FERC Will Likely Approve CIP Version 5 by Thanksgiving

11/21: FERC did approve V5 today, although the Order won't be out 'til later today.  See this post on the meeting this morning.

I have it on good authority that FERC will approve CIP Version 5 before Thanksgiving (of course, I mean US Thanksgiving, since the Canadians - always wanting to stay ahead of the Americans - had theirs in October).  Given that they have an open meeting scheduled for Thursday 11/21, this means it is likely they’ll approve it at that meeting.

Of course, you may remember I was pretty sure they’d do this at their October meeting.  I think the government shutdown may have interfered with that (FERC kept operating, but a lot of other agencies they interface with, like DoE and DHS, didn’t).  But who knows what might interfere this time?  So I’m not going to bet the farm on it at this point.  In any case, it is close to certain they'll approve V5 this year.  The implementation dates will be the same whether approval is in November or December.

However, the big question isn’t the date they’ll approve V5 but what changes they’ll require; those will be in the Order they issue.  I don’t have any more ideas on what those changes will be, other than what I listed in this post from September.  Also, see this post from a couple weeks ago on the likely implementation dates.

I also want to point out that Honeywell and AlertEnterprise are having a webinar on physical security in CIP Version 5 on Thursday 11/14 at 1PM ET.  We already have 463 signups, but I’m told there are still a few good seats left.  You can sign up here.  I’ll be participating in the discussion (although don’t let that stop you from signing up).  Hope to see you there!


P.S. I have a question for NERC: You promised the CIP Version 5 RSAW's (Reliability Standard Audit Worksheets) by Sept. 30.  Tobias Whitney (of NERC) said at an RFC meeting I attended in early October that a couple of them were still being worked on, but it didn't sound to me like they would be too long. So now it's mid-November and I haven't heard any new word on them.  Has anyone heard about them?  Do we need to put this question on milk cartons?

You might wonder why I'm so worried about Version 5 RSAWs, since V5 isn't approved yet, let alone being audited.  Remember, as of 10/1, NERC kicked off the CIP V5 Transition Implementation Study, in which 7 entities will try to do as much as they can to implement V5 compliance over the next 6 months (although that's 4.5 months now) - then NERC will share their lessons learned with the rest of the entities.  Having the RSAW's would really help these seven entities, as well as everyone else given that V5 is about to be approved (and where did seven come from, anyway? It has so much religious and numerological significance that I just have to wonder.  Is this an effort to invoke divine blessing on the CIP Version 5 effort?  I think it could use it).