I'd been assuming that NERC's Y2K program and deadlines applied to the entire electric industry, but recently, I've learned that our local utility does not report to, or consider themselves subject to the deadlines of, NERC's Y2K program, since they are not a "bulk electric" company (generator). Apparently companies like ours, that do not generate but only distribute electricity, report their Y2K status to another trade group, the American Public Power Association (APPA). So I e-mailed APPA, and got this response. Apparently, APPA has their own guidelines, and set no deadlines at all for their members, which probably explains the confused reaction I got when I brought up the NERC deadlines with our electric company ...
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Date: Wed, 1 Sep 1999 13:36:09 -0500
Subject: Is NES Y2K ready?
Dear Mr. Hyland:
As a neighborhood watch director I'm very concerned about health and safety issues that may be impacted by Y2K-related power failures.
As I e-mailed you (via your APPA web site) on August 23rd, representatives from Nashville Electric Service have claimed they were "Y2K Ready" as of 6/30, but also seemed to be assuming the NERC's contingency plan deadline of 6/30 did not apply to NES, since it was only a distributor. They stated that they reported to you on their Y2K status. So I wondered if you could confirm this information about NES's readiness, and also whether distributors are exempt from the NERC deadlines?
I have not received any reply from you so far, so I thought I'd try you again via normal e-mail. Thanks for your attention to this.
- Judy Hoskins
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From: "Hyland, Mike"
To: jhoskins1@juno.com
Date: Wed, 1 Sep 1999 15:22:12 -0400
Subject: RE: Is NES Y2K ready?
Hi Judy!
Glad that you got back to me. I seem to be crushed lately with phone calls, e-mails and paper mails. (i.e. I sometimes receive over 100 e-mails a day.) I apologize if I missed your first e-mail.
Let me explain the background, and I hope this helps. When the North American Electric Reliability Council (NERC) accepted the
Department of Energy's (DOE) task of reporting on the electric industry Y2K readiness status, they (NERC) realized immediately that they help maintain, oversee, etc. only the high voltage generation and transmission grid. They did not have much contact or understanding of the distribution systems throughout the US. To put it in perspective, NERC deals regularly with about 255 Large utilities which operate generation and transmission through it's 10 Regional Councils. Of those 255 (Approx.) TVA is one.
However, there are approximately 3200+/- electric systems in the US.
NERC immediately asked that APPA, EEI, and NRECA assist them in the process of attaining Y2K readiness info.
APPA represents the 2012 municipal, state, locally owned electric systems such as Nashville. However, most are not as large as Nashville.
The NRECA represent about 900 Cooperatively owned electric systems.
EEI represents about 220 Investor owned electric systems.
We all agreed to help in the process. We also each used our own surveys and strategy to attain the Y2K Readiness info. For APPA, that meant using three different surveys, based on the utility size. (Municipals range from Los Angeles, CA with 1.5 million
customers to Radium, Nebraska with 20 customers.)
NERC promoted deadlines and surveys to those 255 +/- throughout the process, with the final date of readiness being 6/30/99. APPA encourages utilities to get Y2K ready ASAP, but did not set a time limit or date. Our (mine) belief is that 'Y2K Readiness' counts on only one date - 12/31/99. However, through the survey process, APPA's numbers followed the survey numbers of NERC, EEI and NRECA. In addition, all numbers have been confirmed by the latest Y2K audits by the DOE. They audited the Y2K programs of about 35 electric systems in the US.
Now, to address your specific questions:
"As I e-mailed you (via your APPA web site) on August 23rd, representatives from Nashville Electric Service have claimed they were "Y2K Ready" as of 6/30, but also seemed to be assuming the NERC's contingency plan deadline of 6/30 did not apply to NES, since it was only a distributor."
- Nashville reported to APPA through the APPA survey process. Nashville answered every survey, which was then tabulated with the other municipals and forwarded to NERC for the NERC Quarterly reports to the DOE. During the process, Nashville may not even have been aware of these 'artificial dates' promoted by NERC. (Remember: Nashville does not report to NERC in any way. NERC is simply a volunteer, non-profit organization to help oversee the US High Voltage Electric Grid) Nashville is a valuable APPA member however. My records confirm that NES did expect to be Y2K ready prior to June 30, 1999. (The same goes for more than 92% of our APPA membership for 6/30/99. By Oct 1, 99 that number increases to 99%).
