Author Archives: mike@standardsmichigan.com

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Michigan Electrical Administrative Act §338.883

The requirement for a licensed electrician and a certified inspector to perform and certify any electrical work above $100 is prohibitive for homeowners and facility managers. To the best of our knowledge, no other US state imposes this requirement. There are more efficacious approaches to supporting effective public electrical safety services.

Licensing and Regulatory Affairs | Electrical Administrative Board

Next Meeting: February 13, 2025 10:00 am

Meeting Minutes: May 2, 2024 

Meeting Minutes: August 8, 2024 (not yet available)

Meeting Minutes: October 31, 2024 (submittals for agenda items due September 26th)

Related:

Michigan Public Service Commission

MPSC takes next steps in enabling interconnection and distributed energy resources

Of considerable importance is the criteria set by this board to determine whether a journeyman electrician is permitted to practice his or her trade in the State of Michigan.

We have been advocating for changes to the State of Michigan Electrical Administrative Act that currently requires all electrical work valued above $100 to be installed by a licensed journeyman electrician and inspected by an accredited electrical inspector.    The $100 threshold was set decades ago and has never been challenged by another other advocacy enterprise representing the user interest.  Almost all of the stakeholders on the present Electrical Administrative Board are stakeholders who benefit economically from the $100 threshold.    Much of the reason for the apparent imbalance of interests lies in tradition; but also because no user interest has been present to advocate for an update of the formal, fee schedule.

This advocacy priority was on the Do-List of the original University of Michigan codes and standards advocacy enterprise which was focused on strengthening the voice of the user/owner/final fiduciary in the promulgation of regulations affecting Michigan educational facilities (CLICK HERE for link to the legacy Advocacy Project 14-1).   Of all the trades covered in the parent legislation — Stille-Derossett-Hale Single State Construction Code Act (Act 230 of 1972) — the electrical power discipline is the only discipline in Michigan building technology regulations that sets a dollar criteria for electrical work to be performed and inspected.   While we recognize the need for safe installation of the electrical power chain within a building; we propose another criteria for establishing the requirement for a licensed electrician and a licensed inspector should be determined (as it is in all other construction disciplines administered by the Bureau of Construction Codes, a division of the Department of Licensing and Regulatory Affairs).

The actual text of the present regulation is available by clicking here:   338.881 Definitions | Electrical Administrative Act 217 of 1956

Father Marquette

As a consequence of former Governor Snyder’s Office of Regulatory Reinvention significant changes to both the Bureau of Construction Codes, a division of the Department of Licensing and Regulatory Affairs) have taken place within the past twelve months; which make us optimistic about political support for our proposals.   We will be collaborating with our colleagues at Michigan State University to make necessary legislative changes we believe will lower the #TotalCostofOwnership of education facilities in the State of Michigan.

We will refer the Michigan Electric Code, and other state electrical codes to the IEEE Education and Healthcare Facilities Committee which hosts bi-weekly breakout teleconferences with electrical professionals in the education facilities industry as required by the demand for them.

Electrical Administrative Board Responsibilities and Meeting Schedule

The next meeting of the Michigan Electrical Board is November 2nd.   We have been attending the meetings in Lansing and have made our proposal to revisit the dollar criteria known to the entire board.  We hope the Electrical Administrative Board will develop another criteria; inspired by the electrical administrative boards of other states.

Issue: [14-1]

Contact: Mike Anthony, Jack Janveja, Richard Robben, Kane Howard

Category: Electrical, State & Local Legislation

Link to Issue 14-1 Legacy Website


LEARN MORE:

Wide Variations in State Adoptions of the NEC® Reveal Neglect of Electrical Safety

 

 

Critical Operations Power Systems

Disaster 500


The original University of Michigan codes and standards enterprise advocated actively in Article 708 Critical Operations Power Systems (COPS) of the National Electrical Code (NEC) because of the elevated likelihood that the education facility industry managed assets that were likely candidates for designation critical operations areas by emergency management authorities.

Because the NEC is incorporated by reference into most state and local electrical safety laws, it saw the possibility that some colleges and universities — particularly large research universities with independent power plants, telecommunications systems and large hospitals  — would be on the receiving end of an unfunded mandate.   Many education facilities are identified by the Federal Emergency Management Association as community storm shelters, for example.

