“The Jack Pine” | Tom Thomson (1916) | National Gallery of Canada
Originally posted January 2014
In these clips — selected from Canadian Parliamentary debate in 2013 — we observe three points of view about Incorporation by reference(IBR); a legislative drafting technique that is the act of including a second document within a main document by referencing the second document.
This technique makes an entire second (or referenced) document a part of the main document. The consensus documents in which we advocate #TotalCostofOwnership concepts are incorporated by reference into legislation dealing with safety and sustainability at all levels of government. This practice — which many consider a public-private partnership — is a more effective way of driving best practices for technology, and the management of technology, into regulated industries.
Parent legislation — such as the Higher Education Act of 1965, the Clean Air Act and the Energy Policy Act – almost always require intermediary bureaucracies to administer the specifics required to accomplish the broad goals of the legislation. With the gathering pace of governments everywhere expanding their influence over larger parts of the technologies at the foundation of national economies; business and technology standards are needed to secure that influence. These standards require competency in the application of political, technical and financial concepts; competencies that can only be afforded by incumbent interests who build the cost of their advocacy into the price of the product or service they sell to our industry. Arguably, the expansion of government is a reflection of the success of incumbents in business and technical standards; particularly in the compliance and conformity industries.
About two years ago, the US debate on incorporation by reference has been taken to a new level with the recent statement released by the American Bar Association (ABA):
The incorporation by reference policy dilemma has profound implications for how we safely and economically design, operate and maintain our “cities-within-cities” in a sustainable manner but, admittedly, the results are only visible in hindsight over a time horizon that often exceed the tenure of a typical college or university president.
A recent development — supporting the claims of ANSI and its accredited standards developers — is noteworthy:
The National Institute for Standards and Technology (NIST) manages a website — Standards.GOV — that is a single access point for consensus standards incorporated by reference into the Code of Federal Regulations: Standards Incorporated by Reference Database. Note that this database does not include specific reference to safety and sustainability codes which are developed by standards setting organizations (such as NFPA, ICC, IEEE, ASHRAE and others) and usually incorporated by reference into individual state public safety and technology legislation.
LEARN MORE:
We applaud the Federal Government’s commitment to fund free access to the National Building Codes that are developed by the @NRC_CNRC. As a not-for-profit developer of standards that contribute to the health, safety and well-being of Canadians, CSA Group…https://t.co/QqhdkDvb7spic.twitter.com/1KRDvxDTaC
Mike Anthony is ID Number 469 | Proposal period closes 11:59 PM US Pacific Time | May 15
Meeting Notes in red
Loss of electric power and internet service happens more frequently and poses at least an equal — if not greater threat — to public safety. So why does neither the National Electrical Code or the National Electrical Safety Code integrate reliability into their core requirements? Reliability requirements appear in a network of related documents, either referenced, or incorporated by reference; sometimes automatically, sometimes not.
NESC Main Committee Membership: Page xii
Apart from the IEEE as the accredited standards developer, there are no “pure non-government user-interests” on this committee; although ANSI’s Essential Requirements for balance of interests provides highly nuanced interpretation. The Classifications on Page xiii represents due diligence on meeting balance of interest requirements.
In our case, we are one of many large universities that usually own district energy plants that both generate and purchase generate electric power (as sometimes provide var support to utilities when necessary; as during the August 2003 North American outage). For University of Michigan, for example, has about 20 service points at 4.8 – 120 kV. Its Central Power Plant is the largest cogeneration plant on the DTE system.
Contents: Page xxviii | PDF Page 29
Absence of internet service is at least as much a hazard, and more frequent, than downed wires. Is there a standards solution? Consideration of interoperability of internet service power supported on utility poles should track in the next revision.
No mention of any reliability related IEEE reliability standards in the present edition. Why is this?
Section 2: Definitions of Special Terms| PDF Page 46
In the 2023 Handbook, the term “reliability” shows up 34 times.
availability (from Bob Arno’s IEEE 3006-series and IEEE 493 Gold Book revision)
reliability (Bob Arno)
utility (PDF Page 57)
communication | PDF Page 47
list of terms defined in the 2023 National Electrical Code that are new and relevant to this revision: (Article 100 NEC)
municipal broadband network, digital subscriber line, surveillance cameras
wireless communication system
010. Purpose | PDF Page 40
Looks like improvement since last edition. Suggest explicit Informational Note, as in the NEC, using “reliability” and referring to other agencies. “Abnormal events” could be tighter and refer to other standards for abnormal, steady-state events. The clarification of purpose is welcomed although a great deal remains uncovered by other best practice literature; though that can be repaired in this edition.
