As an English major, I read a lot. I read a book in one of my college English composition classes that I’ll never forget, because it addresses a topic that I struggled with then, I struggle with now, and I’ll probably struggle with for the rest of my career. That topic is: writing a lousy first draft. I want my efforts to result in good writing on the first try, which often results in “analysis paralysis,” a combination of overthinking and underworking, and in major frustration.
The book I am referring to, Bird by Bird: Some Instructions on Writing and Life by Anne Lamott, is still on my shelf. In the “Writing” section, there is a chapter on “First Drafts,” where Lamott shares her belief that “Almost all good writing begins with terrible first efforts.” The concept that she presents is simple: start somewhere, get words down on paper, and keep refining until you have a polished final version that meets your expectations.
The next section focuses on perfectionism. It opens with a powerful statement: “Perfectionism is the voice of the oppressor, the enemy of the people. It will keep you cramped and insane your whole life, and it is the main obstacle between you and a poor first draft.” Take a moment to really consider this idea.
You might be wondering what this has to do with reliability and compliance. Some of the NERC Reliability Standard requirements mandate components of new and revised documentation. For example, NERC Reliability Standard FAC-008-5: Facility Ratings, states that Generator Owners and Transmission Owners “shall have a documented methodology for determining Facility Ratings…that contains all of the following…” The word “shall” means “will.” A registered entity cannot demonstrate compliance with the standard if it cannot produce a Facility Ratings methodology that includes all the items in the defined requirements and sub-requirements.
Now, a Facility Ratings methodology cannot exist in and of itself. Depending on the organization, it may be supported by plans, standards, criteria, processes, controls, procedures, guides, technical aids…this is not an exhaustive list. Each of these documents can be authored or co-authored by subject matter experts, technical writers, engineers, and/or other utility personnel familiar with the content.
Using a process as an example, the first draft might broadly outline expectations for achieving objectives and describe tasks and their sequencing. The author then moves to a second draft, which involves interviewing personnel with roles and responsibilities described in the process. This stage adds specificity and information flows and addresses quality management. It may take three or four iterations to accurately reflect how the process is executed in practice. This iterative approach applies to procedures, criteria documents, guidelines, etc. While every company’s document hierarchy and documentation methods will differ, one commonality in compliance program documents is they all begin as preliminary first drafts.
Anne Lamott discusses the topic of knowing when a piece of writing is complete, and I think I am nearing that point with this article. I want to address the criticality of Real-Time Operations (RTO) documents, whether they are new or revised. RTO procedures are vital to the safe, secure, and reliable operation of the bulk power system because they include detailed instructions for system control operators during atypical system events like load shedding and blackstart restoration plans, or documentation of interconnection reliability operating limits and remedial action schemes. While a first draft does not need to be perfect, it must provide enough guidance to safely manage an emergency. There is a higher urgency with RTO documents to complete drafts, finalize them, and obtain the appropriate approval(s). When procedural changes occur, it is crucial to communicate the changes to RTO personnel and promptly replace any outdated paper copies with new, effective versions.
I will leave you with a valuable concept a mentor once shared, one I often apply when I am writing or when grappling with a problem that I can’t quickly resolve. When eighty percent of your work on something—like writing this article—is done, and that portion is high quality, consider it complete and set it aside. When you revisit it, apply lessons learned from the first iterations, set goals and deadlines, and make sure you have the resources you need to cross the finish line and complete the remaining twenty percent.
– Sarah Habriga, ENRA NERC Specialist Principal, American Electric Power, and MRO Compliance Monitoring and Enforcement Program Advisory Council Member
About the Author
Sarah Habriga graduated from the University of South Florida in Tampa in 2007 with a Bachelor of Arts in English (emphasis on Professional and Technical Writing). She began working in the North American Electric Reliability Corporation (NERC) compliance space about six months later and has never looked back. Early in her career, she recognized that her skillset was well-suited for investigating potential non-compliant conditions and assuring strict adherence to federal regulations. Some might call it “strange,” but compliance, specifically NERC compliance, is not just a job or career. It is her passion.
In Sarah’s sixteen years as a utility compliance professional, she has worked for a Regional Entity, a vertically integrated municipal utility, a transmission-only utility, a renewables company, and now, one of the largest electric utilities in the United States. Sarah has completed five compliance audits, the last two with no findings, making them the most successful audits in that company’s history.
Much of her work over the last ten years has been focused on Facility Ratings. Sarah provided guidance around and oversight of two ratings self-reports and associated mitigation plans, one that resulted in a compliance exception with a zero-dollar penalty and one that spanned the course of over four years and resulted in a favorable spreadsheet notice of penalty. She is currently working on a large-scale root cause analysis around ratings, which challenges her to think critically and shift her mindset daily. In addition, Sarah collaborated with her former company’s maintenance team to develop a process that leveraged performance-based maintenance on a small subset of equipment where it made sense to use it.
DISCLAIMER
MRO is committed to providing non-binding guidance to industry stakeholders on important industry topics. Subject matter experts from MRO’s organizational groups have authored some of the articles in this publication, and the opinion and views expressed in these articles are those of the author(s) and do not necessarily represent the opinions and views of MRO.