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How to push for Utilities' Y2K readiness

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A Draft Guide for Citizen Action on Utility Y2K Compliance

Version 1.0 September 27, 1998
Compiled by
Tom Atlee

This is an initial compilation which can be much improved by feedback from people who work with it. I am particularly interested in having experts in sustainable, renewable and decentralized energy systems create lists of questions for utility officials, appropriate for this purpose. Please send all suggestions to


I) Are Utilities Vulnerable? - comments by Senator Robert Bennett
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II) Questions for utilities - from Year 2000 Community Preparation information:
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A) Harlan Smith's questions for PUCs (Public Utility Commissions) (to be asked by citizens)(focuses on energy utilities)
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B) Robert Mangus' questions for utility CEOs (to be asked by government agencies/officials, under pressure from citizens) (can be applied to all utilities)
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III) A list of state Public Utilities Commissioners and Consumer Advocates in most states
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I) Are Utilities Vulnerable?

The comments of Senator Robert Bennett, Chair of the
Senate Special Committee on the Year 2000 Technology Problem


I have some disturbing news to report this morning. In order to prepare for today's hearing, I directed Committee staff to conduct a formal survey. The survey was of modest proportions including only ten of the largest electric, oil, and gas utility firms in the U.S. I wanted to know the status of their Y2K preparedness. While the survey is not statistically representative of the entire industry, it does include geographically dispersed firms engaged in all aspects of power generation, and gas and electricity transmission and distribution.

I had anticipated that I would be able to provide a positive report on the Y2K status of these public utilities. Instead, based on the results of this survey, I am genuinely concerned about the prospects of power shortages as a consequence of the millennial date change.

Let me share a few of the survey findings: Only 20 percent of the firms surveyed had completed an assessment of their automated systems. One firm did not even know how many lines of computer code it had. Experts have testified before my banking subcommittee that any major firm that has not already completed its assessment, cannot hope to become Y2K compliant by January 1, 2000.

None of the utilities surveyed were assured after making inquiries that their suppliers, venders, and servicers would be Y2K compliant. Utilities are highly dependent on servicers, suppliers, and other upstream activities to transmit, and distribute gas and electricity. In fact, many power distribution companies are ultimately dependent on foreign oil imports.

None of the firms surveyed had completed contingency plans for Y2K related eventualities. Even though all of these firms are required by their regulators to maintain emergency response plans, none had completed a Y2K contingency plan. My concern is that they probably don't know what contingencies to prepare for.

The last question on our survey asked for recommendations. One respondent, after making several recommendations made the following profound statement: "Whatever actions are taken by Congress, they must be done quickly, during this session, or they will have no impact on the Y2K problem."

I am personally concerned that the Y2K problem is receiving so little public attention. I am concerned that when it does become a matter of general public concern that it will be too late to bring pressure to bear on the timely correction of the many Y2K problems that exist. My greatest fear is that when it does become a matter of general public concern, it will bring with it a measure of panic that will be detrimental to effective and efficient remediation of the problems that will present themselves.

For the private sector, I define the Y2K problem in much broader terms than what I see generally discussed and reported in the trade press which is where many of the Y2K problems are reported. The problem is more than a computer's ability to function on January 1, 2000. It includes not only computers, it includes embedded systems, such as process control units.

I read a story recently about a major oil company that tested one of its oil refineries. They found that the refinery had 90 separate systems that somehow used a microprocessor. Many of these were key systems. Of the 90 systems, they were able to come up with detailed documentation on 70. Of these 70, they determined that twelve had date dependent embedded chips. Of the twelve, four failed a Y2K test and will have to be replaced. Had any of the four failed on January 1, 2000, they would either have completely shut down the plant or would have caused a high level safety hazard which would have caused other systems to shut it down.

What is really worrying the company's experts now is the other 20 systems. They don't know what functions the chips in these systems have and are leaning towards replacing them all. This happens to be a relatively modern plant.

On June 8th, U.S. News & World Report ran a story concerning a Midwestern electric generation facility that was taken off-line to test for Y2K compliance. When the test clock was rolled forward to January 1, 2000, a safety system mistakenly detected dangerous operating conditions and shut the generator down. After three days, they reran the test, only to have a different sector fail, shutting down the generators again.

Another area of the Y2K problem is interfaces. Interfaces sometimes exist between systems within a company, and sometimes exist between a servicer, supplier, vendor, or customer. It is important that Y2K remediation corrections among these parties be compatible.

Infrastructure plays an important supporting role for almost any business. Utilities, for example, are dependent on transportation, telecommunications, water and sewer facilities; all of which are critical to continuous business operations.

Ripple effects are an important concern. If foreign oil production is not Y2K compliant, or if oil tankers' navigation and propulsion systems are not Y2K compliant, what effect will that have on our electric generation facilities that are dependent on petroleum products to generate power? . . .

II) Questions for utilities - from Year 2000 Community Preparation information:

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Between Harlan Smith, Robert Mangus and Gary North, there are over 60 questions here, from which you can formulate you own customized inquiries to utilities (and other companies and agencies) in your area, or to pressure your representatives and governments to find Y2K-readiness answers on behalf of your community. Anyone who wants to get a good education on this entire issue can follow the links referenced in these texts.

