the first quarter of 1999 and longer, if possible. This information will not be released to the public or reported to DOE. It is essential that the reports to NERC focus on those facilities and items that are mission critical to electric operations. Nonmission-critical items that may be completed after the industry target dates should not be the cause of reporting a late completion date. The criteria for a Non-conforming Y2k Program are: 1. Expected to complete Remediation and Testing or Y2k Ready status for mission-critical electrical facilities past industry targets of May 31, 1999 and June 30, 1999, respectively. Reasonable, specific exceptions may be justified for a limited number of facilities, if they do not pose a risk to electric operations into the Year 2000. 2. Reported exceptions are excessive, not reasonably justified, or may pose a risk to electric operations into the Year 2000. 3. Missed Y2k readiness status reports for two consecutive months. 4. No written Y2k plan. 5. Program does not report to executive management. What I found interesting (and contradictory) is this statement These activities will remain confidential within NERC at least through the first quarter of 1999 and longer, if possible. This information will not be released to the public or reported to DOE. It will remeain confidential at least through the first quarter, and longer if possible, followed by the statement that it will not be released? I'm not sure what to make of that.

-- -- (_@_._), March 13, 1999.

Sorry

As for the exceptions, the memo states

Recognizing this, the NERC monthly Y2k reporting status will be modified beginning with the January 1999 reports (due on or before January 29) to allow reporting of specific exceptions. Y2k Program Managers should report baseline completion dates for the overall program and note specific exceptions that fall beyond that baseline date. For example, a program expects all mission-critical facilities to complete remediation and testing by May 15, 1999 and to be Y2k Ready by June 15, 1999 with the following exceptions: A, B, and C.

The example they use in the Excell spreadsheet (the reporting mechanism)

Example Generator One, Units 2 and 3
items not complete - XYZ Controller
reason - Vendor upgrade available 8/31/99; repair during scheduled outage by 9/15/99


I have seen quite a few 10Q statements that point out exceptions for remediating a particular planr and/or system during, for example, a scheduled shut down of a plant for refueling.

Another section of the memo

Also, beginning in January 1999, any Y2k program meeting any of the criteria listed below will be designated as a Non-Conforming Y2k Program. The Y2k Program Manager will be contacted and provided an opportunity to clarify the reported data. If the issue is not resolved, a letter will be sent from the NERC President to the chief executive of the organization noting the deficiencies. If the issue is not resolved, the status of the program may be reviewed by the NERC Operating Committee or the Board of Trustees. These activities will remain confidential within NERC at least through the first quarter of 1999 and longer, if possible. This information will not be released to the public or reported to DOE. It is essential that the reports to NERC focus on those facilities and items that are mission critical to electric operations. Nonmission-critical items that may be completed after the industry target dates should not be the cause of reporting a late completion date.

The criteria for a Non-conforming Y2k Program are: 1. Expected to complete Remediation and Testing or Y2k Ready status for mission-critical electrical facilities past industry targets of May 31, 1999 and June 30, 1999, respectively. Reasonable, specific exceptions may be justified for a limited number of facilities, if they do not pose a risk to electric operations into the Year 2000. 2. Reported exceptions are excessive, not reasonably justified, or may pose a risk to electric operations into the Year 2000. 3. Missed Y2k readiness status reports for two consecutive months. 4. No written Y2k plan. 5. Program does not report to executive management.


What I found interesting (and contradictory) is this statement

These activities will remain confidential within NERC at least through the first quarter of 1999 and longer, if possible. This information will not be released to the public or reported to DOE.

It will remeain confidential at least through the first quarter, and longer if possible, followed by the statement that it will not be released? I'm not sure what to make of that.

-- -- (_@_._), March 13, 1999.

Chris:

This is not a test. Repeat, this is NOT a test. This is a drill. This is just like the exercise they held in Lubbock. The purpose of this drill is to enable utility employees to *practice* their responses to degraded or absent communications. The idea is that everyone learns where to be and what to do in case of such problems. The entire exercise is just like a school fire drill.

I emphasize that the intent of this drill is NEITHER to discover y2k problems nor to test y2k fixes. It is a simulation of possible problems so as to properly train utility employees to be able to handle such problems should they arise in real life later.

NOW, having said that, what is it that makes Rick Cowles so upset? I wrote to him personally and asked what was wrong with practicing? He replied that NERC appears to be making an effort to misrepresent this drill as an actual y2k test (or at least making NO effort to correct this public misapprehension), so as to let the media fall into the error of reporting compliance when the drill itself has nothing to do with compliance.

Bruce Beach is prime example of the result of this policy. He is alarmed at what he sees as a fake test, rather than happy that NERC is sponsoring a useful practice session. I get this funny picture of Beach running through the school corridors yelling "It's a LIE! There NO FIRE, people! It's a LIE!"

Of course we knew there was no fire. Fire drills were never live exercises with real fires. If you read your own quotes from the document and then read what Beach has written, you'll see what I'm talking about. NERC *never* says it's a test. Beach continues to repeat that it's a test. NERC calls it a drill (which it is). Beach never notices this, even when he uses the word 'drill'. Beach calls it an evaluation. NERC does not. NERC says, "if you haven't had a drill lately, keep it simple". Beach *thinks* this means, make the test so easy you can't fail.