Legacy of shared circuit path standards. Should provisions be made for municipal surveillance, traffic and vehicle control infrastructure. What would that look like?
011. Scope | Covered PDF Page 40
3. Utility facilities and functions of utilities that either (a) generate energy by conversion from some other form of energy such as, but not limited to, fossil fuel, chemical, electrochemical, nuclear, solar, mechanical, wind or hydraulic or communication signals, or accept energy or communication signals from another entity, or (b) provide that energy or communication signals through a delivery point to another entity.
5. Utility facilities and functions on the line side of the service point supplied by underground or overhead conductors maintained and/or installed under exclusive control of utilities located on public or private property in accordance with legally established easements or rights-of-way, contracts, other agreements (written or by conditions of service), or as authorized by a regulating or controlling body. NOTE: Agreements to locate utility facilities on property may be required where easements are either (a) not obtainable (such as locating utility facilities on existing rights-of-way of railroads or other entities, military bases, federal lands, Native American reservations, lands controlled by a port authority, or other governmental agency), or (b) not necessary (such as locating facilities necessary for requested service to a site).
012. General Rules | Covered PDF Page 42
For all particulars not specified, but within the scope of these rules, as stated in Rule 011A, design, construction, operation, and maintenance should be done in accordance with accepted good practice for the given local conditions known at the time by those responsible for the communication or supply lines and equipment
General purpose clause could use some work since no definition of “accepted good practice”. Refer to IEEE bibliography.
Section 2: Definition of special terms | PDF Page 46
Recommendations elsewhere should track here.
The word “installation” appears 256 times and is generally understood in context by experts. Suggest borrow from NEC to clarify our concern for including co-linear/communication circuits.
conduit. exclusive control, lines, photovoltaic, NEC interactive. qualified
Section 3: Reference
NFPA 70®, National Electrical Code® (NEC®). [Rules 011B4 NOTE, 099C NOTE 1, and 127
IEEE Std 4™-1995, IEEE Standard Techniques for High-Voltage Testing. [Table 410-2 and Table 410-3]
IEEE Std 516™-2009, IEEE Guide for Maintenance Methods on Energized Power-Lines. [Rules 441A4
NOTE 2, 446B1, and 446D3 NOTE, and Table 441-5, Footnote 4]
IEEE Std 1427™-2006, IEEE Guide for Recommended Electrical Clearances and Insulation Levels in
Air-Insulated Electrical Power Substations. [Rule 124A1 NOTE, Table 124-1, 176 NOTE, and 177 NOTE]
IEEE Std 1584™-2002, IEEE Guide for Performing Arc Flash Hazard Calculations. [Table 410-1,
Footnotes 1, 3, 6, and 14]
IEEE Std C62.82.1™-2010, IEEE Standard for Insulation Coordination—Definitions, Principles, and Rules.
[Table 124-1 Footnote 5]
Add references to Gold Book, 1386, etc. IEC since multinationals conform.
Safety Rules for the Installation and Maintenance of Overhead Electric Supply and Communication Line | PDF Page 111
Has anyone confirmed that these tables match NEC Table 495.24 lately? If it helps: there were no meaningful changes in the 2023 NEC in Article 495, the high voltage article
Section 11. Protective arrangements in electric supply stations | PDF Page 77
A safety sign shall be displayed on or beside the door or gate at each entrance. For fenced or walled electric supply stations without roofs, a safety sign shall be displayed on each exterior side of the fenced or wall enclosure. Where the station is entirely enclosed by walls and roof, a safety sign is required only at ground level entrances. Where entrance is gained through sequential doors, the safety sign should be located at the inner door position. (A clarification but no change. See Standards Michigan 2017 proposals)
Recommend that all oil-filled cans be removed and services upgraded through energy regulations with new kVA ratings
Section 12: Installation and maintenance of equipment
093. Grounding conductor and means of connection
Fences The grounding conductor for fences required to be effectively grounded by other parts of this Code shall meet the requirements of Rule 093C5 or shall be steel wire not smaller than Stl WG No. 5.
D. Guarding and protection | PDF Page 67
124. Guarding live parts| PDF Page 85
Propose roofs required for exterior installations
Part 2. Safety Rules for the Installation and Maintenance of Overhead Electric Supply and Communication Line | Page 72
Section 22. Relations between various classes of lines and equipment | Page 80
222. Joint use of structures | Page 82
Where the practice of joint use is mutually agreed upon by the affected utilities, facilities shall be subject to the appropriate grade of construction specified in Section 24. Joint use of structures should be
considered for circuits along highways, roads, streets, and alleys. The choice between joint use of structures and separate lines shall be determined through cooperative consideration with other joint
users of all the factors involved, including the character of circuits, worker safety, the total number and weight of conductors, tree conditions, number and location of branches and service drops, structure
conflicts, availability of right-of-way, etc.
