OG&E claims in the public record that it is "Y2K Ready" (press release of June 30, 1999, brochure inserted into August 1999 bills). This statement must be evaluated in light of this information gleaned from their Y2K disclosure documents (posted at their website, OG&E website ).

The company has not completed assessing its hardware and software for y2k problems.

The company admits a minority percentage of their systems will be impacted by Y2K (percent not specified).

Repairs and replacement of equipment continues at this time (mid-August 1999) and the company is not able (or willing to publicly disclose) a completion date other than "before the turn of the century" for the completion of these repairs and equipment.

The company has not tested all of its hardware and software, nor its repairs to the same, for year 2000 compliance. It is continuing the testing process.

The company has provided no data for public review or comment regarding its tests.

There is no independent auditing or verification of the company's repair or testing process. Neither the Corporation Commission nor the Department of Energy (state and national, respectively) are exercising any oversight other than collecting reports from the company.

They have not contacted all their vendors/suppliers about their y2k readiness, and they have not received responses from all the vendors/suppliers that they have contacted.

The company is shielded from liability regarding its Y2K disclosures by state and federal legislation.

There are five primary documents that OG&E has published concerning its Y2K compliance status:

1. The letter sent to customers (also posted at their website, www.oge.com)

2. Y2K "FAQS" at the website.

3. The NERC report to the DOE of August 1999.

4. A "Y2K readiness disclosure" posted at their website (which incorporates the FAQS and the letter).

5. A brochure inserted in August bills.

August billing insert

OG&E inserted a brochure in August bills stating:

"After several years of testing and making necessary corrections to essential systems that might be affected by the Year 2000 date change, we're confident about our Year 2000 readiness. If problems should occur, we believe they will be minimal. For extra assurance, we have contingency planning in place that will help us quickly respond to problems. Throughout the remainder of 1999, we will continue to retest and evaluate our systems." Readers are invited to visit www.oge.com for more updates to this disclosure.

From this disclosure we learn OG&E is "confident" about their Year 2000 readiness, they "believe" problems will be minimal, but just in case they have some contingency plans.

No contingency plans are posted for public review and comment at their website. Has the Corporation Commission reviewed and signed off on these contingency plans as being adequate to the potential tasks at hand in January 2000 and thereafter?

The IEEE (the largest international professional organization for electrical and computer engineers) released a statement this summer saying that "Y2K compliant" does not mean "there will be no year 2000 problems." This disclosure, and the OG&E website, has no information about what the company's definition of "Year 2000 readiness." If we follow the suggestion of the brochure and go to the OG&E website, we find some curious qualifications regarding their confidence.

Y2k Readiness Disclosure

"The root of the problem is that some computers and software systems were designed to recognize the year using only its last two digits. The two-digit systems also begin each year with 19. So, when the year changes to 2000, the two-digit design systems will read the year as 1900. If the problem is not corrected, it could cause a variety of operational problems.

"OGE Energy Corp. and its subsidiaries are addressing the "Century Date Change" issues in an aggressive manner. This is reflected by the January 1, 1997 implementation throughout the corporation of SAP Enterprise Software, which is Year 2000 ready, for our financial systems. The SAP installation significantly reduced the potential Y2K risks in our older computer systems.

"In October 1997, OGE Energy formed a multi-functional team of experienced and knowledgeable employees from each business unit. Their task: to review and examine operational systems to further eliminate any potential problems. In addition, our Energy Management System (EMS) that monitors transmission interconnections and automatically signals generation output changes has been contracted for replacement in 1999. Equipment has been ordered and software is currently being configured."

From these paragraphs we learn:

Y2K problems are a threat to the operations of OG&E. (Paragraph 2)

They have Y2k-related problems which they "are addressing" at this time; the present tense of the verb suggests their problems are not all resolved, but are at some stage of a repair or replacement process. (Paragraph 3)

The first major repairs they made were to their financial software (Paragraph 3). By installing new software they reduced (but did not eliminate) their y2k problems in their financial systems. (Paragraph 3).

In January 1997, they started reviewing their operations hardware and software by forming an inter-disciplinary team. Their Energy Management System has been contracted for replacement, equipment has been ordered and software is being configured. The tenses here suggest the equipment has not been received yet, and that the software is not finished yet (it is now the middle of August, this web page was last updated July 6, 1999. In a form letter dated July 26, 1999 sent to me at my request by OG&E, the company says this equipment is installed, the software is configured, and is operational.

Both the OG&E letter and the website go on to say:

"OG&E Electric Services announced on June 30, 1999 that its essential systems that generate electricity and deliver it to nearly 700,000 customers in Oklahoma and Arkansas are ready for the transition to the Year 2000."

Frequently Asked Questions

"Q: Are your power suppliers ready for the Year 2000? A: Vendor and supplier surveys are still being sent out and their responses are being recorded. Additional notices, however, will have to be sent to vendors that have not responded to our original requests for information as to their Y2K status."

