How to push for Utilities' Y2K readiness
(Copy and distribute this page as needed.)
Version 1.0 September 27, 1998
A Draft Guide for Citizen Action on Utility Y2K Compliance
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 email@example.com.
I) Are Utilities Vulnerable?
- comments by Senator Robert Bennett
II) Questions for utilities -
from Year 2000 Community Preparation information:
A) Harlan Smith's questions for PUCs
(Public Utility Commissions) (to be asked by citizens)(focuses on energy
B) Robert Mangus' questions for utility CEOs (to
be asked by government agencies/officials, under pressure from citizens)
(can be applied to all utilities)
III) A list of state Public Utilities Commissioners
and Consumer Advocates in most states
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
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
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
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
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:
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
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 http://2000.jbaworld.com/embed/compare.htm
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 http://www.euy2k.com/cp.htm
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 http://www.angelfire.com/mn/inforest/smpc1.html
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? -
15) Is the utility involved in cooperative efforts to solve their Y2K problems?
- reference http://year2000.epriweb.com/year2000/announcements/senatepress.html
16) Does the utility take advantage of Rick Cowles Industry Forum at http://www.greenspun.com/bboard/q-and-a-challenge.tcl?topic=euy2k.com%20-Players%20Only-
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 http://www.euy2k.com
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 http://www.euy2k.com/embedded.htm,
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 http://www.euy2k.com/reallife.htm
23) Are Utility Company technical personnel acquainted with the Rick Cowles'
Y2K Tool Box? - reference http://www.euy2k.com/toolbox.htm
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
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
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 (www.garynorth.com)
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
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
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
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.
National Association of State Utility Consumer Advocates (NASUCA)
1133 15th Street, NW, Suite 550
Washington, DC 20005
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.