Wednesday, May 10, 2017

The News from RF, Part III: What Happens on 9/1/18?

My last post was the first of at least three or four dealing with interesting things I learned from the presentation by Felek Abbas of NERC and Lew Folkerth of RF at RF’s CIP compliance workshop last month in Baltimore (the download includes all of the presentations at the workshop. Felek and Lew’s presentation starts on slide 19).  

Felek’s part of the presentation started with a discussion of compliance dates for the Low impact requirements in version 6. Since those should be well known to you already, I won’t discuss them now. What I found interesting was slide 29, which says in part:

  • CIP-003-7 was filed with FERC on March 3, 2017
  • However, CIP-003-7 is very unlikely to come into effect before September 1, 2018. You will need to comply with the CIP-003-6 version of these requirements beginning September 1, 2018, until the effective date of CIP-003-7.

This was interesting because, in the whole LERC discussion last year, it had never even occurred to me that CIP-003-7 wouldn’t be in place by 9/1/18; I never thought there would be a serious possibility that entities would have to comply with version 6 of this standard, and then version 7 (as I’ll discuss below, having to do both doesn’t change what you have to do to comply, but it certainly does change the language you need to use to document compliance). However, this was probably because I hadn’t bothered to read the implementation plan that got passed with CIP-003-7(i) this year.

When I read the plan after hearing Felek’s discussion, I realized that the words “very unlikely” on the slide should have been replaced with “mathematically impossible”. This is because the plan says “…Reliability Standard CIP-003- 7(i) shall become effective on the first day of the first calendar quarter that is eighteen (18) calendar months after the effective date of the applicable governmental authority’s order approving the standard…”

So let’s do the math. CIP-003-7(i) was filed with FERC on March 3. If FERC had approved it that day (which I doubt has ever happened for a NERC standard, or almost anything else), the effective date would have been October 1, not September 1, 2018. Of course, I doubt this would have been a big deal, since the Regional Entities wouldn’t have issued any PNCs (the successor of PVs) for turning in V7 documentation during the month of September, 2018. And even if FERC had taken just 3-6 months, I think the Regions would still follow the same approach.

However, unless you’ve been living in a cave in the Himalayas for the past year, you have probably heard that there is a new administration in Washington and they have been very slow to make high-level appointments to almost any Federal agency. In FERC’s case, this situation was made worse by the fact that a key resignation in January left the Commission with only two Commissioners (out of a normal five), meaning they don’t have a quorum to conduct business.

And since one of the remaining commissioners has announced her intention to resign, two more new Commissioners need to be appointed and confirmed by the Senate, then get comfortable in their new jobs, before there is any chance at all that CIP-003-7(i) will be approved. So it’s almost certain now that it will be summer 2019 at the earliest before the new standard comes into effect, and that there will be a period of at least nine months during which entities will have to comply with CIP-003-6 (and when I’m talking about CIP-003 v6 or v7, I’m specifically talking about Section 3.1 of Attachment 1 of CIP-003. The single sentence in this section is the only substantial change between the two versions).

However, as I implied above, this shouldn’t require entities to implement procedures or technologies to comply with CIP-003-6, then rip them out when CIP-003-7 finally comes into play. As I discussed in this post last November, almost everything – with one exception that I’ll discuss below – that you could do to comply with Section 3.1 of Attachment 1 of CIP-003-6 will still work under CIP-003-7.

The one exception to this statement is if you had had your heart set on the fact that there is a routable-to-serial protocol conversion within say a substation, as reason why you don’t have to take any more protections on the routable connection to the substation. I believe this was the one case that FERC had in mind when they ordered NERC to eliminate the word “direct” from the LERC definition, when they approved CIP v6 in Order 822. So don’t plan on being found compliant if you do this.

Given that practically everything else you can do to comply with CIP-003-6 will work for CIP-003-7 as well, this means that the only difference will be your documentation. But you definitely can’t use the same words to describe the same setup in both versions. For one thing, you need to lose the word LERC. It sleeps with the fishes. If you’re looking for clues on how to do the v7 documentation, you might look at the post from last November, referenced two paragraphs above.

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

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