If you are specifically looking at Contingency plans, we did not link the two. Our question for Y2k readiness did not depend on having a contingency plan. Why? Well, I wanted the electric systems to first ensure that their distribution systems would meet the Y2K date without problem. By performing the work needed, by the 6/30/99 date, they could then devote time and manpower to adapting their contingency
plans as needed. The industry wide drill on 9/8/99 and 9/9/99 will help all utilities fine tune their contingency plans.
"So I wondered if you could confirm this information about NES's readiness, and also whether distributors are exempt from the NERC deadlines?"
- As stated above, Nashville reported to APPA, not directly to NERC. As stated above, NERC is a voluntary organization which interacts with only 255 or so of the 3200 electric systems in the US. By the term distributor, I assume that you are talking about the TVA distributors. APPA did survey the municipally owned distributors. TVA however, reported directly to NERC. The NERC deadlines are only for those reporting to NERC.
"I have not received any reply from you so far, so I thought I'd try you again via normal e-mail. Thanks for your attention to this."
- I apologize for not replying, but I can't find the first e-mail. No problem on my attention. Please call me at the number below if you'd like to hear more, or discuss the issue further.(or send me your number, and I'll call.) I'm sure you're contacted NES. As your know, only they can really answer this questions on Y2K readiness.
-mike
Michael J. Hyland, PE
Director of Engineering Services
American Public Power Association
202.467.2986
202.467.2992 Fax
mhyland@appanet.org
-- Anonymous, September 02, 1999
Judith, the American Public Power Association, like NERC, is an industry trade group, a "service organization for the nation's 2000 community owned, locally controlled, not-for-profit electric utilities". ( http://www.appanet.org ) It works for it's member utilities.
It's membership is comprised of what is often called, "Munis" or Municipal utilities. This can include a large city's power generation plant (Anaheim, CA Public Utilities -- serving Disneyland, Boeing Aerospace, etc. and 300,000 residents) or a very small town that for one reason or another has chosen to generate their own electricity (Sherbourne, NY pop. 3,000+).
The APPA Y2K information breakdown in the most recent (Aug.) NERC report to the DOE is a marvel of misdirection in my opinion. It mentions three surveys APPA did of its membership, the first in 1998 to all its members. The next survey was done in March, 1999, for just the middle and largest public power systems. A third survey is mentioned for June, but if you read carefully this can't have been the same as the first or second surveys because the Information and Planning category, and Testing and Results info is all a repeat from the March survey, not June. The June survey did have readiness estimates for 1,737 utilities. ( Which means 275 utilities either did not respond or did not give any readiness estimates.) The June survey appears to have focused on Contingency Planning more than anything else, according to the info given.
The latest survey (June) had a response rate of 86.3%. Obviously, 13.7% did not answer the survey. But I loved the way APPA stated that, "combining the three surveys, the overall response was 98.86% of utilities (1,989)" Who cares if they also say they sent out 2,012 surveys and we're somehow missing 21 in that overall response total? And what does counting a utility which might have reported only once last year in the "combined" response have to do with anything? (NERC does that trick of combining responses, too. If a utility responded just once since July of last year when the surveys began, they would still be counted on the response list NERC puts out.)
We also have the report that "speaking only of mission-critical systems, 73.08% of the middle and 82.76% of the large groups have completed *some* testing." ( Of those middle and large entities which responded, of course, and not all of them did. And this is as of March, with no June data in this category listed.) SOME testing? What? If they'd tested one component they got counted?
By now, Judith, you've undoubtedly gotten the impression that I personally don't think much at all about the quality of APPA's Y2K oversight. And you're right.
But of course 98+% of APPA's members are now mission-critical ready or will be soon. Good news abounds in the APPA press releases. I found a Casebook Study done of three small public power utilities about six months ago, around the time of the March survey. Don't ask me for an URL because I had to do searches on the APPA site and this was a huge zipped file I came across by accident and which gave my computer memory problem fits today and I had to delete the whole thing, grumbling all the way. It was called Y2K case studies [DEED] and PSE-studies, I do remember that. I managed to be able to access a couple of the early summary pages and used a print screen to get just one page before everything froze up.
The three utilities' Y2K projects were in progress from what I could tell. Here's part of the "Summation of Trouble Spots (Or, What Not To Do)":
"Any small public power system is bound to have some problem areas or troublespots with Y2K readiness efforts. We have listed a few that we have observed during this study.
Vendors of billing software were late on promises to deliver in two out of three of the case studies.
Incomplete chronologies were performed prior to this work. Even though Y2K was recognized early on as an important issue, the importance of documenting Y2K activities may not have been recognized as quickly.
