I recently wrote a post pointing out that when FERC approves CIP-003-7, the current CIP-003-6 (with its LERC and LEAP language describing electronic access controls) will be sent to sleep with the fishes. In its place, the compliance date for the Low impact physical and electronic access controls requirement parts in CIP-003-7 (i.e. Sections 2 and 3 of Attachment 1) will be a little more than 18 months after FERC approval (per the implementation plan). But I also pointed out that entities can’t slack off their efforts for access controls at Low assets, because of the small possibility that FERC wouldn’t approve CIP-003-7.
It was just pointed out to me today that the agenda for FERC’s monthly Sunshine Meeting next Thursday includes CIP-003-7. Of course, this doesn’t mean they’ll definitely approve CIP-003-7, but I’d say the likelihood they would remand it – after issuing a Notice of Proposed Rulemaking in October saying they would approve the new version – is very small.
So what will be the CIP-003-7 implementation date, assuming FERC approves the standard next Thursday? It will be the first day of the first calendar quarter that is 18 months after FERC approval. That would be January 1, 2020. And September 1, 2018 will now be just another Saturday of Labor Day weekend.
On the other hand, I wouldn’t recommend you now stop working on the Low impact access controls even if FERC does what I think they’ll do next Thursday. If you get these controls implemented in 2019, you’ll be able to have a relaxing New Year’s Day 2020, assuming you’re not too hung over.
Any opinions expressed in this blog post are strictly mine and are not necessarily shared by any of the clients of Tom Alrich LLC.
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