As managers of publicly owned assets, University of Michigan Plant Operations had no objection to rising to the challenge of using publicly owned education facilities for emergency preparedness and disaster recovery operations; only that meeting the power system reliability requirements to the emergency management command centers would likely cost more than anyone imagined — especially at the University Hospital and the Public Safety Department facilities.  Budgets would have to be prepared to make critical operations power systems (COPS) resistant to fire and flood damages; for example.

Collaboration with the Institute of Electrical and Electronic Engineers Industrial Applications Society began shortly after the release of the 2007 NEC.  Engineering studies were undertaken, papers were published (see links below) and the inspiration for the IEEE Education & Healthcare Facilities Committee developed to provide a gathering place for power, telecommunication and energy professionals to discover and promulgate leading practice.   That committee is now formally a part of IEEE and collaborates with IAS/PES JTCC assigned the task of harmonizing NFPA and IEEE electrical safety and sustainability consensus documents (codes, standards, guidelines and recommended practices.

Transcripts of 2026 Revision:

Public Input Report CMP-13

Public Comment Report CMP-13


The transcript of NEC Code Making Panel 13 — the committee that revises COPS Article 708 every three years — is linked below:

NEC CMP-13 First Draft Balloting

NEC CMP-13 Second Draft Balloting

The 2023 Edition of the National Electrical Code does not contain revisions that affect #TotalCostofOwnership — only refinement of wiring installation practices when COPS are built integral to an existing building that will likely raise cost.  There are several dissenting comments to this effect and they all dissent because of cost.   Familiar battles over overcurrent coordination persist.

Our papers and proposals regarding Article 708 track a concern for power system reliability — and the lack of power  — as an inherent safety hazard.   These proposals are routinely rejected by incumbent stakeholders on NEC technical panels who do not agree that lack of power is a safety hazard.  Even if lack of power is not a safety hazard, reliability requirements do not belong in an electrical wiring installation code developed largely by electricians and fire safety inspectors.  The IEEE Education & Healthcare Facilities Committee (IEEE E&H) maintains a database on campus power outages; similar to the database used by the IEEE 1366 committees that develop reliability indices to enlighten public utility reliability regulations.

Public input on the 2026 revision to the NEC will be received until September 7th.  We have reserved a workspace for our priorities in the link below:

2026 National Electrical Code Workspace

Colleagues: Robert Arno, Neal Dowling, Jim Harvey

 

LEARN MORE:

IEEE | Critical Operations Power Systems: Improving Risk Assessment in Emergency Facilities with Reliability Engineering

Consuting-Specifying Engineer | Risk Assessments for Critical Operations Power Systems

Electrical Construction & Maintenance | Critical Operations Power Systems

International City County Management Association | Critical Operations Power Systems: Success of the Imagination

Facilities Manager | Critical Operations Power Systems: The Generator in Your Backyard

Electrical Resource Adequacy

 “When buying and selling are controlled by legislation,
the first things to be bought and sold are legislators.”
— P.J. O’Rourke

 

“Federal Power Act” | June 10, 1920, Chapter 285 of the 66th Congress] 

Comment on FERC Action

The Federal Energy Regulatory Commission is an independent agency within the U.S. federal government that regulates interstate transmission of electricity, natural gas, and oil. It oversees wholesale energy markets, pipeline infrastructure, and hydroelectric projects, ensuring fair rates and reliability. While independent, FERC operates under the Department of Energy’s umbrella but does not take direct orders from the executive branch.

FERC enforces energy laws, approves infrastructure projects, and regulates market competition. FERC plays a crucial role in balancing economic, environmental, and energy security concerns, aiming to maintain a stable and efficient energy system across the United States.  Since the U.S. shares interconnected electricity grids with Canada and Mexico, FERC’s decisions on transmission rules and pricing affect energy flows and grid reliability in both countries.

Our interest lies in closing a technical gap that exists upstream from the building service point and downstream from the utility supply point. Some, not all of it, can be accomplished with titles in the IEEE catalog.

Given the dominance of vertical incumbents in the electric power domain, we have submitted a tranche of reliability concepts into the ASHRAE, NFPA and ICC catalogs — not so much with the expectation that they will be gratefully received — but that our proposals will unleash competitive energies among developers of voluntary consensus standards.