Many utilities lack contingency plans even in basic form, especially in the area of communcations.
Non-respondents to compliance letters leave the utility unsure of where their Y2K readiness stands.
Y2K support is lacking from engineering firms "of record" who designed and planned utility systems now in operation.
No clear schedules exist of remaining activity to be accomplished over the next ten months.
There are no assurances (or detail) from major suppliers, especially power suppliers and telephone companies.
"Buttoning up" efforts in a concise report or notebook is troublesome.
Difficulty seeking, finding, and using Y2K expertise to supplement the utility's efforts are of concern. Trouble arises coping with a problem that is beyond the expertise of the utility.
Budgets and costs are not clearly articulated, and much of the work on Y2K is unmeasured."
There may have been more but that was all I got before everything went haywire. Have the problems all been solved and public power is good to go? I think your guess is as good as mine or APPA's. Think I'll switch to binoculars like Tom Benjamin because the microscope is showing one very confusing picture.
-- Anonymous, September 02, 1999
Bonnie's diligence inspired me to do a little more searching, and I
found the statement that led me to believe "contingency plans" were
part of APPA's definition of being "Y2K Ready," in spite of their
recent reply (posted above) that seems to deny this, and our local
utility's unawareness of it. This APPA page, entitled "Member
Services" (below) includes the statement:
"Part of being "Y2K ready" means having a
contingency plan in case your systems go down.
For example, you may have tested your substations
and distribution control systems and are confident
that your system will operate on Jan. 1, 2000, but if
something malfunctions for your power supplier, you
may find yourself without any power to distribute...."
This page is apparently intended for APPA members, rather than the
public (requires a password from the APPA page), and I couldn't find
it until I went through the Dept. of Energy's web page
(http://cio.doe.gov/y2k/energy_sector/default2.htm). So I've copied
the text of that whole page here in case that link gets changed [Note:
this forum is one of the sources of "useful information" they
recommend at the bottom of their page ...] - Judy
http://www.appanet.org/y2k.html
Public Power and the Y2K Computer Problem
FACT SHEET
What's all the fuss?
Our modern computerized world may find itself scrambled on Jan. 1,
2000 when digital calendars turn from 12/31/99 to 1/1/00. Many
computers and chips embedded in equipment may shut down or malfunction
because lines of code in their programs will recognize 00 as the year
1900, rather than the year 2000. The potential impact on electric
utility operations could be devastating. The Y2K problem has the
potential to affect billing and customer information systems,
distribution systems, transmission lines and generating plants.
What should each local utility do to address this problem?
Each utility needs to follow a four-step process: inventory,
assess, test and remediation. First determine what equipment on your
utility system may have a Y2K problem. Once your inventory is
completed, assess which systems are most critical to your operations
and test those first. Once tests indicate that a Y2K problem exists,
make the fix--either by replacing parts or equipment or reprogramming,
if possible. Testing computer systems is time-consuming and
labor-intensive. For electric utilities, the potential problems caused
by chips embedded in various kinds of electronic equipment in power
plants and on distribution systems pose the greatest challenge.
Tests of single pieces of equipment often show that, in isolation,
the equipment will work fine when the calendar turns at the end of
next year. However, all equipment needs to be tested within the
system, as data exchanges between two apparently Y2K-ready pieces of
equipment could trigger data confusion and an equipment malfunction.
How can we address the embedded systems problem?
The Y2K problem on embedded systems is the biggest thorn.
Microprocessor and small computer chips have been inserted into
millions of pieces of equipment ranging from elevators and fire
detection systems to environmental control systems, lighting, postage
machines and distribution equipment. Process control systems that
monitor and regulate the flow of electricity could cause a shutdown of
the electric delivery system. To address the problems, it is necessary
to make an inventory of the embedded devices at your utility, to
determine the impact of each device on your operations and to contact
the manufacturer, if possible, to determine whether it will operate
normally when the calendar turns.
Testing may still be required since some manufacturers have gone
out of business and others are unsure of the Y2K status of systems
produced years ago. Company mergers also contribute to confusion on
the part of manufacturers about the readiness of equipment.
What does it mean to be "Y2K compliant?"
It's better to say you are "Y2K ready." In other words, there's no
law to comply with here. You want to take all steps you can to be
ready for the turn of the calendar by testing your systems and
modifying or changing equipment, where necessary, to assure that
systems will operate normally after Dec. 31, 1999. The pervasiveness
of the problem requires each utility to establish priorities. Critical
systems must be addressed first, non-critical systems take a lower
priority.
