In assessing electric industry readiness using the NERC report, there are two one page documents on NERC's website I suggest people review. They seem to essentially say that NERC will sit on bad news until at least June, if it is reported to in a particular manner. (One really needs to see that they are posted on the NERC website. Otherwise, any reasonable person would think they were made-up.)

With your web browser go to:

ftp://www.nerc.com/pub/sys/all_updl/docs/y2k/

Then find and open:

y2k-reporting-changes-1-12-99.pdf

y2k-exceptions-instructions.pdf

I think you would find them interesting, and I would be very interested in your take on them.

Snyder Gokey

-- Anonymous, April 05, 1999

Answers

I sent a version of this question to John Koskinen's office, and got back the following response. It is a very nice response. I do not understand why "The exceptions do not affect the numbers of systems or companies who are compliant." Maybe others can straighten me out.

The response I received:

Thanks for your interest in these sites. I have been aware of the question of "exceptions" and, in fact, NERC discussed them at the February press conference releasing their second quarterly report. The exceptions do not affect the numbers of systems or companies who are compliant. Instead, they are explanations the companies individually can provide NERC as to why their inability to meet the deadlines are understandable and appropriate (e.g. waiting for a planned outtage to test remediated systems). The information is not released because it is company specific and the surveys do not identify companies for the public.

This information allows NERC to monitor closely the readiness of each individual company. As noted on the pages you cite, if there are excessive "exceptions" the company's program will be classified as "non-conforming" and the NERC President will write the CEO of the company and, if necessary, have the matter considered by the full NERC board for appropriate action by the board. This is the only industry association that has such a full, self-monitoring, company specific policy as a general matter. The securities industry is doing a "street-wide" test that will have a similar impact on companies not able to participate.

Because of questions raised about this process, I've asked NERC to provide a fuller explanation with their next report.

Best wishes.

-- Anonymous, April 05, 1999

Snyder, there are several posts commenting on this issue in the "NERC INFO BLACKOUT/Y2K readiness exceptions" thread on this forum at:

http://www.greenspun.com/bboard/q-and-a-fetch-msg.tcl?msg_id=000bkR

Hope this helps you!

-- Anonymous, April 05, 1999

Snyder, I saw your second posting after I'd typed my first response. I'll be interested to see if NERC does " provide a fuller explanation with their next report" and if that report also happens to mention "The exceptions do not affect the numbers of systems or companies who are compliant."

As far as any exceptions not affecting the *numbers* of systems or companies who are compliant, if you pay close attention to the wording, of course they don't! Another way of stating that sentence is to say that the number of systems or companies deemed ready is not changed by the number which aren't. This does not address the fact that the exceptions might affect the *performance* of the utility they are in, or affect the *stability* of grid issues, or create non-conforming issues which will have to be dealt with.

The ways in which sentences are being constructed nowadays is sometimes enough to make me think the government has a team of English grammaticists on staff for the express purpose of creating nice sounding lines which do not actually say what they at first appear to say. It never hurts to remember we have an administration and legal system where "It depends on what is is," was taken very seriously and was not meant as the joke it has become for the average citizen.

In my youth, I once had a battle-axe of an English teacher who would have considered herself to be in a sentence parsing teacher's heaven these last few months. She would have worn those chalk sticks to a nub writing statements on the blackboard and rasping, "Now what does this ACTUALLY say and why?" If I didn't know the lady had already passed on to her reward, I'd suspect she was on Koskinen's payroll. *grin*

-- Anonymous, April 05, 1999

Another entry on that index page looked interesting --

02/10/99 06:55PM 7,842,680 y2k-gas.zip

The link is ftp://www.nerc.com/pub/sys/all_updl/docs/y2k/y2k-gas.zip

I haven't looked at this yet -- it's too late at night. But if it deals with gas, and it's that large, hmmm....

-- Anonymous, April 06, 1999

Bonnie, the reporting change only effects the completion date being reported to NERC, not the percentage complete, or number of systems.

-- Anonymous, April 06, 1999

Hoffmeister, I think we're saying the same thing. That the number or percentage of systems or companies which are ready isn't going to change because of the Exceptions. They're exceptions exactly because they can't be added to the readiness numbers. The point is that this didn't even need to be mentioned in the response from Koskinen's office as it's irrelevant. What exactly the exceptions are and what the potential impact on utility operation might be if they are not completed is the issue.

I'm not sure I agree, however, that NERC only wants the extended readiness "date" reported. Are you saying NERC is only asking a utility to report that an "unknown" system or systems will not be ready by the NERC required date but will be ready at such and such later time? If they're only dealing with dates in the exception reporting, then estimated final completion dates are already given in the regular anonymous NERC reports. The reason given for not releasing the Exception information is that it is company specific. So are all the estimated completion dates in the regular reports, but we still don't know which companies they are.

In the NERC reporting changes document it gives an 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." Sounds to me like they want specifics, not just ready dates put in for that "A, B, and C" with no information about what systems will be delayed in completion.

Unfortunately, since it was stated that "A specific format for reporting the exceptions will be provided by a separate e-mail." we can't know exactly what details NERC wants -- unless someone in the industry would like to post that format.

What hasn't been stated by NERC, is that if these exceptions are reported on the confidential new format, are the utilities then only supposed to report the estimated completion date for the other systems on the regular monthly report? That would make those completion dates all fall into NERC's deadline, wouldn't it? And the available public information would show that everyone was going to finish by the date NERC wanted them to finish -- except for those areas delayed and for which the Exception reports were made -- reports we aren't going to have access to.

I hope that's not what is going to happen, but I can't yet find any specifics which discount that possibility.

-- Anonymous, April 06, 1999

Bonnie,

I also had the good fortune to have a tremendous 9th grade English teacher, Col. Phillip I. Eschbach, who's instruction sentences were like paragraphs and whose paragraphs were like essays. But back in those days we had to "diagram" the sentences. I used to hate it, and I knew it wasn't good English. It was tremendously demanding. However, I had a long discussion with my Mother, a teacher, who said do it, and learn. So I did. It has turned out to be one of the most useful and instructive learning experices of my life. It has helped me write numerous legal contracts, interpret law, interpret contract law, and even understand what clinton is actually saying. I found out he "not never lied, not a single time". I'm sure that your personal "battle ax" contributed much to your excellent posts on this site and she should be given 3 cheers.

-- Anonymous, April 06, 1999