Note that it is counter-productive to have hundreds of local citizens overwhelming their local utility with long lists of technical questions. The utility then spends time dealing with the inquiries instead of fixing the problems. The ideal arrangement is to work with a government official willing to move on behalf of citizens. These lists can help you find, educate, pressure and empower those officials. In the meantime, citizens can select a few of these questions for use with utility execs and media, to raise everyone's awareness.

Citizens who are concerned about developing long-term preparedness and sustainability may wish to add questions concerning utility/government plans to promote alternative energy sources and decentralized energy systems, and to use Y2K preparations to reduce long-term energy use in the community.

IIA) Harlan Smith's questions for PUCs (Public Utility Commissions) (to be asked by citizens)(focuses on energy utilities)


As a concerned member of the community, I'm writing to determine the year 2000 preparedness status of our electrical power generation utilities. What are your plans or answers for the following? When will they be available and will they be posted on your web site?

1) Remediation Plan - reference

2) Remediation Staffing, Organization, Funding, CEO Involvement & Understanding

3) Remediation Status & Methodology for Status Reporting

4) Outage schedule plan for testing and repair of Y2K defects

5) Plan for "advanced clock testing"

6) Contingency Plans - reference

7) Vulnerability to failure of other utilities on the grid.

8) Visibility with regard to the remediation status of other utilities on the grid that will affect the ability to supply power.

9) Reliability of fuel sources in Y2K environment

10) Y2K remediation status of suppliers

11) Has local and state governments been adequately educated on the nature and scope of the Y2K problem - reference

12) Negative impact of deregulation on Y2K remediation efforts - reference

13) "Golden handcuffs" policy for retaining key technical personnel (A very big problem)

14) Does the utility participate in the EPRI embedded systems effort? - reference

15) Is the utility involved in cooperative efforts to solve their Y2K problems? - reference

16) Does the utility take advantage of Rick Cowles Industry Forum at

If not, instructions on how to gain access to this forum can be found at:

17) Are the people on your Public Utilities Commission, and the people in the power industry in your state acquainted with Rick Cowles and his Utilities and Year 2000 web site? - reference

18) Are utility CEOs conversant with the "Embedded Systems" problem and do they have in-house engineering staff and consultants on contract working the problem? - reference, and

19) Are replacement parts on order and is the delivery schedule consistent with completing remediation by December 1998?

20) Do utility company Y2K team members have Internet Access?

21) Do cognizant Public Utilities Commission employees have Internet Access?

22) Are Utility Company Managers and Y2K team members acquainted with real life Y2K problems such as those cited at

23) Are Utility Company technical personnel acquainted with the Rick Cowles' Y2K Tool Box? - reference

24) Have the utilities completed a detailed Y2K assessment? - reference

I look forward to receiving your reply to my message.


IIB) Robert Mangus' questions for utility CEOs (to be asked by government agencies/officials, under pressure from citizens) (can be applied to all utilities)

Good Morning,

As one of your constituents, I'm sure we have the same concerns in regard to our Public Utilities' abilities to provided uninterrupted service through the date rollover into January of the year 2000. In conjunction with those concerns I've attached a list of questions that you should submit in writing to any CEO of a Public Utility within the purview your jurisdiction. You should follow up one-on-one with each for detailed answers. You may get stonewalled. If you do get stonewalled, and have the ear of someone at the next level up in the governing hierarchy, please go to that level and put the list of questions in front of them. Tell them that the CEO's are stonewalling, and suggest they send the questions from their office and demand the meetings and answers.

Public utility commissions should have asked these, or questions like them, back in 1996, at the latest. They can do it today. But most government commissioners are not up to speed on Year 2000 health and safety issues. This is why the CEO's of public utilities answer to nobody in civil authority. They don't have to. Progressing de-regulation will only make accountability more difficult.

And those in civil authority will get blamed in 2000.

If any CEO refuses to fully answer these questions, the submitting government agency should then call a press conference. The list of questions submitted should be handed out to the press informing them of the names of the stonewalling CEO's in question and their companies. The press should be enlisted for their assistance in getting these questions answered. The host of the press conference should discuss the consequences for the public safety if firms fail to meet the 2000 deadline.

Prepare a printed text of remarks to the press well in advance to include with the copy of questions with the original submission to the CEO's.

I wish to acknowledge and credit Mr. Gary North's Web site ( for providing the foundation of this dynamic questionnaire. I will keep your office informed of improvements to this list of - presently 41 - questions, or you can monitor any updates to these questions by accessing the Internet address below, and, of course, your own questions should be added.

Please keep me apprised of your progress on this urgent Year 2000 issue. I appreciate the open dialogue that you and your staff have established in tackling Year 2000 issues.

Thank you for your indulgence in this urgent matter. I look forward to a continuing dialogue on Year 2000 matters.