With less than six months to go, the company had not contacted all of its vendors and suppliers, and it was relying on self-reported data from those vendors/suppliers as to their y2k status. There is no mention of independent verification of those reports.

"Q: Are your embedded chips in control systems compliant? A: No, but upon reviewing the findings of the Y2K Project Team, the technology of the equipment that controls and operates the large majority of the Company's equipment is not susceptible to Y2K issues. The control systems are of analog and pneumatic construction, thus, no concern for dates. For embedded systems and plant operational systems, the Company has generally completed the evaluative process and is commencing corrective plans. In particular, the Company's Energy Management System (EMS) that monitors transmission interconnections and automatically signals generation output changes, has been contracted for replacement in 1999. Equipment has been ordered and software is currently being configured."

The embedded chips in OG&E'S control systems are not compliant. Some of the Company's equipment is susceptible to Y2K issues ("large majority" is not 100%, and the size of that "large majority" is not specified, e.g. is it 70%, 80%, 90%, 95%?.) The company has not completed its assessment of its risk (the "generally" in "generally completed" suggests that some risk areas remain unassessed) and is "commencing" corrective plans (in the summer of 1999!). Then there's another mention of the Energy Management System equipment and software work being ordered.

"Q: Will the "millennium bug" affect my service? A: We are making every effort to minimize the impact of Y2K issues and to continue to provide the excellent service you have come to expect. A computer issue like Y2K has never happened before so it is impossible for OG&E or anyone else to predict with certainty whether or not there will be problems. But, we can say that the issue has our full attention and we have very skilled people working on the problem. The Company is also participating in an "Electric System Readiness Assessment" program, which provides monthly reports to the Southwest Power Pool (SPP) and the North American Electric Reliability Council (NERC). The responses from all participating companies are being compiled for an industrywide status report to the Department of Energy (DOE)."

There will be impacts of Y2K issues on OG&E, but the company hopes to minimize them. The company is making "every effort," the issue has their "full attention," and they have "very skilled people" working on the problem. It's August 1999, and OG&E has not solved its Y2K problems yet. They feel it's not possible to predict "with certainty" whether or not there will be problems.

MOST IMPORTANT FACT GLEANED FROM THIS PARAGRAPH: There is no outside over-sight of this process; it is entirely an internal power industry affair. The report submitted by NERC to the DOE is strictly a self-reported affair. There is no mention of any kind of independent audit or testing verification.

"Q: Is OG&E conducting any tests on its systems? A: Yes. We have tested many of our systems and will continue to test them throughout the year. In addition, we are actively involved with electric utility industry groups that are evaluating and testing the electric system on a larger scale."

OG&E has not tested all of its systems, their testing is continuing throughout the rest of the year. The North American power grid is still being evaluated for its y2k readiness, and testing is continuing at this time. Nothing is said about the nature of the tests, and again it is entirely an electric utility industry affair, no outside audits are being made. The federal government has by law delegated this responsibility to the industry, removing it from the Dept. of Energy.

"Q: Will OG&E be ready when the year changes to 2000? A: At present, the Company has substantially completed the internal inventory and assessment phase of the Year 2000 plan. Remediation efforts are ongoing and even though contingency planning is a normal part of our business, plans must be prepared to include specific activities with regard to Y2K issues. In addition, as a part of the Company's three-year lease agreement for personal computers, all new personal computers are being issued with operating systems and application software that is Y2K ready. All existing personal computers will be upgraded with Y2K ready operating systems before the turn of the century."

Despite it's claim to "being ready for the transition to the Year 2000," the company has not completed its internal inventory and assessment phase ("substantially completed" does not mean "100% complete.") They are still making repairs, and are not able to specify a completion date other than "before the turn of the century." The company also has not completed its contingency planning directly related to Y2K issues.

NERC AUGUST REPORT

As noted above, the NERC report is based on self-reported data provided by OG&E, and using it as "evidence" of y2k readiness is essentially a circular argument.

August letter to customers

In response to my request, I received a letter from OG&E, dated July 26, 1999. This is the same letter it is sending to other customers, suppliers, trading partners, and shareowners who inquire about the company's Y2k status. It is slightly different from the one posted at the OG&E website. It states that the Energy Management System hardware has been installed, the software has been configured, and is currently operational. It also announces the installation of a "Customer Projects System" in June 1999 which "significantly reduced the potential risks in our older computer systems." It repeats the June 30th press release announcing the company's readiness, but it does not disclose the information in the Frequently Asked Questions which severely qualifies this readiness statement.

-- robert waldrop (rmwj@soonernet.com), August 17, 1999

Answers

So, rather than relying on the people who know the system best, you'd rather hear from some moron who knows absolutely nothing about OG&E systems, equipment and software? Typical y2k wacko.

-- weare (laughing@you.com), August 17, 1999.

In response to the first answer: The head lemming has the best view down the path, so we should just go ahead and trust him instead of someone who might be somewhat more objective. AKA This guys paycheck isn't signed by them! Have a spine and use your real address!

-- C.S. Lewis (cls071@aol.com), August 17, 1999.