For example, getting the distribution system ready for the year
2000 may take a higher priority than getting your summer peaking
generator ready. Having backup generation ready to go on Jan. 1, 2000
may take a higher priority for your utility than operating a load
management system. Part of being "Y2K ready" means having a
contingency plan in case your systems go down. For example, you may
have tested your substations and distribution control systems and are
confident that your system will operate on Jan. 1, 2000, but if
something malfunctions for your power supplier, you may find yourself
without any power to distribute.
But haven't some regulatory authorities imposed some compliance
rulings?
Yes. The Governmental Accounting Standards Board on Oct. 14, 1998
issued a technical bulletin requiring governmental entities to
disclose information about their year 2000 compliance. The bulletin,
Disclosures About Year 2000 Issues, affects financial statements for
which the auditor's report is dated after Oct. 31, 1998. It requires
government entities to disclose any significant resources committed to
making computer systems and equipment ready for operation in the year
2000. Additonal information about the bulletin is available on GASB's
Web site.
In addition, the Securities and Exchange Commission on Aug. 4,
1998 published in the Federal Register (Vol. 63, No. 149, pages
41394-41404) an interpretive release recommending that issuers of
municipal securities provide information to their bondholders on their
ability to meet financial obligations in light of potential year 2000
problems. The SEC also suggests that municipal issuers follow
guidelines set forth for stockholder-owned companies. These include
disclosing steps taken and costs incurred to prepare for the year
2000, risks presented by the Y2K problem and a description of
contingency plans if outages occur. To read the interpretive release,
go to the SEC's Web page.
Is Jan. 1, 2000 the only date we need worry about?
Not necessarily. Other dates that might trigger computer chip
malfunctions include 1-1-99; 8-20-99 (for functions involving
satellites), 9-9-99 and 2-29-00. In addition, organizations with a
fiscal year that begins July 1, Oct. 1 or any other date prior to Jan.
1 may experience problems before Jan. 1, 2000.
How serious is the Y2K problem?
In terms of dollars, it has been estimated that addressing
the year 2000 problem will cost $600 billion on a global basis. And
the problem is a global one. It affects all businesses and industries,
governments, schools, and countries around the world. According to a
consultant for the North American Electric Reliability Council, there
are 50 million devices worldwide with Y2K anomalies. One mid-sized
electric utility in the United States has 170,000 devices that may
fail when the calendar turns. Some economists have predicted that the
worldwide problems caused by failed computerized systems on Jan. 1,
2000 could trigger a global recession worse than the 1973 oil embargo
and a 30% drop in the stock market.
What is APPA doing to help its members address the Y2K problem?
APPA is working with the U.S. Department of Energy and several
industry groups to address the problem. Under an agreement reached
with DOE, the North American Electric Reliability Council is
monitoring and reporting on progress on Y2K issues related to
generation and transmission of electricity. APPA and its counterpart
industry associations--the Edison Electric Institute and the National
Rural Electric Cooperative Association--are monitoring and reporting
on Y2K readiness as it pertains to distribution of electricity. APPA
is responsible for monitoring all public power utilities--not just the
1,300 that are dues-paying members of the association. In June 1998,
APPA surveyed all public power utilities to assess their awareness of
the problem and their readiness to deal with it. In September, NERC
reported industry-wide findings to DOE.
The association is preparing to set up a Y2K e-mail list serve
network to facilitate exchange of information among APPA members and
between utility members and APPA staff. To participate in this
information-exchange group, send an e-mail to Mike Hyland:
mhyland@APPAnet.org.
In addition, APPA has published articles in Public Power magazine
and Public Power Weekly newsletter providing information on resources
available for addressing the problems. Experts on the topic have
appeared at APPA meetings and workshops and information is posted on
the APPA's Web site, visit the events section for more information.
Where can we go to get more information?
All information that APPA has prepared to assist its members on
Y2K is available on this page. Utilities that need more information
should call the association. Here are individuals to call:
Technical issues: industry assessment process: Mike Hyland,
Director of Engineering Services, 202-467-2986, e-mail:
mhyland@APPAnet.org
Public relations and communications: Madalyn Cafruny, director of
communications, 202/467-2952, e-mail: mcafruny@APPAnet.org
Congressional/legislative issues: Scott Defife, legislative
representative, 202/467-2985; e-mail: sdefife@APPAnet.org
Attorneys/legal section: Dick Geltman, corporate counsel,
202/467-2934; e-mail: rgeltman@APPAnet.org.