One of our proposals was heard at the April-May meetings of the International Code Council.  We are happy to discuss the outcome of that proposal any day at the usual hour.



Commissioner-Led Reliability Technical Conference Agenda: October 16, 2024, 10:00 AM

 


Nothing happened in August

Technical Conference RE: Large Loads Co-Located at Generating Facilities: November 1, 10AM EDT

Echo Chamber Synonyms: mutual admiration society, self congratulatory club,

back patting session, congratulatory loop, closed loop of praise, reciprocal praise fest,

feedback bubble, endless validation cycle, compliment carousel.

Predictive Reliability Analysis of Power Distribution Systems Considering the Effects of Seasonal Factors on Outage Data Using Weibull Analysis Combined With Polynomial Regression


February 2024 Highlights 

Failure Rate Prediction Model of Substation Equipment Based on Weibull Distribution and Time Series Analysis

January 2024 Highlights



Transmission Planning Using a Reliability Criterion

Readings / The Administrative State

In power system engineering, availability and reliability are two important concepts, but they refer to different aspects of the system’s performance.

Reliability:

  • Reliability refers to the ability of a power system to perform its intended function without failure for a specified period under given operating conditions. It is essentially a measure of how dependable the system is.
  • Reliability metrics often include indices such as the frequency and duration of outages, failure rates, mean time between failures (MTBF), and similar measures.
  • Reliability analysis focuses on identifying potential failure modes, predicting failure probabilities, and implementing measures to mitigate risks and improve system resilience.Availability:
  • Availability, on the other hand, refers to the proportion of time that a power system is operational and able to deliver power when needed, considering both scheduled and unscheduled downtime.
  • Availability is influenced by factors such as maintenance schedules, repair times, and system design redundancies.
  • Availability is typically expressed as a percentage and can be calculated using the ratio of the uptime to the total time (uptime plus downtime).
  • Availability analysis aims to maximize the operational readiness of the system by minimizing downtime and optimizing maintenance strategies.

Reliability focuses on the likelihood of failure and the ability of the system to sustain operations over time, while availability concerns the actual uptime and downtime of the system, reflecting its readiness to deliver power when required. Both concepts are crucial for assessing and improving the performance of power systems, but they address different aspects of system behavior.

 

November 2023 Highlights | FERC insight | Volume 10

Determining System and Subsystem Availability Requirements: Resource Planning and Evaluation

Comment: These 1-hour sessions tend to be administrative in substance, meeting the minimum requirements of the Sunshine Act. This meeting was no exception. Access to the substance of the docket is linked here.

Noteworthy: Research into the natural gas supply following Winter Storm Elliot.

 


August 14, 2003


 UPDATED POLICIES ON U.S. DECARBONIZATION AND TECHNOLOGY TRANSITIONS


June 15:FERC Finalizes Plans to Boost Grid Reliability in Extreme Weather Conditions

On Monday June 13th, Federal Energy Regulatory Commission commissioners informed the House Committee on Energy and Commerce that the “environmental justice” agenda prohibits reliable dispatchable electric power needed for national power security. One megawatt of natural gas generation does not equal one megawatt of renewable generation. The minority party on the committee — the oldest standing legislative committee in the House of Representatives (established 1795) — appears indifferent to the reliability consequences of its policy.

Joint Federal-State Task Force on Electric Transmission

“Our nation’s continued energy transition requires the efficient development of new transmission infrastructure. Federal and state regulators must address numerous transmission-related issues, including how to plan and pay for new transmission infrastructure and how to navigate shared federal-state regulatory authority and processes. As a result, the time is ripe for greater federal-state coordination and cooperation.”












 

Bibliography:

Natural Gas Act of 1938

Natural Gas Policy Act of 1978

Glossary of Terms Used in NERC Reliability Standards

The Major Questions Doctrine and Transmission Planning Reform

As utilities spend billions on transmission, support builds for independent monitoring

States press FERC for independent monitors on transmission planning, spending as Southern Co. balks

Related:

Homeland Power Security

At the July 20th meeting of the Federal Energy Regulatory Commission Tristan Kessler explained the technical basis for a Draft Final Rule for Improvements to Generator Interconnection Procedures and Agreements, On August 16th the Commission posted a video reflecting changes in national energy policy since August 14, 2003; the largest blackout in American history.

