Agenda Date: January 27, 1999 Item Number: Docket: U-971835 Company Names: Administrative - General Staff: Jo Wadsworth, Yr. 2000 Project Coordinator Doug Kilpatrick, Electric Industry Coordinator Tom Spinks, Regulatory Consultant Recommendations: The Secretary should sign an order to : 1. Amend previously issued order to public utilities operating in Washington to adopt uniform reporting formats. The electric companies should use the uniform reporting format developed by the North American Reliability Council (NERC) and adopted by the Federal Energy Regulatory Commission (FERC), and the telecommunications companies should use the uniform reporting format approved by the Federal Communications Commission (FCC). There is no uniform reporting format for gas operations; staff will work with those companies to develop mutually acceptable reporting guidelines. 2. Amend the order previously issued to regulated investor owned utilities operating in Washington to submit final contingency plans at later dates than previously ordered. The dates for submission of final contingency plans should be: April 30, 1999, for gas operations, May 30, 1999 for telecommunications operations, and June 30, 1999, for electric operations. Companies with multiple operations should consult with Commission Staff for an acceptable filing deadline. Discussion On May 27, 1998, the Commission issued an order in Docket No. U-971835, requiring utility companies to submit quarterly status reports on their company year 2000 program implementation. Since that time, affected companies have submitted three quarterly reports to the Commission. Commission staff has reviewed the submitted reports for consistency and completeness of information and found these elements to be lacking. This inconsistency and incompleteness of information may be due in part to the absence of any consistent reporting format requirements. National entities have adopted reporting formats for year 2000 readiness reporting which most of the Commission regulated companies must use in reporting to the national level. These reporting formats have also provided other states useful guidelines for adoption. In terms of adequacy of information as well as minimization of filing requirements, Commission staff believes that it would be in the best interest of both the electric and telecommunications companies if these formats were adopted by the Commission. Docket U-971835 January 27, 1999 Page 1 In addition, the Commission provided in its May 27, 1998, order that all named utilities operating in Washington submit contingency plans for the year 2000 utility restoration. At the time of the order, information regarding specific federal requirements for contingency plans and time lines were not available. Currently, NERC has requires electric companies to file their contingency plans on June 30, 1999. In reviewing the contingency plans due to the Commission on December 30, 1998, it is clear that most of the utilities are in the beginning stages of contingency plan development. Extending the final contingency plan due date is also consistent with state and federal agency contingency planning efforts where plans are due June 30, 1999. Allowing the companies additional time for developing and completing contingency plans will provide both the companies and the Commission with more complete information. Therefore staff recommends that the contingency plan dates be extended as discussed above.