There are also a number of other Web sites with useful
information:
www.eei.org/EEI/press/y2k/
www.nerc.com/~y2k/y2k.html
www.gao.gov/y2kr.htm
www.kode.net
www.euy2k.com/newsroom.htm
www.year2000.com
www.year2000.com/y2klawcenter.html
www.y2kjournal.com
www.nist.gov/y2k/
www.erols.com
www.compinfo.co.uk/y2k
www.tickticktick.com (the Y2K Quarterly News Letter)
www.software.ibm.com/year2000/resource.html#cgp
www.vendor2000.com
www.y2k.gov
www.sba.gov/y2k
Are there commercial resources available for helping address the
Y2K problem?
Yes. APPA has not evaluated any of these commercial groups and
does not endorse any. Listed below are a few vendors that are
providing products and services to help electric utilities prepare
address the year 2000 problem. As APPA receives suggestions from
members or otherwise becomes aware of such commercial sources, we will
add them to this list.
Electric Power Research Institute
Tallahassee Training Institute
TAVA/RWBeck
Century Information Management Systems, Inc.
How should we respond when our customers and vendors ask how we
are dealing with the Y2K problem?
Make no guarantees, as that is nearly impossible. Only indicate
what you have done and are doing, but don't indicate future intentions
that may not eventuate. If you are taking steps to address the
problem in a systematic and responsible manner, you should indicate
that.
What have Congress and the President done about the Y2K problem?
On Oct. 19,1998, President Clinton signed into law the "Year 2000
(Y2K) Information and Readiness Disclosure Act" This law provides
limited liability protection to organizations that share information
about solving the Y2K problem. The measure also creates a specific
exemption from antitrust laws for entities that share information on
Y2K solutions. It does not protect parties from damage claims related
to a failure to make systems Y2K-ready. Nor does it cover statements
by companies to individual consumers, as Congress and President
Clinton believe it is important to protect consumers.
ADDITIONAL RESOURCES
Public Power Weekly Stories
NRC is Urged to Do More to Guard Against Y2K Mishaps (12/21)
Wisconsin Public Power Sets Up a Y2K Database (12/14)
Y2K Requirements Explained in Internet Articles (12/7)
Problem is A Serious One for Utilities, Attorney Warns (11/16)
Y2K Poses 'A Real Threat' Says APPA Report (11/2)
Governmental Accounting Standards Board Requires
Data About Year 2000 Readiness (10/26)
Members of APPA Can Sign Up for New Y2K Computer Forum (10/19)
Alliance Will Offer Y2K Support Services (10/12)
Y2K Information-Sharing Bill Wins Congress' Swift Approval (10/12)
NRC plans audits of 12 nuclear plants to ensure Y2K problems are
addressed (9/28)
Bill Seen Easing Y2K Information-Sharing (9/21)
NERC Report Downplays Y2K Impact on Electric Utilities (9/21)
Y2K computer problem draws international attention: Summit scheduled
for London (9/14)
Missouri PSC launches probe of Y2K readiness (9/7)
EPA takes hard line on Y2K foul-ups (8/24)
SEC takes action on Y2K computer problem (8/17)
How Wisconsin Public Power tackled the Y2K problem (8/3)
President Clinton says he'll introduce a bill to grapple with year
2000 computer problem (7/20)
APPA offers information packet on year 2000 solutions (7/13)
Tallahasse turns Y2K problem into an opportunity (6/29)
Senate panel mulls over year 2000 computer problem (6/22)
APPA gathering data about year 2000 computer problems (6/15)
Washington Report
Y2K, Ready or Not (August 1998) by Robert Varela
DISCLAIMER: This information is provided as a service of the
American Public Power Association to its members. The information is
gathered from the national trade press, state and regional
associations and public power utilities.
This information is intended to be a starting point for further
research and does not necessarily represent the latest research. The
American Public Power Association shall have neither liability nor
responsibility to any person or entity with respect to any loss or
damage caused, or alleged to be caused, directly or indirectly by any
information provided herein or through listed web site links. The
American Public Power Association makes no endorsement of the
accuracy, capability or functionality of any of the information,
products or services mentioned.
ALL INFORMATION IS PROVIDED AS IS WITHOUT WARRANTY OR CONDITION OF
ANY KIND. APPA EXPRESSLY DISCLAIMS ANY AND ALL WARRANTIES WHETHER
EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO IMPLIED WARRANTIES
OF NON-INFRINGEMENT, MERCHANTABILITY AND FITNESS FOR A PARTICULAR
PURPOSE.
-- Anonymous, September 08, 1999