My post on FERC Order 843 got a lot of attention (as do all the posts having to do with FERC orders and NOPR’s), but several people have pointed out some confusing language in the third paragraph (I’ve italicized what is confusing):
As I discussed last week, the fact that FERC approved CIP-003-7 today seems to assure that it will come into effect on January 1, 2020.[i] And it also means that the “requirements” for physical and electronic access controls for Lows, found in Sections 2 and 3 of Attachment 1, will never come into effect (although technically they won’t be retired until 1/1/20. But they’ll be the living dead, since they will expire and be replaced by their CIP-003-7 equivalents on that date). So, as I said next week, September 1 of this year is now just Saturday of Labor Day weekend, not the great D-Day when the “LERC/LEAP” requirement becomes enforceable. Enjoy your long weekend!
Do you see what’s missing in the italicized sentence? In the sentence itself, I say that Sections 2 and 3 of Attachment 1 will never come into effect! This is contradicted by the parenthetical expression, which says they will be replaced by the “equivalents” in CIP-003-7 (that is Sections 2 and 3 of Attachment 1 in CIP-003-7) on 1/1/20, the effective date of CIP-003-7. So which is it?
This confusion could have been eliminated if I had written this sentence as “And it also means that the “requirements” for physical and electronic access controls for Lows, found in Sections 2 and 3 of Attachment 1 of CIP-003-6, will never come into effect (although technically they won’t be retired until 1/1/20. But they’ll be the living dead, since they will expire and be replaced by their CIP-003-7 equivalents on that date).”
I apologize for this omission. I can assure you that we at Tom Alrich’s Blog value clarity and accuracy above all other goals. We have made a thorough assessment of our internal processes for review of new posts, and the people formerly in charge of that task are no longer with us!
PS: Mike Johnson put up a post yesterday that points out that Order 843 was published in the Federal Register yesterday. Since this happened before the end of April, this means that the compliance date for CIP-003-7 will be January 1, 2020 - there is no longer any uncertainty on that.
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 firstname.lastname@example.org. 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.