Summer Meals

Summer Meals for Kids Site Finder

Ann Arbor Public Schools | Student Summer Food Service Program
|


Readings

“The Negro Family: The Case For National Action” 1965 Daniel Patrick Moynihan

“Black Rednecks and White Liberals” by Thomas Sowell

“Please Stop Helping Us: How Liberals Make It Harder for Blacks to Succeed” by Jason L. Riley

“Losing the Race: Self-Sabotage in Black America” by John McWhorter

Related:

Kitchens 100

Kitchens 200

Kitchens 300

Commercial Kitchens

Colloquy (June)

Open agenda; Not Too Organized. Whatever anyone wants to talk about.  We do this once every month.  Use the login credentials at the upper right of our home page.

 

Summer Hours at our State Street Office: 8:30 AM – 4:00 PM

Join us for lunch 11:45 AM – 1:15 PM every Wednesday at the University of Michigan Business School

 

Retrodiction

Education & Healthcare Facility Electrotechnology Committee

 

AI Risk Management Framework

 

We list notable NIST projects or efforts related to LLMs, based on available information from NIST’s publications and initiatives. These projects emphasize NIST’s role in advancing measurement science, standards, and guidelines for trustworthy AI systems, including LLMs. Note that some projects are specific studies, while others are broader programs that encompass LLMs.
  • Evaluating LLMs for Real-World Vulnerability Repair in C/C++ Code
    NIST conducted a study to evaluate the capability of advanced LLMs, such as ChatGPT-4 and Claude, in repairing memory corruption vulnerabilities in real-world C/C++ code. The project curated 223 code snippets with vulnerabilities like memory leaks and buffer errors, assessing LLMs’ proficiency in generating localized fixes. This work highlights LLMs’ potential in automated code repair and identifies limitations in handling complex vulnerabilities.
  • Translating Natural Language Specifications into Access Control Policies
    This project explores the use of LLMs for automated translation and information extraction of access control policies from natural language sources. By leveraging prompt engineering techniques, NIST demonstrated improved efficiency and accuracy in converting human-readable requirements into machine-interpretable policies, advancing automation in security systems.
  • Assessing Risks and Impacts of AI (ARIA) Program
    NIST’s ARIA program evaluates the societal risks and impacts of AI systems, including LLMs, in realistic settings. The program includes a testing, evaluation, validation, and verification (TEVV) framework to understand LLM capabilities, such as controlled access to privileged information, and their broader societal effects. This initiative aims to establish guidelines for safe AI deployment.
  • AI Risk Management Framework (AI RMF)
    NIST developed the AI RMF to guide the responsible use of AI, including LLMs. This framework provides a structured approach to managing risks associated with AI systems, offering tools and benchmarks for governance, risk assessment, and operationalizing trustworthy AI across various sectors. It’s widely applied in LLM-related projects.
  • AI Standards “Zero Drafts” Pilot Project
    Launched to accelerate AI innovation, this project focuses on developing AI standards, including those relevant to LLMs, through an open and collaborative process. It aims to create flexible guidelines that evolve with LLM advancements, encouraging input from stakeholders to ensure robust standards.
  • Technical Language Processing (TLP) Tutorial
    NIST collaborated on a TLP tutorial at the 15th Annual Conference of the Prognostics and Health Management Society to foster awareness and education on processing large volumes of text using machine learning, including LLMs. The project explored how LLMs can assist in content analysis and topic modeling for research and engineering applications.
  • Evaluation of LLM Security Against Data Extraction Attacks
    NIST investigated vulnerabilities in LLMs, such as training data extraction attacks, using the example of GPT-2 (a predecessor to modern LLMs). This project, referencing techniques developed by Carlini et al., aims to understand and mitigate privacy risks in LLMs, contributing to safer model deployment.
  • Fundamental Research on AI Measurements
    As part of NIST’s AI portfolio, this project conducts fundamental research to establish scientific foundations for measuring LLM performance, risks, and interactions. It includes developing evaluation metrics, benchmarks, and standards to ensure LLMs are reliable and trustworthy in diverse applications.
  • Adversarial Machine Learning (AML) Taxonomy for LLMs
    NIST developed a taxonomy of adversarial machine learning attacks, including those targeting LLMs, such as evasion, data poisoning, privacy, and abuse attacks. This project standardizes terminology and provides guidance to enhance LLM security against malicious manipulations, benefiting both cybersecurity and AI communities.
  • Use-Inspired AI Research for LLM Applications
    NIST’s AI portfolio includes use-inspired research to advance LLM applications across government agencies and industries. This project develops guidelines and tools to operationalize LLMs responsibly, focusing on practical implementations like text summarization, translation, and question-answering systems.

