Monday, October 20, 2014

Good News, for a Change (Part I)

I have been accused of only writing about problems, not good things.  Of course, I take strong exception to this idea.  A recent Price Waterhouse study of my blog posts showed that only 99.45% of them were negative.  So there.

And to show you how really wrong the idea is, I have two pieces of good news, which I’ll deal with in two separate posts.  Here’s the first piece:

Some of you may have seen a very low-key email that was sent around to the current CIP SDT Plus List on Saturday, showing the ballot results for the second round of balloting on the “CIP v5 Revisions” (aka CIP version 6).  If you don’t have a life like me, you probably realize this round was very important because it represented the last chance for the two FERC-ordered changes still not approved – Transient Electronic Devices and the Low impact requirement – to be approved in time for them to be included in the filing to FERC, due by early February.

The other two changes mandated by FERC (in Order 791) were removal of the “Identify, Assess and Correct” language and protecting wiring between ESP devices that goes outside of a PSP.  They were approved on the first ballot, and the SDT was preparing to just submit those two changes to FERC by February – this is what the “-X” standards were there for (these were the only two changes that FERC had required by February.  The two changes just approved didn’t have a due date, although I know the last thing the SDT wanted was to have to drag the process out through more meetings and ballots.  They fervently wanted to just do one filing for FERC, with all four changes).   

So it was great that the email showed that both remaining changes passed.  What was odd was that the email didn’t say they had passed.  My first impression was they must have failed, since otherwise I was sure the email would be crowing about the success.  And crowing would be deserved, since the SDT has worked very hard and well to get these changes developed and approved (of course, by NERC rules there still has to be another ballot.  The SDT in theory could still tweak the standards a little before that ballot, but my guess is they’re not going to mess with success).  So good job, SDT!

But that isn’t the end of the story, since I just realized today what this vote really means – namely, that for literally the first time in four years, the industry actually knows what the course of CIP will be for the next two or three years (perhaps longer.  I really don’t see anyone even proposing a new version until v5 and v6 are at least fully implemented, and that won’t be until 2018).  You only have to read the most recent v6 Implementation Plan, combine that with the v5 plan, and you have your timeline for compliance with v5 and v6.[i] 

Of course, when I say “only”, I’m having trouble keeping a straight face, since it is quite complicated to figure out the true timeline.  This is partly thanks to the SDT’s decision not to “rev” all of the standards to v6.  Instead, entities will have to comply with 3 (I believe) of the v5 standards and 7 of the v6 ones.  Plus some of the requirements in v6 have separate compliance dates (and it’s even more complicated than that, if you look at the new plan). 

The result is that there are maybe 15-25 compliance dates that will be involved in coming into compliance with CIP v5 and v6[ii] (or as I called it in my June post on the implementation dates, CIP v5.5.  I need to rewrite that post, since it was based on the first draft of the v6 Implementation Plan, not the second).  And how many were there for CIP v2 and v3?  Just one each.[iii]

But leaving aside this small quibble, the fact remains that there is now – in principle – complete certainty on what an entity will have to comply with and when.  This is no small achievement, after years in which even the number of the next CIP version was very much in question.

Of course, there are still one or two questions (he says slyly) about the actual interpretation of the v5/v6 standards – I believe I've written about that in one or two (or 40) posts recently.

The views and opinions expressed here are my own and don’t necessarily represent the views or opinions of Honeywell.

Note: There has been a further development in v6 that makes me have to amend what I have just said in this post.  See the next post for information on this.

[i] I am somewhat off the mark in saying there is complete certainty now, since the v6 compliance dates all are partly dependent on FERC’s approving v6 by at least the end of 2015; if they don’t, then most of these dates get pushed back.  However, given that these changes are what FERC ordered in the first place, I find it hard to believe they won’t approve them in 2015, when they’ll have them on their desk in February.

[ii] And that doesn’t take into account the Initial Performance of Periodic Requirements dates, found in the v5  Implementation Plan).

[iii] OK, so I did go negative in this post after all.  However, I think there are more positive than negative sentences, by a long shot.  Usually it’s the other way around.

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