No, sorry, they are not related! Just that I wanted to first say Happy Thanksgiving weekend to all our American friends! I also wanted to offer a couple items of note.
The first is that NERC released their response to FERC’s NOPR Docket No. RM11-11-000. There is a lot in there but the main point (in my opinion) is contained in the following paragraph:
NERC notes that its anticipated timeline to file the Version 5 CIP Standards, in conjunction with the Implementation Plan proposed in the initial draft of Version 5, may present the opportunity to suggest an extension of Version 3 until Version 5 can be implemented, thereby eliminating the need for implementing Version 4, to be followed only a short time later by implementation of Version 5. That suggestion is not being made now, and it could be considered only if the industry moves promptly on Version 5. If Version 5 is not approved by the industry, filed by NERC, and approved by the Commission within that anticipated schedule, or reasonably thereafter, it is unlikely that Version 3 could be extended in a manner that eliminates the need for implementation of Version 4.
In plain speak? Get going on v5, hammer out the details, approve it and start working on implementing it OR you will have to live with v3, v4 AND v5! Sounds like me telling my kids to finish their vegetables or they will go to bed with no dessert! However, remember this is NERC now. And this sounds an awful lot like the language FERC put in the original NOPR. Meaning: NERC seems to be onside with FERC as it speaks to the general utility community. Anyone surprised?
Second item of note is a continuation of our discussion on v5 002 language. If you recall from this post we pointed out a problem with the wording in Attachment I that was backed up by the NERC webinar. In essence, one current interpretation of the wording is that a single DCS needs to control (by itself) over 1500 MW of generation in order for it to be considered a medium impact. We suggested lowering the threshold and probably removing the single DCS clause (or interpretation, since it really only is implied now) but what should we lower it to? Well, I posed that question to one of my field guys who walks many miles in the shoes of a compliant entity through his support work at a host of generation facilities. What you see below is his response to me, unedited, which I offer as a conversation starter. What do you think?
My 2 cents:
Instead of generation or generation plant – change the wording of clause 2.1 in attachment one to generation unit , lower the threshold from 1500MW to unit-specific thresholds in which case a BES cyber system (a single DCS) is clearly associated with a single generating unit – this works well for coal-fired plants which I believe is what needs to get in scope.
So Attachment 1 Section 2.1 would then read:
Each BES Cyber Asset or BES Cyber System (comment: in this case a single DCS called a BES cyber system fits well for a single unit as we see in most coal-fired plants), not included in Section 1 above, that if rendered unavailable, degraded, or misused would, within 15 minutes adversely impact one or more BES Reliability Operating Services for:
Generation Unit with an aggregate highest rated net Real Power capability of the preceding 12 calendar months equal to or exceeding ___ MW (comment: I would think 300 MW) in a single interconnection.
NERC Standard MOD-024 (Modeling, Data and Analysis) mandates that every entity verify generator unit gross and net real power capability.
Why 300 MW?
- They are worried about 300MW automatic load shedding (Under Voltage Load Shedding, Under Frequency Load Shedding) without human operator initiation and those systems are in scope as medium impact.
- They have also stated that control centers controlling 300MW or more of generation are in scope as medium impact.
- So why should units rated at 300MW or more not be in scope because of a loophole in section 2.1?
I hope their intention was to originally include 1500MW facilities with the way they worded the standard and this is only a loophole that they haven’t figured out. If their whole intention is to get more facilities out of scope then I don’t know if what we are proposing is right.
Let us know what you think!