Hello all. As the title suggests, our man in the field has penned another collection of thoughts. After having attended the SPP CIP Workshop in Dallas recently and on the heels of the V5 second ballot here is how Tom sees it. What follows is, as always, a collection of Tom Alrich’s personal opinions and observations. These are in no way a reflection of Honeywell corporate perspectives. And I also must warn you, Tom had his ‘creative writing’ hat on!
The SDT Shifts Gears
Tom Alrich – firstname.lastname@example.org
I admit to sometimes having doubts about how nimble the CSO706 Standards Drafting Team is – with seventeen-odd members and a host of constituents to please at NERC and among the NERC entities. But I was very impressed by how quickly they adjusted – on Wednesday, May 23 – to face two new realities: they are in for another big slog before CIP Version 5 is ready for approval, and it is now virtually certain that CIP Version 4 will take effect.
I had two encounters with the SDT that day. The first was listening to Phil Huff, SDT Vice Chairman, address the SPP CIP Workshop in Dallas. He immediately placed himself in my highest opinion (not that he wasn’t there already) by opening his talk with this quotation from Alice in Wonderland, which he thought was very illustrative of CIP:
“But I don’t want to go among mad people,” Alice remarked.
“Oh, you can’t help that,” said the Cat: “we’re all mad here. I’m mad. You’re mad.”
“How do you know I’m mad?” said Alice.
“You must be,” said the Cat, “or you wouldn’t have come here.”
But what Phil said was actually very sane: The SDT realizes it won’t be able to make the schedule for delivering CIP Version 5 to FERC by Sept. 30 of this year, which was its plan only a month or two ago (okay, he didn’t dwell on the fact that the SDT’s plans had changed, but there was no hiding they had).
Why did the SDT change its plans? Again, Phil didn’t discuss this, but the main reason is that, although the results of the second ballot (called a successive ballot) on CIP Version 5 were encouraging, they were not good enough to move the SDT to the next stage they had been planning – namely, to have a successful recirculation ballot in June, which would then take Version 5 out of their hands and turn it over to the NERC Board of Trustees for approval.
What were the ballot results? Phil didn’t actually know them at the time of his address (although I imagine he had an idea, having seen at least some of the comments), but I also attended the SDT’s call Wednesday afternoon, where they were formally presented. The results were certainly much better than the first ballot: ranging from 36% to 68% positive (depending on the standard), with maybe 45-50% being the median. However, this isn’t enough to go to a recirculation ballot, which is only intended for a standard that doesn’t require any substantive changes from the previous ballot. That is not yet the case with CIP Version 5.
The call in the afternoon reinforced this notion: John Lim (the Chairman) confirmed that there will be another successive ballot, and that this time there is no room for error. All or almost all of the standards will have to meet the threshold for approval (I believe that is 60%) – if that doesn’t happen, then the SDT’s whole effort (which has been huge) may go for naught, and NERC will need to start over with a new SAR (Standard Authorization Request) and a new SDT (and this would be for CIP Version 6. Even the name Version 5 wouldn’t survive).
So it seems that the SDT is going to take its time to do this right. John implied that they might not have spent enough time making sure the most recent Version 5 draft addressed all of the comments from the first ballot (although it would be impossible to address them all, since there were over 2,000 pages of comments. It seems there were about 1,000 pages the second time). They are now starting to address the new comments, and are aiming for the second successive ballot (the third ballot in all) in September. Assuming that is successful, then they would go to a recirculation ballot by the end of the year. And they might even be able to go home for the holidays without the prospect of having to come back and work on CIP again in the new year (this would be the first time in five years that this has not been the case, since the team started work in the fall of 2008).
And what John emphasized was that the team is hoping to make FERC’s deadline (set in Order 761, issued when they approved CIP Version 4 on April 19) of March 31, 2013 for delivery of Version 5 for their approval. This is a stretch but *might be a possibility from the SDT side. However, both Phil and John made another admission: There is no longer much likelihood that CIP Version 4 will not come into effect. Even if NERC makes the March 31, 2013 deadline, that leaves only a year for FERC to approve Version 5, before April 1, 2014. FERC took 14 months to approve Version 4, and that only involved a change to CIP-002; all of the other standards were the same as in Version 3. Version 5 is of course a complete rewrite of CIP – it’s hard to see how FERC won’t take even more than 14 months to approve it. [Editor's note: This last statement is in no way intended to imply that FERC would drag its feet or purposely try to inflict V4 on the community if it could avoid it. Plain and simple this is complex and must be done correctly. Therefore a sufficient amount of time will be required to allow for proper review and comment by FERC.]
So there you have it: Version 5 delayed by who knows how long? Six months or more? And Version 4 now poised to actually be implemented on April 1, 2014. I don’t think many people (at NERC, FERC, or the entities) wanted this to be the actual scenario, but it looks like that will be the case.
However, I still think there is a good possibility that even the projected six month delay in approving Version 5 is an underestimate. As we discussed in a previous post, not only does the SDT have to make changes to Version 5 to address the most recent NERC member comments, but they also have to address the requests (commands?) for changes that FERC made sure to include in Order 761 – implying that NERC had better make sure they were addressed in Version 5 when it hits FERC’s desk. Since, unlike the NERC member comments, FERC’s requests aren’t likely to be popular with the NERC entities, addressing these requests will require more effort and political skill, in my opinion. It is very possible that the SDT won’t be able to breathe a big sigh of relief this Christmas.
Which leads me to another quote from Alice in Wonderland, which occurrs just before the one Phil cited:
(Alice asked) “Would you tell me, please, which way I ought to go from here?”
“That depends a good deal on where you want to get to,” said the Cat.
“I don’t much care where, so long as I get somewhere,” said Alice.
“Oh, you’re sure to do that,” said the Cat, “if you only walk long enough.”
 Part of this sentence was said by Phil in the morning, but it was I’m sure on John’s mind in the afternoon.
 This is the date that Version 4 will come into effect, set by FERC’s order of April 19. Those of you who live and breathe NERC CIP know that the current Version 5 implementation plan says that, if FERC approves Version 5 before Version 4 comes into effect, then Version 3 will remain in effect until the effective date of Version 5.
 These changes are listed in the already-cited blog post, but a better description of them is in this post.