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.
If you would like to comment on what you have read here, I
would love to hear from you. Please email me at tom@tomalrich.com. Please keep in mind that
Tom Alrich LLC can help you with NERC CIP issues or challenges like what is
discussed in this post. To discuss this, you can email me at the same address
or call me at 312-515-8996.
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