Reference : Gary North's Y2K Links and Forums

Category: Power_Grid
Date: 1998-07-11 18:03:55
Subject: Updated List of Questions for Legislators and Governors to Ask CEO's of Public Utilities

1. How many lines of mainframe, PC and embedded code do you have?

2. How many desktop computers interconnect with the mainframes?

3. What date did you complete your inventory of code and software systems?

4. On what date did code remediation begin?

5. How many programs are you using for which the source code has been lost? Then, what percentage - in Lines of Code (LOC) units - of your inventory does lost code represent?

6. Do your databases need to be converted to reformat all dates for 4-digit years? If so, when do you plan to shut down all processing of transactions long enough to convert all current and archived databases prior to switching to use of the Y2K compliant programs and converted databases? How long will you be shut down?

7. Which mainframe computer languages, other than COBOL, do your systems contain? For each of these languages, how many programmers do you employ on staff who are familiar with it?

8. Do you have written agreement with all organizations with which you share data on the revised format of dates included in shared data? What date will my office receive copies of, or affidavits attesting to, these written agreements.

9. How many full-time Y2K programmers are presently employed on your staff for remediation efforts? What is your schedule for future Y2K staffing requirements?

10. How much money have you budgeted for Y2K projects?

11. How much have you spent?

12. What percentage of the Y2K project's time have you reserved for testing?

13. How many third-party software products do you use?

14. How many of these products are Y2K compliant today?

15. What are the deadline dates that the noncompliant product vendors have given you? (Please provide a list of the products and vendors: those that gave you a deadline and those that did not.)

16. How many outside suppliers of products and services do you contract?

17. How many of them are presently compliant?

18. How many of these suppliers does your computer interact with?

19. How many compliant substitute suppliers have you identified?

20. Is any company in your industry group Y2K compliant?

21. How many of these sister firms is your firm dependent on?

22. What is the weakest link in your industry's chain today?

23. Have managers supplied you with deadline dates for compliance? What are these dates?

24. What are your sources of fuel for your production facilities?

25. Are your fuel suppliers and delivery systems Y2K compliant?

26. Do you have an inventory of fuel?

27. How long will it last under conditions in January 1, 2000? Consider real world conditions and contingencies that are likely to exist with Y2K ramifications for market competitiveness and scarcity?

28. How many embedded hardware/firmware chips and embedded subsystem configurations are in your systems?

29. Have you begun to replace defective hardware/firmware chips and subsystems? What date did/will this replacement program begin?

30. If this program has begun, what is the percentage of discrete defects so far in hardware/firmware chips and subsystems? How many discrete units/pieces of hardware/firmware chips and subsystems does this represent?

31. What date has your Chief Information Officer told you that all of the bad hardware/firmware chips and subsystems will be replaced? (Please submit a photocopy of his signed letter with this estimate.)

32. What is your deadline date to begin the final system subsystem testing? What is your final deadline date to test the Y2K compliance and integrity of the entire utility generation/delivery grid - end-to-end? What contingency plans will be provided to the public in the event that end-to-end testing of your utility service delivery system should fail? At what date and how do you intend to publish the plans? What contingencies has your company established with Emergency Response organizations and with whom? What date should my office expect to take delivery of documentation for these plans?

33. What are your methods for testing code? By what date can you provide documentation of these methods and processes to my office?

34. Where will you get the extra computer capacity to run the tests?

35. How will your new system identify and exclude noncompliant data from outside computers?

36. What percentage of noncompliant industry partners can your systems manage before you must go back to paper and pen information transfers? What systems and subsystems will not tolerate any defects, therefore, preclude any alternative?

37. Have you designed a contingency plan based on paper and pen communications?

38. Can your industry operate today based on paper and pen communications, such as existed in 1960?

39. What date have you told your industry partners, suppliers, and customers that you will begin final testing?

40. If you should fail to meet this date, will you immediately inform these people of your new deadline dates?

41. Please provide a copy of the draft of this letter, and put my name of the list of people to receive it, should you miss the deadline.

III) A list of state Public Utilities Commissioners and Consumer Advocates in most states


In addition to local government officials (mayors, city council members), state representatives (governors, state legislators) and your US Senators and Representative, Public Utility Commissions and Utility Consumer Advocates are specifically mandated to handle your concerns about the reliability, safety, preparedness and service capacity of your utilities. They are among the best targets for broad citizen concern on this issue.

State Public Utility Commissions and Consumer Advocates

Current information may now be found at:

National Association of Regulatory Utility Commissioners (NARUC)
1100 Pennsylvania Avenue, NW, Suite 603
P.O. Box 684
Washington, DC 20044-0684
Tel: 202.898.2200
Fax: 202.898.2213

In addition to educating its members (state utility commissioners) on utility regulation issues, NARUC also represents states in various utility proceedings at the federal level. The NARUC Web site links advocates and citizens to a directory* of state utility commissioners who may be contacted for information about their state's regulatory activities or for filing complaints.
* /stateweb.html

National Association of State Utility Consumer Advocates (NASUCA)
1133 15th Street, NW, Suite 550
Washington, DC 20005
Tel: 202.727.3908
Fax: 202.727.3911

NASUCA is an association of 42 consumer advocate offices in 39 states and the District of Columbia. Members** are designated by laws of their respective states to represent the interests of utility consumers before state and federal regulators and in the courts.