Remarks:

  • These projects reflect NIST’s focus on evaluating, standardizing, and securing LLMs rather than developing LLMs themselves. NIST’s role is to provide frameworks, guidelines, and evaluations to ensure trustworthy AI.
  • Some projects, like ARIA and AI RMF, are broad programs that encompass LLMs among other AI systems, but they include specific LLM-related evaluations or applications.

 

2024+ Student Paper Competition

ANSI Student Paper Competition paused for 2025

No award for the 2024 cycle (per COE Chairperson)

“A Girl Writing; The Pet Goldfinch” 1870 Henriette Browne

 

The Society for Standardization Professionals Paper Competition 2025

 

 


Updated January 7, 2024

 

For nearly twenty years now,  the American National Standards Institute Committee on Education administers a student paper competition intended to encourage understanding of the global standards system that also provides a solid prize — in the $1000 to $5000 range.  The topic of the 2024 Student Paper Competition will be What Role Do or Could Standards Play in Safe and Effective Implementation of Artificial Intelligence Applications/Systems?

Student Paper Competition Flyer 2024 – Entries due 7 June 2024

For the past six years Standards Michigan has hosted Saturday morning workshops to help students (and faculty) interested in entering the contest.   We will soon post those dates on our CALENDER.  We typically host them — three sessions ahead of the deadline — on Saturday mornings.

We provide links to previous paper winners and refer you to Lisa Rajchel: lrajchel@ansi.org for all other details.

Related:

 

“Normal” Things Americans Do That The Rest Of The World Will Never Understand

ANSI Accredited Standards Developers | Contact Information

2023 Student Paper Competition

2022 Student Paper Competition

2020 Student Paper Winner / Remanufacturing

2020 Student Paper Winner / Road Traffic Safety

ANSI 2019 Student Paper Winner: Cybersecurity & Ukraine Power Grid Attack

2019 Student Paper Winner / Standards in Crisis Prevention & Response:

2018 ANSI Student Paper Winner / Internet of Things

2017 ANSI Student Paper Winner / Cyborg Gen 2330

2016 Student Paper Winner | Life, Liberty and Pursuit of Happiness

2016 Student Paper Winner / World Without Standards

United States Standards Strategy

Update Status

We continue sorting through anomalies with Godaddy Tech Support to resolve Standards Michigan requirement for frequent and timely updates across all of our platforms.  The problem apparently lies with legacy plug-ins and widgets not yet caught up with the most recent WordPress release. 6.8.1 dated May 7th.  Our normal course of business is not effected but some of the visual features will be looking a bit janky until we get it fixed.  To wit:

The Weblizar slider plug in we have used for 10+ year seems to have fallen off the beaten path.  Our frequent visitors and clients will notice the ugly black background and small text.  We hope we can continue working with Weblizar if they can restore the customization feature of their plug in.

  • Posts are not updating across all platforms — particularly on X on iPhones.  Usually a caching problem and not one we haven’t seen before.
  • Some images will not center.
  • Footer and right-side widgets not loading properly.
  • Some, not all, slider images are not loading at high resolution.

The good news is that all our content, including media, survived the WordPress upgrade.  The next step in our “GoDaddy Journey” will be another PHP upgrade.  There will likely be surprises but none that we cannot handle.

In any case, timeliness and normal content flow has not been interrupted.   Much like the hardware in ICT software must also be maintained.

This page will be posted to our X-feed: @StandardsMich to remind our colleagues and followers that software needs to be “maintained”

Reflections / John Nash

“Non-Cooperative Games” 1951 | John Nash

Brian Keating: Cosmology, Astrophysics, Aliens & Losing the Nobel Prize

 

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