Reliability considerations for sustaining internet service when power supply is absent.
Par2 Section 20 Safety Rules for the Installation and Maintenance of Overhead Electric Supply and Communication Line | PDF Page 111
Has anyone confirmed that these tables match NEC Table 495.24 lately?
Part 3. Safety Rules for the Installation and Maintenance of Underground Electric Supply and Communication Lines | Page 220
Renewable energy for internet access
311. Installation and maintenance
A. Persons responsible for underground facilities shall be able to indicate the location of their facilities.
B. Reasonable advance notice should be given to owners or operators of other proximate facilities that
may be adversely affected by new construction or changes in existing facilities.
C. For emergency installations, supply and communication cables may be laid directly on grade if the
cables do not unreasonably obstruct pedestrian or vehicular traffic and either:
1. The cables are covered, enclosed, or otherwise protected, or
2. The locations of the cables are conspicuous.
Supply cables operating above 600 V shall meet either Rule 230C or 350B.
NOTE: See Rules 014B2 and 230A2d.
Part 4. Work Rules for the Operation of Electric Supply and Communications Lines and Equipment | PDF Page 289
When and why was the term “Work” added to the title of this section?
Core text for the definition of wireless communication system reliability
Appendix E Bibliography| PDF Page 355
Index | PDF Page 398
The word “reliability” appears only three times. Should it track in the NESC or should it track in individual state requirements. So neither the NEC nor the NESC couples closely with power and communication reliability; despite the enormity and speed of research.
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.
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).
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.
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
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.
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.
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.
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.
“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.”
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.
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.
A massive number of colleges and universities have shut down within the last couple of years, or will shut down in the next few.
Many of these colleges have cited financial hardship or enrollment decline as reasons for closure. But what’s really going on? 🧵 pic.twitter.com/MoF1Iiejzd
We had so much fun celebrating the magic of this Swedish tradition by making flower wreaths, dancing around the maypole, enjoying a smorgasbord buffet and music with our American friends, families and allies here in DC. pic.twitter.com/NC9tEKa4RS
— Embassy of Sweden USA (@SwedeninUSA) June 21, 2024
In honor of Charles-Augustin de Coulomb’s birthday, we would like you to know that 1 coulomb is equal to the charge of 6.24 quintillion (billion billion) electrons! pic.twitter.com/VnrLu0Lb0P
— National Institute of Standards and Technology (@NIST) June 14, 2024
In honor of Charles-Augustin de Coulomb’s birthday, we would like you to know that 1 coulomb is equal to the charge of 6.24 quintillion (billion billion) electrons! pic.twitter.com/VnrLu0Lb0P
— National Institute of Standards and Technology (@NIST) June 14, 2024
📢📢📢
MSU Observatory will be open for public observing twice a month between April and September. Stay tuned for our public events schedule.. 🔭🌕🪐💫@MSUNatSci@michiganstateu
Video credit: EA Photography
Audio credit: Epicomposer pic.twitter.com/hGF9oEidqd
The IEEE P3119 draft standard is designed to help strengthen AI procurement approaches, using due diligence to ensure that agencies are critically evaluating the AI services and tools they acquire.https://t.co/ujVJxZqjEm@InstituteIEEE
— IEEE Standards Association | IEEE SA (@IEEESA) May 19, 2024
— Standards Michigan (@StandardsMich) May 25, 2024
The word #standard is commonly used in daily language, so much so that people do not always reflect on its definition. Learn how ASTM International’s Regulations Governing ASTM Technical Committees (aka “Green Book”) defines them. #standards See https://t.co/oSBmwh1lbXpic.twitter.com/ynk87XDr7D
— Standards Michigan (@StandardsMich) May 18, 2024
🏆 We applaud the brilliant minds shortlisted for the 2024 IEEE PES Power Engineering Education Committee (PEEC) Outstanding Doctoral Dissertation Award!
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.
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?
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.
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”
New update alert! The 2022 update to the Trademark Assignment Dataset is now available online. Find 1.29 million trademark assignments, involving 2.28 million unique trademark properties issued by the USPTO between March 1952 and January 2023: https://t.co/njrDAbSpwBpic.twitter.com/GkAXrHoQ9T