You don't 'fail' or 'pass' a drill. The whole purpose is to improve responsiveness with practice. To do this, you must practice. When NERC speaks of 'readiness' with respect to this drill, they don't mean they're ready to generate and distribute power. They mean they're ready to handle problems if problems arise.

In my opinion, NERC is at best negligent in failing to clear up this confusion. Already they've made Bruce Beach look like a fool, and the seem prepared to make the media look like fools too. And quite likely fooling the public into thinking they'll have power, rather than understanding that if power problems arise, those on the spot will be better trained to deal with them.

-- Flint (flintc@mindspring.com), March 13, 1999.


Flint,

Still smells to me. Doesn't even look like they plan to conduct a proper "Drill".

Can you address the aspect of secrecy? What motivation do they have to withhold anything from DOE, never mind the public?

-- BJ (lurking@aol.com), March 13, 1999.


Nice analysis and reporting Flint.

-- bdb (cb_rex99@hotmail.com), March 13, 1999.


One thing that has bothered me since I heard about these tests -- is the fact they are conducting them on the 9 of April. This day is Julian date 99 one of the spike dates for trouble (because of end of file tests, in cobol).

I also heard they are doing the testing again on September 9, (09/09/99) another spike date for trouble.

Why did they choose these dates ????

-- ALURKER (nobody@nowhere.com), March 13, 1999.


ALURKER:

This is NOT a test. I believe NERC has stated that they chose those special multi-9's dates deliberately, but I can't recall if they explained why.

As for the confidentiality, I can only speculate. NERC does say "If your system has not run drills testing the backup communication system and plans recently, it may be best to choose simple scenarios that allow you more time to implement the drill."

My reading of this statement is that communications drills are not required. Anything not required isn't going to be done. So "not recently" is a euphemism for, "we know you've never run a drill in your life".

To me, the implication is that nobody is really going to know what to do. They have no drill plans (and never did), they don't know how to make plans, and they're not going to be overjoyed about the whole mess. Since DOE doesn't require the drills, why should any utility run the risk of going through with this exercise and look like a bunch of Keystone Kops?

NERC's only answer to this foot-dragging is what they've made as explicit as they can -- keep it simple, don't try anything fancy, and we'll promise not to tell anyone how badly you screwed it up. It doesn't seem that NERC has the authority to *force* the utilities to meet any particular standards, and maybe not even to participate at all.

If anyone wants to argue that this entire program is intended primarily to generate misleading press coverage, I'm not going to argue with you.

-- Flint (flintc@mindspring.com), March 13, 1999.


Flint,

Thanks for the explanations. A little perspective is always a good thing.

-- BJ (lurking@aol.com), March 13, 1999.


Ah, yes, a little perspective may be a good thing. Now try this bit of perspective: the y2k-reporting-changes-1-12-99.pdf memo does not refer to the drill. It refers to regular monthy Y2K reports.

Jerry

-- Jerry B (skeptic76@erols.com), March 14, 1999.


Good analysis Flint. Thank you.

It would make more sense, though, even as a drill-only scenario, to repeat monthly or even bi-monthly through the end of the year. If they don't start by drilling simple problems on all three shifts and all days of the week, then repeat to see if the lessons were learned, then really test (not just drill) the integrated ops now, they won't know what to do then.

And the resulting failures then will be more severe and longer, possibly permanently damaging equipment and controllers that otherwise would not have been harmed if the operators were fluent and well-rehearsed..

-- Robert A. Cook, P.E. (Kennesaw, GA) (cook.r@csaatl.com), March 14, 1999.



Seems to me Beach is getting bent out of shape over nothing. Read the entire document

ftp://www.nerc.com/pub/sys/all_updl/docs/y2k/drill-preparation- strategies.pdf

it sounds like a thousand other things I have read where you don't want to have a really bad result. IT ISN'T A TEST. THEY DON'T CALL IT A TEST. A test requires random sampling - like health inspections at bakeries.

-- Paul Davis (davisp1953@yahoo.com), March 14, 1999.


Thanks for all your input guys. This place is great :-)

This is a good example of how hype feeds on itself. This email is spreading as wildfire now I'm sure. Bruce Beach has an email list which is pretty big.

The way he constructed this one, he had me calling NERC all sorts of names. I am not knowledgable on how bodies like NERC operate, and couldn't make the difference between "drill" and "test", eh. But something in the back of my mind told me that this was just too much conspiracy on the part of NERC to be real, and being so accessible on the net to begin with!

Just think of all the clueless people like me who didn't have the presence of mind to get different opinions from experts as I did ;-)

-- Chris (catsy@pond.com), March 14, 1999.


Most of you seem to be caught up in this drill/test excersise. I'm more concerned about the witholding of informatin for the next NERC report on the electric reliability status of the states. All the "mission critical" items that will not meet the June 30 deadline will be attached as a seperate email and sent to one man. This information is not going on to the Department of Energy. We will get more happy face reports this summer when in fact, the bad news has been intentionally left out to keep the herd calm.

-- James Chancellor, P.E. (publicworks1@bluebonnet.net), March 15, 1999.

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